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HomeMy WebLinkAbout14-1903 t Supreme Court of, Pennsylvania F Court.. Common 1 Pleas For Prothonotary Use Onlp: Ca vil l Cover Sheet Docket No: CUMBERLAND; County (q 3 Jhe nfoi collected on this ftnwi is used solelP,fr)r com Udnnniswatimi pi0TXL4es. This foi (toes not .eup171enment w. rel?1oce the filing and service oi' other 1wl7ei - s as i un•4d by law or i•ides of court. Commencement of Action: S 2 Complaint Ej Writ of Summons � Petition Transfer fi Another Jurisdiction Declaration of Taking E C Lead Plaintiffs Name: bead Defendant's Name: T JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Wanda K. Neumann, Michael E. Neumann, and Unknod Dollar Amount Requested: [Dwithin arbitration limits I Are money damages requested? El Yes El No (check one) jE10utside arbitration limits 0 N Is this a Class Action Suit? 11 Yes ED No Is this an MDJAppeal? [7 Yes 0 No Name of Plaintiff /Appellant's Attorney: JAIME R. ACKERMAN, ESQ. [] Check here it you have no attorney (are a Self-Represented I Pro Set Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PR /MARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include A/ass Tort) CONTRACT (do not include Judgments) CiViL APPEALS Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution Debt Collection: Credit Card El Board of Assessment 0 Motor Vehicle Q Debt Collection: Other 0 Board of Elections F] Nuisance E] Dept. of Transportation Premises Liability [ Statutory Appeal: Other S Product Liability (does not include E mass tort) :. [] Employment Dispute: Discrimination Q Slander /Libel/ Defamation Employment Dispute: Other El Zoning Board C El Other: Q Other: T 1 Lj Other: O MASS TORT F1 Asbestos N Tobacco [] Tonic Toil - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Other: -- --- - 0 Ejectment _ [] Common Law /Statutory Arbitration g 0 Eminent Dom/Condemnation ain E] Declaratory Judgment F1 Ground Rent E] Mandamus F1 Landlord/Tenant Dispute E] Non - Domestic Relations Q Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLiTY El Mortgage. Foreclosure: Commercial 0 Quo Warranto n Dental D Partition �D Replevin F1 Legal Ej Quiet Title Other: Medical E3 Other: Q Other Professional: Updated 1 1112011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION : CIVIL DIVISION s Plaintiff, V vs. NO.. �LA-Aq 03 Wanda K. Neumann, Michael E. Neumann and = Unknown Occupants Defendant(s). 7, NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TODEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 3 �a� Zucker, Goldberg 9: Acke; man, LLC XCE- 175926 -EV 175926- EVD10020.2.042013P3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION vs. NO.. Wanda K. Neumann, Michael E. Neumann, and Unknown Occupants Defendant(s). AVISO USTED HA SIDO DEMONDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en Ia demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A LINO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND. LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 _ _.(717)..249 -3166 , (717) 249 -3166 Zucker, Goldberg & Ackerman, LLC XCE- 175926 -EV 175926- EVD1002C12042013P4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION VS. NO.. Wanda K. Neumann, Michael E. Neumann, and Unknown Occupants Defendant(s). CIVIL ACTION - COMPLAINT IN EJECTMENT AND NOW, comes JPMORGAN CHASE BANK, . NATIONAL ASSOCIATION, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Ejectment as follows: (1) The Plaintiff, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, which has its principal place of business at 3415 VISION DRIVE, COLUMBUS, OH 43219. (2) The Defendants are adult individuals residing within the Commonwealth of Pennsylvania at 428 South Hanover Street, Carlisle, PA 17013. (3) By Sheriff's Deed dated September 3, 2013, recorded on October 2, 2013, Instrument #201332382, the Sheriff of Cumberland County has conveyed to Plaintiff, all that certain lot or piece of ground, with improvements erected thereon, and as more fully described in the Deed and as purchased by Plaintiff at Sheriff Sale on December 5, 2012. A true and correct copy of the recorded deed is incorporated herein as Exhibit "A ". (4) On September 21, 2012, Defendants were served as owners of the aforesaid premises with a Notice of Sheriff's Sale scheduling the sale for December 5, 2012. A true and correct copy of the Sheriff's return of Service is incorporated herein as Exhibit 'B'. (5) 'By letter dated November. 11, 2013, Defendants and all other Current Occupants, if any;" were notified by,. counsel for the Plaintiff to vacate the premises, via Certified Mail, Return Receipt Requested and First Class U.S. Mail, postage pre -paid, with a Certificate of Mailing. A true and - correct copy of the letter, Certified Mail Receipt and Certificate of Mailing are marked Exhibit "C ", attached hereto and made a part hereof. (6) To date; Defendants have failed or refused to vacate the premises, and therefore, Defendants are, using and enjoying the premises without right and Claim of Title. Zucker, Goldberg 8r Ackerman, LLC XCE- 175926 -EV 175926- EVD1002C12042013P5 (7) Defendants have unjustly and unlawfully retained possession of the premises to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendants for possession of the premises known as 428 South Hanover Street, Carlisle, PA 17013, together with such other relief as this Honorable Court may deem necessary and appropriate. ZUCKER, GOLDBERG ARM BY: Dated: Scott A. Die ick, Es u re; PA I. . #55650 ' Kimberly . Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. 4306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032.._ — Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCE- 175926 -EV /sc 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCE- 175926 -EV 175926- EVD1002C12042013P6 EXHIBIT A 1 "elan l..laillinin, UP m Cash SystemPA. Page i of I 1617 JFK Boulevard, S 0t 1400, One Penn Center Plaza, Philadelphia, PA 19103 Phone. 235-563-7000 Casa umnmr 10 4 r.. Rptfvrr l Type: Fbred sure Old PH 200326 PH #.- 700187 Pile Received. 05/11,`2009 Loam #. 004"4785883 Follcsw-up: tahts. 0 %1T Can Hold: Property- 428 SOUP i 11AN ✓VF's?. S`i RE s County. CUMBERl.M0 CARLISLE, PA 17013-3916 D efendants- NEWIANN, WH',l'+DA K. NEUVIANN,, MICHAEL E . Pri'marf ser vic er " CHASE- Bl`NIK, NAT"I.ONAl. A`HSOUN1 0N (21)SAN DIEGO, CA 97127 Repot t To- Insurer: Referred By. LPS DE=SKTOP (52) Court Term* Complaint 10- 3849 -CIVIL TERM Docket: Freddie Mar: Fannie Mae #, Client Billed. 12/05/2012 PIIAI 4. Bill Amount: K00 Closed- Writ Sale t: Report To # . PM1 4t: P I Arne: rjwnslilP�. . t.)( ..3 �j 6') 0 Tax Parcel l o, 04 - 22 - 0413 - 056 ".ITaat I, Ronny R. And.ersori., Sheriff of the Cowify of C'Laanbe.rland, In the State of Perrnsylvzaraia, for an(l in co ,.sid.eratio n of the starrn of $ 1.00 (One Dollar) to n e in hand paid, do lrerelay grant and convey to JP Morgan Chase Bank, N.A. ti'° -31149 C ivil Term JI Morgan C hase Bank, N.A. s Wanda K. Neumann Michael E. Neumann ALL that certain lot of groinict sit:tate; in the Borough of Carlisle, Cuniberland County, PQn.nsylvani.a, botincl =d and described as follovi s: BE Ili N l l G at a poj on the cart Nine of South JTanover Street, at corner of lot: now or f6rr le y caf' Ala s. i.,c i .I-lert:zier; thence wc;st vat -dly throu h the center line of the lnartit:ican wall hou se tll kaou, t.il .ter {V lent 11 d ° °r-t.l3y l€LirrS core °ycel 6r,c1 tlae laor sew on the lot now or :formerly of the said Mr's. Devi Hertzler, a disttancw, o.f ` Nvo hundre(1 Forty (240) :feet, more: or less, to the center' lilac: of School Alloy; thence Northwardly by Saul center line of said School Alley, a instance of feet ('40). thence Eastw artily by lot 0f'. j,t0L1Dd now or for'rrrerly of W. A. Wetzel, ra. disi arice of Cale Hundred Se vdi.ty -nine (1 19) :test line (9) .inches to a point at the center of the c,stefrna entrance to an Galley -way two (2) feet sic (6) inches wide, which said all.e~y -way is hetween the, 1rt3usL on the- let hereby l being; convevecl atr(l the h.onse on the lot, now or formerly of the st id W, A, Wetzel, thence Nortlrw ard.ly by saki l.ot ri.ow or formerly of the said W, A. Wetzel, oaae° (1) foes six (6) inches to ,a point in the center ift:he partition wall between the hoarse hereby being conv=:,` and that no (ri' Jbmnerly of the said W. A Wei tzel; thence Eastw" {ar by the c ora er 1ii" e t ?f said p£t'l riti:ol..1 w all, sa. klltitallc(: of sixty (60) ficeL three (3) inches, n'iore or less to a Point on. the curb Brae of'said crrrin line distance of Twenty -one (21) feet six (ti) inches to corrwr 01:' lot now (ar = arrra.erly of the said NIts. 1_,evi .f ler the place of BEGINNING, BEING hriproved with <, tlxrcc stork- -bricl . dwellin�y, lnortse, RESERVING, HOWEVER. to the owner of the lot of growid on the North of the property herby being conveyed, his heirs and assipi , thic to tlae use of the €a.toresald. alley -way, two (2) feet six (6) imbes whie as the :sarn is r.ov. constrta.cted rand used hi rornnnon with the Grantors, hercir`i, their heirs ail a, ssigns; as :mcessary charges Barad expenses which shall ftorn tinge to tingle trccrta:e ira 1,avin�..rel dair.i..ilw, and cl;:l anin, the saicl zallev.wa'y to be shared eclually by the owners cal' said adfor.r: ing.. properties, their" heirs and ,a. srg:tas. T.I 1,E ] O SAID PREMISES VESTED .lN T� ichael E. Neumann and Wanda K. Neunl.aa.lrr, h /w, ley Deed fr°ont.Betty A. Brown, single per"sor dated'12 %31%2001, recorded 01,/04/2002 Hi Book 249, gage 452 ?. PREMISES BEING, 4' SOU':lH�I-l��I�OVE;12 S1REET„ CARUSLE, PA 17013 -3916 PARCI I.. NC's. 04 22 0483 - 056 The same havhig been. sold by nw to Te said gmnWe on Me 5th day of Decew er Amno Do-mini Two `T"hmisand and Twelve (201 2) a 0m; due advertisement aCCOI - ding to law, under and by VAs,m of a VA oCExa.cution issued on the 31A of,August AIx.?` o . omini 2 012 cmt of the €' €.purl ofC;ornmon Picas of Cumberland Comity, .Pennsylvania, as o:( 0vil 'T'e°rm, ' v"o Thousand and Ten (201.0) dumber 3849 at the suit of JP A• mla n Chase Bank, ILA. _ _ s- Wanda €! Mummna and ichael E, Neumann Ian Wrhmss Wher°enL t have hei S'iinaC` affixed my signature this 3rd day of }E' 1t~£`ii1be Anno Dort iii ' "no 1housund mul Ranee (2013) 4 ` Z- rin .�� :oaesrson, Sheriff C ortranaamve;walth of i'€.nnsylvanin, ss. a C'tiun y ofC;trraAmdatnd A Itwe d w u adui"ua.i.'.ned, David 1F, Bu el, l,1, Pr of thQ Co i. of COPntI "tiiil Pleas of Cumberland C~t7ura Amin >ylv aria, personally appeared. R.oinny R. Anderson, Sheriff ofCaxinTerl nd Coma y a%'nmaid, arml in dace form of law declared that the facts Set .lc)rth in the Mgoin 1 arkw true, and that lie aekntowkdged tlae smne in order that Said deed .ini,,dii be rec"ordcd. Witness my hand. and seal. of said Court, this :3rd clay or . September Njuv I)o i1ji � � "t.) (itE t?f;;lil. � <�la ;� Thirteen (2013) x N thonatary, Cumberland County, C'miste, PA My Cormnissign Expires the first Monday of jan. 2014 I llerel.a} certify that the resiclelace And Post: Office address of the Within Grantee is 10790 Raneho .Ber nar do Rd San I:?ie o, CA 92127 Richard W. ;Stewart Solicitoa 1 P I lei -: -63 "7 F � b 4 9 rq Trtsti•rrrne'n't lNurnber• - 3 01332382 ecor dcd (.)u U/1"'2013 ,fit :1 AM I "Total Page i.rr tr rr rz� rt' ", - DEEP- �g�-�: ;. t�:l�'t�'S :rr °r eax ' rrsrr :fa . 483 t'isw`.Di'J 10"V Cost €plan €r w. SIM5111 "T STATE WRIT T AX Certification Page STATE JCS/ACCESS CESS TO $23,50 JUSTICE DO NOT DE ' rACH RECORDING FEES °- Rr,c 3amiq. OF v—rDS PARCEL CEPTIFICAz3IMT 8 15, 0 01 This page is now part rEES of this legal document, AFIFOY�DRBIITZ H.0 SING $13_50 COUNTY Y ARC H I S FEE $2.00 ROD A. .C;� IVES` FEE $w' . 00 CPALISLE ARPM SCHOOL $ DISTRICT CARLISLE BOROUGH $0,00 T01-VAL PAID $68.0o I tm;e - tit t to ete w x Coun- REC ORDER Or D ,S In formation denoted by an asterisk may change during flw wrifir:ation Imicess t. sad may riot ire re#ietted oat this page. 0t 2 R EXHIBIT B Ronny R Anderson SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff �4aat'E et 6unrb Jody S Smith Chief Deputy Richard W Stewart Solicitor orM OF na swe RIFF JP Morgan Chase Bank, NA Case Number vs. Michael Edward Neumann (et al.) 2010 -3849 SHERIFF'S RETURN OF SERVICE 09/21/2012 07:05 PM - Deputy Tim Black, being duly swom according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 09/21/2012 07:05 PM - Deputy Tim Black, being duly swom according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be WANDA NEUMANN, WIFE, who accepted as "Adult Person in Charge" for Michael Edward Neumann at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, 09/21/2012 07:05 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Wanda K. Neumann at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 10/05/2012 Received addl copy of Writ, Notice of Sheriffs Sale and Legal Description this date from Atty Schmieg with instructions to deputize for Michael Edward Neuman to Erie County in SCI Albion. cab. 10/05/2012 Ronny R. Anderson, Sheriff, being duly swom according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Michael E. Neuman, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Erie County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 10/23/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Erie County upon Michael Edward Neumann, personally, at SCI Albion, 10745 Route 18, Albion, PA 16475. So Answers: Judy Tome, Deputy, Sheriff, SHERIFF COST: $924.20 SO ANSWERS, November 07, 2012 RON R ANDERSON, SHERIFF (c) CountySude Sheriff. Teledsok Inc. JP MORGAN CHASE BANK, NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO.: 10- 3849 -CIVIL TERM WANDA K. NEUMANN MICHAEL E. NEUMANN CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WANDA K. NEUMANN MICHAEL E. NEUMANN 428 SOUTH HANOVER STREET, CARLISLE, PA 17013 -3916 "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.