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HomeMy WebLinkAbout14-3305 t Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County IV,, The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the sling and service of leadin s or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: JPMorgan Chase Bank, Lead Defendant's Name: William L. Woodside,Jr. C National Association T Dollar Amount Requested: D within arbitration limits I Are money damages requested?: ❑ Yes ® No (Check one) ® outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A 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 PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability(does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other F-1 Zoning Board C F] Other: T ❑ Other: I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated I/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.N0. 203437 3600 HORIZON DRIVE, E 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY vs. ; 33os C., �; NO: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 DEFENDANTS 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 TELEPIIONE 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. (2) a�A4 tE 12,X -I)A- 2 r3o ��� I 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. r NOTICIA LE HAN DEMANDADO A LISTED 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 O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O 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 O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 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 Mortgageit, Inc., its successors and assigns Mortga gEW: William L. Woodside, Jr. (b) Date of Mortgage: June 30, 2008 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Document ID#200822392 Date: July 1, 2008 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 Mortgageit, Inc., its successors and assigns Assignee: JPMorgan Chase Bank, National Association Date of Assigmnent: March 1, 2012 Recording Date: April 3, 2012 Instrument No.: 201209487 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 either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property that is subject to the Mortgage is generally known as 219 West Pine Street, Mount Holly Springs, PA 17065 and is more specifically described as attached as part of Exhibit "A". 4. William L. Woodside, Jr. 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: William L. Woodside, Jr., 219 West Pine Street, Mount Holly Springs, PA 17065. 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 September 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 $85,476.86 Interest Currently Due and Owing at 6.75% $4,327.29 From August 1, 2013 through April 30, 2014 Late Charges $202.01 Escrow Advances $197.19 Property Inspection $70.00 TOTAL $90,273.35 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. 1 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. Notice pursuant to the Homeowners'Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq.,was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Copies of the material part of the Notice are attached hereto as Exhibit "C" in accordance with Pa.R.C.P. 1019(i). 12. Pursuant Pa.R.C.P. 1019(d), the Notice sent to the Defendant(s) contains the information required by the act of March 14, 1978 (P.L. 11,No. 6), 41 P.S. § 403 et seq., and separate Notice of Intention to Foreclose is not required. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant 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 Promissory Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO &DeNARDO, LLC Date: BY: Attorneys for Plaintiff S & D File No. 14-045619 CHRISTOPHER A.DeNARDO,ESQUM Prepared By: STEPHANIE RALSTON,CLOSER 1360 DEMING WAY 3RD FLOOR MIDDLETON WI 53662 Return To: MORTGAGEIT 1360 DEMING WAY, 3RD FLOOR MIDDLETON,WI 53562 Parcel Number:40-32-233 4.053 Premises: 219 WEST PINE STREET,MT HOLLY SPRINGS, PA 17065 I3p400 Above This Lino For Reoording Dahl MORTGAGE DEFINITIONS Words used In multiple sections of this document are defined below and other words are defined In Sections 3, 11, 13, 18, Zo and 21. Certain rules regarding the usage of words used In this document are also provided In Section 16. (A)"Seourity Instrument"means this document,which is dated JUNE 30,2008 together with all Riders to this document. (B)"Borrower"is WILLIAM L.WOODSIDE,JR.,SOLE&SEPARATE PROPERTY Borrower is the mortgagor under this Security.Instrument. (C) "MFRS" Is Mortgage Electronic Registration Systems, Inc. MERS is It separate corporation that Is acting solely as a nominee for Lender and Lender's successors and asstgm. MFRS is the mortgagee under this Seourity Instrument. MERS Is organized and existing under the laws of Delaware,and has an address and telephone number of P.O.Box 2026,Flint MI 48501-2028,tel. (886)879-MFRS. fotf.k PENNSYLVANIA-Single Fomily-Fannie Mae/Freddle Mao UNIFORM INSTRUMENT WITH MFRS Form 30311 1101 V-BA(PA)(07ospi Past I of to LENDER SUPPORT SYSTEMS,INC.NERSOAPA.NEW(10107) � b � � x � (D)"Lender"Is MORTGAGEIT, INC Leader Is a CORPORATION organized and existing under the laws of NEW YORK Lender's address is 33 MAIDEN LANE,6TH FLOOR, NEW YORK, NY 10036• (13)"Noto"means the promissory note signedby Borrower and dated JUNE 30, 2008 The Note states that Borrower owes Lender NINETY ONE THOUSAND THREE HUNDRED FIFTY AND NO/100 X X X X X X X X X X X X Dollars (U.S.$ 91,380,00 )plus interest.Borrower has promised to pay fhrs debt In regular Periodic Payments and to pay the debt in full not later than JULY 01, 2030 (F)"Property" means the property that Is described below under the heading "Transfer of Rights in the Property." (0)"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, (M "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): Q Adjustable Rafe Rider Q Condominium Rider 14 Family Rider �] Graduated Payment Rider © Planned Unit Development Rider Q Biweekly Payment Rider Q Balloon Rider Q Rate Improvement Rider Q Second Home Rider [] Other(s) [specify] VA RIDER (ID "AppTioablo Law" means all controlling a pliceble federal, state and local statutes, reggulations, ordinances and administrative rules and orders(that have the effect of law) as well as all epplleabIt final, non-appealable Judicial opinions. (,1)"Community A9sociahon Duos,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 shWW organization. (K) "Electronio Funds Transfer" weans 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 iransuctlons, transfers Initiated by telephone, wire transfers, and automated clearinghouse transfers, (L)"Escrow Items"means those nems that are described In Section 3. — (M)"Misoellaneous Proomda"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: (Q damage to, or destruction of, the Property; (il) condemnation or ether taking of all or any part of the jal erty; illi) conveyanceInlienofondemnation; or (ivmisrepresentations of, or emissions as to, the ue and/or condition ofperty,"Mortg6��Insuraaae" me InsurancepratactlagLender against the nonpayment of, or default on,LePeriodiaPayment" meansthe