HomeMy WebLinkAbout14-2333 Supreme Cot ffbf`Pennsylvania
Cour(b" CommoWTleas For Prothonotary UseOnlp:
i Cover Sheet Docket No:
CUMBERLAND: County ✓
77re ir7forrnutlurt cullrcted an thi,� form is tcsecl solely f�rr cutrrt nclnrinistrcrtion hrnlx�ses. This form sloe.+• Trot
sulydetnent or rel)luce the filling and service of plem./tm, or other l7[:thers as required by 1mv or rules Of. cour7.
Commencement of Action:
S 0 Complaint ❑ Writ of Summons ❑ Petition
Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiffls Name: L ead Defendant's Name:
T JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Leonie Raum and Unknown Occupants
I Are money damages requested? El Yes F1 No Dollar Amount Requested: lwithin arbitration limits
O (check one) ❑outside arbitration limits
N Is this a Class Action Suit? ❑ Yes F1 No Is this an MD,JAppeal? 0 Yes 0 No
A Name of Plaintiff /Appellant's Attorney: ASHLEIGH LEVY MARIN, ESQ.
❑ Check here if you have no attorney (arc a Self - Represented I Pro Set Litigant)
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PRIMARY CASE. If you are making more than one type of claim. check the one that
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- - Updated 1/1%2011
, .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION CIVIL DIVISION
Plaintiff,
vs. NO..
Leonie Raum 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
ITT,
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�- - Zucker, Goldberg & Ackerman, LLC
XFE- 183332 -EV l •
183332 002CO3312014P3
_ ?�U Ll :5 9
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION CIVIL DIVISION
Plaintiff,
NO..
VS.
Leonie Raum 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 la 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 O
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 UNO, 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) - 994;9308- -
- (717) 249 -3166
Zucker, Goldberg & Ackerman, LLC
'FE- 183332 -EV
183332 EVD1002CO331201AP4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION CIVIL DIVISION
Plaintiff,
NO..
vs.
Leonie Raum 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 1801 English Drive, Mechanicsburg, PA 17055.
(3) By Sheriff's Deed dated November 1, 2013, recorded on November 22, 2013 ,
Instrument #201337496, 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 pbrcha`sed by Plaintiff at Sheriff Sale on September 4, 2013. A true and correct copy of the
recorded deed is incorporated herein as Exhibit "A ".
(4) On May 1, 2013, Defendants were served as owners of the aforesaid premises with a
Notice of Sheriff's Sale scheduling the sale for September 4; 2013. A true and correct copy of the
Plaintiff's Affidavit of Service is incorporated herein as Exhibit 'B'.
(5) By letter dated December 23, 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 & Ackerman, LLC
XFE- 183332 -EV
183332- EVD1002CO3312014P5
(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 1801 English Drive, Mechanicsburg, PA 17055, together with such other relief as this
- Honorable Court may deem necessary and appropriate.
ZUCKER, GOLDBERG & ACKERMAN, LLC
qWIq BY: 0� Ma 2�
Dated: Scott A. Y Atterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
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
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFE- 183332 -EV /sc
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
- (908) 233-8500; 233 -1390 FAX
Email: Office @zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFE- 183332 -EV
183332- EVD1002CO3312014P6
EXHIBIT A
rnetan .tiawnan, LLr - uase6ystemYA rage 1 ui 1
Phelan Hallinan, LLP
1617 3FK Boulevard, Suite 1400, One Penn Center Plaza, Philadelphia, PA 19103
Phone: 215-563-7000
Fax: 215-568-7616
Case Summary 12/13/2013
Referral Type: Foreclosure Old PH #: 281651
PH #: 775483 File Received: 09/15/2011
Loan #: 1955518357 Follow -Up:
Status: 0 On Hold:
Property: 1801 ENGLISH DRIVE County: CUMBERLAND
MECHANICSBURG, PA 17055 -5648
Defendant: RAUM, LEONIE
Primary Servicer: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION (34)COLUMBUS, OH 43240
Report To:
Investor:
Insurer: Federal Housing Administration (FHA)
Referred By: LPS DESKTOP (52)
Court Term: Complaint 12 -4917
Docket #:
Freddie Mac #:
Fannie Mae #: Client Billed: 10/28/2013
FHA /VA #: 441- 8395208 -734 Bill Amount: $350.19
Closed:
Writ Sale #:
Report To #:
PMI #: PMI Name:
Township:
� oosaaa
t Tax Parcel No 42 -27- 1490- 039.0 -6-
J A -1
Know all Merl by these Presents
That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of b 1,40 (One Dollar)
to in.e in hand Maid, do hereby grant and convey to .IP.Morgan Chase Bank, National
Association
2012 - 4917 Civil Term
JPMorgan Chase I3t>uk, National Association
Vs
Leonie Rawn
ALL TI IAT CERTAIN apartment dwelling unit situated in English Court Condominium, Upper Allen Township, Cumberland County,
Pennsylvania, being designated as unit No. G -A in the Declaration and Declaration Plans of said condominium, recorded in the Recorder of
Deeds Office of Cumberl County, Pennsylvania, in Misc. Bonk 285, Page 573, and Plan Book 43, Page 42, respectively under the provisions
of the Uniform Condominium Act of July 6, 1980.