** Your house (real estate) at 428 SOUTH HANOVER STREET„ CARLISLE, PA 17013 -3916 is scheduled to be sold at the Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $138,672.23 obtained by JP MORGAN CHASE BANK, NA (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215 -563 -7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 21.5 -563 -7000 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215 -563 -7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 EXHIBIT C LEONARD B. ZI CKER Z UCKER, GOLDBERG Cif: A4o r f1MAN, LLC FOUNDED IN 1923 MICHAEL S. ACKERMAN AS ZUCKER & GOLDBERG JOELACKERMA.N• ATTORNEYS AT LAW FRAN G 1ty ?SARDEL LA MAURICE J. ZUCKER (1918 -1979) 200 SHEFFIELD STREET SUITE 101 LOU D. GOLDBERG (19z3 BRIAN I.. NICHOLAS 4 P.O. BOX 1.024 LEONARD H. GOI.DB£RG ( ( 1929.1.979 SCOTT A. D ! IE'FrFRICK a BF.NIAMINVJEISS 1949 - '!9811 KIMBERLY A. BONNER Y M OUNTAINSIDE, N1 07092 - 0024 STEViiN D. KROI. CHRISTOPHER G. FORD TELEPHONF: 908 - 233 - 8.500 Pennsyia•ania Office: 1) CARLON G FACSIMILE: 908-233-1.39 The Union Hotel Office Building CHRISTINE E, POTTER C.e 240 Gettysburg Road RYAN S, MALC E - MAIL: office@zuckergoIdberg.corrl Mechanicsburg, PA 17055 STEPHANIE INOLCHOK ASHLEIGH LEVY feiARIN E DOUGLAS , McDONOUGH For payoff /reinstatement figures -IKA0-,4y I. ZIEGLER Please send your request to: zuckergoldberg.com /pr ALSO AIi ilfiBER ()F NY, PAAND CA PAR RALPH H M. SALVIA ROBERT 0. BAILEY t Ai50ME.ti�BEFOEPJY, PAANL, n^I-:BAR AlME R.ACK£Rt4ANt 0 ALSO NITA48[POFNYAND , iPAR R. ACKERMA REPLY TO NEW JERSEY ADDRESS j At5'OME1Vj8EROFNYEAS RACHE . P t £ AL50 MEMBER OF PA BAR KACIE W. ALSO ME. 4 ER Or NYANO DC BAR N':ONIKA. S. PUNDALIK : -' P. !:h49E "!? OF PA EAR ONLY TODD N4 ARKS R 0 ALSO N11:rV.6LR OF Ft. BAR TIMOTHY D. KUHLSA ;AtdA PRIDFINNSDC?TTIR Y XCE- :175926 -ELI November 11, 2013 Wanda Neumann and /or Tenant(s) known or unknown at: � 428 South Hanover Street 7196 9008 9111 6605 6180 Carlisle, PA 17013 ! • DEMAND FOR POSSESSION OF PROPERTY Property Address: 428 South Hanover Street Carlisle, PA 17013 Sale Date: December 5, 2012 Dean Tenant: On December 5, 2012, the property located at 428 South Hanover Street, Carlisle, PA 17013 was sold before the Courthouse door of Cumberland County, Pennsylvania during the legal hours of sale. You are hereby notified that possession is demanded by JPMORGAN CHASE BANK, N.A., which was the highest bidder at the sale, and now owns the property, as evidenced by deed recorded on October 2, 2013 in Instrument #201332382, If you are the former owner of the property, the child, spouse, or parent of the former owner, and you do not relinquish possession within 10 days of this letter, dispossessory proceedings will be initiated in the Court of Cumberland County, PA, to evict you. YOU HAVE 10 DAYS TO CONTACT THIS OFFICE. If you are a tenant of the former owner of the property, and not the child, spouse, or parent of the former owner of the property, you may be entitled to additional rights as provided by the Protecting Tenants at Foreclosure Act of 2009, including the right to remain in the property for 90 days from the date of receipt of this notice, before dispossessory proceedings are initiated against you. In order for us to determine on behalf of JPMORGAN CHASE BANK, N.A. what rights you may have under the Protecting Tenants at Foreclosure Act of 2009, you must forward us the following within ten days of the date of this letter: (a) a copy of your written lease (if an oral lease you must provide us a summary of the terms of your oral lease, - the term of the lease, monthly rental amount and all other relevant lease terms); (b) proof of your alleged monthly rental amount (proof may in the form of a copy of your lease showing the rental mount, or, if an oral lease, copies of cancelled checks or money orders); (c) proof that all monthly rental payments due under the lease have been paid to date (proof may be in the form of copied of cancelled checks, money orders or a signed statement from your landlord stating that you have paid your rent in full as required by your lease); (d) the names of all occupants of the property who are over the age of 18 years of age; and (e) indicate whether you are Section 8 tenant For any questions regarding your rights as a post - foreclosure tenant, contact Sonay Culpepper at 908 - 233 -8500 ext. 206. Please note that you may wish to consult an attorney to help you determine what rights you may have, if any, under the Protecting Tenants at Foreclosure Act of 2009. IMPORTANT NOTICE FO SEiRVICEMEMB A ND THEI DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Service members Civil Relief Act, (SCRA). This includes protection from foreclosure or eviction. You also may be eligible for benefits and protections under state law, SCRA and state military benefits and protections also may be available if you are the dependent of an eligible service member. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard • Active service with the National Guard Active service as a commissioned officer of the National oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Health Service • Service with the forces of a nation with which the United States is allied in a war or military action • Service with the National Guard or a state militia under a state call to duty; or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. Address: Zucker, Goldberg & Ackerman, LLC .200 Sheffield Street, Suite 101 Mountainside, NJ 07092 _ Attn: Barbara Soogrim /Caroline Kriak Phone: (908) 233 -8500 ext. 184 Fax: (908) 654 -7378 Email: militarymember @zucicergoldberg.com All questions regarding the property should be addressed to the following agent: Name: Harry Speelman Phone: 717 -440 -6336 Email; harry.speelrnan @century2l.com Very truly yours, ZUCKER, GOLDBERG & ACKERMAN, LLC Sonay Culpepper- ext. 206 Zucker, Goldberg & Ackerman, LLC Page 2 IMPORTANT NOTICE TQGERV|CEK8EK80EHS AND THEIR DEPENDENTS: PROTECTIONS UNDER THE SERV|CE&1EN4BERS CIVIL RELIEF ACT If you are a semicemember on "active duty"' or "active service," or dependent of such a *e/vicemember, you may be entitled to certain |egal rights and protections, including protection from eviction, pursuant to the Service membersOvi| Relief Act (SO USCApV. §§ 581'596), as amended, (the °SCRA'')and, possibly, certain related state statutes. Eligible service can include: 1� active duty (osde0nedin»action1Ol(d)(1)ofhdelU,UnitedStateo[ode)withtheArmy,Navy Air Fome, Marine Corps, or Coast Guard; L active service with the National Guard; Z. active service as a commissioned officer of the National Oceanic and Atmospheric Administration; 3. active service asa commissioned officer of the Public Health Service; or 4. service with the forces of a nation with which the United States is allied in the prosecution of a war or military action, Eligible service also includes any period during which aservicememberis absent from duty on account n[ sickness, wounds, leave, o, other lawful cause. If you are such a servicemernber, or a dependent of such a servicemember, you should contact Deena Allen at (g08)-233-OSVVext184bo discuss your status under the SCRA, ' ' ' ' ' ` ` ` - Zud(er, Goldberg &Ackerman, LLC Page UNIT STATES >����������� F-owEs x ZIP 0; tJ his u s a t cat of hf a ling . �: +oVides e id:nce ,ha a has bec'I ;; eseniod to U"'1 02 ' - i {CTFIet�On21 r^21i ... "� D 1 ;: f 4 . >O <IV domeanc and rn ; 20'3 From: Sonay CLIl.DeppeE �__ c/o Zucker, Goldberg Ackeri - nan, LLC 200 Sheffield Street, Suite 101 Mountainside NJ 07092 XCF 1 75926 EVI To; Wanda Neumann andjor'renant(s) known or unknown Postmark Here ..... ...... . __ __........ _._... 428 South Hanover Street Carlisle , PA 17013 County of P.Q.: Cumberland PS Form 3817, APri! 2007 PSN 7530 -02 -000 -9065 Zucker, Goldberg & Ackerman, LLC Page 4 7196 9 008 911, 6015 8180 TQ : l �`tt!trj::i \ 'i sl:;lttn n ir,' ttnl:nrnvt} zt; i a SE NDER: sc . REFERENCE: i ; So2 6- I,V.... 1; 1 1 1 i SERVICE r''r_'i`ied Fee �— t�eturr? � ���atfrctcg9l�p(ivnn T �� W w Total �r ;yep Fees Receipt for " certified tail - x � � i�a tnn�rr;rs,,;e t. "�svrr� _ +� Aron- +re ° �'"' . "" • � "a Ck> Not Llg�= y tc r g6r�ru;Juv�w3 c $ s z 'ys s I NO. t =�af�t T � /" LZ TM FOR . 1S PAT. 5, 0t 3Q3 THE 7196 9008 9311 6605 8160 WALZ S CERTIFIED Wanda Ncurnann TO Neumann MAILERTM and /or Tenants) known or unknown at: and, /Or' enarlt(s) known or unknowil at: 428 South Iianover Street 428 South 1 lanover Street Carlisle. PA 17413 Label #1 Carlisle, Pia 17413 I� SENDER: SC Wanda ;Neum.att» anchor 'reiiant(s) known or unknown at: REFERENCE: 17.5926 -EV NTV 11112013 428 l -,outh Ham.wer Street Label #2 Carlisle, PA 17013 RETURN P25 ' RECEIPT Certified Fee y SERVICE R eturn Rec eipt Fee _ Wanda Neumann R estricted Dolly anC�oi' T't;narll(4} known 0[' tililCt2C ?��7'I at: Toter Postag a Fees 428 South Hanover Street US Postal Services' POSTMARK OR DATE Label #3 Carlisle.. PA 17013 Receipt for Certified [Mail"' No Insuranca Coverage Provi0ed A FOLD AND TEAR THIS WAY ----► OPTIONAL Igo Not Use for InomillonN MM Label . ��=..s......_.. ._. t� rat Wanda. IVOL(mcain anchor'rertartt(s) known oi unknowm at: 428 South Hanover ISArect Carlisle, PA 17413 or . l XG C3 charge C7 Amount• 111" 7196 9006 9111 66015 6160 Ir Charge TO; teDtdl At Iii Y Awl r9iiS WA C �2. Article Number COMPLETE T:HIS SEC T IO 1 A. fiaoolvsd by (Please Print Clearly) B. Bate of Delivery .. AI 1 �t0 � i C. Signature 0AOoM 1 � ^ 1 _ _ rc Addreaeae t -•• I 7196 9008 9111 6605 818GI ---° () '� t D. is dailvery address different frcxn item 17 Yes U ilk ¢ m ,.._.._ __ It YES, eater deitvary address below: No 0) 3. Service Typo CERTIFIED MAILTM a Q CL r 4.. R estricted Delivery? (Extra Fee) [ 1yen it J t. Article Addressed to: W 4 Z 1 Wanda Neumann co iii " O alid/or Tenant(s) ktit)wn or unk.no�Nn at: •G �7 ( 428 South t lanover Street W V Carlisle, PA 17013 ,Q Q 1 0 (D 1759264"V N FV l I I I?413 SC t — PS Form 3811, January 2005 '� Domestic Return Receipt Chase Occupant Contact Information Sheet xYx Each OccupantlAdult (I8 or Oltlet) must fill ow a separate form WIST have a valid photo identification ❑ Tenant ❑ F ormer Ho ❑ Unknown 1. ()c l.rtform;atit)tr. Full Le a, Narne: Secti 8: ❑Yes ❑No ❑ Unknown Eerit Control: ❑Yes ❑ U nkno wn Do you have an existing written lease or rental agreement? Yes No If yes, attach a copy. i Did you have a verbal agreement with the Former Homeowner /Landlord? ❑Yes ❑No If yes. attach evidence of terms. i Is any occupant an active duty servicernember, the dependent of an active duty servicemember, or otherwise qualified for p rotection according to the notice provisions on page three? []Yes ❑No Larne of the ser•viceinember and relationshi to Occti )ant: Date of Birth - -- Horn No.: C urrent Address: City: Sta te: — _Zi ) Code: E -mail Address: Curren Employer: — Position: _ E mploye r Telephone N o.: E: - tiiail Facsimile No.:_ _ — _ - -- - - I_ Employ Ad dres s — _ Ho Long Emplo ?: City - _— - - -- — — �- State: _ . . Zip .. Code: s _ Relation to Former Homeowner / Landlord: -- — ._.._..___ . - ........� Ren ter's Ins ?. ❑Yes ❑No _ n urance Company Name: I 2. Ellier•genci C )I ct. InUormati —. Natne of a perso» not residing with you: Address: -_ - -- _Y Stat 777 7= Zi Code: Telephone No onshi - - � p: 3. Veh iniornmti4m: �— Make _ Mode — ,- - Color Year No.: i Vehicle #1: _1 Vehicl 92 Vehicle 93 : — — - - -- _ 4. 0ther (lccut►rrnt I ntorrrra _ I Name: D _ Occupant 41 Occup #2 ( occu ant #3 Occti patit -14 —� Occu �aipt #5� ate of Birth: -_ -- Se ivt ❑F ❑M a - ❑M � S. I'et Information: —� ' Pet # I Pet #2 Pct #3 Pet #4 Pet #5 . _ ? Breed: I — -- Weight: - - � - -- — - — I authorize the verification of the information provided on this form and have received a copy of this docrunent. I I acknowledge com of this document does nof gua rantee contin occupancy by an individual or pet. Full Legal Signature of Occupant: I Date: 4 Pro cit Ad ter dress: yak -- ___ Ci (' ,� -- - Slate: `p .. _.r. Zi Code: t o�t3 F ormer Homeowner ❑Tenant LL Un.known� No C ontac t Secti 8: Yes No Unknown T _ I Rent C_ontr_ol___ _Yes No 3nknown Personal Property: If property is_vacant, is there any property remaining in or on the property? :9Yes MNo If property is occupied by a Tenant (as indicated above), is there any personal property present that belongs to the Former Homeowner: []Yes ❑No Unknown __I &_.__. Any code violation or hazardous condition noted? es o If yes, please explain: 5"'V ©; C Is any occupant an active duty servicemember, the dependent of an active duty servicemember, or otherwise ,qu lified for protection according to the notice provisions on page three? ❑Yes ❑Noi'nknown If yes, is protection under: ❑Federal Law SCRA ❑State Law SCRA ❑ Unknown _ Name of the se and r to Occupant: Please provide a detailed reason for any boxes checked "Unknown' in the Listing Agent/Property Inspector section and for any fields left blank in the Occupant section. Describe how you confirmed the REO property was occupied (i.e., With whom did you speak? What observations did you make ?) If there is personal property on the REO property, please describe the location of the personal property and separatel list the perso property on page e 4. NEW MM Mm" Date Time Contact Name Information W Follow -up Complete? Required? 1 1. ►*1 OC l� 0l1 N o , Swt,✓ N ---- Yes o es No __ 2 c+ �. Al Am _ �roa. On c'�r' - f � Q �� ScU�'r` ❑Yes o es No I ���IUC " 0�1 t;,d /�%r� �}r1 Yes s No t tg -{ CVI c el /Jb XIr :�' K Yes o es No �iT. ,v 0 ,�-nJ- _ ...Yes o -- ^ � No Signature of Listin Agent/Property Insp /Chase C Team: Date: i Rev. 0.5.12 IMPORTANT NOTICE FOR SERVICEMEtMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemernbers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You also may be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissionned officer of the Public Health Service • Service with the forces of a nation with which the United States is allied in a war or military action • Service with the National Guard or a state militia tinder a state call to duty; or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, you should contact ,1PMorgan Chase Bank, National Association toll free at (877) 584 -3290. LIST OF PERSONAL PROPERTY Must include photograph of .Personal Property listed below VERIFICATION verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S.A. § 4904 related to unsworn falsification to authorities, ,1PMORGAN CHASE BANK, NATIONAL ASSOCIATION By: Name: Alma Hmeie �Vioe President Title: DATE: Q a I Borrower Name: Wanda K. Neumann, Michael E. NeUnlann, and Unknown Occupants Property Address: 428 South Hanover Street, Carlisle, PA 17013 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OE, -74F TV-1E RROTHOHO A 2 i PR 21 PSI 3.. 32 CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. vs. Wanda K. Neumann (et al.) Case Number 2014 -1903 SHERIFF'S RETURN OF SERVICE 04/02/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Edward Neumann, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Erie, Pennsylvania to serve the within Complaint in Ejectment according to law. 04/10/2014 07:10 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Matt Neuman, who accepted as "Adult Person in Charge" for Occupant at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013. RYAN BURGETT, DEPT! Y 04/10/2014 07:10 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Matt Neuman, son, who accepted as "Adult Person in Charge" for Wanda K. Neumann at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013. R YAN BURGETT DE SHERIFF COST: $73.56 SO ANSWERS, April 15, 2014 c) ou tySio e _ tleritt Te eosctt, inc. !K°: RONNY ANDERSON, SHERIFF SHERIFF'S ~°" .~~.�". . ^~ ��. . o~*=~ OF CUMBERLAND COUNTY . Ronny RAnderson "F 0F F ICE Sheriff OF THE PROTHONOT ARY m_,- Jody S Smith Chief Deputy Richard W Stewart Solicitor 41,6. OFF'O,E OF THE $HERiFe - AMENDED 7 2D|4MP��� PM �:�� �._— ..