regularly scheduled amount duefor(t)principal and interest under the te,plus(It)any amounts under Secl on 3 of this Security Instrument. i I"e41c V-6A(PA)(oToeLot Pse*2 of 18 Form 3039 1101 (P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq)and Its Implementing regulation, Regulation X (24 C.F,R. Part 3500), as they might be amended from time to tlme, 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(hat are Imposed In regard to a"federally related mortgage loan" even If the Loan does not qualify as a "federally related mortgage loan"under ESPA. arty noot thatpartyhas assumed Borrower's obligationsaunde tfie Note has this Security Instrument. ropur Property, or TRANSFER OF RIGHTS IN THE PROPERTY shv This Security Instrument secures to Lender:(1)the repayment of the Loan,and all renewals,extensions and modifications of the Note; and (it) 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 Lander and Lender's successors and assigns) and to the successors and assigns of MERS,the following described property located In the COUNTY pWo of Recording,iurtsdiction) of CUMBERLAND .(Name of Recording Ndsdieaooi: SEE COMPLETE LEGAL DESCRIPTION DESCRIBED IN EXHIBIT"A"ATTACHED HERETO AND MADE A PART HEREOF which currently has the address of 219 WEST PINE STREET (stroe►i MT HOLLY SPRINGS (Caul ,Pennsylvania 17065 IZ►v Code] ("Property Address"): TOGETHER WITH all the Improvements now or hereafter erected oa the property, and all easements, appurtenances, and fixtures now or hereafter a part of the properrtyty. All replacements and additions shall also be covered by this Security Instrument, All of the foreggo�fn�g Is referred to in this Security Instrument m the"Property." Borrower understands end agrees that MEFiS holds only legal title to the Interests ranted by Borrower in this Security Instrument, but, if accessary to comply with law or custom,MER!Jas nominee for Lender and Lenders successors and assigns)has e.right: to exercise any or all of thoso Interests,.tncluding, but not limited to,the rlgk�t to foreclose and sell the Property;and to tette any action required of Lender Including, but not limited to, releasing and canceling this Security Instrument. laattY V-CA(PA)(ovoe).os rag.a s a Form 3039 1 T01 t i BORROWER COVENANTS that Borrower Is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Properly and that the Property is uneucwnbered, 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, Interost, Escrow Items, Prepayment Charges, and Lata 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 tinder the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Nate 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 4(the location designated in the Note or at such other location as may be designated by Leader in accordance With the notice provisions in Section 15, Lender may return any payment or partial payment it the payment or partial payments 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 here►mder 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 unappiled 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 Seaton 2, all payments accepted and applied by Leadet-shall be applied in the following order of priority: (a) Interest due under the Note: (b) principal due under the Note; (c) amounts duo 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. If Lender receives a payment from Borrower for a delinquent Periodic Payment which Includes a suMclent 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 aye V-6A(FA)(e70G)A1 Page+a1e Rrm3039 Val 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 Beorow Items. Borrower shall pay to Lender on the day Periodic Payments are due under(he 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 it Ilea or encumbrance on the Property; (b) leasehold payments or ground rents 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 Leader 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 ell 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 0 and pay such amount and Borrower stall 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 ore insured by a federalency. — 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 paid on t11e 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 uwra• V-OA(PA)(oioe),ot Paas 3 at to Form 3030 1101 , shall be paid on the Funds. Leader 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 shalt notify Borrower as required by RESPA, and Borrower shall pay to Leader 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,Lendershall 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; Lions. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Properly which can attain priority over this Security Instrument, lensebold 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 9, 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 lion 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 Properly is subject to a lien which can attain priority over this Security Instrument,Lender may give Borrower a notice iden*ing 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 vetlflcatlon and/or reporting service used by Lender In connection with this Loan. 5, Property Insuranoe. 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 Leader requires Insurance. This insurance shall be maintained in the amounts (Includlag 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 i require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone - 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 wllh the review of any flood zone determination resulting from an objection by Borrower. _ 3 RAW V-GA(FA)(woe).oi hge e of 1e Form M 1101 i , If Borrower falls 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 obligation to purchase any particular type or amount of coverage.Therefore,such coverage shall cover Lender, but might or might not protect Borrower,Borrower's equity In 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 tinder 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 pollcles shall be subject to Leader'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 requites, 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 Properly, If the restoration or repair Is economically feasible and Leader's security Is not lessened.During such repair and restoration period,Lender shall have the right to hold such insurance proceeds until Leader 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. Leader 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 Fender may negotiate and settle the claim.The 30-day period will begin when the notice Is given. In either event, or if Lender aequires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds In an amottat 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 I11*ument,whether or not then dun. `�y1� IA��lr..