TOGIi`TIFR. with all right of title and interest, being an 11.32% interest of, in and to the Common Elements as more fully set forth in the
Declaration: of Condominium and Declaration Plans.
UNDER. AND SUBJECT to all agreements, conditions, casements and restrictions of record and to the provisions, casements, covenants and
restrictions as contained in the Declaration and the lleclaration Plans.
The Grantee, for and on behalf of the Grantee, and the Grantee's heirs, personal representatives, successors and assigns, by the acceptance of this
Deed, covenants and agri;es to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the Common
Elements as may be assessed from time to time by the Executive Board in accuidance with the Uniform Condominium Act of Pennsylvania, and
further covenants and agrees that the Unit conveyed by this Deed shall be subject to a charge for all amounts so assessed and that, except insofar
as Section 3315 of said Uni R)rnn Condominium Act, may relieve a subsequent Unit owner of liability for prior unpaid assessments, this covenant
shall run with and hind (lie land or Unit hereby 6onveyed and all subsequent owners thereof.
The Grantee, for and on behalf of the Grantee, and the Grantee's heirs and assigns, by the acceptance of the Deed and execution below,
admow•ledges that this conveyance is subject in every respect to the Declaration, the Declaration Plans and all amendments thereto; and the
Grantee further aeknowledges that each and ever; provision of the foregoing is essential to the best interest and for the benefit of all Unit owners
therein. Grantee and all owners of Units in said condominium covenant and agree, as a covenant running with the land, to abide by each and
every provision of said documents.
Tfl'l...E TO SAID PREMISES IS VESTED IN Leonic Raum, a single person, by Deed from Michael Lee Prim.. Executur of the Estutc of Ethel
M Prinz, formerly afSwatara Township, dated 06119/2009, recurded 06/20/2008 in fnstrument Number 200820311
PREMISES BEING: 1801 ENGLISH DRIVfi, NIECIJANICSBURG, PA i7055 -5648
PARCEI. NO. 42 -27- 1890 - 039.- U -6 -A -1
The same having been sold by me to the said grantee on the 4th day of September
Anno Domin.i Two Thousand and Thirteen (2013) after due advertisement according to
law, under and by Virtue of a Writ of Execution issued on the 16th of April Anno
Domin.i 2013 out of the Court of Conunon Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Twelve (2012) Number 491.7 at the suit of
JPMorgan C.liase Bank, National Association —vs- Leonie Raum
In Witness Whereof, I have hereunto affixed my signature this 1st ay of November
Anna Domin.i Two Thousand and Thirteen (2013) f
Z6ia v R. Anderson, Sheriff
Commonwealth of Pennsylvania, ss.