^ � °� CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. vs. Wanda K. Neumann (et al.) Case Number 2014-1903 SHERIFF'S RETURN OF SERVICE 0482/2014 Sheriff Ronny R Anderson, being duly sworn according to Iaw, states he made diligent search and inquiry for the within named Defendant to wt: Micha& Edward Neumann, but was unable to Iocate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Erie, Pennsylvania to serve the within Complaint in Ejectment according to law. 04/10/2014 07:10 PM Deputy Ryan Burge#, being duly sworn according to |avv, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Matt Neuman, son, who accepted as "Adult Person in Charge for Wanda K. Neumann at 428 S Hanover Street, Carlisle 8onovgh, Carlisle, PA 17013. RYAN BURGETT, DEPUTY 04/10/2014 07:10 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a per on representing themselves to be Matt Neuman, who accepted as "Adult Person in Charge" for Occupant at 428 S Hanover Street, Carlisle Borough, Carlisle, PA 17013. 04/14/2014 02:39 AM - The requested Complaint in Ejectmen served by the Sheriffof Erie County upon Michael Edward Noumann, personally, at SCI Albion, 10745 Route 18, Altion, PA 16475. John T. Loom/a, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $73.56 SO ANSWERS, April 15, 2014 (r) CountySuilo Sheriff: Toleosoft, RONNYR ANDERSON, SHERIFF JOHN T. LOOMIS Sheriff JON HABURSKY Chief Deputy SHERIFF'S OFFICE OF ERIE COUNTY FORGED WOW PRIDE JEFFREY GUILD Captain WILLIAM FENTON Lieutenant JPMORGAN CHASE BANK, NATIONAL ASSOCIATION vs. WANDA K NEUMANN (et al.) Case Number 2014- 01903M SHERIFF'S RETURN OF SERVICE 04/14/2014 02:39 PM - DEPUTY JUDY TOME, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN EJECTMENT (CIEJ) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: MICHAEL EDWARD NEUMANN AT SCI ALBION, 10745 RT 18, ALBION, PA 16475. JUDY TOME, DEPUTY SHERIFF COST: $81.00 SO ANSWERS, April 15, 2014 Affirmed and subscribed to before me this 15---At___day of ?lainfiff Attorney ZUCKER, GOLDBERG & ACKERMAN, 200 SHEFFIELD STREET, SUITE 301, MOUNTAINSIDE NJ 0709: � � � (c) Count }Suite Sheriff, Teleosofl. Inc. NOTARY N dear /14'4) JOHN T. LOS, S HERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JP MORGAN CHASE BANK, NATIONAL : CIVIL DIVISION ASSOCIATION, NO: 14 -1903 Civil Plaintiff, vs. Wanda K. Neumann, Michael E. Neumann, and Unknown Occupants Defendant(s). CIVIL ACTION - PLEADING TO COMPLAINT IN EJECTMENT In answer to complaint filed by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, by its attorneys, Zucker, Goldberg & Ackermann, LLC. I do understand that 1 must vacate the property at 428 South Hanover Street, Carlisle, PA 17013. Effective on Monday, April 28, 2014, I will be the only person residing at this address. My stepson, Matthew E. Neumann, is moving to Austin, TX on that day and my husband is incarcerated at SCI - Albion, Albion, PA. I had been working with Harry Speelman Jr, a realtor at Century 21 in Carlisle, PA through email to negotiation a "Cash for Keys" settlement with JPMORGAN CHASE. The last contact that 1 had with Mr. Speelman was Friday, November 29, 2013. 1 have included these emails and they are marked as Exhibit "A ". I had also emailed the realtor, Greg Phenicie, which had sold us the home. I explained my needs to him, and he had contacted a "friend" to see if they would be able to assist me. He advised that they were unable to help me. The said emails are marked as Exhibit "B ". I am in the process of liquidating all of my assets so that my pets and I are able to move out of this home. The only thing that I ask of the courts is for a 90 -day extension to give me time to liquidate all that I have and find a new home in which to move to since I am now doing this on my own. Dated: /;/ Jt/ BY: Wanda K. Neumann EXHIBIT A )EFIPfFY Connect m.e.neumann@comcast.net + Font Size -- Re: 428 S Hanover Street From : Harry Speelman Jr <brk8balls @aol.com> Subject _:_ Re: .428 S. Hanover Street. To : m e neurrnnn <m.e.neumann @comcast.net> Thu, Jan 31, 2013 02:38 PM The negotiator just left we a -message. Thee- bank -is -not in acceptance to your counter offer for the-cash for keys. Harry Speelman Jr Century 21 A Better Way — Original Message — From: m.e.neumann <m.e.neumann @comcast.net> To: Harry Speelman Jr <brk8balls @aol.com> Sent: Thu, Jan 31, 2013 10:42 am Subject: Re: 428 S Hanover Street Harry, Just wondering if you've heard anything from the negotiator? Wanda From: "Harry Speelman Jr" <brk8balls @aol.com> To: "me neumann" <me.neumann @comcast.net> Sent: Tuesday, January 22, 2013 2:24:19 PM Subject: Re: 428 S Hanover Street Just spoke with my negotiator about your home. She was wondering if you had an attorney representing you with the issues of the mortgage company? If you do, can you please get me the contact information for me. Thanks, Harry Speelman Jr Century 21 A Better Way — Original Message— From: m.e.neumann <m.e.neumann @comcast.net> To: brk8balls <brk8balls @aol.com> Sent: Tue, Jan 22, 2013 11:42 am Subject: Re: 428 S Hanover Street Okay, I was only asking. I keep forgetting that yesterday was a holiday because I had to work. Thanks for your response. From: brk8balls @aol.com To: "m e neumann" <m.e.neumann @comcast.net> Sent: Tuesday, January 22, 2013 11:17:48 AM Subject: Re: Fwd: 428 S Hanover Street No I have not heard. With holiday yesterday 1 don't expect to hear from them till later in week. Sent via BlackBerry by AT &T From: me.neumann @comcast.net Date: Tue, 22 Jan 2013 16:16:02 +0000 (UTC) To: Harry Speelman Jr <brk8balls@aol.com> Subject: Fwd: 428 S Hanover-Street Hello Speelman, I know that it's probably too early to ask, but I was wondering if you have heard anything from Chase or the negotiator? Thank you, Wanda Neumann From: "me. neurrenn" <m. e. neumann @comcast.:oet> To: "Harry Speelman Jr" <brk8balls @aol.com> Sent: Friday, January 18, 2013 4:36:56 PM Subject: Re: 428 S Hanover Street Hello Harry, I spoke with my husband, and he said that he feels that they should give us until the end of March and 15K or until the end of February and 20K. I told him the offer that they bank made, and he came up with his amount due to we had filed papers with the courts and are still waiting for a decision from the judge. Plus when the mortgage was originally decided on, the broker that we had used included my husband's unemployment as part of my pay without us knowing it. The broker was also later arrested (or so I believe) and is no longer a broker. There has been some other issues with Chase that we have had and rry husband feels that they owe us for the problems that . we have had with them. If you like, you can have your negotiator go to the bank with these amounts and then we can see what they come back to us with. As far as needing a moving company, we can do the moving ourselves and I really feel that if I have a place to go to, we can be out by the end of February. Thanks, Wanda From: "Harry Speeknan Jr" <brkBbafs @aoi.com> To: "me neunenn" <me. neumann@comcast. net> Sent: Friday, January 18, 2013 4:23:55 PM Subject: 428 S Hanover Street You can email rre at brk8balls @aoicom or at harry.speelrrmn @century21.com or phone me at 717- 440 -6336. I spoke with the negotiator and explained the situation to her. She said once you had a chance to talk to your husband and discuss what it would take; more time or cash for moving expenses or even the bank hiring a moving company for you to let her know and she will attempt to make it work. I also mentioned that there was no way you would be out by months end she said that if we could make it happen by middle of next month that should not be a problem Ultimately everything has to be approved through the bank. Let rre know what you may need in vacating the home so I can pass It along to the bank. Thanks, Harry Speekren Jr Century 21 A Better Way 4/23%2014 XFINQTY Connect XFINITY Connect m.e.neumann @comcast.net + Font Size - Re: Fwd: 428 S Hanover Street From :- brk8balls @aol: com Subject : Re: Fwd: 428 S Hanover Street To : me neumann <me.neumann @comcast.net> Reply To : brk8balls @aol.com Fri, Feb 22, 201303 :36 PM Just got off phone with new negotiator he's checking back with bank on offer for cash for keys if it still stands and best they can do for you. I will let you know when I hear something. Sent via BlackBerry by AT&T From: me.neumann @comcast.net Date: Thu, 14 Feb 2013 16:33:36 +0000 (UTC) To: <brk8balls @aol.com> Subject: Fwd: 428 S Hanover Street Have you heard anything more from the negotiator conceming the amount that the bank is willing to offer? I know that they originally said $4000, but after telling them what my husband wanted, I didn't know if they may have come up with a higher amount or not. Please advise. Thank you! From: "m e neumann" <m.e.neumann @comcast.net> To: "Harry Speelman Jr" <brk8balls @aol.com> Sent: Thursday, January 31, 2013 6:08:58 PM Subject: Re: 428 S Hanover Street What is the mostthat they are willing to offer? From: "Harry Speelman Jr" <brk8balls @aol.com> To: "m e neurrenn" <m e. neuntann @comcast. net> Sent: Thursday, January 31, 2013 2:38:42 PM Subject: Re: 428 S Hanover Street The negotiator just left rre a message. The bank is not in acceptance to your counter offer for the cash for keys. Harry Speelman Jr Century 21 A Better Way — Original Message — From: m.e.neumann <m.e.neumann @corcast.net> To: Harry Speelman Jr <brk8balls @aol.com> Sent: Thu, Jan 31, 2013 10:42 am Subject:. Re:. 428 S Hanover Street Harry, Just wondering if you've heard anything from the negotiator? Wanda From: "Harry Speelman Jr" <brk8balls @aol.com> To: "me neummnn" <me.neunnnn @comcast.net> Sent: Tuesday, January 22, 2013 2:24:19 PM Subject: Re: 428 S Hanover Street • 4/23/2014 XFINITY Connect XFINITY Connect m.e.neumann@comcast.net + Font Size - Re: 428 S Hanover Street From :-Harry Speelman Jr <brk8balls @aol.com> Subject : Re: 428 S Hanover Street To : m e neumann <m. e. neumann @comcast. net> i Wed, Mar 06, 2013 11:28 AM The negotiator had just sent me an email. He wanted to know how soon you could vacate the home with a cash for keys offer. Not sure of the figure that they are looking at making you. Harry. Speelman Jr Century 21 A Better Way —Original Message-- - From: m.e.neumann <m.e.neumann @comcast.net> To: brk8balls <brk8balls @aol.com> Sent: Thu, Feb 14, 2013 11 :33 am Subject: Fwd: 428 S Hanover Street Have you heard anything more from the negotiator conceming the amount that the bank is willing to offer? I know that they originally said $4000, but after telling them what my husband wanted 1 didn't know if they may have come up with a higher amount or not. Please advise. Thank you! from: "m e neumann" <m.e.neumann @comcast.net> To: "Harry Speelman Jr" <brk8balls @aoLcom> Sent: Thursday, January 31, 2013 6:08:58 PM Subject. Re: 42$ S Hanover Street What is the Trost that they are willing to offer? From: "Harry Speelrren Jr" <brk8balls @aol.com> To: "me neumann" <m.e,neumann @comcast.net> Sent: Thursday, January. 31, 2013 2:38:42 PM Subject: Re: 428 S Hanover Street The negotiator just left me a message. The bank is not in acceptance to your counter offer for the cash for keys. Harry Speelman Jr Century 21 A Better Way — Original Message — From:. m.e.neumann <rn.e.neumann @comcast.net> To: Harry Speelman Jr <brk8balls @aol.com> Sent: Thu, Jan 31, 2013 10 :42 am Subject: Re: 428 S Hanover. Street Harry, Just wondering if you've heard anything from the negotiator? Wanda From: "Harry Speeiman Jr" <brk8balls @aol.com> To: "me neumann" <m.e.neumann @comcast.net> Sent: Tuesday, January 22, 2013 2:24:19 PM Subject: Re: 428 S Hanover Street 4/23/2014 XFINLTY Connect XFINITY Connect m.e.neumann@comcast.net + Font Size - Re:428 S Hanover Street From -: -Harry , Speelman -Jr <brk8balls @aol.com> Subject : Re: 428 S Hanover Street To : true tieumann <m e. neumann@comcast.net> Thu, Apr 04, 2013 12:48 PM_ Spoke with agent fromthe bank little bit ago. They gave me an offer of $3000 cash for keys with a vacate date of May 10th. What are your thoughts on this? Have you had any luck finding a place to go? Let me know if you would be wiling to entertain an offer of this nature or what will it take in the aspect of an offer from them for the keys. Harry Speelman Jr Century 21 A Better Way 4/23/2014 XFINQTT Connect XFINITY Connect m.e.neumann@comcast.net t Font Size - Re: 428 S Hanover Street From : Harry Speelman Jr <brk8balls @aol.com> Subject : Re: 428 S Hanover Street To in e neumann <rn e. neumann @comtast. net> Just sent them a message in regards to what you have just said, will let you know when they contact me. Thanks, Harry Speelman Jr Century 21 A Better Way ---- Original .Message — From: m.e.neumann <m.e.neumann@comcast..net> To: Harry Speelman Jr <brk8balls @aol.com> Sent: Sat, Apr 27, 2013 12:42 pm Subject: Re: 428 S Hanauer Street Sat, Apr 27, 2013 01:36 PM There is no way that] could vacate the property .by.5 /10, !would say the earliest would be no later than 6/1. I would also settle for the $4000. I am looking at a home in Steelton for $25k, but there is a repair escrow on the home that needs to be paid by the buyer, and I'm not really sure what that would mean to me. From: "Harry Speelman Jr" <brk8balls @aol.com> To: "m e neumann" <m.e.neumann @comcast:.net> Sent: Friday, April 26, 2013 3:23:24 PM Subject: Re: 428 S Hanover Street Just heard from the asset manager for the bank. They are willing to give you an offer of $4000 cash for keys with vacate date of 5 -10. I - mentioned tofiimthattime wse would rr retharriikely not be- sufficient enough. What are yourthoughts? Harry Speelman Jr Century 21 A Better Way --- Original Message-- - From: Harry Speelman Jr <brk8balls @aol.com> To: m.e.neumann <m.e.neumann @comcast.net> Sent: Fri, Apr 26, 2013 10:23 am Subject: Re: 428 S Hanover Street Just sent agent another message wanting to know status on getting back to me. How has the house hunting been going? Have you found anything fitting your needs as of yet? Or have you received any other information from the bank since our last conversation? Wondering if there was a date you had planned on vacating property or are you awaiting to hear if they are willing to change the amount offered? Harry Speeknan Jr Century 21 A Better Way 4/23/2014 XFINITY Connect XFINITY Connect m.e.neumann@comcast.net + Font Size - fwd: 0024785883 - 428 S HANOVER ST CARLISLE, PA From : Harry Speelman Jr <brk8balls @aol.com> Subject : Fwd: 0024785883 - 428 S HANOVER ST CARLISLE, PA To : me neumann <me.neumann @comcast.net> Mon, Apr 29, 2013 04:30 PM 2 attachments Just received this message earlier this afternoon from the asset manager at Chase. Cash for keys at $4000 and vacate of 6 -1 -13. What's your thoughts, if interested will need you to read over attached documents and sign and get back to me ASAP. Thanks, Harry Speelman Jr Century 21 A Better Way Sent: Mon, Apr 29, 2013 1:31 pm Subject: 0024785883 - 428 S HANOVER ST CARLISLE, PA Hi Harry, CFK approved for 4000 with a vacate date of 06/01/2013. Please have RAP docs signed and sent back ASAP Thanks! Mike The information in this electronic mail message is the sender's business confidential and may be legally privileged. it is intended solely for the addressee(s). Access to this Internet electronic mail message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful." 