�l� V-0A(PA)(olaet.ol Pops 7 d 1e Form 3039 1/01 i 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. T. Preservation, Maintenance and Protootion 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 Properly 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 Leader has released proceeds for such purposes. Loader 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 candemnatlon proceeds are not suf dent to repair or restore she 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,Leader 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. g. Borrowor's Loan Application. Borrower shall be in default if, during the Loan application process, Borrower or any persons or entitles acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, misleading, or Inaccurate lafermation or statements to Lender (or failed to provide Lender with material Information) in conmecllon 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 falls to perform the covenants and agreements contained to 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 bankruptcy, probate,for condemnation or forfeiture,for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regatatloas), or (c) Borrower bas 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 Instrianent, 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 lostrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest to 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 condlllotts, and have utilities boned on or off. Although Lender may take action under this Section 9,Lender does not have to do so and is not r 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. V-SA(PA)(0100).01 Pea o of to Form 3039 1/01 I' 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 Oils Security Instrument Is on a leasebold, 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.Motgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay Ute 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 avallable, Borrower shall continuo 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 Urese 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 he requtred to pay Borrower any Interest or earnings on such loss reserve.Lender can no longer require loss reserve paymants if Mortgage Insurance coverage(in the amount and for the period that Leader requires) provided by an Insurer selected by Lender again becomes available, Is obtained, and Lender requires separately designatedppaymants 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 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 Now 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 do terms and conditions that are satisfactory to the mortgage tosurer acid the other party(or parties)to these agreements,These agreements may require the mortgage Insurer to make payments using any source of funds that the mortgage insurer may have avallable (which may Include funds obtained from Mortgage Insurance premiums). As a result of thesereements, Lender,any purchaser of the Note, another Insurer, any reinsurer, _ any other entity, or any afilliale 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 Mo If ge Insurance, in exchange for sharingg or modifying the mortgage Insurer's risk, or reducing losses, such agreement provides that an affiliate of lender (ekes a share of the insurer's risk In exchange for a share of the premlums paid to the Insurer, the arrangement is often termed"captive reinsurance."Further: (a)-Any such agreements will not affoot the amounts that Borrower bas agreed to pay for Mortgage Insuranoe,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. rcrm 3n 1/01 V-OA(PA)(Dmpi Page e d to 1 (b) Any such agreements will not affeot the rights Borrower has-if any -with respect to the Mortgage Inm iranoo under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to reoeive 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 Mortgago Insuranoe promiums that wore unearned at the time of such cancellation or termination. 11. Assignment of MieoeUsneous 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 bender has had an opportunity to Inspect such Propperty 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 shall not he required to pay Borrower any Interest or earnings on such .Miscellaneous Proceeds.If the restoration or repair is not economically feasible or Leader'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 Mlscellaueous 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 toss 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 equal to or greater than the amount of the sums secured by this Security Icstnuncat immediately before the partial taking, destruction,-or loss to value, unless Borrower and Lender otherwise agree in writing, the sums secured•by tilts Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds �ultipliedby the following fraction; (a) the total amount of the sums secured immediately before the tialtaking, destruction,or loss In value divided by(b)the fair market value of the Property immediately ore the partial taking,destruction,or loss in value.Any balance shall be paid to Borrower. In the ovent of'a pattial 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. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the opposing Party (as donned in the next sentence) offers to make an award to settle a claim for damages, Borrower falls to respond to Lender within 90 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. "l?pposing 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, outer material Impairment of Londer's Interest in the Property or rights tinder 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 to 03>a 101 V-GA(PA)WNW P.I to of to Form 3 dismissed with a ruling that, In Lender's Judgment, precludes forfeiture of the Property or other material Impairment of benders Interest In the Property or rights under this Security Instrument.The proceeds of any award or claim for damages that are attrlbutabte to the impairment of Lender's Interest in the Property are hereby assigned and shall be paid to Lender. All Mtsoellaneous Proceeds that are not applied to restoration or repair of(Ito Property shall be applied In the order provided for in Section 2. 12. Borrower Not Released; Forbearanoe 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 1n 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 Leader In exercising any right or remedy Including, without limitation, Lender's acceptance of payments from third persons, entitles or Successors In Interest of Borrower or in amounts less than the amount then due,shaft not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Su000ssors and Assigns Hound. 