HomeMy WebLinkAbout14-1875 Supreme Court. of, Pennsylvania
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Cour. C m �' Tleas
For Prothonotary Use Only:
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Cu Count
�' Docket No:
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The information collected on this form is used solely for court administration purposes. This form does not
supp lement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
S Commencement of Action:
❑D Complaint ❑ Writ of Summons ❑ Petition
1✓+ ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: JPMORGAN MORTGAGE Lead Defendant's Name: BRET SHELDON A /K/A BRET E.
T ACQUISITION CORP. SHELDON
I Are money damages requested? ❑ Yes ❑x No Dollar Amount Requested: ❑ within arbitration limits
(Check one) ❑x outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes ❑x No
A Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esq., Id. No.312244, Phelan Hallinan, LLP
❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
❑ Product Liability (does not
S include mass tort) ❑ Employment Dispute:
❑ Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
O ❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
• Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
• Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
• Legal ❑ Quiet Title ❑ Other:
• Medical ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 Updated 01/01/2011
PHELAN HALLINAN, LLP
John D. Krohn, Esq., Id. No.312244 ' J i` 4 E' -R L A ND COUNTY
1617 JFK Boulevard, Suite 1400 PENNSYLVANIA
One Penn Center Plaza ATTORNEY FOR PLAINTIFF
Philadelphia, PA 19103
john.krohn@phelanhallinan.com
215 -563 -7000
JPMORGAN MORTGAGE ACQUISITION CORP.
1111 POLARIS PARKWAY COURT OF COMMON PLEAS
COLUMBUS, OH 43240
CIVIL DIVISION
Plaintiff
V. TERM
( 11 V c
BRET SHELDON A/K/A BRET E. SHELDON NO.
36 SOUTH PHEASANT RUN ROAD
COUPEVILLE, WA 98239 -4518 CUMBERLAND COUNTY
THE UNITED STATES OF AMERICA C/O THE
UNITED STATES ATTORNEY FOR THE MIDDLE
DISTRICT OF PA
228 WALNUT STREET, SUITE 220, PO BOX 11754
HARRISBURG, PA 17108 -1754
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
J File #: 938983 DA k IL/b
l L
F apl o
I . Plaintiff is
JPMORGAN MORTGAGE ACQUISITION CORP.
1111 POLARIS PARKWAY
COLUMBUS, OH 43240
2. The name(s) and last known address(es) of the Defendant(s) are:
BRET SHELDON A/K/A BRET E. SHELDON
36 SOUTH PHEASANT RUN ROAD
COUPEVILLE, WA 98239 -4518
THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR
THE MIDDLE DISTRICT OF PA
228 WALNUT STREET, SUITE 220, PO BOX 11754
HARRISBURG, PA 17108 -1754
who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described.
3. On 05/04/2007 BRET SHELDON made, executed and delivered a mortgage upon the
premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS NOMINEE FOR FIRST NATIONAL BANK OF ARIZONA,
which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND
County, in Mortgage Book 1993, Page 1777. By Assignment of Mortgage recorded
03/21/2013 the mortgage was assigned to J.P. MORGAN MORTGAGE ACQUISITION
CORP. , which Assignment is recorded in Assignment of Mortgage Instrument No.
201309087.The mortgage and assignment(s), if any, are matters of public record and are
incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule
relieves JPMORGAN MORTGAGE ACQUISITION CORP. from its obligations to
attach documents to pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
File #: 938983
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 06/01/2013 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage as of 10/10/2013:
Principal Balance $148,574.11
Interest from $1,981.00
05/01/2013 through 09/30/2013
Late Charges $151.12
Appraisal/Brokers Price Opinion $450.00
Escrow Advance $706.87
TOTAL $151,863.10
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in
2008, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s).