'The sender believes that this E -mail and any attachments were free of any virus, worn, Trojan horse, and /or malicious code when sent. This message and its attachments could have been infected during transmission. By reading the message and opening any attachments, the recipient accepts full responsibility for taking protective and remedial action about viruses and other defects. The sender's employer is not liable for any loss or damage arising in any way from this message or its attachments. " {sar} _ 'The information in this electronic mail message is the sender's confidential business and may be legally privileged. It is intended solely for the addressee(s). Access to this Internet electronic mail message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful." "The sender believes that this E -mail and any attachments were free of any virus, worm, Trojan horse, and /or malicious code when sent. This message and its attachments could have been infected during transmission. By reading the message and opening any attachments, the recipient accepts full responsibility for taking protective and remedial action about viruses and other defects. The sender ?s company is not liable for any loss or damage arising in any way from this message or its attachments." "Nothing. in this email shall be deemed to _create a binding contrail topurchase /sell real estate. Thesender.of this email does not have the authority to bind a buyer or seller to a contract via written or verbal communications induding, but not limited to, email communications." GCB r2� Relocation_Assistance_Agreements_1[1].pdf 113 KB fw9[1].pdf 104 KB 41231211i4 UNITY Connect XFINITY Connect m.e.neumann@comcast.net -- Font Size - Re: 0024785883 - 428 5 HANOVER ST CARLISLE, PA From : Harry Speelman Jr <brk8balls @aol:com> Subject : Re: 0024785883 - 428 S HANOVER ST CARLISLE, PA To : me neurrann <nbe.neunann @comcast.net> Mon, Jun 17, 201304:23 PM Have not heard back from you in awhile. The representative from the bank was wondering what the status is on the home. Are you willing to do the cash for keys offer? If so can you please fill out the paper work that I had emaled you previously and get that to me as soon as possible.. Any information I -can forward onto them would be helpful. Thanks, Harry Speelman Jr Century 21 A Better Way — Original Message — From: m.e.neumann <m.e.neumann @comcast.net> To: Harry Speelman Jr <brk8balls @aol:com> Sent: Sun, May 26, 2013 11:25 pm Subject: Re: 0024785883 - 428 S HANOVER ST CARLISLE, PA Harry, I am interested in their offer, but having difficulty with a new home. From: "Harry Speelman Jr" <brk8balls @aol.com> To: "rn e neumann" <m. e. neumann @comcast. net> .Sent: Thursday; Play 16, 2013 -8:04:41 AM Subject: Re: 0024785883 -428 S HANOVER ST CARLISLE, PA Haven't heard a response to their offer. What are your thoughts on this? Harry Speelman Jr Century 21 A Better Way — Original Message — From: Harry Speelman Jr <brk8balls @aoi.com> To: m.e.neumann <m.e.neumann@comcast.net> Sent: Mon, Apr 29, 2013 4:30 pm Subject: Fwd: 0024785883 - 428 S HANOVER ST CARLISLE, PA Just received this message earlier this aftemoon from the asset Hanger at Chase. Cash for keys at $4000 and vacate of 6 -1 -13. What's your thoughts, if interested will need you to read over attached documents and sign and get bad( to me ASAP. Thanks, Harry Speelman Jr Century 21 A Better Way Sent: Mon, Apr 29, 2013 1:31 pm Subject: 0024785883 - 428 S HANOVER ST CARLISLE, PA Hi Harry, CFK approved for 4000 with a vacate date of 06/01/2013. Please have RAP does signed and sent back ASAP Thanks! Mike 'The information in this electronic mail message is the sender's business confidential and may be legally privileged It is intended solely for the addressee(s). Access to this Internet electronic nail message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful." 4i2a 2014 XFIrlFrY Connect XFINITY Connect m.e.neumann@comcastnet + Font Size - Re: Fwd: 428 s hanover From : brk8balls@aol.com Subject : Re: Fwd: 428 s hanover Ta : m-e- neunann <me.neumann @comcast.net> Reply To : brk8balls@aol.com I can try to contact rry assest manager to see if option is still available. Thanks, Harry Speelman Sent via BlackBerry by AT&T Fri, Nov 29, 2013 10:19 AM From: nn e.neumann @comcast.net Date :Fri, 29Nov2013 15:17:33 +0000 (UTC) To: Harry Speelman Jr <brk8batls @aol.com> Subject: Fwd: 428 s hanover Hello, the homes that we were looking at were under contract and already sold. We are going to look at another on Monday in Harrisburg, and hopefully that will pan out. Do you know if the bank is still offering the $4000 for the cash for keys option? In my quest for finding a home, I now see on Trulia that the home we are in is going to be auctioned on December 3rd.. I understand that I need to get out of this home, and am trying to find a place to go to. Thank you, Wanda Neumann From: "m e neumann" <m.e.neumann@comcast.net> To: "Harry Speelman Jr" <brk8balls @aot.com> Sent: Monday, November 4,. 2013 2:13:05 PM Subject: Re: 428 s hanover Sorry, I had a system crash and didn't have access to my emails. Yes, I am stilt interested. I am waiting to hear back from another reactor about a -home. Will keep you updated once I know more. Regards, Wanda From: "Harry Speelman Jr" <brk8balls @aol.com> To: "m e neumann" <m.e.neumann @comcast.net> Sent: Monday, October 7, 2013 2:2128 PM Subject: 428 s hanover Are you still interested in some relocation assistance? What are your plans? The bank just contacted me wondering what your intentions are with the property? Have you spoken to your attorney in regards to the lawsuit you had mentioned that you were filing . against the bank? Can you please update nne so I can forward this information onto the bank? Thank you, Harry Speelman Jr Century 21 A Better Way EXHIBIT B 4/23/2014 XF1NF Y Connect XFINITY Connect m.e.neumannOcomcastnet Font Size - Re: Home to move in to From : gregphenicie <gregphenicie @verizon.net> Subject : Re: Home to move in to To : m e neumann <m. e. neumann @conx ast. net> Hi, My friend had nothing avaiiab e, sorry. Greg Sent from my I phone On May 16, 2013, at 11:20 AM, m.e.neumenn @coraxast.net wrote: Thu, May 16, 2013 12:04 PM Hello Greg, Was just wondering if your friend had gotten back to you or not. The bank is pushing for me to be out by 6/01 and at this point, I don't see it happening. I would like to go back to them with a better date if possible. Thanks again! From: "Greg Phenicie" <gregphenicie ©verizon.net> To: "m e neumann" <m.e.neumann @comcast.net> Sent: Monday, May 13, 2013 3:19:49 PM Subject: Re: Re: Horne to move in to Hi Wanda, Can I forward this to my friend George to see if he has anything for you? Regards, Greg On 05/13/13, m.e.neumann @comcast.net wrote: Hello Greg, I have no one other than my son who just graduated from college. I do have about $2500 cash, plus the bank is willing to give me $4000 on a "cash for keys" agreement. I know that it will be difficult for me, but I'm stuck between a rock and a hard place. I can't rent because of my credit and pets. i was hoping that I could find an inexpensive home or a foreclosed home that would be around $250 -300 a month. 1 could probably go as much as $400. I don't know if this will help or not. My previous mortgage was over $800 a month and !tried to refinance with Chase and they wanted me to go even higher with my payments. There was no way that I could do it myself. If you are not able to help, I understand completely. 4/23/2014 Thank you for your time, Wanda XFIN ITY Connect From "Greg Phenicie" <gregphenicie©verizon.net> To: "m e neumann" <m.e.neumann ©comcast.net> Sent: Friday, May 10, 2013 9:54:05 AM Subject: Horne to move in to Hi Wanda, Sorry to hear of your circumstances. It must- be difficult- for you. Is there anyone in your fife that could give you asistance to help with a house? You need some financial strength to go forward if your credit is poor. Please let me know if this is an option for you. Regards, Greg IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, �= NO.: 14-1903 Wanda K. Neumann, Michael E. Neumann, and r' r, Unknown Occupants; _J L.� C_ i Defendant(s). - ' MOTION FOR SUMMARY JUDGMENT AGAINST DEFENDANTS PURSUANT TO PaR.C.P. 1035.2 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION ("Plaintiff"), by its attorneys,Zucker, Goldberg& Ackerman, LLC,files the following Motion for Summary Judgment against Defendants Pursuant to Pa. R.C.P. 1035.2: 1. Plaintiff commenced the above-captioned action by filing a Complaint in Ejectment on or about April 1, 2014, with respect to Plaintiff's real property known and numbered as 428 South Hanover Street,Carlisle, PA 17013 (hereinafter"Real Property"), a copy of which Complaint is attached hereto as Exhibit"A" . 2. In its Complaint, Plaintiff alleges that Defendants Wanda K. Neumann; Michael E. Neumann and Unknown Occupants(hereinafter"Defendants"),are unjustly and unlawfully retaining possession of the Real Property to the detriment of Plaintiff. 3. In its Complaint, Plaintiff also alleges that Defendants are occupying, using and enjoying the Real Property without right and/or Claim of Title. 4. On or about September 21, 2012, Defendants were personally served with Plaintiff's Notice of the Sheriff's Sale.A true and correct copy of the Sheriff's return of Service is attached to Plaintiff's complaint. 5. Plaintiff purchased the Real Property at Sheriff Sale on December 5,2012,and Plaintiff has made final settlement with the Sheriff of Cumberland County. 6. By sheriff's Deed dated September 3, 2013, recorded on October 2, 2013, Instrument #201332382,the Sheriff of Cumberland County has conveyed to Plaintiff, all that certain lot or piece of ground,with improvements erected thereon, and as more fully described in the Deed and as purchased by Plaintiff at Sheriff Sale on December 5, 2012.A true and correct copy of the recorded deed is attached to Plaintiff's Complaint as Exhibit"A" and incorporated herein by reference. Zucker,Goldberg&Ackerman, LLC XCE-175926-EV r i t 7. On November 11, 2013, Defendants were requested to vacate Plaintiff's Real Property, a copy of which request is attached to Plaintiff's Complaint as Exhibit"C" and incorporated herein by reference. 8. Defendants have failed to vacate the Real Property, and therefore Plaintiff filed the aforesaid Complaint. 9. On or about April 28, 2014, Defendants filed an Answer to Plaintiff's Complaint (hereinafter"Answer"). A true and correct copy of Defendants'Answer is attached hereto as Exhibit "By'. 10. Defendants'Answer admits all relevant allegations in Plaintiff's Complaint, and only generally denies that they are occupying the property unlawfully as a conclusion of law. 11. Defendants'only apparent purpose for filing this Answer was to continue in possession of the Premises rent-free and without right of title. 12. Defendants'Answer fails to specifically deny any of the averments in the Complaint or offer any valid, supported defenses in their Answer. 13. To further support the averments in its Complaint, Plaintiff has filed a sworn affidavit, which is attached hereto as Exhibit"C"and made a part hereof. In the Affidavit, an authorized representative of Plaintiff certifies that Plaintiff has requested Defendant to vacate the Real Property, but Defendant has failed or refused to do so; and that Plaintiff has no contractual or lease arrangement with Defendant for Defendant to remain in possession of the Real Property. 14. Plaintiff is the title-holder of the Real Property that Defendants refuse to vacate. Defendants have failed to raise any genuine issue of material fact in the Answer and have failed to offer any defense for their failure to vacate the Real Property.Therefore, pursuant to Pa.R.C.P. 1035.2, Plaintiff is entitled to summary judgment as a matter of law. Zucker,Goldberg&Ackerman, LLC XCE-175926-EV F WHEREFORE, pursuant to Pa.R.C.P. 1035.2, Plaintiff respectfully requests this Honorable Court grant its Motion for Summary Judgment and enter Judgment in Ejectment in its favor and against Defendants for possession of the Real Property. CKER,GOLDBER ERMAN, LLC By: Dated: j� , 2014 Scott A. Dietterick, Esquir ; PA I.D.#55650 imberly A. Bonner, Esquir , PA I.D.#89705 oel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XCE-175926-EV/jf 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman, LLC XCE-175926-EV e t Exhibit A Zucker,Goldberg&Ackerman, LLC XCE-175926-EV "THIS IS NOT AN ARBITRATION CASE" "AN ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL CIVIL DIVISION -L ASSOCIATION (�f 1 (�/�'z eta L NO.: Plaintiff, ISSUE NO.: vs. TYPE OF PLEADING: Wanda K. Neumann, Michael E. Neumann, and CIVIL ACTION—COMPLAINT IN EJECTMENT Unknown Occupants Defendant(s). � CODE- : FILED ON BEHALF OF: 1PMORGAN CHASE BANK,NATIONAL ASSOCIATION TO: Defendant(s) COUNSEL OF RECORD FOR THIS PARTY: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE : Scott A. Dietterick,Esquire; Pa. I.D.#55650 ENCLOSED COMPLAINT WITHIN TWENTY(20) Kimberly A. Bonner, Esquire;Pa. I.D.#89705 DAYS FROM SERVICE HEREOF OR A DEFAULT Joel A.Ackerman, Esquire;Pa I.D.#202729 JUDGMENT MAY BE ENTERED AGAINST YOU, Ashleigh Levy Marin, Esquire;Pa I.D.#306799 Ralph M.Salvia,Esquire; Pa I.D.#202946 Jaime R.Ackerman, Esquire;Pa I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Denise Carlon,Esquire;PA I.D.#317226 ZUCKER,GOLDBERG&ACKERMAN, LLC Attorneys for Plaintiff 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX iiffice@ZLIckergoldberR.com File No.:XCE-175926-EV/sc T u.kei, )o,dk}EyP, X:I "THIS IS NOT AN ARBITRATION CASE" "AN ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL CIVIL DIVISION ASSOCIATIONe/��3 (/t NO.: 1 Plaintiff, ISSUE NO.: vs. TYPE OF PLEADING: Wanda K. Neumann, Michael E. Neumann,and CIVIL ACTION—COMPLAINT IN EJECTMENT Unknown Occupants Defendant(s). � CODE- FILED ON BEHALF OF: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION T0: Defendant(s) COUNSEL OF RECORD FOR THIS PARTY: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE Scott A. Dietterick, Esquire; Pa, I.D.#55650 ENCLOSED COMPLAINT WITHIN TWENTY(20) : Kimberly A. Bonner, Esquire;Pa.I.D.