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: ) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Leader 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. Subject to the provisions of Section 18, any Successor In Interest of Borrower who assumes Borrower's oblietions tinder 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 to Section 20)and benefit the successors and assigns of Lender, 14. Loan-Charges. Lander 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,pproperly 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 cllarging.of such fee.Lender may aot charge fees that are expresslyrohiblied by this Security Instrument or by Applicable Law. If the Loan is subylect to a law which sets maximum loan charges,and that law Is finalky 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 WeFrinclpal owed under the Note or by maldag a direct payment to Borrower, if a refund reduces principal, the reduction will be treated as apartial 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 Leader in connection with this Security Instrument must be in writing. Any notice to Borrower In connection with this Security Instrument shall be deemed to In' V-OA(PA)(o7oapt• Paul 11 or 16 Form 3039 1101 F r have been given to Borrower when malted 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 requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender.Borrower shall promptly notify Leader 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 mny be only ono designated aotico address under this Security Instrument at any one time. Any notice to Deader shall be given by delivering It or by mailing It by first class mail to Lender's address stated h�cin unless Lender has designated another address by notico to Borrower, Any notice In connection with this Security Instrument shall not be deemed to have been glven to Lender until actually received by Lander, If any notice required by this Security Instrument is also required under Appliable Law, the Applicable Law requirement will satisfy ibe corresponding requirement under this Security Instrument. 16, Governing Law;, Severability; Rules of Conetruotion. 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 Securittyy Iristrumont are subject to an 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 sho not a 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 otherpprovisions of this Security Instrument.or the Note which can be .give 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 femhrine gender; (b) words in the slagular shall mean and Include,the plural and vice versa;and (c)the word "may"gives sole discretion without any obligation to take any action. 11.Borrower'a Copy. Borrower shall be given one copy of the Note and of this Security Instrument. 18. Transfer of the Property or a Benefiotal Interest in Borrower. As used In this Section 18, "Interest,In the Property"means any legal or beneficial interest in the Properly, Including, but not limited to, those beneficial Interests transferred in a bond for deed, contract for deed, Installment sates 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 Leader'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, Leader 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 falls to pay these sums prior to the expiration of this period, Lender may Invoke any remedles permitted by this _ Securl(�yY Instrument without further notice or demand on Borrower, 19, Borrower's.Right to Reinstate After Aoneleratian. 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 Property ppursuant 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 (ca) end Of a j dgmeWbtcenf enforcing thiswoulbec Security un der methit. Those conditions are'that Borrower: (a) pys Instrument and the.Note as if no accelity eration had occurred;(b) cures any default of any other covenants or [AM V-6A(PA)(0709).01 Par 12 0,10Fomt 3D39 Mf agreements;(c) pays all expenses incurred in enforcing this Security Instrument, Includingbut 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 rtghts 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 p such reinstatement sums and expenses In one or more of the following forms, as selected by Lender: ((aa) 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.Upon reiasiatement by Borrower,this Securlty 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 Servicor;Notioc of Grievants.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 tinder the Note, this Security InsirumeaL 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 Securlty.instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this SecurI7 instrument, until such Borrower or Lender has notified the other party(with such a'otice 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 token, 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"moans federal laws and laws of the jurisdiction where the Properly Is lbeated that relate to health, safety or onvlronmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or removal action, as defined In Environmental Law;and (d) an"Lrnvironmeatal Condition" means a condition that can cause, contribute to, or otherwise trigger an l;avironmental Cleanup. c Waw V-SAMA)tw�oaT•ot ran.a 0 1 Form 909 1/01 I 1 a 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 Propsrty, Borrower shall not do, nor allow anyone else to do, anything affecting the Pro arty(a) that is in violation of any Environmental Law, (b)which creates an Environmental Condition, or gc)which, due to the presence,use,or release of a Hazardous Substance, creates a condition that adversely affects the value of the PropPerty. The preceding two sentences shall not apply to the presence, use, or storage on the Property a small quantities to Hazardous Substances thef are ggenerally recoggnized to be appropriate to normal rasideatll uses and to of maintenance of the Property(Inciuding,but no limited to,hazardous substances la consumer products). 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 pa Involving the Property and any Hazardous Substance or Environmental Law of which Borrower fias 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 remedlatlon o any Hazardous Substance affecting Ura Property is necessarryy, orrower 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;Remedios.Lender sholl give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but notrior to aoocleration under Soetion 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 acoeloration of the sums secured by this Security Instrument, foreolosure by judicial proceeding and sale of the Property.Lender shall further inform Borrower of the right to reinstate after sooelmation and the right to assert in the foreclosure proceedingthe non ease of d default or any other defame of Borrower to secoleration and foreolosure.If the default is not cured as specifiedLender at its option may require immediate payment in full of all cams secured by this Security Instrument without•fluther demand and may foreclose this Security Instrument by judicial proceeding, Lender shall be entitled to eallect all expenses incurred in pursuing the remedies provided in this Section 22, including but not limited to, attorneys' fees and costa of title evidence to the extent permitted by Applbeabio Law, 23. Release. Upon payment of all sums secured by this Sec r4 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 fes 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, Reinstatemmt Period. 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. �y 26. Purchase Money Mortgage. if any of the debt secured II this Security Instrument is lent to Borrower to aequlre title to the Property,this Security Instrument she be a purchase money Mort 01 27. Interest Rate After Judgment. Borrower agrees that the Interest rate payable after a udgment is entered on the Note or In an action of mortgage foreclosure shall be the rate payable from dime to time - under the Note. V-OA(PA)Iwoa).oi Pop 14 01 16 Farm 303 11 1 This Is a contract under seal and may be enforced under 92 PA.C.S.Section 5528(b). 