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Home My WebLink About14-3381 Supreme Cour t_of Pennsylvania Court cif COIL ifion Pleas 11"i1'CQ`'ei'Sheet For Protllonotat�t�Use,On Tv: f CU'MberlAn'1 Count. Doc)•:Et�To: r The information collected on this form is used solely for court administration pwposes. This form does not Supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: JPMC SPECIALTY MORTGAGE LLC F/K/A WM TAMARA R.YOST C SPECIALTY MORTGAGE LLC T I Dollar Amount Requested within arbitration limits O Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits 1 Is this a.Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group,P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation 5 ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other 1E mass tort) ❑ Employment dispute: ❑ Slander/Libel.Defamation Discrimination ❑ Employment Dispute:Other ❑ Other ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 s KML LAW GROUP,P.C. SUITE 5000-BNY MELLON INDEPENDENCE CENTER t [. `i t+ ' 701 MARKET STREET PHILADELPHIA,PA 19106 `�1 - 2 3 J s (866)413-2311 WWW_KMId,AWGRniiP.COM A r � f rni1,.J .r JPMC SPECIALTY MORTGAGE LLC F/K/A'Wlv"E t�N S YL '°M�i'j A IN THE COURT OF COMMON PLEAS SPECIALTY MORTGAGE LLC 3415 Vision Drive OF Cumberland COUNTY Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs. TAMARA R. YOST ACTION OF MORTGAGE FORECLOS Mortgagor(s)and Record Owner(s) ti ? P( lvt 168 West Middlesex Drive �,l VIL ACTION:MORTGAGE Carlisle,PA 17013 FV OS+M Defendant(s) 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 the 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 claim in the Complaint of 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 C� 74i-?90S AVISO %(W8a Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://w\vw.pbiladelpla_iafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(akmll.awgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 13087817C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC, 341.5 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is/are TAMARA R. YOST, 168 West Middlesex Drive, Carlisle, PA 17013,who is/are the mortgagor(s)and record owner(s) of the mortgaged premises hereinafter described. 3. On April 19, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY AS NOMINEE FOR ACCREDITED HOME LENDERS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on April 25, 2006 as Book 1947,Page 4611. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC by assignment of Mortgage recorded on September 28, 2007 as Instrument No. 200737644. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for November 01, 2013 and each month thereafter and by the terms of the Mortgage,upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of May 9, 2014: Principal Balance........................................................................................$156,790.77 Interest from 10/01/2013 through 04/30/2014 .............................................$7,773.29 Accrued Late Charges.....................................................................................$4,008.24 EscrowAdvance .............................................................................................$2,892.59 PropertyInspections...........................................................................................$126.00 Reasonable Attorney's Fee.............................................................................$1,650.00 $173,240.89 7. If the Mortgage is reinstated prior to a Sheriff's Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further,Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing,title searches,recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability(or an"in personam'judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit"B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff,the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$173,240.89, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: Qr� KML LAW GROV Michael Mc eever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Va lykL. Oflazian Pa. ID 312912 lvatore Filippello Pa. ID 313897 nnifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Pennsylvania Verification Lauren Green , hereby states that he/she is Vice President of JPMC Specialty Mortgage LLC 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. 