#89705 DAYS FROM SERVICE HEREOF OR A DEFAULT Joel A.Ackerman, Esquire;Pa I.D.#202729 JUDGMENT MAY BE ENTERED AGAINST YOU. Ashleigh Levy Marin, Esquire;Pa I.D.#306799 Ralph M.Salvia, Esquire; Pa I.D.#202946 Jaime R.Ackerman, Esquire;Pa I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Denise Carlon,Esquire;PA I.D.#317226 ZUCKER,GOLDBERG&ACKERMAN,LLC Attorneys for Plaintiff 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX office Pzuckergoldberg.com File No.:XCE-175926-EV/sc , U' l f Zucker,Goldberg&Ackerman,LLC XCE-175926-EV 175926-EVD1002C12042033P2 Supreme Court of Pennsylvania Court of CommonPleas For Prothonotary Use OnIV. Civil Cover sheet Docket No: CUMBERLAND County The t1tfi)rmo ion i7�1//�'�.:1('i/(111 dli'N /ol!III 1'; lt,c,'<f,}(1i!'IP jUi' (,llfl.l to/Mimsivaltrnl l)It!']R),t"s. lhlc fo l"Il aw ct�)717/tilt Pltl Ut'ri`t+/,!, t�!(' lJ17t7�;il17Gi S�'!PIr'�'!'�T�Jc'r!!/tll,j i ��T fi(l7PI"j?t:{l!'1'., 1'�;,1t7!t1'i'(I���C/illi' N!'I'l fl�'•5' Of CUill'l. Commencement of Action: S 0 Complaint El Writ of Summons Q Petition © Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: lead Defcndant's Name: T JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Wanda K. Neumann, Michael E. Neumann, and Unknod I Dollar Amount Requested: Elwithin arbitration limits Are money damages requested? El Yes Q NO (check one) ❑outside arbitration limits N Is this a Class Action Suit? Q Yes ❑ No Is this an MWAppeal? ❑ Yes 0 No A Name of Plaintift7Appellant's Attorney; JAIME R.ACKERMAN, ESQ. ❑ t h,;1. 1 ,-"t i= i..--^: I,�._...• (al ti :1 "I li._RR,t'.`,c• ':mcd 1 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,l/as.% Tort) CONTRACT(do not inchude Jndguuents) CIVIL APPEALS Intentional ❑ Buyer Plaintiff Administrative Agencies El Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept,of Transportation E] Premises Liability ❑ Statutory Appeal:Other Product Liability (clues'not inchiele ntuss fol-1), ❑ Employment Dispute: E Slander/Libel/Defamation Discrimination C ❑ Other: ❑ Employment Dispute:Other ❑ Zoning Board T __ ❑ Other: Other: O MASS TORT Asbestos ❑ Tobacco [] Toxic"fort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS © Toxic Waste Q Ejectment ❑ Common Law/Statutory Arbitration B Q Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment — -- -- - ❑ Ground Rent Mandamus --- -- --- - ❑ Landlord/Tenant Dispute 8 Non-Domestic Relations - - — [] Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY Q Mortgage Foreclosure:Commercial ❑Quo Warranto Dental ❑ Partition ❑Replevin Legal ❑ Quiet Title ❑Other: Medical ❑ Other: Other Professional: Updated 1/1/2011 LEONARD B.ZUCKER ZUCKER, GOLDBERG & ACKERMAN, LLL FOUNDED IN 1923 MICHAELS,ACKERMAN ATTORNEYS AT LAW AS ZUCKER&GOLDBERG IOELACKERMAN` MAURICF I.ZUCKER(1918-1979 FRANCES GAMBARDELLA 200 SHEFFIELD STREET-SUITE 101 LOUIS D.GOLDBERG(1923-1967 BRIAN C.NICHOLAS 1 P.O.BOX 1024 LEONARD H,GOLDBERG 1929-1979 SCOTTA.DIETTERICK 3 BENJAMIN WEISS 1949-1981 KIMBERLY A.BONNERV MOUNTAINSIDE,NJ 07092-0024 STEVEN D.KROL CHRISTOPHER G.FORD TELEPHONE;908-233-8500 Pennsylvania Office: DENSE CARLON dD FACSIMILE:908-233-1390 The Union Hotel Office Building CHRISTINE E.POTTER 240 Gettysburg Pike RYAN S.MALL E-MAIL:office@zuckergoldberg.com Mechanicsburg,PA 17055 STEPHANIE WOLCHOK ASHLEIGH LEVY MARIN£ DOUGLAS J.McDONOUGH For payoff/reinstatement figures TIMOTHY J.ZIEGLER Pleose send your request to:zuckergoidberg.com/pr - ALSO MEMBER OF NY,PAAND CA BAR RALPH M.SALVIA V ♦ALSO MEMBER OF NY,PAANDMEBAR ROBERT D. BER OF NYAND PA BAR AIME R.A KERIVIAN♦ REPLY TO NEW JERSEY ADDRESS dd AlSOA ALSO MEMBER OF NY BAR KACIE W.BROWN £ ALSO MEMBER OF PA BAR MONIKA S.PUNDALIK Y MEMBER OF PA BAR ONLY TODD MARKSft 0 ALSO MEMBER OF FL BAR TIMOTHY D.KUHLS d LANA FRIDFINNSDOTTIR Y DENNIS P.UHLMANN,JR. XCE-175926-EV March 17,2014 Prothonotary of Cumberland County Cumberland County Courthouse 1 Courthouse Square,Suite 100 Carlisle, PA 17013-3387 Re: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION vs. Wanda K.Neumann,Michael E. Neumann,and Unknown Occupants Property Address: 428 South Hanover Street Carlisle,PA 17013 Dear Sir/Madam: Enclosed please find the following Complaint In Ejectment. Please file the original complaint and return the extra copy of the face page,time-stamped,to me in the enclosed self-addressed stamped envelope provided. A check in the amount of$ 103.75 is enclosed, representing your filing fee, Please forward copies of the complaint to the Sheriff for service upon the defendant. Sheriff service forms and a check in the amount of$100.00 are enclosed representing your service fee. If you should have any questions, please do not hesitate to contact me. Very Truly Yours, ZUCKER,GOLDBERG &/ACKERMAN,LLC BY: Allillf u� Sonay Culpepper, Legal Assistant 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com File No.: XCE-175926-EV (908)233-8500;(908)233-1390 FAX sc enclosures Zucker,Goldberg R,Acke1nian, LI.0 XCE-J 75926-FV "THIS IS NOT AN ARBITRATION CASE" "AN ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL CIVIL DIVISION ASSOCIATION NO.: Plaintiff, ISSUE NO.: Vs. TYPE OF PLEADING: Wanda K. Neumann,Michael E. Neumann, and CIVIL ACTION—COMPLAINT IN EJECTMENT Unknown Occupants Defendant(s). CODE- FILED ON BEHALF OF: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION TO: Defendant(s) COUNSEL OF RECORD FOR THIS PARTY: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE Scott A. Dietterick, Esquire; Pa, I.D.455650 ENCLOSED COMPLAINT WITHIN TWENTY(20) : Kimberly A. Bonner, Esquire; Pa. I.D.#89705 DAYS FROM SERVICE HEREOF OR A DEFAULT Joel A.Ackerman, Esquire;Pa I.D.#202729 JUDGMENT MAY BE ENTERED AGAINST YOU. Ashleigh Levy Marin, Esquire;Pa I.D. #306799 Ralph M.Salvia,Esquire; Pa I.D.#202946 Jaime R.Ackerman, Esquire; Pa I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Denise Carlon,Esquire;PA I.D.#317226 ZUCKER,GOLDBERG&ACKERMAN, LLC Attorneys for Plaintiff 200 Sheffield Street,Suite 101 Mountainside,N1 07092 (908)233-8500; (908)233-1390 FAX office @zucker}nIdllerg.com File No.:XCE-175926-EV/sc Zucker, Goldberg&Ackerman,ILC XCE-1 75926-EV 375926-EVD!0020 2 042013P2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION vs. NO.. Wanda K, Neumann, Michael E. Neumann,and Unknown Occupants Defendant(s). NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle,PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 7.uekei,Goldheig& Ac:la>:iW111, I IC: X(T 175926 N 175926-1-VD1002CJ2042013P3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION VS. NO.. Wanda K. Neumann, Michael E. Neumann, and Unknown Occupants Defendant(s). AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas,debe tomar action dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de,y objecciones a, los demandas presentadas aqui en contra suya. Se ie advierte de que si usted falla de tomar action tomo se describe anteriormente, e► caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propieded u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A LINO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL, NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 .(717)24973166 (717)249-3166 Zucker,Goldberg&.Ackerman, LLC. XCF-175926-EV t7���zc-rv��loozci�onla�3r4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION vs. NO.. Wanda K. Neumann,Michael E. Neumann, and Unknown Occupants Defendant(s). CIVIL ACTION - COMPLAINT IN EJECTMENT AND NOW, comes JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, by its attorneys, Zucker, Goldberg&Ackerman, LLC,and files this Complaint in Ejectment as follows: (1) The Plaintiff, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, which has its principal place of business at 3415 VISION DRIVE, COLUMBUS, OH 43219. (2) The Defendants are adult individuals residing within the Commonwealth of Pennsylvania at 428 South Hanover Street,Carlisle, PA 17013. (3) By Sheriff's Deed dated September 3, 2013, recorded on October 2, 2013, Instrument #201332382, the Sheriff of Cumberland County has conveyed to Plaintiff, all that certain lot or piece of ground, with improvements erected thereon, and as more fully described in the Deed and as purchased by Plaintiff at Sheriff Sale on December 5, 2012. A true and correct copy of the recorded deed is incorporated herein as Exhibit "A". (4) On September 21, 2012, Defendants were served as owners of the aforesaid premises with a Notice of Sheriff's Sale scheduling the sale for December 5, 2012.A true and correct copy of the Sheriff's return of Service is incorporated herein as Exhibit '13'. (5) By letter dated November 11, 2013, Defendants and all other Current Occupants, if any, were notified by counsel for the Plaintiff to vacate the premises, via Certified Mail, Return Receipt Requested and First Class U.S. Mail, postage pre-paid, with a Certificate of Mailing. A true and correct copy of the letter, Certified Mail Receipt and Certificate of Mailing are marked Exhibit "C", attached hereto and made a part hereof. (6) To date, Defendants have failed or refused to vacate the premises, and therefore, Defendants are, using and enjoying the premises without right and Claim of Title. Zucker,Goldberg&Ackf'rnlan, LLC XCE-175926-EV 175926-EVD1002C12042013P5 (7) Defendants have unjustly and unlawfully retained possession of the premises to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendants for possession of the premises known as 428 South Hanover Street, Carlisle, PA 17013, together with such other relief as this Honorable Court may deem necessary and appropriate. ZUCKER,GOLDBER KfRM BY: Dated:' Scott A. Die is , .Es re; PA I, #55650 Ire Kimberly Bonner,Esquire; PA I.D.#89705 I Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire;PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032..._- Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Denise Carlon,Esquire;PA I.D.#317226 Attorneys for Plaintiff XCE-175926-EV/sc 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 (908) 233-8500;(908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg&Ackerman, LLC XCE-175926-EV 175926-EVD1002C12042013P6 EXHIBIT A ]'itef���: I-I:llin�ii7, LIP - Case' st�ti�i'.�1 Page 1 of 1 Phalan liallioan, LLP 1617 JFK Boulevard,Suit.1400, One Fenn Center Plaza,Philadelphia, PA 19103 Phune: 215-567-7000 l ax: 215-568-7616 I Case Summafy 10/22/2013 Referral Type: F aredoSure Old PH #: 20632E PH #. 701:11£;7 File Received: 45/11/2049 Loan #: 002,1r"85,ZW3 Follow-Up: Staters: C 1"1T On Hold: Property* 428 SJL,riA i P4N,OVLR STREET, County, CUMBERLAND CAR.!ISL.L, Fah L'Q13 3916 Defendants: NE'UMANN,VVAN[)A K. NFUMANN; MICI FALL t_, iarirtaary Ser-v€,-.es; )jIt,1'01 (_AN (4� i� , 5AINK, 1.IA110jA,; AS`OC1AIION (21)SAN DIEGO, CA 92127 Report To: X>3v4Cstar.. r n.su rer Referred 0y: LPS Court Term: Complaint 103849-CIVIL TLRM Docket#: Freddie Mac#: Fannie Mae #: Client Billed: 12/05/2012 FHAIVA Bill Amount: $0.00 Closed: 'grit Sale #: Report To#: PMI s#. PMI Name: TownsWp, 21R T'ax Parcel No. 04-22-0483-056 1 1, Ronny R. And ersort,, Sheri ff*of*th c Cotatty of C tvilbetiand,In the State 0f Penn-s,vlviama. for and in consideration of the stirn ofs 1.00(One Dollar) to me in hand paid, do heicby gr(ant and convey to .11, Morgan Chase Bank,N.A. 2010 Y14D CivH Term �.Iovgaj) (,'h-,)s(, llanl,, N,A. N's Wanda K, N.Jemnann Alidmel E. Neumann ALL that ccrlain lot oferorind sjtiiaL(: in the Borough ofCm4isle, Cumberland C01.111ty., PmnsvIvania, bomlmled and descrjbed as, follovvs: Bl­1"(jjNNNl.\(_', at apointor th.c, curb line ofSnoth'llanover Street. at corner of lot now or formerly ofivfis. Levi llei'l/Jel'i thicticc wcshvardly through the center line of the partition wall of the house on the lot.lvcrcby hc.ijlj,, c,.)ljveycd allct flie house on th I ,►c lot now or formerly of the said 141rs. Levi I jertzler, a (1i istimcc of')'-vvo hundred Forty(240) .feet, more or less, to the center line of School Alloy; thence Nortimardly try said center lige of said School Alley, a distance Of twem'v feet(20); thence E�ostwardly by lot Of'grOLAId 110W Or formerly of W. A, Wetzel, a distance of".)ne flundred Seve.31ty-nine(1 19) tbet Nine(9) inches to apoint at the center of the 'N't;sLern entrance to an iffley-way two (2) fc.et six (6) inches wide, which said alley-way is thc house on tic; lot hereby being conveyed and the house on the lot., now Or fonnerly of (he, said W, A, Wctzel-> thence Nlorthlvardly by said lot now or forn-iCTIV of the;Said W, A. Wetzel, onk,(l) rool, .,iy, ('(")) im-'hes to c o point in the criter ifthe piflitioll Wall between the house hereby being collvevLA and of kth";I. llov", of "'limnly oftlic said W. A. Weikel; then(t Eastwardly by the - ,szljd p ~Fall, o di�;talicc ofsl dy (60) feel, three(3)inches, morc or lessto it li� point on,the euro linecorli line distallc(s of Tvertty-cmc(21) feet six ((0 iiices to corner 0,11 lot T10"N/ or f'OTMOVIV Ot'tlic said 14rs. I&vi I lortzler, the place of BEGINNING, 131'[N(.,y irnproved e6'th a three story-brick dwelling?house. RI,--'SERVINGi' IlOWFvEjZ. to the ovvnei of the lot of'ground on the North of the propeily herby be collvevcd' his assigns, therigh( to the use of the affiresaid alley-way, two (2) [tet six (()) im,-Aiei wide m thicsanic is now constructed and used in common with the Gramors., hereln, thell-heirs and"assigns, as rieccssary charges mid expenses which shall from time to tinge XCrLle in and cleaning the said alley-way to be shared equally by the owners of said ad, i i mics, their heirs quid jolmng� prop-31 1 TITIX-'I'l 0 SAID PPFvll'SIRS VESTUD IN Michael Neumann and Wanda K, Neummirl, k/w, by DQ,,,d from Betty A. lirotvti., single pmon,dated 12/31/2001, recorded 01,/04i2002 in Book '149. Page 4523. PREMISES )SEING: 428 SOUTH HANOVER STREET„ CARLISLE,PA 17013-39116 PARC]31, NO, 04-22-0483-056 lm u I Co. Cie kdbl do", jymnm, joi A w. w 0. now nnmnq Mos yd , mbmbmd ClaW, Pcn"YvwhA W, }i 1 J ,� ol 1 -nu Way. �Awlwt awl [AicWwl V, In WG"',.., is hot cut, I i"wr An"win) &. ti inv"rowcois Anw Dwroi I to 1 1n1wand lmd WOW (AHN, It )wiv; �,'Aiidostilt, Sheriff ui isof WIE"k Kan in. sq, Q-0 w'd [)'.°'vO I YnAn P QUA at cotwnuni Ronjiti R. Anklcrson. am! in ilitc- "urin oflimb' d,,�,-Iarcd J,wt IN Nuts S 1�-� iorth It! 0 !,)I Tw, and lot he achilowic(Igcd the in ord"! tllid d,,��d 111;1,2,1111 11", llt'y 11;m"d wl'6 ";'cal of said (,ourt. this Oa , C QQVP (2013) 6-'1 "tIIIj()Iviot a ky ProthanoUry,Cumberland County,Carlis)c,PA My Commission Expires the First Monday of Ian,2014 I [icrcby certify Thai the rcsidencc And NO Ofnce addivss of the Ellin Owdee is 10790 Ranclio.Bernar(lo Rd San Diego, CA 92127 Richard W. Stewail SOWN F"('0 R i)L R V f>1' 3 1) men Sao. I COURT110t,"18F, SQ("ARE 117 2 40-6 3 (1, 114MU13 At S:17:67 A M Toul Pogo - 5 NO upwal toto DEFS A"W1F!