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HomeMy WebLinkAbout14-3365S E C T I 0 N A S E C T I 0 N B Court of Common Pleas Civil Cover Sheet Cumberland County The information collected on this form is used solely for court administration purposes. This form does not For Prothonotary Use Only: ❑ Petition ❑ Declaration of Taking Docket No: 3...V- lement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: ❑ Petition ❑ Declaration of Taking Complaint ❑ Writ of Summons ❑ Transfer from Another Jurisdiction Lead Plaintiff's Name: JPMorgan Chase Bank, National Association Lead Defendant's Name: Matthew A. Negley; Deane L. Negley Dollar Amount Requested: ❑ within arbitration limits Are money damages requested?: ❑ Yes L No (Check one) @ outside arbitration limits • Other: Is this a Class Action Suit? ❑ Yes // No Is this an MDJ Appeal? ❑ Yes /1 No Name of Plaintiff/Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ Check here if you have no attorney (are a Self -Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your type of claim, check the one that PRIMARY CASE. If you are making more than one you consider most important. TORT (do not include Mass Tort) ■ Intentional ■ Malicious Prosecution ■ Motor Vehicle • Nuisance ■ Premises Liability • Product Liability (does not include mass tort) • Slander/Libel/Defamation • Other: CONTRACT (do not include Judgments) • Buyer Plaintiff • Debt Collection: Credit Card ■ Debt Collection: Other CIVIL APPEALS Administrative Agencies 0 Board of Assessment • Board of Elections • Dept. of Transportation ■ Statutory Appeal: Other • Employment Dispute: Discrimination ■ Employment Dispute: Other U Zoning Board ■ Other: • Other: MASS TORT ■ Asbestos • Tobacco ■ Toxic Tort - DES • Toxic Tort - Implant ■ Toxic Waste • Other: REAL PROPERTY ■ Ejectment ■ Eminent Domain/Condemnation ■ Ground Rent • Landlord/Tenant Dispute Mortgage Foreclosure: Residential ■ Mortgage Foreclosure: Commercial ■ Partition ■ Quiet Title IN Other: MISCELLANEOUS ■ Common Law/Statutory Arbitration ■ Declaratory Judgment • Mandamus ■ Non -Domestic Relations Restraining Order ■ Quo Warranto ■ Replevin ■ Other: PROFESSIONAL LIABILITY • Dental • Legal ■ Medical • Other Professional: Updated 1/1/2011 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 DEFENDANTS r PRO THONG "1- CLINBERLA ND PENNSYLVANIA �f i }� s COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNT et NO: 143314 COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. oko,kSle3.-isp4x141 eK.i� I`�d�'a58 Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO 0 SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO OSI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, JPMorgan Chase Bank, National Association, the address of which is, 3415 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Mortgage Electronic Registration Systems, Inc., as nominee for Howard Hanna Mortgage Services, its successors and assigns Mortgagor(s): Matthew A. Negley and Deane L. Negley (b) Date of Mortgage: July 31, 2013 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Document ID# 201325571 Date: August 2, 2013 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Howard Hanna Mortgage Services, its successors and assigns Assignee: JPMorgan Chase Bank, National Association Date of Assignment: March 4, 2014 Recording Date: March 10, 2014 Instrument No.: 201404854 The Assignment(s) is/are a matter a matter of public record and are therefore incorporated herein as provided by Pa. R.C.P. No. 1019(g). 2. Plaintiff is the current holder of the mortgage by operation of law. 3. The real property that is subject to the Mortgage is generally known as 646 Highland Avenue, Mount Holly Springs, PA 17065 and is more specifically described as attached as part of Exhibit "A". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Promissory Note"). A true and correct copy of the Promissory Note is attached and marked as Exhibit "B". 5. The names and mailing addresses of the Defendants are: Matthew A. Negley, 1907 George Avenue, Carlisle, PA 17013 and Deane L. Negley, 1907 George Avenue, Carlisle, PA 17013. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of November 1, 2013 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of May 3, 2014: Principal Balance Due $162,757.47 Interest Currently Due and Owing at 3.75% $3,560.34 From October 1, 2013 through April 30, 2014 Late Charges $90.72 Escrow Balance ($423.19) TOTAL $165,985.34 9. Interest continues to accrue for each day that the debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible under the Note and Mortgage. 10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. The property is vacant, accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable, and as such the Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. Date: U1311'4 S & D File No. 14-045717 BY: SHAPIRO & DeNARDO, LLC orneys for Plaintiff CAITLIN M. DONNELLY, ESQUi E .l Inst. $ 201325571 - Page 19 of 19 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201325571 Recorded On 8/2/2013 At 8:17:00 AM * Instrument Type - MORTGAGE Invoice Number - 143599 User ID - SW "Mortgagor- NEGLEY, MATTHEW A " Mortgagee - MORTGAGE ELECTRONIC REGISTRATION " Customer - SINIPLIFILE LC E -RECORDING "FEES N Total Pages -19 STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES — RECORDER OF DEEDS PARCEL CERTIFICATION FEES AFFORDABLE HOUSING COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $23.50 $39.50 $15.00 $11.50 $2.00 $3.00 $95.00 SYSTEMS INC Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER 01? DEEDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. Y• y 014 - [Space ' ' / Record and Return to: Howard Hanna Mortgage Services 119 Gamma Dr Pittsburgh, PA 15238 PARCEL TAX ID#: 40-31-2187-023 PMI CASElt: DEFINITIONS [Space Above This Line For Recording Data] MORTGAGE Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16. (A) "Security Instrument" means this document, which is dated July , 31st 2013 , together with all Riders to this document. (B) "Borrower" is MATTHEWA NEGLEY AND DEANE L NEGLEY, HUSBAND AND WIFE Borrower is the mortgagor under this Security Instrument. (C) "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate corporation that is acting solely as a nominee for Lender and Lender's successors and assigns. MERS is the mortgagee under this Security Instrument. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of 1901 E. Voorhees Street, Suite C, Danville, IL 61834 or P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. PENNSYLVANIA RUMS - Yea Family39— l- MaelFrcdNeMac t*____f-01-° UNlFORMPISIRUMCN'r Fom9039 Lal- mG3039-01 (12/10) (Page 1 of17) Initials: sI (D) "Lender" is Howard Hanna Mortgage Services Lender is a a Pennsylvania Corporation Iaws of THE COMMONWEALTH OF PENNSYLVANIA 119 Gamma Dr, Pittsburgh, PA 15238 organized and existing under the . Lender's address is (E) "Note" means the promissory note signed by Borrower and dated July 31st 2013 . The Note states that Borrower owes Lender ONE HUNDRED SIXTY THREE THOUSAND TWO HUNDRED FIFTY AND NO/100 Dollars (U.S. $ 163,250.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than August 1st, 2043 • (F) "Property" means the property that is described below under the heading "Transfer of Rights in the Property." (G) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (H) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: Adjustable Rate Rider 0 Condominium Rider Q Second Home Rider Q Balloon Rider Q Biweekly Payment Rider Q 1-4 Family Rider Other(s) [specify] Q Planned Unit Development Rider LEGAL (I) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non -appealable judicial opinions. (J) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (K) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (L) "Escrow Items" means those items that are described in Section 3. (M) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. (0) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. PENNSYLVANIA—Single Family— Fannie Mac/Freddie Mac UNIFORM INSTRUMENT Farm 3039 1/01 mG3039.02 (0012) (Page 2 of 17) Initials. it 440 fa)0 (P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (Q) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS the following described property Iocated in the COUNTY [Typo of Recording Jurisdiction] of CUMBERLAND [Name of Recording Jurisdiction] SEE ATTACHED LEGAL DESCRIPTION which currently has the address of 646 HIGHLAND AVENUE (Street) MOUNT HOLLY SPRINGS • , Pennsylvania 17065 • ("Property Address"): (City) (Zip Code) TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument, but, if necessary to comply with law or custom, MERS (as nominee for Lender and Lenders's successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing and canceling this Security Instrument. PENNSYLVANIA —Single Family— Fannie Mae/Freddie Mae UNIFORM INSTRUMENT Form 303,9 1/01 PAd 01j°MG3039-03 (0012) (Page 3 of 17) Initials• BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payment are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument, 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. PENNSYLVANIA —Slagle Family— Penile Mae/Freddle Mae UNIFORM INSTRUMENT Form 3039 U0r 03039-04 (0012) (Page 4 ofI7) » /4/ OLS If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment 'can be paid in full. To the extent that 'any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) Ieasehold payments or groundents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. • The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be PENNSYLVANIA —Single Family — Fannie Mae/Freddle Mat UNIFORM INSTRUMENT Form 3039 1/01 63039 -OS (0012) (Page 5ofl7) Initials. ° 14,f) �� " paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. . If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for floodzone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and certification services and subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. PENNSYLVANIA —Single Family— Fume Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1101 G3039-06 (0012) (Page 6 of 17) InitiateJJALL) Oi If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligationto purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower, Borrower's equity ih the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not Iessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be.paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30 -day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. PENNSYLVANIA —Single Family --nage Mae/Freddie Mac UNIFORM INSTRUMENT Farm 3039 vim G3039-07 (0012) (Page 7 of 17) Initials I1A' tL 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal• residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration. Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. S. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security Instrument (such as a proceeding in banlcruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Instruunent, including protecting and/or assessing the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. PENNSYLVANIA — swami* — Fannie MaccFredd a Mac UNIFORM INSTRUMENT Parra 3039 1/01 G3039-08 (0012) (Page 8•of1 V Initials: M1 0`-' Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan, is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such Ioss reserve. Lender can no Ionger require Ioss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until the Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if Borrower does not repay the Loan as agreed._ Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payment using any source of funds that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance premiums). PENNSYLVANIA—Etagle Pamily— Paade Mae/Freddlc Mac UNIFORM INSTRUMENT Ponn3039 1/01 13039-09 (0012) (Page 9 ofl7) Initials DL As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is often termed "captive reinsurance." Further: (a) Any such agreements will not affect -the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund. (b) Any such agreements will not affect the rights Borrower has -if any- With respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender sball not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured -by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. • In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. PENNSYLVANIA—Slagle Family —Faml&Mae/Freddie Mac UNIFORM INSTRUMENT Form 9039 7/01 G3039-10 (0012) (Page 10oflV Ilutials /14/0 . ( vl\) If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts Iess than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's consent. PENNSYLVANIA —Single Family— Panel, Mae/F;eddle Mac UNIFORM INSTRUMENT Porta 3039 1/01 G3039-11 (0012) (Page 11 of17) in„ia. Zu\-) Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all. of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security Instrument unless Lender agrees to such. release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All Notices given by Borrower or Lender in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requiresotherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only one designated notice address imder this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security Instrument. PENNSYLVANIA —Single Faintly —Fannie Mae/Freddie Mac UNIFORM INSTALMENT Foam 3039 1101 G3039-12 (0003) (Page 12 of IV 16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. In the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument. 