4Lur en Green Vice President Date: 05/20/14 JPMC Specialty Mortgage LLC Borrower: Tamara Yost Property Address: 168 W Middlesex Dr. Carlisle, PA 17013 County: Cumberland Last Four of Loan Number:3435 Eyh i 6 i t A ALL that certain tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of North Middlesex Road at corner of lands now or formerly of Calder Clemson; thence by the center line of said North Middlesex Road, North 84 degrees 30 minutes East 323 feet, more or less, to corner of lands now or formerly of George Hinda; thence by said lands now or formerly of George Hinda and lands now or formerly of Raymond A. and Gladys I. Smyser, his wife, South o5 degrees 30 minutes West 845 feet, more or less, to a point in line of lands now or formerly of Calder Clemson; thence by said lands now or formerly of Calder Clemson, South 86 1/2 degrees West 338 feet, more or less, to a point; thence by the same, North 6 1/2 degrees East 841.5 feet to a point, the place of beginning. BEING known and designated as Tax Parcel No. 21-06-0017-018 in the Deed Registry office of Cumberland County, Pennsylvania. EXHIBIT "A" i Ct rkify this to be recorded In Cumberland County PA Recorder of Deeds ON1947PG4630 Ey, hibit *Exhibit has been redacted to remove allpersonally identifiable information or non-public information Chase(0114-7399)-7399) CHASE o i P.O.Box 1.83205 Columbus,OH 43218 For Undeliverable Mail Only 10/31/2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 007638-1 of 4 NSPOHDLA-ZA J0449441 0000000 TAMARA YOST 168 W MIDDLESEX DR CARLISLE,PA 1701378495 Act 91 Notice Account: ******3435 (the "Loan") Property Address: 168W MIDDLESEX DR CARLISLE,PA 17013 (the "Property") Dear TAMARA YOST: On the following page,you will find a notice regarding your home as required by Pennsylvania law. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is Provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help,you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (33� DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies servingyourCounty are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 800-342-2397. (,Persons with impaired hearing can call 717-780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): TAMARA YOST PROPERTY ADDRESS: 168W MIDDLESEX DR CARLISLE,PA 1701.3 LOAN ACCOUNT NUMBER: 0690953435 ORIGINAL LENDER: ACCREDITED HOME LENDERS,INC.,A CALIFORNIA CORPORATION CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30)days from the date of this Notice (plus three (3)days for mailing). During that time,you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE(33) DAYS OF THE DATE OF THIS NOTICE.IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty (30)days after the date of this meeting. The names,addresses.and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting.Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To-do so,you must fill out, sign,and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE HEMAPAPPLICATIONASSOONASPOSSIBLE IF YOUHAVEA MEETING WITH CO UNSELING A GENCY WITHIN THIRTY-THREE(33)DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN THIRTY(30)DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE A CTIONA GAINST YOUR PROPERTY,AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOUHAVE THE RIGHT TO FILE HEMAP APPLICA TION EVEN BEYOND THESE TIME PERIODS.A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSUREACTION,BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED ATANY TIME BEFOREA SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 007638-2 of 4 NSPOHDLA-ZA J0449441 0000000 AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60)days to make a decision after it receives your application. During that time,no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date . NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located at: 168W MIDDLESEX DR, CARLISLE,PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 09/01/2013 $1,769.32 10/01/2013 $1,769.32 Other charges: Late Charges: $3,694.56 Insufficient Funds(NSF)Fees: $25.00 Other Fees: $0.00 Advances: $126.00 Amount Held in Suspense: $688.38 TOTAL AMOUNT PAST DUE: $6,695.82 HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS $6,695.82, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)-DAY PERIOD.Payments must be made by cash.cashier's check,certified check or monev order made payable and sent to: Ovemight/Regular Mail: Chase Mail Code: OH4-7133 3415 Vision Drive Columbus,OH 43219-6009 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30) DAYS of the date of this Notice,the lender intends to exercise its rights to accelerate the mortgage debt.This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY(30)DAYS,the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to $50.00.However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. If you cure the default within the THIRTY (30)-DAYen riod• you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time un to one hour before the Sheriff's Sale You may do so by pgying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale- and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Chase Address: Mail Code: OH4-7384 P.O. Box 41275 Jacksonville,FL 32203-1275 Telephone Number: 800-848-9380 Fax Number: 614-500-4605 Contact Person: Bruno Mejia E-mail Address: state.programs.intake@jpmchase.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges,and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 007638-3 of 4 NSPOHDLA-ZA J0449441 0000000 YOU MAY ALSO 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY PHONE ADDRESS CITY ZIP CODE Advantage Credit Counseling 888-511-2227 2000 Linglestown Road Harrisburg 17102 Service/CCCS of Western PA Community Action Commission of 717-232-9757 1514 Derry Street Harrisburg 17104 Capital Region Housing Alliance of York/Y Housing 717-855-2752 290 West Market Street York Resources 17401 Maranatha 717-762-3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community 717-334-1518 40 E.High Street Gettysburg 17325 Programs,Inc. PHFA 717-780-3940 211 North Front Street Harrisburg 17110 800-342-2397 007638-4 of 4 NSPOHDLA-ZA J0449441 0000000 1 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. 