— IMVNW War M SSES'RIM" STATI TAIT WXX ( ertificatiolt Page RESTATE Mh/ACCESS TO JUSTICE DO NOT DETACH CORDING FEES - V12 , 50 RECORVER OF DEEDS! PARCEL CERTIFICATION 125 v INS pagc k r"Ay part kers of this legal document, AFYORDABLE, co"ITI ARC91VEY YEE ROD ARCHIVE8 FEE CARLISLE ARFR SCHUM c 2 DISTRICT CARLISLE BOROUGH TOTAI PATD .1 Ccrtifv this to be recorded in 0-1111-wrland Cown"� iA AS, I z L RD r 1 0(o 4c D S Ap MMM process and n"q mA he i efleded on M page, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Asir et tun,b�r�ae Jody S Smith Chief Deputy Richard W Stewart Solicitor QFM oF'ra SHERIFF JP Morgan Chase Bank, NA Case Number vs. 2010-3849 Michael Edward Neumann(et al.) SHERIFF'S RETURN OF SERVICE 09/21/2012 07:05 PM-Deputy Tim Blaok,being duly swom according to law,states service was performed by posting a true copy of the requested Real Estate Writ,Notice and Description,in the above titled action, upon the property located at 428 S Hanover Street,Carlisle Borough,Carlisle,PA 17013,Cumberland County. 09/21/2012 07:05 PM-Deputy Tim Black,being duly swom according to law,served the requested Real Estate Writ, Notice and Description,in the above titled action,by making known its contents and at the same time personally handing a true copy to a person representing themselves to be WANDA NEUMANN,WIFE, who accepted as"Adult Person in Charge'for Michael Edward Neumann at 428 S Hanover Street, Carlisle Borough,Carlisle, PA 17013,Cumberland County. 09/21/2012 07:05 PM-Deputy Tim Black, being duly swom according to law,served the requested Real Estate Writ, Notice and Description, in the above titled action,by making known its contents and at the same time personally handing a true Copy to a person representing themselves to be the Defendant,to wit:Wanda K. Neumann at 428 S Hanover Street, Carlisle Borough,Carlisle,PA 17013,Cumberland County. 10/05/2012 Received addl copy of Writ,Notice of Sheriffs Sale and Legal Description this date from Atty Schmieg with instructions to deputize for Michael Edward Neuman to Erie County in SCI Albion.cab. 10/05/2012 Ronny R.Anderson,Sheriff,being duly swom according to law,states that he made a diligent search and inquiry for the within named Defendant,to wit: Michael E.Neuman, but was unable to locate the Defendant in his bailiwick.He therefore deputized the Sheriff of Erie County to serve the within Real Estate Writ,Notice and Description, in the above titled action,according to law. 10/23/2012 The requested Real Estate Writ,Notice and Description, in the above titled action,served by the Sheriff of Erie County upon Michael Edward Neumann,personally,at SCI Albion, 10745 Route 18,Albion,PA 18475, So Answers:Judy Tome, Deputy,Sheriff, SHERIFF COST:$924.20 SO ANSWERS, 6Z xxa�—� November 07,2012 RONW R ANDERSON,SHERIFF (c)CounlySule Sheriff.7918050X,Inc JP MORGAN CHASE BANK,NA : COURT OF COMMON PLEAS Plaintiff ; CIVIL DIVISION VS. NO.: 10-3849-CIVIL TERM WANDA K.NEUMANN MICHAEL E.NEUMANN CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WANDA K. NEUMANN MICHAEL E. NEUMANN 428 SOUTH HANOVER STREET, CARLISLE,PA 17013-3916 *THIS FIRM IS A DEBT COLLEC'T'OR 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" Your house(real estate) at 428 SOUTH HANOVER STREET„CARLISLE,PA 1701.3-3916 is scheduled to be sold at the Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$138,672.23 obtained by JP MORGAN CHASE BANK,NA (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE+' OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges,costs and reasonable attorney's Fees clue. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment. was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAI,HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 EXHIBIT C ZUCKER GOLDBERG & ACKERMAN, LLC FOUNDED IN 1.923 IVIICIJARD B. CKI.RM , AS ZUCKER&GOLDBERG MICIIAEL S.4CKLRNIAN ATTORNEYS AT LAW JOEL ACK(RMAN` IOt UAICF.L ZIJt_Yrk 191A-1979) I'AANCES GAMIRARUFLLA 2.00 SHEFFIELD S1 REP-SUI1 E 101 Louis n r,OrOAERG 1924-1957) BRIAN C.NICHOLAS 0 LEOFIARLI...GOI.UBERG 1929.1979) SCOTT A DIERERICK x P.O.BOX 1024 RF NIAMIN WEISS,1949'1981) lvl KIMBERLY A.BONNE:RY MOUNTAINSIDE,NJ 07092-0024 S f EVE N D.KAOi Pennsylvania Office CHRISTOPHFit G.FORD TELEPHONE:908 233-8500 The Union Hotel Office Building DENISE CARLON G FACSIM11 E:908.233 1390 240 Gettysburg Road CHRISTINE F.POrTER(. RYAN S.MALC E-MAIL:office@ 7mckergoldberg.com Mechmticsburg PA 170SS STEPHANIE WOU:HUK ASHLEIGH LEVY MAP.IN E DOUGLAS'.Mr.DONOL%H For payoJJ/refflstatemenifigures TIMOTHY 1.ZIE,CiLFR Pleose send your request to:ruckergoldberg.com/pr Al u>rnt.AIMH(»NY.PSI:�r+r�,-,,,PAR RALPH M,SALVIA Y ALSO d111AP„ri Ot NI; P1,A?19?,V 11” ROBERT D.BA{l FY 0 Ai 4+L)MEA;tit:R(1F ttl'ANf)Mt VAI? 1AM4 R ACKERMAN♦ REPLY TO NEW JERSEY ADDRESS d fltsrlt.'rh;ar"titT+u+°offi RACHEL G.PACKERI f At5�1,tlAd6ERit}�l•fflt., KA.CIEVV BROWN t AI'tr'n'1f+,'iNEt7+;.rNrr;Nl ; s41r NIOPIIKA S.PtlNDAI IK t' AALSO Pit IMOLH 01/t_1RAR '1001)MARKSA 0 ALSOMfMIifROFII BAF I IMO1HY D,KUIRS A '.APIA TIR Y XCE-175926-EV November 11,2013 Wand and/or aTenanNeumann t(s) knawn or Llnknvwn at; 71969008��. • 91 , 6605 ®6180 + � I 428 South Hanover Street Carlisle, PA 17013 ' " 2 111111 DEMAND FOR POSSESSION OF PROPERTY Property Address: 428 South Hanover Street Carlisle,PA 17013 Sale Date: December 5,2012 Dear Tenant: On December 5, 2012, the property located at 428 South Hanover Street, Carlisle, PA 17013 was sold before the Courthouse door of Cumberland County, Pennsylvania during the legal hours of sale. You are hereby notified that possession is demanded by JPMORGAN CHASE BANK, N.A., which was the highest bidder at the sale, and now owns the property, as evidenced by deed recorded on October 2, 2013 in Instrument #201332.382. If you are the former owner of the property,the child,spouse,or parent of the former owner,and you do not relinquish possession within 10 days of this letter, dispossessory proceedings will be initiated in the Court of Cumberland County, PA,to evict you. YOU HAVE 10 DAYS TO CONTACT THIS OFFICE. If you are a tenant of the former owner of the property,and not the child, spouse, or parent of the former owner of the property,you may be entitled to additional rights as provided by the Protecting Tenants at Foreclosure Act of 2009, including the right to remain in the property for 90 days from the date of receipt of this notice, before dispossessory proceedings are initiated against you. In order for us to determine on behalf of 1PMORGAN CHASE BANK, N.A. what rights you may have under the Protecting Tenants at Foreclosure Act of 2009,you must forward us the following within ten days of the date of this letter: (a) a copy of your written lease (if an oral lease you must provide us a summary of the terms of your oral lease, including: the term of the lease, monthly rental amount and all other relevant lease terms); (b) proof of your alleged monthly rental amount(proof may in the form of a copy of your lease showing the rental mount,or, if an oral lease,copies of cancelled checks or money orders); • a Y (c) proof that all monthly rental payments due under the lease have been paid to date(proof may be in the form of copied of cancelled checks, money orders or a signed statement from your landlord stating that you have par+.f yore rent in full as required by your lease); (d) the names of all occupants of the property who are over the age of 18 years of age;and (e) indicate whether you ares section 8 tenant For any questions regarding your rights as a post-foreclosure tenant,contact Sonay Culpepper at 908-233-8500 ext.206. Please note that you may wish to consult an attorney to help you determine what rights you may have, if any,under the Protecting Tenants at Foreclosure Act of 2009. IMPORTANT NOTICE FOR SERVICE,MEMBERS AND THEIR_pEPENiJENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Service members Civil Relief Act (SORA). This includes protection from foreclosure or eviction. You also may be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible service member, Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Flealth Service • Service with the forces of a nation with which the United States is allied in a war or military action • Service with the National Guard or a state militia under a state call to duty; or • Any period when you are:absent from duty because of sickness, wounds, leave, or other lawful cause. Address: Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attn:Barbara Soogrim/Caroline Krialc Phone: (908)233-8500 ext.184 Fax: (908)654-7378 Email: militarymember@zucicergoldberg.com All questions regarding the property should be addressed to the following agent: Name: Harry Speelman Phone: 71.7-440-6336 Email: harry.speelman@century2l.com Very truly yours, ZUCKER,GOLDBERG &ACKERMAN,LLC Sonay Culpepper-ext.206 Zucker, Goldberg&Ackerman, LLC Page 2 IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS: PROTECTIONS UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT If you are a servicemember on "active duty" or "active service," or a dependent of such a servicemember, you may be entitled to certain legal rights and protections, including protection from eviction, pursuant to the Service members Civil Relief Act (50 USC App. §§ 501.596), as amended, (the "SCRA") and, possibly, certain related state statutes. Eligible service can include: 1. active duty (as defined in section 101(d)(1)of title 10, United States Code)with the Army, Navy,Air Force, Marine Corps,or Coast Guard; 1. active service with the National Guard; 2. active service as a commissioned officer of the National Oceanic and Atmospheric Administration; 3. active service as a commissioned officer of the Public Health Service;or 4. service with the forces of a nation with which the United States is allied in the prosecution of a war or military action, Eligible service also includes any period during which a servicemember is absent from duty on account of sickness, wounds, leave,or other lawful cause. If you are such a servicemember, or a dependent of such a servicemember,you should contact Deena Allen at (908)-233-8500 ext 184 to discuss your status under the SCRA, Zucker,Goldberg&Ackerman, LLC Page 3 UNITED STATES POSTAL SERVICE,,' This .it....iea e of Ve;l:rg Po'ddcs OvIZK lha'mal h nccn .r 10l•Sr'E dom^;!ic wo,mlemalion?I r^,t Front Sonay Culpepper c/o Zucker, Qoldherg &Ackoi mall, LLC 200 Sheffield Street Suite '101 Mol_Intail+side, NJ 0709; XCE-175926-E.V/sc EVI PoMmaik Here " Wanda Neu+Hann and/or (erlant(s) known or unknown 426 South Hanover Street Carlisle PA 17013 tlounty at P.Q:Cumberland PS Form 3817,April 2007 PSN 7530-02.000-9065 Zucker,Goldberg&Ackerman,LLC Page 4 i 7]'96 9008 9111 6605 61b0 TO:11�r,J;l:i '�cun;'uut ,i!hi�w I,l;i:utlfc I 1 ,nett n ;Ji ruJi:nutt a.,� �' ti�nJll? I lnnr;�t i S(rrcl REFERENCE; 6 1`V ivi t, fleiurn fio.��ii71 Feo ��' � ',`T Twal f'u4I l STj11A}tltpj UAT;. Plane?ipt for mm C r •.:t' .J,,,t i i I I i J WALZ FOAM 1135693 VERSION:01/12 7196 9008 9111 6605 8180 TM U,S,PAT,NO.6,541,3V3 THE.� FROM WALZ �Q•VIlinda Neumann CERTIFIED �?t tuuiti NCutlltu0n •anilior Tcnalttts}known or unitinuwn at: MAIIERTM <ind:''ili��)cntlnl(s) I:nnv.�n or unkltt���'n til 42$ South Hanover Street 428 South 1 lanolin Street Carlisle,PA 17013 Label#i Carlisle. PA 17013 SENDER: SC; Wanda Neumann and/ot''Venant(s) kilowtt or ttnkilown al: REFERENCE' 175926-EV y'1'\' 1I 112013 428 South 1-1wit)ver S)reel � Label#2 Carlisle, PA 1701 °+�; r:,rrn,n_'s�ort I�±rnl,ry7rats_ RETURN RECEIPT Certified Fee £ SERVICE Retum Receipt Fee £ ' Wanda Netiniann RestrlctedDollvory and/ur Tenan((s) known 01'uliknown all, Total Postage&Fees 428 South 1 lanover Steeel US Postal service® POSTMARK OR DATE Label#3 Carlisle. PA 1701 Receipt for Certified Mail"o No Insurenco Coverage Provided A FOLD AND TEAR THIS WAY---- OPTIONAL Do Not Use for Intemetlonul May Label YB 1AbM 110 Q on Wanda Neuh.)ann M' i t* + will and/or"Tenant{s) known or unknown at: C3 r 429 South I kinover Strcct �A Carlisle., PA 17013 u- er C3 Charpa l C3 Amount: (r t 7196 9006 9111 6605 8160 l Charpe *� To, r- I(A a IWO rr Att I II r WAY._ 2. Article Numb er _ _ _. ... ..__ ..., 7Aa-t'1.'.'d Gy(Pisses Pmt Clearly) B, DateorDellvery_, _.. z ACM CO a r X O W t3: d 7196 9008 9111 6605 81hU D. isdsllveryedrhrt)drfadwilfroebo 17 Noe N -a W cc 11 YES,eater delivery I l ; N It L 3. Servico Type CERTIFIED MAILTM I E _ _ iE tG U w i 4 Restricted Delivery?(Exim Fee) You i. Article Addressed to: ---- ----- C U �Z s 1VHndtl NeumHtnl Of W HILI/OI 1 ewmt(s)known or Unknown af: Z ZIL 428 South I£anovor Strcct ` i CC v Carlisle, PA 17013 J2 ro x c d i 1759:.6-I•:V N I V Ili 1301.3 tiC: t PS Form 3811,January:C05 volnewie Holum Recolpl Chase Occupant Contact Information Sheet Each Occupant/Adult(18 or Older) must fill out a separate form *** MUST have a valid photo identification Ll Tenant .I!! Fo' rrner Homeowner L] Unknown t:tic;trtt�i�ttlt..itttAur•nttti{yit' £� _ ` Full e al Mame Section 8:-r--_es�No P Unknown —_ Rent Control: Yes ONo (� Unknown Do you have an existing written lease or rental agreement? uYes []Nth If yes, attach a copy. Did you have a verbal agreement with the Former Homeowner/Landlord? ❑Ycs ❑No If yes,attach evidence of terms. It any occupant an active duff servicemember, the dependent of an active duty servieemember, or herwiseequalified for I)rotertion accordii% to the notice pro%isiuns on1age three? L]Yes ❑Noamof the servicmem eber and relatiortshi to Occu ant: Date of Birth: Home Telephone No.: Current Address; t iiY: JStaw Lilt Code: E-mail Address: Current Emlrlurcr; roosition - - - _- _ - - Fmltlo �r ]elchlu>>t: N��.: E,-Mail. FacsimileNo,: [.iitl}It,yt r Address: How Long Em�yed?: C, - .. I - j Suite: Zip Code: Relationship to Formri Homeowner/Landlord: Renter's Instlrance?; ]Yes (-_!No Insurance Company Name: 2. lata p Rxt nt� { ttttt,tct lttl'ornlatian: Name of rr ersO t not residitp with You: � Address. ---� C'ily: i State: Zip Code;____ - I c lcphone No.: --Relationship: 3 1 ehielul,tfprmalioit; I_ ^ Year T l.iccnse Ne_.:Make Model Color - Vehicle fl: Vehicle#7, 1 _ - ---- - - Vehicle #3: J. Wiwi- Ckvuparsps JnP.)rwatioa. _ Occupant 1 Uc�uj��rnt n2 _{)u:u)ant N3 ()ectt Ant lt�l ` Occupant t€i _. _—_ II — _ Name: Date ofBn-th:. i _ _ Sea; PM OF � �M F j �.J� �:F _�M�F 5. t'�t.