18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in•Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) five days before sale of the Propertypursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds PnNNSYLVANIA — Stogie Famlly— Fannie Mae/Freddie Mae UNIFORM INSTRUMENT Form 3039 1/01 G3039-13 (0012) (Page 13 of IV AO_ q)uo Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There. also might be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer products). PENNSYLVANIA —Slagle Family —Famde Maelneddle Mae UNIFORM DeTRUMSNT Form 2039 1101 G3039-14 (0012) (Page 14 of17) InitiaLs: (_ Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not limited' to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (o) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. 23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. • 25. ReinstatementPeriod. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. PENNSYLVANIA —sl*Famiy— Fannie MaaFieddle Mac UNIFORM INSTRUMENT Para 3039 3/01 03039-15 (0012) (Page IS of Initials' �'/" I i BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witnesses: MATTHEW A NEGLEY DEANE L NEGLEY 44 - (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower Prepared By: KEITH KAMICKE.R Howard Hanna Mortgage Services 119 Gamma Dr Pittsburgh, PA 15238 PENNSYLVANIA —Single Family — Fondle Mae/Freddto Mee UNIFORM INSTRUMENT Form 3039 vol 03039-16 (0408) (Page 16oftV INDIVIDUAL ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA, COUNTY OF eafiLbeitla ,f SS On this, the 31st day of July undersigned officer, personally appeared • MATFHEW A NEGLEY AND DEANE L NEGLEY , HUSBAND AND WIFE , 2013 before me, the known to me (or satisfactorily proven) to be the person(s) whose name(s) subscribed to the within instrument and acknowledged that executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and offi al seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KANDI L. LENKER, Notary PubllO HAMM ACOUNTY 20 MY COMMISSION TO, UGUST 24, 2013 CERTIFICATE/OF RESIDENCE I, -loin L . `&rJ e4t•— address of the within -named Iender is Witness m this 119 Gamma Dr, Pittsburgh, PA 152 8 S , day of Agent of Lender do hereby certify that the correct 5u1� A9)3 PENNSYLVANIA — Single Family—Ramie Mac/Freddle Mac UNIFORM INSTRUMENT Form 9039 1/01 G3039-17 (0012) (Page 17oft7) Initials' / tz W ALL THAT CERTAIN lot or piece of ground situate in South Middleton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point 100 feet South of the intersection of the eastern line of Highland Avenue and the Southern line of Mountain View Drive as shown on the hereinafter mentioned Plan of Lots, said point being in the Eastern line of Highland Avenue and the dividing line between lots numbered 39 and 40 on said Plan; thence eastwardly by the dividing line between lots numbered 39 and 40 on said Plan, 150 feet to a point on the Western line of•lot number 75 on said Plan; thence Southwardly by the Western line of lot number 75 on said Plan 100 feet to a stake; thence Westwardly by the dividing line between lots numbered 41 and 42 on said Plan, 150 feet to a point on the Eastern line of Highland Avenue; thence in a Northerly direction by the Eastern line of Highland Avenue, 100 feet to a point, the place of BEGINNING. HAVING erected thereon a one-story dwelling known as 646 Highland Avenue, Mt. Holly Springs, PA 17065. BEING THE SAME PREMISES which Paul R. Delvitto, previously misspelled as Paul R. Delvito, by deed dated January 26, 2009 and recorded January 29, 2009 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania as Instrument number 200902342 granted and conveyed unto Paul R. Delvitto and Theresa P. Delvitto, husband and wife, Grantors herein. 'mix/ ri)N) *ORIGIN Li t s PMI CASE# July 31st, 2013 (Date) CAMPHILL NOTE fad 848 HIGHLANDAVENUE MOUNT HOLLY SPRINGS, PA 17085 IPropaO'Adrdross) Ne P . PENNSYLVANIA (Stare) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, i promise to pay U.S. S 183,250.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is Howard Hanna Mortgage Services, a Pennsylvania Corporation i will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 3.750 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on September 1st 2013 . i will make these payments every month until i have paid all of the principal and interest and any other charges described below that i may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on August 1st, 2043 I still owe amounts under this Note, i will pay those amounts in full on that date, which is called the "Maturity Date." i will make my monthly payments at 118 Gamma Dr, Pittsburgh, PA 15238 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. S 758.04 4. BORROWER'S RIGHT TO PREPAY i have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment. I will tell die Note Holder In writing that I am doing so. I may not designate a payment as a Prepayment if i have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that i owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the Interest or other loan charges collected or to be collected In connection with this loan exceed the permitted limits, then: (a) any. such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments if the Note Holder has nal received the full amount of any monthly payment by the end of 15 calendar days after the date It Is due, I wilt pay a late charge to the Note Holder. The amount of the charge will be 4.000 of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it Is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if i do not pay the overdue amount by a certain date, the Note Holder may require me to pay Immediately the full amount of Principal which has not been pall and all the interest that I owe on that amount. Thal date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even If, at a time when i am in default, the Note Holder does not require me to pay immediately in till as