9. The mortgage premises are vacant and abandoned
File #: 938983
10. The United States of America is made a Defendant herein pursuant to 28 U.S.C. 2410,
because of federal tax liens that have been filed with the Prothonotary of
CUMBERLAND County in the Judgment Index Unit as follows:
(A). United States vs. BRET SHELDON, A/K/A BRET E. SHELDON;
CUMBERLAND County Docket No. 2010- 02774; Filed 04/26/2010; in the amount of
$5,644.70
(B). United States vs. BRET SHELDON, A/K/A BRET E. SHELDON;
CUMBERLAND County Docket No. 2011 - 08740; Filed 11/18/2011; in the amount of
$14,412.19
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$151,863.10, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN, LLP
By: ( a
John D. 10'r hn, Esq., Id. No.312244
Attorney Plaintiff
File #: 938983
LEGAL DESCRIPTION
ALL THAT CERTAIN parcel or piece of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at appoint on the north line of Township Road T -595, which point is on the
division line between Lots Nos. 4 and 5 on the hereinafter mentioned Plan; thence north twenty -
five (25) degrees thirty-six (36) minutes east along the western line of Lot No. 4 one hundred
fifty and one one - hundredths (150.01) feet to a point; thence north thirty -one (3 1) degrees
twenty -three (23) minutes West along other lands of Grantors one hundred nineteen and twenty -
six one - hundredths (119.26) feet to appoint in the eastern line of Lot No. 6; thence South twenty -
five (25) degrees thirty -six (36) minutes West along the eastern line of Lot No. 6 two hundred
fourteen and ninety -nine one - hundredths (214.99) feet to a point in the northern line of Township
Road T -595; thence along the northern line of said road South sixty -four (64) degrees twenty -
four (24) minutes East one hundred (100) feet to a point, the place of BEGINNING.
BEING Lot No. 5 on Plan No. 1 of Mountain View Park as recorded in Cumberland County
Recorder of Deeds Office in Plan Book 13, Page 30.
PROPERTY ADDRESS: 156 PLEASANT GROVE ROAD, MECHANICSBURG, PA
17050 -1528
PARCEL #38 -14- 0850 -001
File #: 938983
b ~
VERIFICATION OF COMPLAINT
The undersigned, Opal J. Daigle , does hereby certify that he / ®is
Vice President of JPMorgan Chase Bank, N.A. ( "Chase "), and that Chase has been duly
nominated and appointed by the Plaintiff as its mortgage servicing agent in regard to the
mortgage loan which is the subject of this action (the "Mortgage "). Plaintiff lacks sufficient
information to make this verification because Plaintiff is not the entity that maintains the
business records for the Mortgage. Chase, in its capacity as mortgage servicing agent for
Plaintiff, maintains the business records for the Mortgage, and therefore, as an employee of
Chase, I have sufficient information to make this verification in accordance with Pa.R.C.P.
1024(c)(1).
I am authorized to make this Verification on Plaintiff's behalf and do hereby verify that
the facts as set forth in the foregoing Complaint are true and correct to the best of my
information and belief. I have access to and have reviewed the business records of Chase for and
relating to the Mortgage, and I make this Verification based on my review of those records,
which are maintained by Chase in the course of its regularly conducted business activities and
are made at or near the time of the event, by or from information transmitted by a person with
knowledge.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904 relating to unsworn falsification to authorities.
1 , a01V Dated: G / /07 By-
Name pal'' J it
Vice President, JPMorgan Chase Bank, N.A.
Loan No. XXX - .._34.16
IN THE COURT OF COMMON
JPMORGAN MORTGAGE ACQUISITION CORP. PLEAS
Plaintiff(s) OF CUMBERLAND COUNTY,
PENNSTLVANIA
vs.
BRET SHELDON A /K/A BRET E. SHELDON
Defendant(s) ��% ivil
-1
�y
NOTICE OF RESIDENTIAL MORTGAGE
FORECLOSURE DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you
may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter
with your lender.
If you do not have an attorney, you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact
MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request
appointment of a legal representative at not charge to you. Once you have been appointed a legal
representative, you must promptly meet with the legal representative within twenty (20) days of the
appointment date. During that meeting, you must provide the legal representative with all the requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal representative
will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the
Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your
lender in attempt to work out a reasonable arrangements with your lender before the mortgage foreclosure
suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for
the appointment of a legal representative. However, you must provide your lawyer with all the requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work
our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward,
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date Signature of ounsel for Plaintiff
t--7� C`
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Please Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMERIPRIMARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date you Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles boats motorcycles ): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2° Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child SuppordAlim. Spending Money
Day /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if you know, regarding your lender or lender's
loan servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above
named to use /refer this information to my lender /servicer for the
sole purpose of evaluating my financial situation for possible mortgage options. I /We
understand that I /we am /are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this page along with the following information to lender:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
6. Listing agreement (if property is currently on the market)
p w
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249 -3166
(800) 990 -9108
File #: 938983
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND ~O NTY
T����^u-
/1101107\.:`|
Y0/ti0���7 PM �^ �"
APR ' . '' �. ��
CUMBERLAND COUNTY
JPMorgan Mortgage Acquistion Corp.
vs.