✓nfttt°tlt:tli+rfi: _` _ . Pet ,1 I Pet ;t2 Pet 93 �_ Pet 04 Pet#S _1 X. - -- — I authorise the verification()(the informalioli provided on this form and have received a copy of this document. I aeknowledgc con piction orthis document does notguarantee continued occupancy by an individual or pct• Full Legal Signature of t)Ccui)ant: Date; Ptuperty Address y r'__5 nem S-trc;'-t G1 rl, � 1 State A i 13 Zi Code: b horrner.Homeowner Tenant Unknown No Contact Section 8: Yes N�ou nknown v Rcnt Control: Yes No3nknown on 8 _�__Oj -- __ _— -J- - - -- _ , Personal Property: If property is.vacaw, is there any property remaining in or on the prop:rty?:JoYes❑No Ifproperty is occupied by a Tcnanl (as indicated above), is there any personal property present that belongs to the Former Homeowner:LI-Yes PNo FtUnkilown _ _ ______._ — ,_ ____ An__y c�ode v_io_lation_- or hazardous condition noted? es No If yes,please explain: Is any occupant an active duty servicemember,the dependent of an active duty servicemember,or otherwise qu lified for protection According to the notice provisions on page three? E]Yes❑No �7oknown jr yes,is protection under: ❑Federal Law SCRA❑State Law SCRA❑ Unknown Name of the servicemember and relationshi to Occupant; Please provide a detailed reason for any boxes checked"Unknown" in the Listing Agent/Property Inspector section and for any fields left blank in the Oecupant section. Describe how you confirmed the REO property was occupied(i.e.,With whom did you speak?What observations did you make?) If there is personal property on the REO property,please describe the location of the personal property and separates list the personal property on page 4. �Z v1 d<_(k 6-**,, �e-�� r�. 1 e\,S ,)k r i fill M1z ­h14,2:;zrV17 I Date Time Contact Name Information Follow-up _ _ Complete? Re aired? 1` . .. _3�S vh ��l2fL vh m1' /00 �j?Sr,�,{-y. Yes oes No On ��c' , _�C ��`Set) Yes o es No v K' Elyess No 1 ta=i_ nrv�n [;7��1� Yesyoo es No Y1 r. . f� ,v. Ns;t1r J. .. Yes No -- =- -- _ L - Signature of Listilrl,Ageutll'roperty Ins; !Chase C Team: Date: It- Rev.0.5.12 , M tNUIOR'I AN"I NO"I"WE 1-011 AND THEIR DEI'Lt.!Vt)I?NTs If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You also may be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. • Active duty with the Army, Navy, Air Force,Marine Corps,or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Health Service • Service with the forces of a nation with which the United States is allied in a war or military action • Service with the National Guard or a state militia under a state call to duty;or • Any period when you are absent from duty because of sickness,wounds, leave,or other lawful cause. For more information, you should contact,IPMorgan Chase Sank,National Association toll free at(877) 584-3290. 1 M I-IS 1OI, PERSONA I; PROPERTY Must include photogrnhh of Pcrsonal Property listed below �I I i VERIFICATION ���We I C , verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa.C.S.A. § 4904 related to unsworn falsification to authorities, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION By: ir Name: Alma Mffiqla- Vice President Title: DATE: (925 - 11 Borrower Name: Wanda K.Neumann,Michael E.Neumann,and Unknown Occupants Property Address: 428 South Hanover Street Carlisle, PA 17013 SHERIFF'S INSTRUCTION TO: Sheriff of Cumberland County,Pennsylvania PLAINTIFF: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION DEFENDANT(S): Wanda K.Neumann, Michael E.Neumann,and Unknown Occupants TYPE OF WRIT OR COMPLAINT: COMPLAINT 1N EJECTMENT SERVE AT: 428 South Hanover Street,Carlisle,PA, 17013 Sir: ❑ Please serve Defendant,Wanda K. Neumann,OR an adult member of the family with whom she resides,OR an adult individual in charge of the residence with a true and correct copy of the Complaint in Ejectment. Date of Service: Time: Served Upon (if someone otherthan Defendant): Address(if different than as stated above): Cumberland County Sheriff's Office: Name: Title: Date: PLEASE RETURN SERVICE TO THE FOLLOWING ADDRESS IN THE SELF-ADDRESSED,STAMPED ENVELOPE: Zucker,Goldberg&Ackerman,LLC ATTN:Scott A.Dietterick,Esq. 200 Sheffield Street,Suite 301 Mountainside,NJ 07092 SHERIFF'S INSTRUCTION TO: Sheriff of Cumberland County,Pennsylvania PLAINTIFF: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION DEFENDANT(S): Wanda K.Neumann,Michael E.Neumann,and Unknown Occupants TYPE OF WRIT OR COMPLAINT: COMPLAINT!N EJECTMENT SERVE AT: 428 South Hanover Street,Carlisle,PA, 17013 Sir: ❑ Please serve Defendant,Michael E.Neumann,OR an adult member of the family with whom she resides,OR an adult individual In charge of the residence with a true and correct copy of the Complaint in Ejectment. Date of Service: Time: Served Upon (If someone other than Defendant): Address(if different than as stated above): Cumberland County Sheriff's Office: Name: Title: Date: PLEASE-RETURN SERVICE TO THE FOLLOWING ADDRESS IN THE SELF-ADDRESSED,STAMPED ENVELOPE: Zucker,Goldberg&Ackerman,LLC ATTN:Scott A.Dietterick,Esq. 200 Sheffield.Street,Suite 301 Mountainside,Ni 07092 . . . / . SHERIFF'S INSTRUCTION TO: Sheriff ofCumberland County,Pennsylvania PLAINTIFF: ]PIMOBOAN CHASE BANK,NATIONAL ASSOCIATION DEFENDANT(S): Wanda K.Y4eumunn, Miuboo( B.Neumann,and Unknown Occupants TYPE OFWRIT 0RCOMPLAINT: COMPLAINT 0VEJECTMENT 5 ' 'EAT: 428South Hanover Street,Carlisle, PA, 17U13 Sir: [] Please serve Defendant, Unknown Occupants,KJRanadult member oYthe family with whom she resides,OR an adult individual in charge of the residence with a true and correct copy ofthe Complaint|nEjectment. Wite of Service: Time: Served Upon(if someone m:her than Defendont): ______ Address(if different than as stated above): Cumberland County Sheriff oOffice: � Nome, Title: oote:________. PLEASE RETURN SERVICE TOTHE FOLLOWING ADDRESS|NTHE SELFADDRE3SED,STAMPED ENVELOPE: Zucker,Goldberg&Ackerman,LLC ATTm'Scott A.o|ette,ick,Es*. 2$0Sheffield Street,Suite 301 _ Mountainside,mJq7V92' Exhibit 6 Zucker,Goldberg&Ackerman, LLC XCE-175926-EV 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JP MORGAN CHASE BANK,NATIONAL CIVIL DIVISION ASSOCIATION, NO: 141903 Civic Plaintiff, C-) rte . VS. Wanda K. Neumann,Michael E. Neumann,and tnr' 'um Unknown Occupants ..�D � �. Sim Defendant(s). C 3 C:) f CIVIL ACTION—PLEADING TO COMPLAINT IN EJECTMENT w : In answer to complaint filed by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,by its attorneys, Zucker,Goldberg&Ackermann, LLC. I do understand that I must vacate the property at 428 South Hanover Street, Carlisle, PA 17013. Effective on Monday,April 28,2014, 1 will be the only person residing at this address. My stepson,Matthew E.Neumann,is moving to Austin,TX on that day and my husband is incarcerated at SCI-Albion.Albion.PA.. I had been working with Harry Speelman Jr,a reallor at Century 21 in Carlisle.PA through email to negotiation a"Cash for Keys"settlement with JPMORGAN CHASE. The last contact that I had with Mr.Speelman was Frkiny,November 29,2013. 1 have included these emails and they are marked as Exhibit"A'. I had also emailed the reaftor,Greg Phenicie,which had sold us the home.I explained my needs to him,and he had contacted a"friend"to see if they would be able to assist me. He advised that they were unable to help me. The said emails are marked as Exhibit"B°, I am in the process of liquidating all of my assets so that my pets and I are able to move out of this home. The only thing that I ask of the courts is for a 90-day extension to give me time to liquidate all that I have and find a new home in which to move to since I am now doing this on my own. )n�4vg -j/ Alo Dated / E ` Wanda K. Neumanr. EXHIBIT A XFLNrrY Connect rn e,neumannocorncast.net rc,nt fir.. 428 S Hanauer Street From :Harry Speen Jr<brk8bal1s0ao1.com> Thu, Jan 31, 2013 02:38 PM Subject:Re:428 S Hanover Street To:m e neumann<me.neurnann0corrcast.net> The negotiator W left rre a ffessage. The bank is not in acoeptance to your counter offer for the cash for keys. Harry Speeiman Jr Century 21 A Better Way ---Original Message From: m.e.neumann <m.e.neumann@comcast.net> To: Harry Speeiman Jr<brk8ba1ls@ao1.com> Sent: Thu, Jan 31, 2413 13:42 am Subject: Re: 428 S Hanover Street Harry, Just wondering ff you've heard anything from the negotiator? Wanda From:"Harry Speekren Jr"<brk8bafis*aol.aam> To:"me neumann"<me.neumannocomcast.net> Serrt:Tuesday,January 22, 2013 2:24:19 PM Subject:Re:428 S Hanover Street Just spoke with nN negotiator about your hoar~. She was wondering if you had an attorney representing you with the Issues of the rr o tgape company? If you do, can you please get me the contact information for me. Thanks, Harry Speeirran Jr Century 21 A Better Way --Original Message- From: m.e.neumann <m.e.neumann@comcast.net> To: brk8balls <brk8balls@aol.corn> Sent: Tue, Jan 22, 2013 11:42 am Subject: Re: 428 S Hanover Street Okay, I was only asking. I keep forgetting that yesterday was a holiday because I had to work. Thanks for your response.. From: brk8balls@aol.com To: "me neumann" <m.e.neumann@comcast.net> Sent: Tuesday, January 22, 2013 '11:17:48 AM Subject: Re: Fwd: 428 S Hanover Street No I have not heard. VV'ith holiday yesterday l don't expect to hear from them till later in week. Sent via BlackBerry by AT&T From:me.neurreann0corncast,net Efate:Tue, 22 Jan 2013 16:16:02+0000(UTC) To:Harry Speeiman Jr<brkBba#s@aol.corn> Subject:Fwd:428 S Hanover Street Hello Spee r:, ,T know that it's probably too early to ask, but I was wondering if you have heard anything from Chase or the negotiator? Thank Vou, Wanda N urmnt, From:"me neurrann"<me.neumannocorrrast.net> To:'Harry Speelnan Jr"<brk8baks@aol.axn> Sent:Friday,January 18, 2013 4:36:56 PM Subject:Re:428 S Hanover Street Hello Harry, I spoke with my husband,and he said that he feels that they should give us until the end of Morar and 15K or until the end of February and 2M I told him the offer that they bank made,and he came up with his amount due to we had filed papers with the courts and are std waiting for a decision from the judge. Pius when the mortgage was originally decided on,the broker that we had used included my husband's unemploymerit as part of rry pay without us knowing it. The broker was also later arrested(or so I believe)and is no longer a broker. There has been some other issues with Chase that we have had and my husband feels that they owe us for the problems that we have had with them If you like, you can have your negotiator go to the bank with these amounts and then we can see what they come back to us with. As far as needing a moving company, we can do the moving ourselves and I really feel that if I have a place to go to, we can be out by the end of February. Thanks, Wanda From:"Hang Speelm an Jr"<brk9baks@aoi.cmm> To:"me neurrann"<m,e.neumann@conxast.net> Sent:Friday, January 18, 2023 4:233:55 PM Subject.,428 S Hanover Street You can email me at brk8baHs@aol.com or at harry.speelmon@century21.mm or phone me at 717-440-6336. 1 spoke with the negotiator and explained the situation to her. She said once you had a chance to talc to your husband and discuss what It would take; mare time or cash for m Nhg expenses or even the bank hiring a moving company for you to let her know and she wig attempt to make K work, I also mentioned that there was no way you would be out by months end she said that If we could make it happen by middle of next month that should not be a problem. Ultimately everything has to be approved through the bank. Let me know what you may need in vacating the home so I can pass it along to the bank. Thanks, Harry Speelman Jr Century 21 A Better Way 41MOU XFtNITY C"Yx ad XF1hM Connect m.e.neumannOcomcast.net I , Font`�izc Re:Fwd:428 S Hanover Street From :b"bats@aol.com Fri, Feb 22, 2013 03:36 PM :subject:Re: Fwd: 428 S Hanover Street To:m e neurnann <m e.neurnann@contast.net> Reply To:brkBbaQs@aol.eom lust got off phone with new negotiator he`s checking back with bank on offer for cash for keys V it stile stands and best they can do for you, I wig let you know when I hear something. Sent via BlackBerry by AT&T f-rom:me.neumann@cormast.net Date:Thu, 14 Feb 2013 16:33:36+0000(UTC) To:<brk8baks@aol.com> Subject:Fwd:428 S Hanover Street Have you heard anything more from the negotiator concerning the amount that the bank is willing to offer? I know that they originally said $4000, but after telling them what my husband wanted, I didn't know if they may have come up with a higher amount or not. Please advise. Thank you? From: "m a neumann" <m.e.neumann@comcast.net> To: "Harry Speelman Jr" <brk8balis@aol.com> Seat: Thursday, January 31, 2013 6:08:58 PM Subject: Re:428 S Hanover Street What is the must that they are wig to offer? From:"Harry Speelman Jr"<brk8baRs(ba0,com> To:"m a neumnn"<me.neumann@corrcast.net> Sent:Thursday, January 31, 2013 2:38:42 PM Subject:Re:428 S Hanover Street The negotiator just left we a message. The bank is not in acceptance to your counter offer for the cash for keys. Harry Speekmn Jr Century 21 A Better Way --Original Message From: m.e,neumann <m.e.neumann@comcast.net> To: Harry Speelman Jr<brR8balls@aol.com> Sent: Thu, Jan 31, 2013 10:42 am Subject: Re: 428 S Hanover Street Harry, Just wondering if you've heard anything from the negotiator? Wanda From:"Harry Speekmn Jr"<brkabaIs@aol.corn> To:'tn a neumann"<m e.neutrann@comcast.net> Seat:Tuesday, January 22, 2013 2:24:19 PM Subject:Re:428 S Hanover Street -01232014 )(FINrTY conned MKITY Connect m.e.neumannOcomcastmet Font suc 8e:42*8 S Hanover Street From :Harry'Speeirran Jr <brk8ba1s*ao1.com> Wed, Mar 06, 2013 11:28 AM Subject:Re:428 S Hanover Street To:me neurrann<me.neurnann@corrcast,net> The negotiator had just sent me an erred. He wanted to know how soon you could vacate the home with a cash for keys offer. Not sure of the figure that they are kK*ing at making you. Harry Speekren Jr Century 21 A Better Way —Original Message From: m.e.neumann <m.e.neumann@comeast.net> To: brk8balls <brk8bal1s@ao1.com> Sent: Thu, Feb 14, 2013 11:33 am Subject: Fwd: 428 S Hanover Street Have you heard anything more from the negotiator concerning the amount that the bank is willing to offer? I know thatt they originally said $4000, but after telling them what my husband wanted, I didn't know if they may have come up with a higher amount or not. Please advise. Thank you! From: "m a neumann" <m.e.neumann@corncast.net> To: "Harry Speelman Je <brk8balls@aol.corn> Sent: Thursday, January 31, 2013 6:08:58 PM Subject: Re: 428 S Hanover Street What Is the rrost that they are willing to offer? From:"Harry Speelren Jr"<brk8ba11s#ao1.comv To:"me neum®nn"<m.e.neunTannUconxast.net> Sent:Thursday,January 31, 2013 2:36:42 PM Subject:Re.428 S Hanover Street The negotiator just left me a message. The bank Is not kr acceptance to your counteroffer for the cash for keys. Harry Speehrran Jr Century 21 A Better Way ---Original Message From: m.e.neumann <m.e.neumannPcomcast.net> To: Hart' Speelman Jr<brk8ba11sCao1.com> Sent: Thu, Jan 31, 2013 10:42 am Subject: Re: 428 S Hanover Street Harry, Just wondering if you've heard anything from the negotiator? Wanda From-"Harry SpeOnan Jr"<brkSballsoaol.corm To:"me neumann"<rn,e.neurrenn@corrr_ast.net> Sent:Tuesday,January 22, 2413 2:24:14 PM Subject:Re:428 S Hanover Street 412:1J2014 XFINITY Cava Connect m.e.neumannOcomcast.net Re:428 5 Hanover Street From :Harry Speekren)r<brk8balls@aol.com;> Thu, Apr 04,2013 12:48 PM Subject :Re:428 S Hanover Street To :me twunenn<m.e.neurrenn@comcast.net> Spoke with agent from the bank Rttle bit ago. They gave me an offer of$3000 cash for keys with a vacate date of May 10th. What are your thoughts on this? Have you had any iuckfinding a place to go? Let me know K you would be wilting to entertain an offer of this nature or what wig It take In the aspect of an offer from them for the keys, Harry Speekren.Jr Century 21 A Better Way 4123+2014 XFINITY Ga r<x-, XM TY Connect m.e.neumann comcast.net Font&�r Re:428 S Hanover Street From :Harry Speelman Jr<brk8ba4s@aol.com> Sat, Apr.27,2013 41:36 PM Subject:Re:428 S Hanover Street To:me neurrann <me.neurrenn&omcast.net> Just sent them a rressage in regards to what you have just said, wit let you know when they contact M Thanks, Harry Speelman)r Century 21 A Better Way --original Message— From: m.e.neumann <m.e.neumann@comcast,net> To: Harry Speelman Jr<brk8balls@aol.com> Sent: Sat, Apr 27, 2013 12:42 pm Subject: Re: 428 S Hanover Street There is no way that 1 couk,4 vacate the property by 5!10, 1 would say the earliest would be no later than 6t1. 