described above, the Note Holder will still have the right to do so if I am In default at a later time. MULTISTATBPAtBDRATBNOTE —SterleFaaey-Paenteldsd,raddhaMao esopoaMnaraID®Nr Po,m1200 VOI 63200-01 (0006) (Page I of2) Tnit181J:a lA0 f • • IMO (B) Payment of Nota Holder's Costs and Expenses If the Note Holder has required me to pay Immediately in full as described above, the Note Holder will have the right to be paid back by me for all of Its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me al the Properly Address above oral a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address slated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of Ibis Note, is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some Jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (tlie "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts! owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given to accordance with Section 15 within whicb Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED Pay er of: urSe Int Ai®ala Cotton/t Secretary DEANE L NEGLEY MULTISTATBFDa3DRATB34O78—sr.Nermay—rweudrnaamwevxaoauumenuneer n"rm=0uoi 0320002 (0003) (Pase2of2) (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower [Sign Original Ona] I OP 00 OM AL ALLONGE MORTGAGOR: MATTHEW A NEGLEY DEANE L NEGLEY ADDRESS OF MORTGAGOR: 646 HIGHLAND AVENUE MOUNT HOLLY SPRINGS, PA 17065 MORTGAGE AMOUNT: $ 163,250.00 NOTE DATE: 07/31/2013 WITHOUT RECOURSE PAY TO THE ORDER OF: JPMORGAN CHASE BANK, N.A. Its Assigns and/or Successors HOWARD HANNA MORTGAGE SERVICES A Pennsylvania Corporation By: (.-d' Mark D. Steele President P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only i H i U USPS CERTIFIED MAIL1'td i I 111 0 i i i i II I 9214 8901 0754 4634 0247 95 001195. 1 of 4 N090HDLA-CA 50505263 0000000 MATTHEW A NEGLEY 646 HIGHLAND AVE MOUNT HOLLY SPRINGS PA 17065 Chase (0H4-7399) P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only MATTHEW A NEGLEY 646 HIGHLAND AVE MOUNT HOLLY SPRINGS, PA 17065 NOTICE OF INTENT TO FORECLOSE MORTGAGE Account: Property Address: 646 HIGHLAND AVE MOUNT HOLLY SPRINGS, PA 17065 (the "Property") Dear MATTHEW A NEGLEY: CHASE 0 02/13/2014 Under the terms of the Mortgage or Deed of Trust ("Security' Instrument") securing your Loan, JPMorgan Chase Bank, N.A.("Chase"), as servicer of your loan, hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 11/01/2013 for the mortgage held by JPMorgan Chase Bank, National Association. 2. As of 02/13/2014, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $3,968.20 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800-848-9380. Total Monthly Payments $3,877.48 Late Fees $90.72 NSF Fees $0.00 Other Fees and Advances* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and/or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. Certified Article #: 9214 8901 0754 4634 0247 95 001195 - 2 of 4 NSPOHDLA-CA J0505263 0000000 You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 03/18/2014 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the 33 -day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee; d) Pay any reasonable late penalty, if outlined in the mortgage. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before 03/18/2014, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. Certified Article #: 9214 8901 0754 4634 0247 95 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX, AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800-848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll-free at 800-569-4287 or at www.hud.gov. Sincerely, Chase 800-848-9380 800-582-0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Certified Article 8: 9214 8901 0754 4634 0247 95 001195 - 3 of 4 NSPOHDLA-CA J0505263 0000000 IMPORTANT NOTICE TO SERVICEMEMBERS 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 Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also 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. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866-840-5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling 888 -995 -HOPE; 888-995-4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR840 Certified Article #: 9214 8901 0754 4634 0247 95 An important message : from th. ~: F: der'al: Trade Cornrnissior}: Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure! " "97% success rate! ". "Guaranteed to save your home! " These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance — and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some scammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay for a "second opinion." Certified Article 4*: 9214 8901 0754 4634 0247 95 Imitations = Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address directly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to a HUD -Certified Counseling Agency - For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov. Federal. Trade :Cbri'rizisiirl ftc.ycv/Mrii jMtatttrs 001195 - 4 of 4 NSPOHDLA-CA J0505263 0000000 Call 1 -888 -995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov Certified Article 9: 9214 8901 0754 4634 0247 95 . �$ofJf�•'rPRuuliimtp+Sar>1c^tieaw::et MAKING L: AFFORDABLE gad P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only 001202 - I of 4 NSPOHDLA-CA/0505263 0000000 MATTHEW A NEGLEY 1907 GEORGE AVE CARLISLE PA 17013 i H i Ui USPS CERTIFIED MAIL'''' 1 UI i I HI i i i II i HU 9214 8901 0754 4634 0248 25 Chase (0114-7399) P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only MATTHEW A NEGLEY 1907 GEORGE AVE CARLISLE, PA 17013 NOTICE OF INTENT TO FORECLOSE MORTGAGE Account: Property Address: 646 HIGHLAND AVE MOUNT HOLLY SPRINGS, PA 17065 (the "Property") Dear MATTHEW A NEGLEY: CHASE ! 02/13/2014 Under the terms of the Mortgage or Deed of Trust ("Security Instrument") securing your Loan, JPMorgan Chase Bank, N.A.("Chase"), as servicer of your loan, hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 11/01/2013 for the mortgage held by JPMorgan Chase Bank, National Association. 2. As of 02/13/2014, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $3,968.20 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800-848-9380. Total Monthly Payments $3,877.48 Late Fees $90.72 NSF Fees $0.00 Other Fees and Advances* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and/or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. Certified Article #: 9214 8901 0754 4634 0248 25 001202 - 2 of 4 NSPOHDLA-CA J0505263 0000000 You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 03/18/2014 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the 33 -day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee; d) Pay any reasonable late penalty, if outlined in the mortgage. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before 03/18/2014, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. Certified Article 8: 9214 8901 0754 4634 0249 25 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. • Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX, AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800-848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll-free at 800-569-4287 or at www.hud.gov. Sincerely, Chase 800-848-9380 800-582-0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Certified Article #: 9214 8901 0754 4634 0248 26 001202 - 3 of 4 NSPOHDLA-CA J0505263 0000000 IMPORTANT NOTICE TO SERVICEMEMBERS 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 Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also 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. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866-840-5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling 888 -995 -HOPE; 888-995-4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR840 Certified Article 8: 9214 8901 0754 4634 0248 25 An irTlportant .Yr1es o.ag from t'- Federal: Trade::.Ocrr rrn >.:,.ion . Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure! " "97% success rate! " "Guaranteed to save your home!" These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance — and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some scammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay for a "second opinion." Certified Article #: 9214 8901 0754 4634 0248 25 Imitations = Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address directly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to a HUD -Certified Counseling Agency - For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov. Federal. Trace .00'rrri.Jissieri.: ftc.go /Mr>l ejMatttrs 001202 - 4 of 4 NSPOHDLA-CA J0505263 0000000 Call 1 -888 -995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov Certified Article 8: 9214 8901 0754 4634 0248 25 h1F,€3l,.:. �S+Rf+cert & Cet aoi;.> 9cr %iaticawvier.: P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only i USPS CERTIFIED MAIL' i 9214 8901 0754 4634 0248 18 001197. 1 of 4 NSPOHDLA-CA/0505263 0000000 DEANE L NEGLEY 646 HIGHLAND AVE MOUNT HOLLY SPRINGS PA 17065 Chase (0H4-7399) P.O. Box 183205 Columbus, OH 43218 For Undeliverable Mail Only DEANE L NEGLEY 646 HIGHLAND AVE MOUNT HOLLY SPRINGS, PA 17065 NOTICE OF INTENT TO FORECLOSE MORTGAGE Account: Property Address: 646 HIGHLAND AVE MOUNT HOLLY SPRINGS, PA 17065 (the "Property") Dear DEANE L NEGLEY: CHASE i 02/13/2014 Under the terms of the Mortgage or Deed of Trust ("Security Instrument") securing your Loan, JPMorgan Chase Bank, N.A.("Chase"), as servicer of your loan, hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 11/01/2013 for the mortgage held by JPMorgan Chase Bank, National Association. 2. As of 02/13/2014, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $3,968.20 are past due. This past -due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at 800-848-9380. Total Monthly Payments $3,877.48 Late Fees $90.72 NSF Fees $0.00 Other Fees and Advances* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and/or permitted by applicable law, or that were authorized for services rendered. If you need additional information regarding any of these amounts, please contact us at the number provided below. Certified Article #: 9214 8901 0754 4634 0248 18 001197 -2 of 4 NSPOHDLA-CA J0505263 0000000 You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 03/18/2014 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past -due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorneys fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the 33 -day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee; d) Pay any reasonable late penalty, if outlined in the mortgage. Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before 03/18/2014, Chase may accelerate the maturity of the Loan, declare all sums secured by the Security Instrument immediately due and payable, and commence foreclosure by judicial proceeding and sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees, if permitted by law, related to any foreclosure action we initiate. Certified Article 8: 9214 8901 0754 4634 0248 18 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX, AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. 1f you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800-848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll-free at 800-569-4287 or at www.hud.gov. Sincerely, Chase 800-848-9380 800-582-0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet Certified Article It: 9214 8901 0754 4634 0248 18 001197 - 3 of 4 NSPOHDLA-CA J0505263 0000000 IMPORTANT NOTICE TO SERVICEMEMBERS 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 Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also 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. Eligible service may include: • Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or • Active service as a commissioned officer of the Public Health Service, or • Service with the forces of a nation with which the United States is allied in a war or military action, or • Service with the National Guard of a state militia under a state call of duty, or • Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866-840-5826. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling 888 -995 -HOPE; 888-995-4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR840 Certified Article 9: 9214 8901 0754 4634 0248 18 Ari portant rx ess.ige from the: Federal Trade. 