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 877-469-0110. 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 PreventLoan Scam s.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. BW860 Exhibit *Exhibit has been redacted to remove allpersonally identifiable information or non-public information P ' Prepared By and Return To: Michael Smith GOLDBECK McCAFFERTY&McKEEVER Mellott Independence Center-Suite 5000 •701 Market Street Philadelphia,PA 19106-1532 215-627-1322 GMM File Number:53173FC Parcel ID#: 21-06-0017-018 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.ACTING SOLELY AS A NOMINEE FOR ACCREDITED HOME LENDERS,INC. (Assignor), for and inconsideration of the sum of Ten Dollars($10.00)and other good and valuable consideration, the receipt of which is acknowledged,does grant,bargain, sell,assign and transfer to WM SPECIALTY MORTGAGE LLC. WM SPECIALTY MORTGAGE LLC (Assignee), all of its right,title and interest,as holder of,in,and to the following described mortgage,the property described and the indebtedness secured by the mortgage: Executed TAMARA R.YOST ,Mortgagor(s);to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.ACTING SOLELY AS A NOMINEE FOR ACCREDITED HOME LENDERS, INC.. Bearing date of:April 19,2006;Amount Secured:$170,000.00;Recorded on April 25,2006;in Book 1947,Page 4611;in the Recorder of Deeds Office of Cumberland County,Commonwealth of Pennsylvania("Mortgage") Property: 168 W.Middlesex Drive,Carlisle,PA 17013 AS FURTHER DESCRIBED IN EXHIBIT"A",ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or.obligation described in the Mortgage endorsed to the Assignee,("Note")and all moneys due and to become due on the Note and Mortgage,with interest. Assignee its successors,legal representatives and assigns shall hold all rights under the Note and Mortgage forever,subject however,to the right and equity of redemption,if any,of the maker(s)of the Mortgage,their heirs and assigns forever. Assignor,by its appropriate corpo to officers ase uted and sealed with its corporate seal this Assignment of Mortgage on this ? day of 2007. I MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.ACTING SOLELY AS A NOMINEE FOR ACCREDITED HOME LENDERS,INC. (Affix Corporate Seal) (SEAL) Name: ' !l lam= ' ! ( n Title.V _ (SEAL) Name: "J Title: �� ss: �A STATE OF )COUNTY OF Jul ) BE IT REMEMBERED,that on this l day of 2007,before me,the subscriber,a Notary Public personally appeared ' (•it•b'.A Rry:s�r_1'I99w.(� '_e'L iu- (tC(�<.� c� {�:a+-C •'..s/<!S ,y officers of Assignor,who I am satisfied are the persons who signed the wi ins ent and they acknowledged that they signed,sealed with the corporate seal and delivered same as such officers aforesaid,and that the within instrument is the voluntary act and deed'of sue corporation made by virtue of a Resolution of its Board of Directors. Notary Pu ib A � e% My commission expires: I hereby certify the address of the Assignee is: 7255 ado Wa Jacksonville,FL 32256 Loan No. . 5 Case#:53173 FC Ex�rk S�yRMr5siD 30 TA ^�-.-.�;�,zoos e ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC l.� 1 �� Case No. ) /'3 / ctz �� ` 13 �.. Plaintiff f =, 't r~' TAMARA R.YOST '� r Defendant(s) 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 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. Respect M bmi d: C (Signa"e f&unvsel for Plaintiff) 6/4/2014 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common ideas Docket# 13ORROWF-R REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance,your lender roust consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s), Property Address: City State: Zip.- Is the property for sale? Yes No Listing date: Price: S Realtor Marne: Realtor Phone: Borratrer Occupied? Yes 0 No Mailing Address(if different): ' City: State: Zip: Phone Numbers: lHome: Office, Cell: Other: Email of people in household: How Iong? Mailing Address; City: State: Zip: Phone Numbers: Hoene: Office: Cell: Other: Email: #ofpeople in household: Haw long? FINANCIAL [Nr. jl�JATIQN First Mortgage Under: 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[D 1 If yes,provide names,location of court,case nuunber&attorney:�_ T 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 Namc of Employers: 1. 2. 3, . Additional Income Description(not wages): 1. monthly amount: 2._^ x monthly amount: Borrower Pay hays: Co-Borrower Pay Days: Monthly Expenses (.Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgagp. . Food 2` Mort a es Utilities Car l?a ent s Condo/Nei Pees Auto Insurance Med. not covered Auto fuel/re airs Other prop.payment install.Loan Payment Cable TV Child Su rtlAlirn. S ndin Mone s 13 y1Ch lil Carel°Tt it Other Expenses Amount Available for Monthly Mortgage Payments Based on Tocorne&Expenses. Have you been working with a lousing Counseling Agency? Yes El No El If yes,please provide the following information: Counseling Agency:. . Counselor: Phone.