1 would also sette for the $4000. 1 am looking at a home in Steelton for$25k, but there is a repair escrow on the dome that needs to be paid by the buyer, and Cm not really sure what that would mean to me. From: "Hang Speelman Jr" <brk8balis@a)aoi.com> To: "m a neumann" <m.e.nes_jmann q_f?comcast.net> Sent: Friday, April 26, 2013 3:23:24 PM Subject: Re: 428 S Hanover Street Just heard from the asset manager for the bank. They are willing to give you an offer of$4000 cash for keys with vacate date of 5-10. 1 mentioned totmn#kttime wise would imrethan tlltety not be sufficient enough, What are your thoughts? Hang Speelman)r Century 21 A Better Way —original Message--- From: Harry Speelman Jr<brWballS(c)aof.com> To: m.e.neumann <m,e.neurnann(ficomcast.net> Sent: Fri, Apr 26, 2013 10:23 am Subject: Re: 428 S Hanover Street Just sent agent another message wanting to know status on getting back to ire. How has the house hunting been going? Have you found anything fitting your needs as of yet? Or have you received any other Information from the bank since our last conversation? Wondering if there was a date you had planned on vacating property or are you awaiting to hear if they are wling to change the amount offered? Harry 5peet ten Jr Century 21 A Better Way 4/23/2014 RFINITY Cmnff'r XFINttTY Connect m.e.neumann0comcast.net Fent Size 0024795M- 428 S KANC M ST CARLISLE PA From :Harry Speekren Jr<b"balls@a)aol.com> Mon, Apr 29, 2013 04:30 PM. Subject:Fwd: 0024785683-426 5 HANOVER ST CARLISLE, PA 02 attachments To:me neumtann <me.neurrann0comcast.net> Just received this message earlier this afternoon from the asset manager at Chase. Cash for keys at$4000 and vacate of 6-1-13. What's your thoughts, if interested will need you to read over attached documents and sign and get back to me ASAP. Thanks, Harry Speekman Ir Century 21 A Better Way Sent: Mon,Apr 29, 2013 1:31 pm Subject: 0024785883-426 S HANOVER ST CARLISLE, PA Hi harry, CFK approved for 4000 with a vacate date of 06/01/2013. Please have RAP docs signed and sent back ASAP Thanks! Mike "The information in this electronic mail message is the sender's business confidential and may be legally privileged. It is intended solety for the addressee(s).Access to this internet electronic mail message by anyone else Is unauthorized. If you are not the Intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful." "The sender believes that this E-rraii and any attachments were free of any virus, worm, Trojan horse, and/or rrel{cious code when sent. This message and its attachments could have been infected during transnission. By reading the message and opening any attachments, the recipient accepts full responsibility for taking protective and remedial action about viruses and other defects.The sender's employer is not liable for any loss or damage arising in any way from this message or its attachments."{sar? "The information in this electronic mail message is the sender's confidential business and may be legally privileged. It is intended solely for the addressee(s). Access to this Inter-net electronic mail message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying,distribution or any action taken or orritted to be taken in reliance on it is prohibited and may be unlawful," "The sender believes that this E-mail and any attachments were free of any virus, worm,Trojan horse, and/or malicious code when sent. This message and its attachntents could have been infected during transmssion. By reading the message and opening any attachments, the recipient accepts full responsibility for taking protective and remedial action about viruses and other defects.The senders company is not liable for any loss or damage arising in any way from this message or its attachments." "Nothing in this emal shag be deemed to create a binding contract to purchase/sell real estate. The sender of this email does not have the authority to bind a buyer or seller to a contract via written or verbal communications including, but not limited to, err>ail communications." Relocation_Assfstance_lg reements_1[1].pdf 13 IB vfvlr9[1].pdf 1104 KF XF UTY Gotvle(., y Connect m a neumannecunrcast, t Re:002478SU3-428 5 KA.NDVER ST C1ri LE, FSA From :Harry 5peetrran Jr<brk8WksiPaol.corrn ton, Jun 17, 2013 04:23 PM Subject :Re: 002.4785883-428 S HANOVER ST CARLL;AE, PA To :me neurnann <m.e.neumannProrrrast.net> Have not heard back from you in awhile. The representative from the bank was wonderk►g what the status is on the home. Are you willing to do the cash for keys offer? It so can you please f1k out the paper work that I had emakd you previously and get that to rre as soon as possible. Any information I can forward onto them would be hek" Thanks, Harry Speen lr Century 21 A Better Way ----Original Message---- From: m.e.neumann <m.e.neumann@comcast.net> To: Harry Speelman Jr <brt(8baIIs@aol.com> Sent: Sun, May 26, 2013 11:25 pm Subject: Re: 0024785883 -428 S HANOVER ST CARLISLE, PA Harry, I am interested ki their offer, but havkig diffkvlty with a new home. From:"Harry Speekttan Jr"<brk'halitsrmrwl f s'r: To:"m a neurr+ann"<rTl.£.nelJrf 13 nn(Q'COi7� i'ie[> Sent:Thursday, May 115, 2013 8.04:41 AM Subject:Re: 0024785883-428 S HANOVER ST CARLISLE, PA Haven't heard a response to their offer. What are your thoughts on this? Harry Speeknan Jr Century 21 A Better Way ---Original Message— From: Harry Speelman Jr<t)rk8ba1ls(6'a0l.c011-:> To: m.e.neurnann <in.e.neurnann(&comcast.net> Sent: Mon, Apr 29, 2013 4:30 pm Subject: Fwd: 0024785883 -428 S HANOVER ST CARLISLE, PA Just received this message earlier this afternoon from the asset manager at Chase. Cash for keys at$4000 and vacate of 6-1-13. What's your thoughts, if interested wild need you to read over attached documents and sign and get back tc me ASAP, Thanks Harry Speekmn Jr Century 21 A Getter Way Sent: Mon,Apr 29, 2013 1:31 prn Subject: 0024785883-428 S HANOVER ST CARLISLE, PA Hi Harry, CFK approved for 4000 with a vacate date of 05/01/2013. Please have RAP docs signed and sent back ASAP Thanks! Mike "The informtion kr this electronic mail message is the sender's business confidential and my be legally pr'rviieged, It is intended solely for the addressee(s). Access to this Internet electrt :mag message by anyone else is unauthortzed. If you are not the untended recipient, any disciovire, copying,distrbution or ary actkyt taken or on*-ted to he taken in reliance on it k prohibked and may be w4awfuf," 4;Z3i2G14 XFINITYC(xvw� XF1WTY Connect m.e.mumbnn0comcas;t.rwt Foill Slzc Re:Fvvd:428 s hanover From -brkBbA@aol.com Fri, Nov 29, 201310:19 AM Subject.Re: Fwd: 428 s hanover To-me neumann <m e.neurnann@comcast.net> Reply To:brk6balls@aal,com I can try to contact my assest rnanager to see if option is still available. Thanks, Harry Speelman Sent via BlackBerry by AT&T From;m e.neurrianngconxast,net bate:Fri, 29 Nov 2013 15:17:33+0000(UTC) To:Harry Speekmn Jr<brkf3ba§s@aol.ccm> Subject:Fwd:428 s hanover Hello, the homes that we were looking at were under contract and already sold. We are going to look at another an Monday in Harrisburg, and hopefully that wig pan out, Do you know if the bank is still offering the$4000 for the cash for Lys option? In rTy quest for finding a horre, I now see on Truka that the home we are in is going to be auctioned on December 3rd. I understand that I need to get out of this home, and am trying to ftid a place to go to. Thank you, Wanda Neumanr From "m e neumann" <m.e.neumann@comGast.net> To: "Harry Speelman Jr' <brk8ba11s@ao1.com> Sent: Monday, November 4, 2013 2:13:05 PM Subject: Re: 428 s hanover Sorry,I had a system crash and didn't have access to my emails. Yes, I amstitl interested. I am waiting to hear track from another reakor about a home. Will keep you updated once I know more. Rega rds, Wanda From: "Harry Speelman Jr" <brk8ba11s@ao1.com> To: "me neumann" <m.e.neumann@comcast.net> Sent: Monday, October 7, 2013 2:21.28 PM Subject: 428 s hanover Are you still interested in sorre relocation assistance? What are your plans? The bank just contacted me wondering what your intentions are with the property? Have you spoken to your attorney in regards to the lawsuit you had mentioned that you were filing against the bank? Can you please update me so I can forward this information onto the bank? Thank you, Harry Speelman Jr Century 21 A Better Way EXHIBIT B XFIN"Goaw., ,*Vmconnect me.neumannovemcastner Font&ZL Re:Home to move in to From gregphenkie<gregphenicie@verizon.net> Thu, May 16,2013 12,04 PM Subject Re:Horne to rrove In to To rn e neurnann<rn,e,neurnann@corrtast.net> K My friend had nothing avaMbM1e, swry. Greg Sent from rry I phone On May 16,2013, at 11.20 AM, il-i e, nt:, wrote: Hello Greg, Was just wondering if your friend had gotten back to you or not The bank is pushing for me to be out by 6/01 and at this point, I don't see it happening. I would like to go back to them with a better date if possible. Thanks again! From: "Greg Phenicie" <gregphenI:cie�)verizon.net> To: "m e neumann" <m,e.neumanmacomcast.neI-> Sent: Monday, May 13, 2013 3:19:49 PM Subject: Re. Re: Home to move in to Hi Wanda, Can I forward this to my friend George to see if he has anything for you? Regards, ("g, On 05/13/13, wrote: Hello Greg, I have no one other than my son who just graduated from college. I do have about $2500 cash, plus the bank is willing to give me $4000 on a "cash for keys" agreement- I know that it will be difficult for me, but rm stuck between a rock and a hard place. I can't rent because of my credit and pets, I was hoping that I could find an inexpensive home or a foreclosed home that would be around $250-300 a month, I could probably go as much as $400. 1 dont know if this will help or not. My previous mortgage was over$800 a month and I tried to refinance with Chase and they wanted me to go even higher with my payments. There was no way that I could do it myself. V you are not able to help, I understand completely. '23 ata )(FINITY Thank you for your urric VVanaa From: "Greg Phenicie" <gregplienicie Cci)verizon.net> To: "m e neumann" <m.c.neu rn anti Cocot-Ticast.net> Sent: Friday, May 10, 2013 9:54:05 AM Subject: Home to move in to Hi Wanda, Sorry to hear of your circumstances. It must be difficult for you. is there anyone in your life that could give you asistance to help with a house? You need some financial strength to go forward V your credit is poor. Please let me know if this is an option for you. Regards, Greg l r s Exhibit C Zucker,Goldberg&Ackerman, LLC XCE-175926-EV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION CIVIL DIVISION Plaintiff, NO.. VS. Wanda K.Neumann,Michael E.Neumann, and Unknown Occupants Defendant(s). AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT I, IJ)tl'IQ kno C , 1/1 c e fres JCIPPJ for Plaintiff, being first duly sworn,say of my own personal knowledge that: 1. I am a 40— /�''Pd�G�e11 ( and a duly authorized representative Plaintiff in the above-captioned action. 2. This action is brought by Plaintiff to obtain possession of its real property located at 428 South Hanover Street,Carlisle,PA 17013. 3. Plaintiff purchased the Real Property at Sheriff Sale on December 5, 2012,with said Real Property conveyed to Plaintiff by a Deed from the Sheriff of Cumberland County. 4. Plaintiff has requested Defendant to vacate the Real Property,but Defendant has failed or refused to do so. 5. Plaintiff has no contractual or lease arrangement with Defendant for Defendant to remain in possession of the Real Property and Plaintiff has received or accepted no money from Defendant as rent for remaining in the Real Property. JPMorgan Chase Bank,National Association By:— �'P� Name: ident- Title: Me Pres SWORN TO AND SUBSCRIBED BEFORE ME THIS (27 DAY OF Q%,,au S+ .2014. NOTARY PUBLIC Shannon F anigan MY COMMISSION EXPIRES: q (3 1 S r+w•�•� 814ANNON FLAMM"M F Nohry FwbNc-8W#of FWW Mq COMM.EWMI Sop 13.2015 COIM 18810n#EE 130066 ";t' BMW TWO NNIN11 Netery Am. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, VS. NO.: 14-1903 Wanda K. Neumann, Michael E. Neumann, and Unknown Occupants; Defendant(s). CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Motion for Summary Judgment Pursuant to Pa.R.C.P. 1035.2 was served on the following this ?,--Pof�c St014,via First Class U.S. Mail, Postage Pre-Paid: Wanda K. Neumann; Michael E. Neumann and Unknown Occupants 428 South Hanover Street Carlisle, PA 17013 ZUCKER GOLDBERG &A LLC K� By: S ott A. Dietterick, Esquire-AVy I. .#55650 imberly A. Bonner, Esquire- I.D.#89705 oel A.Ackerman, Esquire-Atty I.D.#202729 Ashleigh Levy Marin, Esquire-Atty I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire-PA I.D.#317240 Denise Carlon, Esquire- PA I.D.#317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Zucker,Goldberg&Ackerman, LLC XCE-175926-EV 0.4 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) Motion for Summary Judgment CAPTION OF CASE (entire caption must be stated in full) JPMORGAN CHASE BANK, NATIONAL ASSOCIATION vs. Wanda K. Neumann, Michael E. Neumann, 0 No. 14-1903 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Motion for Summary Judgment 2. Identify all counsel who will argue cases: (a) for plaintiffs: Kimberly A. Bonner, Esquire (Name and Address) 200 Sheffield Street, Suite 101, Mountainside, NJ 07092 (b) for defendants: Wanda K. Neumann; Michael E. Neumann (Name and Address) 428 South Hanover Street, Carlisle , PA 17013 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: February 6, 2015 Date: ( v 1114 Signature Print your name Plaintiff Attorney for INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 14 days prior to argument. 3. The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. )91S PC/ V