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: l (Seal) (Seal) WILLIAM L.WOODSIDF,JR. Borrower -Barrow (Seal) (Seal} . •Borrowor .. . •Borrower -Borrow Borrower (Seat) (Seal) -Borrower -Borrower V-GA(PA)tomyoi rape 15 or ra Form 3039 1/01 COMMONWEALTH OF PENNSYLVANIA, �jVY�3 &o.(\A County as- On this, the 0 day of ILX1e aOD8 ,before me,the undersigned officer,personally appeared WILLIAM L.WOODSIDE,JR. known to me (or satisfactorily proven) to be the person(s)whose aame(s) Is/are subscribed to the wilitin insiniment and acluiowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires; NopMd Sal KAY L.Mmamat,Notary POKc CklWa awougb,otmebetbW Coo*,PA My Commbafon Expina August 11,2011 Title of ofacer Certificate of Residence 1, ,do hereby certify that the correct address of the withln•named Mortgagee is P.Q. Box 2026,Flint,MI 48501-2026. Witness my hand this day of Agent of Modgegee 1 WIN V-GA(PA)W'roepi rage 16 of 16 Form 3030 1 1 VA GUARANTEED LOAN AND ASSUWTIO QT TQ—v LOAN NO.; 40923037 NOTICE- THIS LOAN IS NOT AS ABLE TH 10T THE APP % L OF THE DEP R MENNT F VETERANS AFFAIR OR ITS AUT ENT GENT. THIS VA GUARANTEED LOAN AND ASSUMPTION POLICY RIDER Is made this 30th day of JUNE, 2008 , and is Incorporated Into and shall be deemed to amend and supplement the Mortgage, Deed of Trust or Deed to Secure Debt (herein "Security Instrument") dated of even date herewith, given by the undersigned (herein "Borrower`) to secure Borrower's Note to MORTGAGEIT, INC (herein "Lender") and covering the Property described In the Security Instrument and located at 219 WEST PINE STREET, MT HOLLY SPRINGS,PA 17085 {Property Address) VA GUARANTEED LOAN COVENANT; In addition to the covenants and agreements made in the Security Instrument, Borrower and Lender further covenant and agree as follows; If the Indebtedness secured hereby be guaranteed or insured under Title 38, United States Code, such Title and Regulations Issued thereunder and In effect on the date hereof shaft govern the rights, duties and liabilities of Borrower and Lender,Any provisions of the Security Instrument or other instruments executed in connection with said Indebtedness which are Inconsistent with said Title or Regulations, Including, but not limited to, the provision for paymont of any sum in connection with prepayment of the socurAd indebtedness and the provision that the Lender may accelerate payment of the secured indebtedness pursuant to Covenant 18 of the Security Instrument, are hereby amended or negated to the extent necessary to conform such Instruments to said Title or Regulations. M ULTISTATE VA GUARANTY LOAN ANIS ASSUMPTION POLICY RIDER 10103 V-538R(0405),01 page 1 of 3 LEWER suPPORT SYSTEMS IRC,538KNEW(0a"" r LATE CHARGE: At Lender's option, Borrower will pay a "late charge" not exceeding four per centum (4%) of the overdue payment when paid more than fifteen (1 S) days after the due date thereof-to cover the extra expense Involved In handling delinquent payments, but such "late charge" shall not be payable out of the proceeds of any sale made to satisfy the Indebtedness secured hereby, unless such proceeds are sufficient to discharge the entire indebtedness and all proper costs and expenses secured hereby, GUARANTY: Should the Department of Veterans Affairs fall or refuse to Issue Its guaranty in full amount within 60 days from the date that this loan would normally become eligible for such guaranty committed upon by the Department of Veterans Affairs under the provisions of Title 38 of the U.S. Code "Veterans Benefits," the Mortgagee may declare the Indebtedness hereby secured at once due and payable and may foreclose Immediately or may exercise any other rights hereunder or take any other proper action as by law provided, TRANSFER OF THE PROPERTY:This loan may be declared Immediately due and payable upon transfer of the property securing such loan to any transferee, unless the acceptability of the assumption of the loan Is established pursuant to Section 3714 of Chapter 37, Title 38, United States Code. An authorized transfer ("assumption"). of the property shall also be subject to additional covenants and agreements as set forth below: (a)ASSUMPTION FUNDING FEE:A Fee equal to one half percent ( so %) of the balance of this loan as of the date of transfer of the property shall be payable at the time of transfer, to the loan holder or Its authorized agent, as trustee for the Department of Veterans Affairs, If the assumer fails to pay this fee at the tone of transfer, the fee shall constitute an additional debt to that already secured by this instrument, shall bear Interest at the rate herein provided, and, at the option of the payee of the Indebtedness hereby secured or any transferee thereof,shall be immediately due and payable. This fee is automatically waived if the assumer Is exempt under the provisions of 38 U.S.C. 3729(c). (b) ASSUMPTION PROCESSING CHARGE: Upon application for approval to allow assumption of chis loan, a processing fee may be charged by the loan holder or Its authorized agent for determining the creditworthiness of the assumer and subsequently revising the holder's ownership records when an approved transfer Is compteted.;The amount of this charge shall not exceed the maximum established by the Department of Veterans Affairs for a loan to which Section 3714 of Chapter 37, Title 38, United States Code applies. (c) ASSUMPTION INDEMNITY LIABILITY: If this obligation is assumed, then the assumer hereby agrees to assume all of the obligations of the veteran under the terms of the - Instruments creating and securing the loan. The assumer further agrees to Indemnify the Department of Veterans Affairs to the extent of any claim payment arising from the guaranty or Insurance of the Indebtedness created by this instrument. V-538.11(0405).01 Page 2 of 3 W, �, IN WITNESS WHEREOF, Borrower(s) has executed this VA Guaranteed Loan and Assumption Policy Rider, (Seal) (Seal) WILLIAM LID Borrower 'Borrower (Seal} fSeaQ -Borrower Borrower (seal) (seal) -Borrower -Borrower .