(Oflice): _ Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program ,(HEMAP)assistance? Yes-Ej 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 fallowing information, if know, regarding your lender or leader's loan servicing company: Lender's Contact(Nance): Phone, Servicing Company (Name): Contact: Phone: authorize the above named to uselrefer this information t<)my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. Me understand that I/we am/are under no obligation to use the services provided by the above narned 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 Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(if propert: ,y is currently on, the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �t Cx�1rairct. � Jody S Smith "; . 1 t t i Chief Deputy Richard W Stewart , IMBERLA; COs Solicitor ,c P ENNSYLWA I:\ JPMC Specialty Mortgage, LLC Case Number vs. 2014-3381 Tamara Renee Yost SHERIFF'S RETURN OF SERVICE 06/11/2014 09:04 PM- Deputy Amanda Ebersole, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tamara Renee Yost at 168 W. Middlesex Road, Middlesex Twp, Carlisle, PA 17013. kW"CIDIE1101/ AMANDA EBERSOLE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, June 12, 2014 RONIW R ANDERSON, SHERIFF In the Court of Common Pleas of Cumberland County JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 vs. TAMARA R. YOST (Mortgagor(s) and Record Owner(s)) 168 West Middlesex Drive Carlisle, PA 17013 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 14-3381 civil -r rri � c T (v rz GCD wo C) -ir THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against TAM Assess damages as follows: Debt Interest from 5/1/2014 to Date of Sale per diem at $36.62 Total (Assessment of Damages attached) R. YOST by default for want of an Answer. $173,240.89 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days irior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 90, By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 _Jay E. Kivitz Pa. ID 26769 _Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 _Salvatore Filippello Pa. ID 313897 _Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa ID 316160 Attorneys for Plaintiff it 11UU4 AND NOW t,�C �' j+ , Judgment is entered in favor of JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC and against TAMARA R. YOST by default for want of an Answer and damages asses ed in ,240.89 as the above certification. Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 TAMARA R. YOST (Mortgagors and Record Owner(s)) 168 West Middlesex Drive Carlisle, PA 17013 Plaintiff vs. Defendant(s) No. 14-3381civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothonotary By- Deputy If you have any questions concerning the above, please contact: KM, Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 ..... • • 7 : ' : ' • ' --------- •:1 • -- ----- • - , 130878 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT .._...0W.ED. TO.OUR,CLIENT. ANY INFORMATION OBTAINED. FROM YOU WILL. BE USED FOR.PIE. _ PURPOSE OF COLLECTING THY, DEBT. TO: TAMARA R. YOST YOST, TAMARA R. 168 West Middlesex Drive Carlisle, PA 17013 JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. TAMARA R. YOST (Mortgagor(s) and Record Owner(s)) 168 West Middlesex Drive Carlisle, PA 17013 Defendant(s) TO: TAMARA R. YOST 168 West Middlesex Drive Carlisle, PA 17013 DA IE OF THIS NOTICE: August 14, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-3381civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EN1ER 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 BEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS 01•1 -ICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: . I KML LAW P 1 P.C. Michael Mc eever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 1,Iennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC vs. TAMARA R. YOST Plaintiff Defendant(s) NO. 14-3381civil VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): TAMARA R. YOST, has a last known residence of 168 West Middlesex Drive, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the inforrnation provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date it4 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56P9 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Depart Pursuant to Servicemembers Civil Relief Act Last Name: YOST First Name: TAMARA Middle Name: R. Active Duty Status As Of: Sep -18-2014 Results as of : Sep -16-2014 04:16:15 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 No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects where the individual left active duty status within 367 days 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 Dale Order Notification End Date Status Service Component NA NA No - NA This response reflects whether the individual or hislher unit has received early 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 Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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/pis1PC09SLDR.