County of Cumberland
Before the ruidersigned, David D. Buell, Prothonotary of the Court of Common
Pleas of Cumberland. County, Pennsylvania, personally appeared Ronny R. Anderson,
Sheriff of Cumberland County aforesaid, and in due fonn of law declared that the facts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said deed might be recorded. Witness my hand and seal of said Court, this 1st day
of November Anno Domini Two Thousand and Thirteen (2013)
r. 4ruloi a
Prothonotary, Cumberland County, Carlisle, PA
a My Cnmmissiwi F isires the first Monday of Jan. 2014
t �t r• ' ' ; I hereby certify that the residence
And Post Office_ address of the
Within Grantee is _
1111 Polaris. Parkway
lo 111 %10 " Columbus, OR 43240
Richard. W. Stewart
Solicitor
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE -
CARLISLE, PA 1.7013 Y g
717 -240 -6370
Instrument Number - 201337496
Recorded On 11/22/2013 At 8:57:01 AM * Total Pages - 5
• Instrument Type - DEED - SHERIFF'S
Invoice Number - 151866 User ID - BMM
• Grantor - RAUM, LEONIE
• Grantee - JPMORGAN CHASE BANK N A
• Customer - SHERIFF
* FEES
STATE WRIT TAX $0.50 Cer tification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT .DETACH
RECORDING FEES — $12.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $15.00 This gage is now dart
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00 --
MECHANICSBURG SCHOOL $0.00 _.
DISTRICT
UPPER ALLEN TOWNSHIP $0.00
TOTAL PAID $68.00
- I Certify this to be recorded
in Cumberland County PA
1u ° RECORDER O /D7EDS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
0033RR
. �I�Il�llll�llllllllil�lll
EXHIBIT B
A'F.'FTDA \TIT OF SERVICE
PLAINTIFF CLfl1BERLAND COUN'T'Y
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
PHS # 281651
DEFENDANT SERVICE IF"/ lxh
LEON RAUM COURT NO.: 12.4917
SERVE LEONIE RAUM AT: TYPE OF ACTION
1801 ENGLISH DRIVE XX Notice of Sherit'f''s Sale
MECTIANICSBURG, PA 17055 -5648 SALE DATE: September 4, 2013
SERVED
.S and made kao wn to {a.11 RA N4, Dcfendant sin for day of _ _ , 20 B, at
�
o'clock e—N , at 1 J - LJA�_ - in the manner described below:
Dtfendant I u. ortally served.
Adult amily mrmber wit,t) whom Defendant(s) reside(s).
Relationship is _
_ Adult in charge of Defendant's residence who refused to give name or relationship.
_ Manager /Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant's office or usual place of business.
_ an officer of said Defendant's company.
Other:
Description: Age Height Weight Race Otlrex
I, a competent adult, hereby verify that I personally handed a true and rorrert coley of the
Notice of Sheriffs Sale in the manner as set forth herein. issued in the captioned case on the date . and at tine address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec, 4 relating to
unswom falsification to authorities.
DATE: ? 3 NAME: _
PRINTED NAME:.
TITLE:
NOT SERVED
On the day of 20 at o clocks, M„ 1, _ a competent adult hereby
state that befendant IT07T0U1gnecause:
Vacant Does Not Exist Moved _ Does Not Reside (Not Vacant)
No Answer on i °� at ttt
Service Refused U
Other:
I understand that this statement is made' subject to "the penalties_ of 18' Pa: C.& See. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
A.TT DRNEY FOR P LA N TIFF
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103 �.
(215) 563 -7000
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION : COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
VS. NO.: 12 -4917
LEONIE RAUM
Defendant(s) CUMBERLAND COUNTY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: LEONIE RAUM
1801 ENGLISH DRIVE
MECHANICSBURG, PA 17055 -5648
"THIS FIRM IS A DEBT COLLECTOR ATTEMFI'INGG 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 1.801. ENGLISH DRIVE, MECHANICSBURG, PA 1.7055 -5648 is scheduled
to be sold at the Sheriff's Sale oil 09/04/201.3 at 10:00 AM in the Cumberland County Courthouse, South
Hanover Street, CarlisIe,,PA 17013 to enforce the court judginent of $92,816.15 obtained by JPMORGAN
CHASE BANK, NATIONAL; ASSOCIATION (the mortgagee) against you. In the event the sale is continued,
an announcement will be made at sale in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PR T SHE RIFF' 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 x1.230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgmer.it,
if the judgment was. improperly entered- You.m.ay also ask the Court, to postpone the ,saif. for, good cause.