'Commission sion Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications — for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure! " "97% success rate!" "Guaranteed to save your home!" These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance — and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some scammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay for a "second opinion." Certified Article 8: 9214 8901 0754 4634 0248 18 Imitations = Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address directly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to a HUD -Certified Counseling Agency - For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline — open 24/7 — is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov. eder<il. Trigle . ftc.cq�'/1,1r PjMatli rs 001197 - 4 of 4 NSPOHDLA-CA J0505263 0000000 Call 1 -888 -995 -HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD -certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov Certified Article*: 9214 8901 0754 4634 0248 18 ikki..1 • gtrspt•ra&3u14)I ar �Snnisaweist ® V.1 iviAKING -I ;; AJF :DAr L Go P.O. Box 183205 Columbus, 013 43218 For Undeliverable Mail Only 001196 - 1 of 4 NSPOHDLA-CA 00505263 0000000 DEANE L NEGLEY 1907 GEORGE AVE CARLISLE PA 17013 i H i II USPS CERTIFIED MAIL'' i II i I III I i i i i vu i 9214 8901 0754 4634 0248 01 Pennsylvania Verification Fatima Stigger , hereby states that he/she is Vice President of JPMorgan Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. dr .4( Fat a Stigger Vice President Date: 05/23/14 JPMorgan Chase Bank, N.A Borrower: Matthew Negley; Deane Negley Property Address: 646 Highland Avenue Mount Holly Springs, PA 17065 County: Cumberland Last Four of Loan Number: 5154 FORM 1 : IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff(s) : VS. Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 DEFENDANTS Defendant(s) 105s Civil rri NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court -supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. /Sh Date Respectfully submitted: SHAPIRO & DeNARDO, LLC A orn ys for Plaintiff CAITLIN NI. CONNELLY, ESQUlf FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No 0 Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? CO -BORROWER Mailing Address: City: Phone Numbers: State: Zip: Home: Office: Cell: Other: Email: # of people in household How Long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes 0 No 0 If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount Owed: Value: Automobile #2: Model: Year: Amount Owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co -Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently a in ) EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes 0 No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, named , authorize the above to use/refer this information to my lender/servicer for the sole purpose of evaluating m financial situation for possible mortgage options. I/We understand that I/We am/are under no obligation to use the services provided by the above named Borrower Signature Date Co -Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Ai Proof of any expected income for the last 45 days Ai Copy of a current utility bill Ai Letter explaining reason for delinquency and any supporting documentation (hardship letter) 'I Listing agreement (if property is currently on the market) FORM 3 : IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank, National Association : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 DEFENDANTS Defendant(s) : Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court -supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date SHERIFF'S OFFICE OF CUMBERLAND ����U K��TY COUNTY � Ronny RAnderson Sheriffcet ember! ` � �� 7„ , „ �7'^`' Jody SSmith - Richard W Stewart ����A-�i/��U ����-i �*��t�ne�mem� ^ .~� Solicitor ' -- PENNSYLVANIA JPMorgan Chase Bank, N.A. Case Number vs. 2014-3365 Matthew Anthony Nog\ey (et m\j SHERIFF'S RETURN OF SERVICE 06/09/2014 Ronny R Anderson, Sheriff, 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 Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 646 Highland Avenue, South Middleton, Mt. Holly Springs, PA 17065. Residence is vacant. 06/00/2014 10:56 AM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing atnuouopyhoepenoonvapraoanUngthomoe\veatobetheD- dant, to wit: Matthew Anthony Negley at 1907 George Avenue, North Middleton, Carlislz, P y' 013. /, .410 'TrU^ �U � . D ~UTY � 0609/2014 10:56 AM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Matthew Negley, Husband,who accepted as "Adult Person in Charge"for Deane L Negley at 1907 George Avenue, North Middleton, Carlisle, PA 17013. WI I CLINE, DEPUTY SHERIFF COST: $79.69 SO ANSWERS, p" June 10, 2014 R(]NNYRANDERSON, SHERIFF SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS 1 C")77.' --er TA G' r' COURT OF COMMON PLEA 2 CIVIL DIVISION 'mac z37 ' CUMBERLAND COUNTY NO:14-3365 7-7 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $169,925.48 in favor of the Plaintiff and against the Defendants, jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid Interest Accrued Late Charges Escrow Advances Property Inspection Attorney Fees & Costs of Foreclosure TOTAL BY: AND NOW, judgment is entered in favor of damages are assessed as above in the sum of $169,925 14-045717 aintiff and $162,757.47 $5,086.20 $90.72 $694.34 $28.00 $1,268.75 $169,925.48 Pro. rothy. wo cot, .so-aia4i ILA iqb•f-3(0A --p_4;1%16(Lup No\p-\2_ mciAA.e,4„ SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO, 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY LD. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO, 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-3365 Matthew A. Negley and Deane L. Negley DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Matthew A. Negley DATE OF NOTICE: August 8, 2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o name por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Matthew A. Negley, 1907 George Avenue, Carlisle, PA 17013 Deane L. Negley, 1907 George Avenue, Carlisle, PA 17013 Date: BY: SI-IAPIRO & DeNARDO, LLC ttorneys for Plainti SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY ID. NO, 312169 CHANDRA M. ARKEMA, ATTORNEY ID. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-3365 Matthew A. Negley and Deane L. Negley DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Deane L. Negley DATE OF NOTICE: August 8, 2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o !lame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer 'Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WI -IOM RULE 237.1 NOTICE SENT TO: Matthew A. Negley, 1907 George Avenue, Carlisle, PA 17013 Deane L. Negley, 1907 George Avenue, Carlisle, PA 17013 Date: C/5- I3Y: SHAPIRO & DeNARDO, LLC SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Matthew A. Negley and Deane L. Negley DEFENDANTS NO:14-3365 CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Matthew A. Negley, 1907 George Avenue, Carlisle, PA 17013 Deane L. Negley, 1907 George Avenue, Carlisle, PA 17013 Date Mailed: Date: 2,-91-1(J BY: SHAPIRO & DeNARDO, LLC for Plaintiff SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Matthew A. Negley and Deane L. Negley DEFENDANTS NO:14-3365 CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: JPMorgan Chase Bank, National Association 3415 Vision Drive Columbus, OH 43219 and that the last known addresses of the judgment debtors (Defendants) are: Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 Date: 14-045717 BY: SHAPIRO & DeNARDO, LLC • rneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-3365 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Deane L. Negley 1907 George Avenue Carlisle, PA 17013 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-3365 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278-6800. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS 3415 Vision Drive CUMBERLAND COUNTY Columbus, OH 43219 PLAINTIFF 14-3365 VS. Matthew A. Negley and Deane L. Negley DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Date: 63t2l 114— BY: Sworn to and subscribed before me this 2..13" day , 2014. SHAPIRO & DeNARDO, LLC Attorneys for Plaintiff CHANDRA M. ARKEMA, ESQUIRE COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Sharkey, Notary Public Upper Merlon Twp., Montgomery County My Commission Expires Oct. 19, 2014 Member. Pennsylvania Association of Notaries , Dapartment of Defense Manpower Data Center Status Report Pursuant to Servieemembers Civil. Relief Act Last Name: NEGLEY First Name: MATTHEW Middle Name: A. Active Duty Status As Of: Aug -21-2014 Results as of : Aug -21.2014 04:55:48 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .4 •••• , _ - - , No '''-, NA This response reflects the incirvidtial;:ective dory status baseti on the Active Duly Status Date 40-/ ".„ fie Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA i NA ... ..: - .:"... - ' , ' • . No NA This response reflects :vhere the individual active duty s atus Within36idais preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call•Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ,i. NA ''' 4.. ` '`. r. '.. -v'. :14o' NA This response reflects whether the indidual grtlis/her unit has received ea1y notification to report for active duty ------ - Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed ervices (Arn, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The,Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenseiink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: CCU1CA89101E060 , Department of Defense Manpower Data Center Status Report Pursuant to Se icemembers Civil Relief Act Last Name: NEC LEY First Name: DEANE Middle Name: L Active Duty Status As Of: Aug -21-2014 Results as of : Aug -21-2014 04:55:35 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA se' ,• , A• , No\. NA This response reflects the i Widuais* active duty sta. tus based on the the Active Duty Status Date r,. Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA .1 NA' -7 ----. i7P:if‘ 't 4 . 7.: .NocY 1 t NA This re ponse reflects inhere the individual ieft ectisie ctubistatu's Within67 daYSpreceding theActive Duty Status Date t7, The Member or HisMer Unit Was Notified of a FuLue Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ‘_ NA '‘, — ' ''.4. l'(:;140 NA This response reflects whether the individual of his/her unit has receiVed6Zynotification to report for active duty , ' • -,-, ....-0- • et s.• , ' - , - 7 r Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Arrn-c, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: XC1 OZA69301 E6E0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: JPMorgan Chase Bank, National Association PLAINTIFF vs. Matthew A. Negley and Deane L. Negley DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: () Confessed Judgment ther FileONo. • J3l9 s (;; Amount Due $169,925.48 rte. Interest August 1, 2014 to Decem1 r 30 -f } 2014 is $2,182.25 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described,in the attached exhibit. Date: 19.to q "-Pcs c L.�tk I�Pua3l�(�� 2_1;60,)),oltiete WcikoPERE., Ts'veGi tL4i a r- 1. Signature: Print Name: B . 4. J Osborne Address: 3 ,06 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 312169 �aa ALL THAT CERTAIN lot or piece of ground situate in South Middleton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point 100 feet South of the intersection of the Eastern line of Highland Avenue and the Southern line of Mountain View Drive as shown on the hereinafter Plan of Lots, said point being in the Eastern line of Highland Avenue and the dividing Iine between lots numbered 39 and 40 on said Plan; thence Eastwardly by the dividing line between lots numbered 39 and 40 on said Plan, 150 feet to a point on the Western line of lot number 75 on said Plan; thence Southwardly by the Western line of lot number 75 on said Plan 100 feet to a stake; thence Westwardly by the dividing line between lots numbered 41 and 42 on said Pian, 150 feet to a point on the Eastern line of Highland Avenue; thence in a Northerly direction by the Eastern line of Highland Avenue, 100 feet to a point, the place of beginning. HAVING erected thereon a one-story dwelling known as 646 Highland Avenue, Mt. Holly Springs, PA 17065. PARCEL No. 40-31-2187-023 BEING the same premises which Paul R. Delvitto and Theresa P. Delvitto, husband and wife, by Deed dated July 15, 2013 and recorded August 2, 2013 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201325570, granted and conveyed unto Matthew A. Negley and Deane L. Negley, husband and wife. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS 2014 AUG 22 AN . 28 PE�RS/YLY NIA' COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-3365 AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, National Association, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 646 Highland Avenue, Mount Holly Springs, PA 17065. 