(Seal) (Seal) -Borrower -Borrower W538191(0405),01 Page 3 of 3 i I i Loan Narne:'WWAM L;WOODSIDE,JR. ' I Property Address:219 WEST PINE STREr,MT HOLLY SPRINQs,PA 17005 EXHIBIT LWAL DESCRIPTION OF PROPERTY . ALL THAT CERTAIN tract of land with the improvements thereon erected situate In South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with the-Plan for Bruce_L. Barner, dated March 16, 1994, prepared by Mark A. Kuntz, Surveyor, recorded in the hereinafter mentioned Recorder's Office in Plan Book.9 i, Page 65, as follows: y BEGINNING;at an existing 0oint in the dividing line between lands now or formerly of Bruce L. and lois A. Barner and Lot No. 2 as shown on the above mentioned plan at the comer of lands now or formerly of Charles Hockley;thence along said lands now or formerly of Hockley, South 88 degrees 14 minutes';10 seconds East a distance of 38.21 feet to an existing pipe;thence by same and continuing along lands now or formRdy of James Skelton, South 83 degrees 18 minutes 55 seconds East a distance of IfO'26 feet to a point in fine of lands now or formerly of Gary Emlet; thence along said lands now or formerly of Emlet, South 03 degrees 36 minutes 20 seconds East a distance of 188.65 feet to a point In line of lands now or formerly of Bruce L. Barner, et ux;thence along said lands now or formerly of Bamer, South 65 degrees 36 minutes 35 seconds West a distance of 118.84 feet to a point; thence by same, North 05 degrees 26 minutes 30 seconds West a distance of 219.92 feet to a point, the Place of BEGINNING. TOGETHER WITH a right of way in favor of the within described premises-over other lands now or formerly of Bruce L. and Lois A. Barner, said right of way being 15 feet and width and extending southwardly from the southern dedicated right of way line of Sandbank Road to the above-described premises. W . MNDER SUPPORT SYSTEMS INC. EX,,A•XX.FRM 1021111 I I i I i i � e NOTI E: THIS LOAN IS NO�TASSUMMABLE WITHOUT THE APPR�VAL OF THE DEPARTMENT 4F VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. JUNE30,2008C9 CARLISLE PENNSYLVANIA [Date) [City) (State) 219 WEST PINE STREET,MT HOLLY SPRINGS,PA 17065 [Property Address) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received,I promise to pay U.S.$ 91,350.00 (this amount is called"Principal'7, plus Interest, to the order of die Lender.The Lender Is MORTGAGEIT,INC 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 6.750 %. 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 let day of each month beginning on AUGUST, 2008 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 JULY 01,2038 , 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 month payments at CENTRAL LOAN ADMINISTRATION&REPORTING P.O.BOX 986,NEWARK,NJ 7 8 -0986 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. $ 592.49 4. BORROWER'S RIGHT TO PREPAY The Borrower shall have the right to prepay at any time, without premium or fee, the entire Indebtedness or any part thereof not less than the amount of one installment, or$100.00, whichever Is less. Any Prepayment in full of the Indebtedness shall be credited on the date received,and no interest may be charged thereafter.Any partial Prepayment made on other than an installment due date need not be credited until the next following installment due date or 30 days after such Prepayment, whichever is earlier. wa�►a• PENNSYLVANIA FIXED RATE NOTE-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Folin 3200 1101 Amended for Veterans Affairs Amended 6/00 VM P 5G(PA)(0707) Page 1 of 3 LENDER SUPPORT SYSTEMS,INC.SGPA.NEW(10/07) N ,.5. LOAN CHARGES If a low,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 sl►all 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 not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due,I will pay a late charge to the Note Holder.The amount of the charge will be 4.000 %of my overdue payment. 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 paid and all die interest that I owe on that amount. That date must be at least 30 days after the date on winch 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 full as described above, the Note Holder will stili have the right to do so if I am in default at a later time. (E)Payment of Note 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 at the Property Address above or at 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 stated 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 this 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. wean VM P-5G(PA)(o7o7) ray.2 or 3 Form 3200 1101 t _ .10. AI.LONQE TO THIS NOTE . If an.allonge providing for payment adjustments or for any other supplemental Information is executed by the Borrower together with this Note, the covenants of the allonge shall be Incorporated Into and shall amend and supplement the covenants of this Note as If the allonge were a part of this Note. [Check applicable box] ❑Graduated Payment Allonge 0 Other[Specify] ❑Other [Specify] VA A8SUMFrION POLICY ALLONGE AMENDING NOTE 11. 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(the "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 I owe under this Note.Some of those conditions are described as follows: Regulations (38 C.F.R. Part 36) issued under the Department of Veterans Affairs ("VA") Guaranteed Loan Authority (38 U.S.C. Chapter 37) and in effect on the date of loan closing shall govern the rights, duties and liabilities of the parties to this loan and anyprovisions of this Note which are Inconsistent with such regulations are hereby amended and supplemented to conform thereto. This is a contract under seal and may be enforced under 42 PA.C.S.Section 5529(b). WITNESS THE HAND(S)AND SEALS) OF THE UNDERSIGNED. (Seal) (Seal) WILLIAM . OODS D JR. -Borrower Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Sean (Seal) FORME REC30,PayTOThe Order Of -Borrower -Borrower JPMorgan Chase Bank,N.A. rw,3y Orn',; Without Recourse: JP 01ortgageiT,Inc. BY Asan OrioalO*J I Ber�s�•� Title:Erin 1(ozenha,Asst t Secretary VMP-GG(PA)pw) Page 3 of 3 Form 3200 1/01 6 Pay to the Order of. Wtthout Recourse JPMorgan Chase Bank,NA By: Tonl T.Mall,Assistant Secretary 1� ��I P.O.Box 183205 Columbus,OH 43218 USPS CERTIFIED MAIL1Af For Undeliverable Mail Only 9214 8901 0754 4630 0028 41 015486.1 of$NSPOHDLA•CAJ04494450000000 WILLIAM L WOODSIDE 219 W PINE ST MOUNT HOLLY SPRINGS PA 17065-1123 Chase(OH4-7399) CHASE Cp P.O.Box 183205 Columbus,OH 43218 For Undeliverable Mail Only 10/31/2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail WILLIAM L WOODSIDE 219 W PINE ST MOUNT HOLLY SPRINGS,PA 17065-1123 Act 91 Notice Account: Property Address: 219W PINE ST MOUNT HOLLY SPRIN,PA 17065(the"Property") Dear WILLIAM L WOODSIDE: On the following page,you will find a notice regarding your home as required by Pennsylvania law. Certified Article#:9214 8901 0754 4630 0028 41 015486-2 of 5 NSPOHDLA-CA J0449445 0000000 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 Rages. 