3. You may also be able to stop th,e sale.through other legal proceedings..
You may need an attorney to assert your rights. The sooner you contac.t.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 'ss 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. 'Thi 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 `I'O 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 -91( )$
LEGAL DESCRIPTION
ALL THAT CERTAIN apartment dwelling unit situated in English Court Condominium, Upper
Allen Township, Cumberland County. Pennsylvania, being designated as Unit No. 6 -A in the
Declaration and Declaration Plans of said condominium, recorded in the Recorder of Deeds
Office of Cumberland County, Pennsylvania, in Misc. Book 285, Page 578, and Plan Book 43,
Page 42, respectively under the provisions of the Uniform, Condominium. Act of July 6, 1980.
TOGETHER with all right of title and interest, being an. 1.1..32% interest of, in and to the
Common Elements as more fully set forth in the Declaration of Condominium and Declaration.
Plans.
UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and
to the provisions, casements, covenants and restrictions as contained in the Declaration and the
Declaration Plans.
The Grantee, for and on behalf of the Grantee, and the Grantee's hews, personal representatives,
successors and assigns, by the acceptance of this Deed., covenants and agrees to pay such charges
for the maintenance of, repairs to, replacement of and expenses in connection with the Common.
Elements as may be assessed from time to time by the Executive Board in accordance with the
Uniform Condominium Act of Pennsylvania, and further covenants and agrees that the Unit
conveyed by this Deed sliall be subject to a charge for all amounts so assessed and that, except
insofar as Section 331.5 of said Uniform Condominium Act, may relieve a subsequent Unit
owner of liability for prior unpaid assessments, this covenant shall run with and bind. the land or
Unit hereby conveyed and all subsequent owners thereof.
The Grantee, for and on behalf of the Grantee, and the Grantee's heirs and assigns, by the
acceptance of the Deed and execution below, acknowledges that this conveyance is subject in
every respect to the Declaration, the Declaration Plans and all amendments thereto; and the
Grantee further acknowledges that each and every provision of the foregoing is essential to the
best interest and for the benefit of all Unit owners therein. Grantee and all owners of Units in
said condominium covenant and agree, as a covenant running with the land, to abide by each. and
every provision of said .docurnents.
TITLE TO SAID PREMISES IS VESTED IN Leoni.e Raum, a. single person, by Deed from
Michael Lee Prinz, Executor of the Estate of Ethel M. Prinz, formerly of Swatara Township,
dated 06/19/2008, recorded 06./20/2008 in Instrument Number 200820811
PREMISES BEING: 1801. ENGLISH DRIVE, MECHANICSBU -RG, PA 17055 -5648
PARCEL NO. 42-27-1.890-039.-U-6-A-.1
EX HIBIT C
LEONARD B.7_UCKER ZUCKER GOLDBERG & AC KERMAN , LLC FOUNDED !N 1923
MICHAEL S.ACKERMAN ATTC ►RNEYSATLAW ASZUCKER &GOLOBERG
JOEL ACKERMAN*
MAURICE J. ZUCKER
FRANCES GAMBARDELLA 200 SFIEFFIELD STREET- SUITE 101 LOUIS D. GOLDBER y ('92
BRIAN C'. NICHOL S ♦ P.O. BOX 102 � LEONARD H GOLDBERG X82 s �� ?�?.