1. Name and address of Owner(s) or Reputed Owner(s) Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Deane L. Negley 1907 George Avenue Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, National Association 3415 Vision Drive Columbus, OH 43219 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, National Association 3415 Vision Drive Columbus, OH 43219 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 646 Highland Avenue Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. .41PIRO & DeNARDO, LLC BY: ey J Osborne 14-045717 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 c KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 r'rn S & D FILE NO. 14-045717 r r,) JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY 7:-(2 Matthew A. Negley and Deane L. Negley DEFENDANTS NO: 14-3365 - NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew A. Negley 1907 George Avenue Carlisle, PA 17013 Your house (real estate) at: 646 Highland Avenue, Mount Holly Springs, PA 17065 40-31-2187-023 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:OOAM to enforce the court judgment of $169,925.48 obtained by JPMorgan Chase Bank, National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, National Association the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 14-045717 r ALL THAT CERTAIN lot or piece of ground situate in South Middleton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point 100 feet South of the intersection of the Eastern line of Highland Avenue and the Southern line of Mountain View Drive as shown on the hereinafter Plan of Lots, said point being in the Eastern line of Highland Avenue and the dividing line between lots numbered 39 and 40 on said Plan; thence Eastwardly by the dividing line between lots numbered 39 and 40 on said Plan, 150 feet to a point on the Western line of lot number 75 on said Plan; thence Southwardly by the Western line of lot number 75 on said Plan 100 feet to a stake; thence Westwardly by the dividing line between lots numbered 41 and 42 on said Plan, 150 feet to a point on the Eastern line of Highland Avenue; thence in a Northerly direction by the Eastern line of Highland Avenue, 100 feet to a point, the place of beginning. HAVING erected thereon a one-story dwelling known as 646 Highland Avenue, Mt. Holly Springs, PA 17065. PARCEL No. 40-31-2187-023 BEING the same premises which Paul R. Delvitto and Theresa P. Delvitto, husband and wife, by Deed dated July 15, 2013 and recorded August 2, 2013 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201325570, granted and conveyed unto Matthew A. Negley and Deane L. Negley, husband and wife. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS c COURT OF COMMON PLEA cS`.. v ©E , CIVIL DIVISIONr— CUMBERLAND COUNTY 33; c-) cp �^ NO: 14-3365 v 1 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Deane L. Negley 1907 George Avenue Carlisle, PA 17013 Your house (real estate) at: 646 Highland Avenue, Mount Holly Springs, PA 17065 40-31-2187-023 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:OOAM to enforce the court judgment of $169,925.48 obtained by JPMorgan Chase Bank, National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, National Association the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 14-045717 ALL THAT CERTAIN lot or piece of ground situate in South Middleton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point 100 feet South of the intersection of the Eastern line of Highland Avenue and the Southern line of Mountain View Drive as shown on the hereinafter Plan of Lots, said point being in the Eastern line of Highland Avenue and the dividing line between lots numbered 39 and 40 on said Plan; thence Eastwardly by the dividing line between lots numbered 39 and 40 on said Plan, 150 feet to a point on the Western line of lot number 75 on said Plan; thence Southwardly by the Western line of lot number 75 on said Plan 100 feet to a stake; thence Westwardly by the dividing line between lots numbered 41 and 42 on said Plan, 150 feet to a point on the Eastern line of Highland Avenue; thence in a Northerly direction by the Eastern line of Highland Avenue, 100 feet to a point, the place of beginning. HAVING erected thereon a one-story dwelling known as 646 Highland Avenue, Mt. Holly Springs, PA 17065. PARCEL No. 40-31-2187-023 BEING the same premises which Paul R. Delvitto and Theresa P. Delvitto, husband and wife, by Deed dated July 15, 2013 and recorded August 2, 2013 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201325570, granted and conveyed unto Matthew A. Negley and Deane L. Negley, husband and wife. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. NO 14-3365 Civil Term CIVIL ACTION — LAW MATTHEW A. NEGLEY AND DEANE L. NEGLEY WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfythe judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $169,925.48 L.L.: $.50 Interest AUGUST 1, 2014 TO DECEMBER 3, 2014 IS $2,182.25 Atty's Comm: Atty Paid: $228.44 Plaintiff Paid: Date: 8/22/14 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary (Seal) By Deputy REQUESTING PARTY: Name: BRADLEY J. OSBORNE, ESQUIRE Address: SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 312169 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144 SARAH K. McCAFFERY, ATTORNEY I.D. NO, 311728 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045717 JPMorgan Chase Bank, National Association PLAINTIFF VS. Matthew A. Negley and Deane L. Negley DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:14-3365 CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, JPMorgan Chase Bank, National Association, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on October 8, 2014, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Date: 14-045717 By: SHAPIRO & DENARDO, LLC Meghan Williams Legal Assistant w ; U.S. POSTAGE »»PITNEYBOWES 010,01, Name and Address of Sender Shapiro & DeNardo, LLC 3600 Horizon Drive Suite 150 King of Prussia, PA 19406 Check type of mail or service: 0 Certified 0 Recorded Delivery (International) ❑COD 0 Registered 0 Delivery Confirmation CIReturn Receipt for Merchandise ❑ Express Mail 0 Signature Confirmation ❑ Insured Affix Stamp Here -T=`1.. };.,. • i (If issued as a jz: . '#!t 'r'ji certificate of mailing, '' ZIP 19406 or for additional_' 02 1lN copies of this bill) { ' . 0001387362 Postmark and Date of Receipt �__ i, 2014, ��� oo1.41 OCT. 08. Article Number Addressee (Name, Street, City State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee • 14-045717 MW Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 Tenant or Occupant Highland Avenue Mount Holly Springs, PA 17065 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 2646 3. pA: � . g� O UJ \QO o as Sai 5. onfirmation Special Handling II T a 1 T 15 V Fj 6. Q O 7. t}:, is 0 U Sinature C� 8. a.) Total Number of Pieces Listed by Sender 3 Total Number Pieces Received at POffice Postmaster, Per (Name o " " e loyee) See Privacy Act Statement on Reverse orm 3877, February 2002 (Page 1 of 1) Complete by Typewriter, Ink or Ball Point Pen