Bret Sheldon
Case Number
2014-1875
SHERIFF'S RETURN OF SERVICE
04/02/ 2014 12:30 PM - Ronny R Anderson, Sheriff, being duly sworn accor inQtolmw.obshsehemodedi|igen1nearoh
and inquiry for the within named Defendant to wit: Bret She|don, but was unable to locate the Defendant
in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage
Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 156
PLEASANT GROVE ROAD, Silver Spring Township, K8ECHAN|CSBURG, PA 17050. Residence is
vacant.
SHERIFF COST $44.30 SO ANSWERS,
April 04, 2014 RON S' R ANDERSON, SHERIFF
w��uile Shenfl, Teleosoft,�
PLAINTIFF
JPMORGAN MORTGAGE ACQUISITION CORP.
DEFENDANT
BRET SHELDON A/K/A BRET E. SHELDON; ET AL.
SERVE UNITED STATES ATTORNEY FOR THE
MIDDLE DISTRICT OF PA AT:
950 PENNSYLVANIA AVENUE, N.W., MAIN JUSTICE
BUILDING, WASHINGTON, DC 20530
Affidavit of Service
CUMBERLAND COUNTY
PHS # 938983
SERVICE TEAM
COURT NO.:14 -1875 CIVIL
TYPE OF ACTION
CIVIL COVER SHEET; NOTICE AND CIVIL ACTION -
COMPLAINT IN MORTGAGE FORECLOSURE WITH
ATTACHMENTS
SERVED
Served and made known to United States Attorney for the Middle District of PA ,Defendant on the 17 of April , 20 14 , at
1:11 PM , at 950 Pennsylvania Avenue, N.W., Main Justice Building, Washington, DC 20530 in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is
Adult in charge of Defendant's residence who refused to give name or relationship.
Manager /Clerk of place of lodging in which Defendant(s) reside(s).
X Agent or person in charge of Defendant's office or usual place of business. Steffon Edmonds as Clerk
an officer of said Defendant's company.
Other:
Description: Age 20 - 30 Yrs. Height 6'1" - 6'3" Weight 191 -220 Race Black Sex Male Other
I James L. Hilton , a competent adult being duly sworn according to law, depose and state that I personally handed a
true and correct copy of the CIVIL COVER SHEET; NOTICE AND CIVIL ACTION - COMPLAINT IN MORTGAGE.FCLOURE
WITH ATTACHMENTS in the manner as set forth herein, issued in the captioned case on the date and at the address indiolted above
Sworn to and subscribed before
me this 17th
of April 2014
day
On the of
, 20 , at
hereby state that Defendant NOT FOUND because:
Vacant Does Not Exist Moved
No answer on at
Service Refused
Other:
Sworn to and subscribed
before me this 17th
day of April 2014 By:
Notary: Martha L. Lazo Ruiz
OT SERVED
o'clock
.M., I,
Does Not Reside
ATTORNEY FOR PLAINTIFF
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg Esq., Id No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Jay B. Jones, Esq., Id. No. 86657
Andrew L. Spivack, Esq., Id. No. 84439
at
, a competent adult
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Courtenay R. Dunn, Esq., Id. No. 206779
Allison F. Zuckerman, Esq., Id. No. 309519
Melissa J, Cantwell, Esq., Id. No. 308912
Mario J. Hanyon, Esq., Id. No. 203993
John M. Kolesnik, Esq., Id. No. 308877
Matthew G. Brushwood, Esq., Id. No. 310592
Zachary J. Jones, Esq., Id. No. 310721
Justin F. Kobeski, Esq., Id. No. 200392
Adam Davis, Esq., Id. No. 203034
One Penn Center at Suburban Station
1617 John F. Kennedy Blvd., Suite 1400
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTPEt
JPMORGAN MORTGAGE ACQUISITION CORP.