SCOTT A. DIETT #TRICK Y BENJAMIN WEISS (114'.. _B##. :
KIMBERLY A. BONNER Y MOUNTAINSIDE, NJ 07092-0024
STEVEN D. KROL
CHRISTOPHER G. FORD TELEPHONE: 908 - 233 -8500 Pennsylvania Office:
DEN CARLON AA The Union Hotel Office Building
CHRSTINE E. POTTER o FACSIMILE: 908 -233 -1390 240 Gettysburg Pike
RYAN S. MIALC E -M AIL: office @zuckergoldberg.com Mechanicsburg, PA 1705`-'
STEPHANIE WOLCHOK
ASHLEIGH LEVY MARIN f
DOUGLAS J. McDONOIUGH For payo ffIreinstate rrient figures
TIMOTHY J. ZIEGLER Please send y our request to: zuckergoldberg.com1pr * ALSO MEMBER OF NY, PA AND CA BAR
RALPH M. SALVIA Y 4 ALSO MEMBER OF NY, PA AND ME BAR
ROBERT D. BAILEY 66 ALSO MEMBER OF NYAND PA BA13
JAIME: R. ACKERMAN ♦ REPLY TO NEW JERSEY ADDRESS d ALSO MEMBER OF NY BAR
KACIE W, BROWN t ALSO MEMBER OF PA BAR
MONIKA 5, PUNDALIK �y MEMBER OF PA BAR ONLY
TODD MARKS d n ALSO MEMBER OF FL BAR
TIMOTHY O. KUHLS A
JANA FRIDFINNSDOTTIR Y
DENN!S P. OHLMANN, JR.
BRIAN M. GILBERT
XFE- 183332 -EV December 23, 2013
Leonie Haum and Unknown Occupants cert Article N
�r
and /or Tenant(s) known or unknown at: 7116 9008 9111 6605 8500
1801 English Drive .I
Mechanicsburg, PA 17055
;W,
DEMAND FOR POSSESSION OF PROPERTY
Property Address: 1801 English Drive C ertifie d iir u A in 1 ,N rrr b irk r
Mechanicsburg, PA 17055 p
Sale Date: Sep tember 4, 2413 7116 006 9111 6605 8
Dear Tenant: . ,ECCIIR ID
On September 4, 2013, the property located at 1801 English "Deive, Mechanicsburg, PA 17055 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, NATIONAL ASSOCIATION, which was the
highest bidder at the sale, and now owns the property, as evidenced by deed recorded on November 22, 2013 in
Instrument 4201337496.
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 HAV 10 D AYS 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
farmer 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, NATIONAL ASSOCIATION 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 motley orders);_ rt
(c) proof that all monthly rental payments dr.re under the lease have been paid to date (proof may be in
the form of copied of cancelled checks, rnoney 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 Dave,
if any, under the Protecting Tenants at F=oreclosure Act of 2009.
IM PORTANT NOT FOR StE EME BE A ND THEIR _Q9L E #Q SST
If you are or recently were on active duty or active service, you may be eligible for benefits and protections
under the federal Service rnembers 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 j
• Active service with the National Guard .. I
• 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 frorn duty because of sickness, wounds, leave, or other lawful cause.
Address: Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 201
Mountainside, NJ 07092
Attn: Barbara Soogrim /Caroline Kriak
Phone: (908) 233-8500 ext.
Fax: (908) 654 -737$
Email: militarymember @zuckergoldberg.corn
Very,truly yours,
Z.UCKER, 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)-231.8500 ext 184 to discuss your status under the SCRA.
Zucker, Goldberg & Ackerman, LLC
Page 3
,
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UNITED STATES Certificate Q�; �` � O rJ 4; `
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POST13L SERVICE
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This Certificate of Mailing provides evidence that mail has been presented to USPSO for ma+ling. This form may be used for
domestic and International mail
From' Sona C
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200 Sheffield Street, Suite 101^ __ T
Mou ntainside, NJ 07092
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unknown
1801 English Drive ~ � -� � 111 7 1 .', s
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Mech PA 17055
County of P.Q.: Cumberland
PS Form 3817, April 2007 PSN 7530 -02- 000 -9065 I 2 3 201 - 3
s-
Zucker, Goldberg & Ackerman, LLC
Page 4
1'HE FROM
WALZ IM U.S. PAT. NO. 5,501,393 ri 1uu0 1AAA bbu3 03uu
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?IIAILERT'" and /or Tenant(s) known or unknown at
and /or Tenant(s) kno\ini or unknown at 1801 English Drive
1801 E n gl ish Drive Mechanicsburg, PA 17055
Label #1 Mechanicsburg, PA 17055
SENDER: SC
Leonie Raum
and /or Tenants) known oi unknown at: REFERENCE:
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1801. English. Drive
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Chase Occupant Contact Information Sheet
Each OreispontlAduft(lg tir Older) trwifillmit a separate form
Al US T harr a vidid phafa identification
0 Terva"I 0 Former Homeowner Unknown
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If you arc or recently were on active dwY or active wrvice: }vu rreay be eligible for tx-acfits and prvtmions under
the Wcral Scrvicernembcrs Civil Relie Act (SCR A). This 1ric1u4cs protix(ion 'from foreclosure or eviction. yi)LI
alw nmy be eligible for bcoeftts and protections tmder state law, 'CRAk a0 state tullitary 4csicftts and protections
0150 rtacty lac a ;ailablc if you. -ac the depende4ntaf an eligible scrViCCrttcmtxr.