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 (NOAA 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: IDR4H9F7F08FM60 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 vs. TAMARA R. YOST (Mortgagor(s) and Record owner(s)) 168 West Middlesex Drive Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 14-3381civil ORDER FOR JUDGMENT Please enter Judgment in favor of JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC, and against TAMARA R. YOST for failure to file an Answer in the above action within (20) day from the date of service of the Complaint, in the sum of $173,240.89. KML LAW GROUP, P.C. Michael McKeever Pa. ID Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 ).Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 and that the name(s) and last known address(es) of the Defendant(s) is/are TAMARA R. OST, 168 West iddlesex D J arlisle,17013; By: J. KML LAW GROUP, P.C. Michael McKeever Pa, ID 5 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 10/01/2013 through 04/30/2014 Reasonable Attorney's Fee Accrued Late Charges Escrow Advance Property Inspections AND NOW, this 14-338 1 civi1/130878FC $156,790.77 $7,773.29 $1,650.00 $4,008.24 $2,892.59 $126.00 $173,240.89 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 ,C, Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff day of , 2014 damages are assessed -as above. Pro Prothy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 vs. TAMARA R. YOST Mortgagor(s) and Record Owner(s) 168 West Middlesex Drive Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 14-3381civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: 11):3 -CO 34. i8 C2F 14 • Sb(t s CCS • Amount Due Interest from 5/1/2014 to Date of Sale per diem at $36.62 (Costs to be added) sg. p sl)LAA 6. e 77763/ 2,1)Rel By: $173,240.89 ND N.) C=) KML LAW GROUP, P.C. Michael McKeever Pa. ID 5 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa, ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa, ID 92382 4,e_Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff 'If(E1o Isr cl 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 JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC Vs. NO 14-3381 Civil Term CIVIL ACTION — LAW TAMARA R. YOST WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the 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: $173,240.89 L.L.: $.50 Interest FROM 5/1/2014 TO DATE OF SALE PER DIEM AT $36.62 Atty's Comm: Atty Paid: $183.53 Plaintiff Paid: Date: 9/22/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 313897 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 vs. TAMARA R. YOST (Mortgagor(s) and Record Owner(s)) 168 West Middlesex Drive Carlisle, PA 17013 Plaintiff iF PROTHONO-TAh'; 2(714 SEP 22 AN le: 20 CUMBFRLAND CO PE UNTY YLV Defendant(s) COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 14-3381civil AFFIDAVIT PURSUANT TO RULE 3129 JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC , Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 168 West Middlesex Drive Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): TAMARA R. YOST 168 West Middlesex Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: TAMARA R. YOST 168 West Middlesex Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 WM Specialty Mortgage LLC 9451 Corbin Avenue, Northridge, CA 91324 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 168 West Middlesex Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my 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. DATED: //— Bv: iS KML LAW GROUP, P.C. /7 Michael McKeever Pa. ID ' .1 ' 9 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff ' THE OH Z0r�4SEP 22 �O�t�f, IC: 20 CUNCERL PENpjSAND COUNTY t JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 3415 Vision Drive Columbus, OH 43219 vs. TAMARA R. YOST Mortgagor(s) and Record Owner(s) 168 West Middlesex Drive Carlisle, PA 17013 14-3381civil IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s Docket No. 14-3381civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: YOST, TAMARA R. TAMARA R. YOST 168 West Middlesex Drive Carlisle, PA 17013 Your house at 168 West Middlesex Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $173,240.89 obtained by JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC 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 to JPMC SPECIALTY MORTGAGE LLC F/K/A WM SPECIALTY MORTGAGE LLC , the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 14-3381civil 3. You may also 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 below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of Cumberland County at 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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. 6. 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 within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 14-3381civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 130878FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344.