PH # 938983
DEFENDANT SERVICE TEAM/ mig
BRET SHELDON A/K/A BRET E. SHELDON COURT NO.: 14-1875 CIVIL
THE UNITED STATES OF AMERICA C/O THE UNITED STATES
ATTORNEY FOR THE MIDDLE DISTRICT OF PA
SERVE BRET SHELDON A/K/A BRET E. SHELDON AT:
36 SOUTH PHEASANT RUN ROAD
COUPEVILLE, WA 98239-4518
TYPE OF ACTION
XX Mortgage Foreclosure
XX Civil Action
SERVED
Served and made known to BRET SHELDON A/K/A BRET E. SHELDON, Defendant on the 2actiay of
MAY, 20 14 at 36 S. Pheasant Run Road,
11 • 24,o'clock Am„at Coupeville Wa. , in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is Co resident
Adult in charge of Defendant's residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
Other:
Description: Age 45/5 5Height 5'3" Weight 170 Race C Sex F Other
Hoard L.
1, An teaser) , a competent adult, being duly sworn according to law, depose and state that I personally
handed a true and correct copy of the Foreclosure Complaint in the anner as set forth herein, issued in the captioned
case on the date and at the address indicated above.
Sworn to and subscribed
before me this t4k. day
of KA./1/1 , 20
Notary:
owar
NOT SERVED
On the day of 20_, at o'clock . M., I, , a competent adult hereby state that
Defendant NOT FOUND because:
— Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant)
///,
n• easen
No Answer on at at
Service Refused
Other:
Sworn to and subscribed
before me this day
of , 20 . By:
Notary:
ATTORNEY FOR PLAINTIFF
Lawrence T. Phelan, Esq., Id, No. 32227
Francis S. Hallinan, Esq., Id, No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id, No. 69849
Judith T. Romano, Esq., Id. No. 58745
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Jay B. Jones, Esq., Id. No. 86657
Andrew L. Spivack, Esq., Id. No. 84439
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Courtenay R. Dunn, Esq., Id. No. 206779
Mario J. Hanyon, Esq., Id. No. 203993
John M. Kolesnik, Esq., Id. No. 308877
Matthew G. Brushwood, Esq., Id. No. 310592
Justin F. Kobeski, Esq., Id. No. 200392
Adam Davis, Esq., Id. No. 203034
Joseph E. DeBarberie, Esq., Id. No. 315421
EMILY M. PHELAN, Esq., Id. No. 315250
Michael Dingerdissen, Esq., Id. No. 317124
One Penn Center at Suburban Station
1617 John F. Kennedy Blvd., Suite 1400
PHELAN HALLINAN, LLP
Michael Dingerdissen, Esq., Id. No,317124
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Michael.Dingerdissen@phelanhallinan.com
215-563-7000
JPMORGAN MORTGAGE
ACQUISITION CORP.
vs.
BRET SHELDON A/K/A BRET E.
SHELDON
THE UNITED STATES OF AMERICA
CIO THE UNITED STATES ATTORNEY
FOR THE MIDDLE DISTRICT OF PA
Attorney for Plaintiff
: CUMBERLAND COUNTY
COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 14-1875 CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against BRET SHELDON A/K/A
BRET E. SHELDON, Defendant for failure to file an Answer to Plaintiff's Complaint within 20
days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint
TOTAL
$151,863.10
$151,863.10
I hereby certify that (1) the Defendant's last known addresses are 36 SOUTH
PHEASANT RUN ROAD, COUPEVILLE, WA 98239-4518 and 156 PLEASANT GROVE
ROAD, MECHANICSBURG, PA 17050-1528, and (2) that notice has been given in accordance
with Rule Pa.R.C.P 237.1.
Date
Michael Dingerdissen, Esq., Id.
No.317124
Attorney for Plaintiff
DAMAGES ARE E;EBY ASSESSED AS INDICATED.
/DATE: J
PH # 938983
PROTHONOTARY
ow\
938983
CAAA. I it 3 g
V t_ 11741-
PHELAN HALLINAN, LLP
Michael Dingerdissen, Esq., Id. No.317124
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Michael.Dingerdissen@phelanhallinan.com
215-563-7000
JPMORGAN MORTGAGE
ACQUISITION CORP.
vs.
BRET SHELDON A/K/A BRET E.
SHELDON
THE UNITED STATES OF AMERICA
CIO THE UNITED STATES ATTORNEY
FOR THE MIDDLE DISTRICT OF PA
Attorney for Plaintiff
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 14-1875 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendant BRET SHELDON A/K/A BRET E. SHELDON is not in
the Military or Naval Service of the United States or its Allies, or otherwise within the provisions
of the Servicemembers Civil Relief Act, as amended.