* Accive duty with dio Army, Na y, Air F e, Marint Corps. or Coast Guard
* r' vivc viviCC with the National fitt�ud
• Active service as a comjnissiorlcd ofricer of tha Notional Occar+ic and Atmospheric Administration
e Activo scrvi�4; as a ofTiver of the Public Health Scr+ ",
• Sen1cc with the forces ora nathin with wt the U►tiled Stares. is allied in a wair or military action
+ -Stm °i" With the Naliort.al Guard or a state militia und&,, a state call 10 duty, or
Any period when )vu arc a$scnt i`nirn duty becrosw of sicknew, wounds, learn, or other lawfW ",usc.
l ar more. inronnatroa, you should c+mtaOt lPMOrprt Cltasc tank, National Associ toll .rrrc at (g77) 534. 3290.
UST ot Pr-,kSf)NAL PROPERTY
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VERIFICATION
F
I, L 1� &,-k 6= � JwY► , 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
s'.
falsification to authorities.
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
By:
Name: Linda G Tow
mice President
Title:
�014
DATE:
Borrower Name: Leonie Raum and Unknown Occupants.,
Property Address: 1801 English Drive, Mechanicsburg, PA 17055
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
-
Ronny RAnderson
Ronny THE PROTHON`i Tr�r
at CHAr ,er,
Jody S Smith 2014 APR 30 PM 3; 00
Chief Deputy
Richard W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
JPMorgan Chase Bank, National Association
vs. Case Number
Leonie Raum 2014-2333
SHERIFF'S RETURN OF SERVICE
04/28/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 1801
English Drive, Upper Allen Township, Mechanicsburg, PA 17055. Residence is vacant.
04/28/2014 Sergeant Jason Vioral served the requested Complaint in Ejectment by"personally" handing a true copy
to a person representing themselves to be the Defendant, to wit: Leonie Raum at the Cumberland County
Sheriffs Office, One Courthouse Square, Carlisle, PA 17013.
JASON IO , DEPUTY
SHERIFF COST: $55.30 SO ANSWERS,
April 28, 2014 RONR ANDERSON, SHERIFF
u< _
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK, CIVIL DIVISION
NATIONAL ASSOCIATION
Plaintiff,
vs.
Leonie Raum and Unknown Occupants
TO THE PROTHONOTARY:
Defendant.
NO.: 14-2333
PRAECIPE TO SETTLE AND DISCONTINUE
Please mark the case filed at the above -captioned term and number SETTLED and
DISCONTINUED.
By:
Dated: May 22, 2014
Respectfully Submitted:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietteric , Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
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
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFE-183332-EV/btm
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: office@zuckergoldberg.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION
CIVIL DIVISION
NO.: 14-2333 Civil
Plaintiff,
vs. TYPE OF PLEADING
Leonie Raum and Unknown Occupants PRAECIPE TO SETTLE AND DISCONTINUE
Defendant. CODE:
FILED ON BEHALF OF:
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire- Pa. I.D. #55650
Kimberly A. Bonner, Esquire- Pa. I.D. #89705
Joel A. Ackerman, Esquire- Pa I.D. #202729
Ashleigh L. 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
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
office@zuckergoldberg.com
File No.: XFE- 183332-EV/btm