(b) that defendant BRET SHELDON A/K/A BRET E. SHELDON is over 18
years of age and the last known addresses of the defendant are 36 SOUTH PHEASANT RUN
ROAD, COUPEVILLE, WA 98239-4518 and 156 PLEASANT GROVE ROAD,
MECHANICSBURG, PA 17050-1528.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date
w
Phelan Ifallinaff, LIP
Michael Dingerdissen, Esq., Id. No.317124
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza, Philadelphia, PA 19103
215-563-7000
938983
Department of Defense Manpower Data Center
Status Report
Pursuant to Seivicern
Last Name: SHELDON
First Name: BRET
Middle Name:
Active Duty Status As Of: Sep -08-2014
10 1
61
Civil Relief Act
Results as of : Sep -0B•2014 12:05:37 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA ..1..'"- +: \'- -�
--- -r hiN
NA
This response reflects the individuals' active duty status.based on the Active Ditty Status Date
Len Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Dale
Active Duty End Date
Status
Service Component
NA
' , NA
+� .- No-:�-- .
NA
r
This response reflects where the individual len active datpstatuswithin 367 Gays preceding the Active Duty Status Dale
The Member or HislHer Unit Was Noted de Future Catt.Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
,:.,rNo": f
NA
This response reflects whether the individual or his/her unit has received "early ni tIcatton to tenon for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Department of Defense Manpower Data Center
Status Report
Pursuant to Service em ss ;, i. belief Act
Last Name: SHELDON
First Name: BRET
Middle Name: E
Active Duty Status As Of: Sep -08-2014
Results as of : Sep -08.2014 12:21:51 AM
SCRA 3.0
On Active Duty On Active Duty Status Data
Active Duty Start Date
Active Duty End Date
Status
Service Component
Sta°°t++uss,
Service Component
NA
NA
- -
- ..
.. hirr .
NA
This response reflects the Indivlduais'
ve duty s' be
on the ActtveDuty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
f i NA -
. } .1 _ "^No..^':- ..
NA
This response reflects where the individual leftactiveduty status within 387 days preceding the Active Ditty Status Date
The Member or His/Her Unit Was Notified of a Futu e Gall -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
` NA -
- i . Nu - „r
NA
This response reflects whether the individual or his/her unit has received early noSification toleport for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
JPMORGAN MORTGAGE ACQUISITION CORP.
Plaintiff
v.
BRET SHELDON A/K/A BRET E. SHELDON
THE UNITED STATES OF AMERICA CIO THE
UNITED STATES ATTORNEY FOR THE MIDDLE
DISTRICT OF PA
Defendant(s)
TO: BRET SHELDON
A/K/A BRET E. SHELDON
36 SOUTH PHEASANT RUN ROAD
COUPEVILLE, WA 98239-4518
DATE OF NOTICE:
9),111ff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14-1875 CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR AI I EMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER,
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH it 938983
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
Michael Dii g tli,4sen, Esq., Id. No.317124
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
JPMORGAN MORTGAGE ACQUISITION CORP.
Plaintiff
v.
BRET SHELDON A/K/A BRET E. SHELDON
THE UNITED STATES OF AMERICA C/0 THE
UNITED STATES ATTORNEY FOR THE MIDDLE
DISTRICT OF PA
Defendant(s)
TO: BRET SHELDON
A/K/A BRET E. SHELDON
156 PLEASANT GROVE ROAD
MECHANICSBURG, PA 17050-1528
DATE OF NOTICE:
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14-1875 CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OPFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH # 938983
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
Michael Di. gerciissen, Esq., Id. No.317124
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
(Rule of Civil Procedure No. 236) - Revised
• JPMORGAN MORTGAGE : CUMBERLAND COUNTY
ACQUISITION CORP.
: COURT OF COMMON PLEAS
vs.
BRET SHELDON A/K/A BRET E. : CIVIL DIVISION
SHELDON
THE UNITED STATES OF AMERICA : No. 14-1875 CIVIL
C/O THE UNITED STATES ATTORNEY
FOR THE MIDDLE DISTRICT OF PA
against you on
Notice is given
hat a Judgment in the above captioned nutter hag been entered
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Michael Dingerdissen, Esq., Id. No.317124
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
938983