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 Q 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 serving your County 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,PLIES 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 CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): WILLIAM L WOODSIDE PROPERTY ADDRESS: 219W PINE ST MOUNT HOLLY SPRIN,PA 17065 LOAN ACCOUNT NUMBER: - ORIGINAL LENDER: MORTGAGEIT INC CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A. Certified Article#:9214 8901 0754 4630 0028 41 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 aeencies for the county in which the propg y 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 A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN THIRTY-THREE(33)DAYS OF THE POST MARK DATE OF THIS NOTICE AND FILE AN APPLICA'T'ION WITH THE PHFA WITHIN THIRTY(30)DAYS OF T HAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTINGA FORECLOSUREACTIONAGAINST YOURPROPERTY,AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY S7AY OF FORECLOSURE." YOU HAVE THE RIGHT TO FII E A HEMAP APPI ICATION EVEN BEYOND THESE TIME PERlOD.S.A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOURAPPLICATIONI.S EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Certified Article#:9214 8901 0754 4630 0028 41 015486.3 of 5 NSPOHDLA•CA JD449445 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 (Bring it up to date). NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located at: 219W PINE ST,MOUNT HOLLY SPRIN,PA 17065 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 $717.79 10/01/2013 $717.79 Other charges: Late Charges: $57.42 Insufficient Funds(NSF)Fees: $0.00 Other Fees: $0.00 Advances: $-154.75 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $1,338.25 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 $1,338.25,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 money order made payable and sent to: Overnight/Regular Mail: Chase Mail Code: 01-14-7133 3415 Vision Drive Columbus,OH 43219-6009 Certified Article N:9214 8901 0754 4630 0028 41 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 Ada.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 fro, e{ejU. 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)-DAYep riod• you will not be required to liar 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 up to one hour before the Sheriff's Sale You mU do so by paying 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 Sheriff's 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 Sheriff's 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 Sheriff's 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 32203-1.275 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 Sheriff s 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. Certified Article a:9214 8901 0754 4630 0028 41 015486-4 of 6 NSPOHDLA-CA J0449446 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. Certified Artide#:9214 8901 0754 4630 0028 41 i 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 Philadel hia Avenue Wa nesboro 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 Certified Article#:9214 8901 0754 4630 0028 41 015486-5 of 5 NSPOHOLA-CA J0449445 0000000 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 wider 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 PreventLoanSeams.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. BR860 Certified Article#:9214 8901 0754 4630 0028 41 f 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. 4ab( - 4 10 xo��4�W-4 0-1� Fatima Stigger Vice President Date: 05/20/14 JPMorgan Chase Bank,N.A Borrower: William Woodside Property Address: 219 West Pine Street, Mount Holly Springs, PA 17065 County: Cumberland . Last Four of Loan Number:6458 FORM 1 IN THE COURT OF COMMON PLEAS OF JPMorgan Chase Bank,National Association : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. - William L. Woodside, Jr. - 219 West Pine Street `-T Mount Holly Springs, PA 17065 /�C 1q, - — DEFENDANTS Defendant(s) Civil q c 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. Respectfully submitted: SHAPIRO &DeNARDO,LLC Date Attorneys for Plaintiff CHRISTOPHER A.DCNARDO,ESQUIRE 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 Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No 0 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: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household How Long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes 0 No ❑ i If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount Owed: Value: Automobile#2: Model: Year: Amount Owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses•(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2 nd Mortgage Utilities Car Payments 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/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 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, , authorize the above named 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 Nf 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 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. William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 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 �������� ~�~��°"����"�°�"�"��� COUNTY Ronny R Anderson Sheriff _ ot � | �� �`���X '�� �/`/` Jody S Smith �, -v Chief Deputy JUN 20 PA 2: 3� Richard VVStewart :.:UBEN ' NU "" LiJSolicitor PENNSYLVANIA JPMorgan Chase Bank, NA. Case Number vs. 2014-3305 NhUiomLVVnodaide. Jr. SHERIFF'S RETURN OF SERVICE 08/05/3014 09:30 AM- Deputy Ryan Burgett, 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: William L. Woodside, Jr. ot21QW. Pine Street, South Middleton Township, Mount Holly Springs, PA 17065. RYAN BURGETT, DEPUTY— OG/OQ/2O14 12:10 PM- Deputy William C|ina, 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 Bill Woodside, Owner,who accepted as"Adult Person in Charge' for Occupant at 219W. Pine Street, South Middleton To s' ', Mount Holly Springs, PA 17065. � 4:11Perr ^�^ � LIA C INE, DEPUTY SHERIFF COST: $51.91 SO ANSWERS, June 10, 2014 RDNNYRANDERSON, SHERIFF w�=*s"/wOs" /�� JPMorgan Chase Bank, National Association Plaintiff v. William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : Docket No. 14-3305 4 rr� - t w : CIVIL ACTION- : MORTGAGE FORECLOSURE REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012, governing the Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned hereby certifies as follows: 1. Defendant is 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. «.c-C,ccp Signature of Defendant's Counsel Legal Representative (o3(zor4 ppointed Date Signature of Defendant 7 —3 Date JPMorgan Chase Bank, : IN THE COURT OF COMMON PLEAS National Association : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA v. William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Defendant : Docket No. 14-3305 : CIVIL ACTION- : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant, William L. Woodside, Jr., hereby certify that I am serving a copy of the Praecipe for Entry of Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney, on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre -Paid Christopher A. DeNardo, Esq. Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 DATE: 04(m3 (Zo MIDPENN LEGAL SERVICES q( Jaime M. Haley, Esquire Attorney for Defendant Supreme Ct. ID # 205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 JPMorgan Chase Bank, : IN THE COURT OF COMMON PLEAS National Association : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA v. William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Defendant : Docket No. 14-3305 : CIVIL ACTION- : MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: CD Please enter the appearance of MidPenn Legal Services on behalf of the Defendant, William L. Wood side, Jr., in the above matter, representing the Defendant in the Cumberland County Residential Mortgage Foreclosure Diversion Program. DATE: O'--/03 z.o (4 Respectfully Submitted, MIDPENN LEGAL SERVICES Jaime M Halry Esquire M. Haley, Esquire Attorney for Defendant Supreme Ct. ID # 205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 JPMorgan Chase Bank, National Association Plaintiff v. William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : Docket No. 14-3305 : CIVIL ACTION- : MORTGAGE FORECLOSURE CASE MANAGEMENT ORDER AND NOW, this /I/4day of , 2014, the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court -supervised conciliation Conference on C2 t � o? // atin eitonie 1g V Pennsylvania. at the Cumberland County Courthouse, Carlisle, 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made and may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange • for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, DISTRIBUTION: Jaime M. Haley, Esquire MidPenn Legal Services 401 E. Louther Street, Ste 103 Carlisle, PA 17013 For the Defendant stopher A. DeNardo, Esq. Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 For the Plaintiff JPMORGAN CHASE BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. WILLIAM L. WOODSIDE, JR., Defendant : CIVIL ACTION — LAW : NO. 14-3305 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z `` day of August, 2014, following conciliation conference, it appearing that a completed packet has been submitted to the lender for their review, further conciliation conference in this case is set for Friday, October 17, 2014, at 2:00 p.m. in Chambers of the undersigned. ✓ Christopher A. DeNardo, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 ..Jaime M. Haley, Esquire 401 E. Louther Street, Suite 103 Carlisle, PA 17013 :rlm Cop ITLAC15-cL BY THE COURT, JPMORGAN CHASE BANK, N.A., : Plaintiff vs. WILLIAM L. WOODSIDE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 14-3305 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 7-6% day of October, 2014, following conciliation conference, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is lifted. .Xlathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff ..71)airme M. Haley, Esquire 401 E. Louther Street, Suite 103 Carlisle, PA 17013 For the Defendant :r1m c /724 'LEL BY THE COURT, r"..) (J1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment () Other JPMorgan Chase Bank, National Association File No. 1330 it)1 g PLAINTIFF Amount Due $96,209.14 Interest November 1, 2014 to March 4;2015 is S2,206.21 vs. Atty's Comm Costs William L. Woodside, Jr. DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: 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. \\,a()A Date: p-fir0,50, c8r• )bs.-)s tk It 1�a SD"igtb 1Db FP.4 Signature: Print Name: J Osborne Address: 11 orizon Drive, Suite 150 ing of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 312169 SOLL C t-ff M-76Do6 (1161)k.'i wv,=i bi)02 �zr� ALL THAT CERTAIN tract of land with the improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with the Plan for Bruce L. Barner, dated March 16, 1994, prepared by Mark A. Kuntz, Surveyor, recorded in the hereinafter mentioned Recorder's Office in Plan Book 90, Page 65, as follows: BEGINNING at an existing point in the dividing line between lands now or formerly of Bruce L. and Lois A. Barner and Lot No. 2 as shown on the above mentioned plan at the corner of lands now or formerly of Charles Hockley; thence along said lands now or formerly of Hockley, South 88 degrees 14 minutes 10 seconds East a distance of 38.21 feet to an existing pipe; thence by same and continuing along lands now or formerly of James Skelton, South 83 degrees 18 minutes 55 seconds East a distance of 89.26 feet to a point in line of lands now or formerly of Gary Emlet; thence along said lands now or formerly of Emlet, South 03 degrees 36 minutes 20 seconds East a distance of 198.65 feet to a point in line of lands now or formerly of Bruce L. Barner, et ux; thence along lands now or formerly of Barner, South 85 degrees 36 minutes 35 seconds West a distance of 118.84 feet to a point; thence by same, North 05 degrees 26 minutes 30 seconds West, a distance of 219.92 feet to a point, the place of beginning. TOGETHER WITH a right of way in favor of the within described premises over other lands now or formerly of Bruce L. and Lois A. Barner, said right of way being 15 feet in width and extending Southwardly from the Southern dedicated right of way line of Sandbank Road to the above described premises. PARCEL No. 40-32-2334-063 BEING the same premises which Robert W. Schriver, widower, by Deed dated June 30, 2008 and recorded July 1, 2008 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 200822391, granted and conveyed unto William L. Woodside, Jr. 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. 14-045619 JPMorgan Chase Bank, National Association PLAINTIFF VS. William L. Woodside, Jr. DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-3305 A 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 219 West Pine Street, Mount Holly Springs, PA 17065. Name and address of Owner(s) or Reputed Owner(s) William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 2. Name and address of Defendant in the judgment: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 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 Midland Funding, LLC 8875 Aero Drive Suite 200 San Diego, CA 92123 Portfolio Recovery Associates, LLC 120 Corporate Blvd. Norfolk, VA 23502 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 Commonwealth of Pennsylvania, Bureau of Compliance Lien Section P.O. Box 280948 Harrisburg, PA 17128 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 219 West Pine Street 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. BY: 14-045619 SHAPIRO & DeNARDO, LLC 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY William L. Woodside, Jr. DEFENDANT NO: 14-3305 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Your house (real estate) at: 219 West Pine Street, Mount Holly Springs, PA 17065 40-32-2334-063 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $96,209.14 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. 14-045619 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with the Plan for Bruce L. Barner, dated March 16, 1994, prepared by Mark A. Kuntz, Surveyor, recorded in the hereinafter mentioned Recorder's Office in Plan Book 90, Page 65, as follows: BEGINNING at an existing point in the dividing line between lands now or formerly of Bruce L. and Lois A. Barner and Lot No. 2 as shown on the above mentioned plan at the corner of lands now or formerly of Charles Hockley; thence along said lands now or formerly of Hockley, South 88 degrees 14 minutes 10 seconds East a distance of 38.21 feet to an existing pipe; thence by same and continuing along lands now or formerly of James Skelton, South 83 degrees 18 minutes 55 seconds East a distance of 89.26 feet to a point in line of lands now or formerly of Gary Emlet; thence along said lands now or formerly of Emlet, South 03 degrees 36 minutes 20 seconds East a distance of 198.65 feet to a point in line of lands now or formerly of Bruce L. Barner, et ux; thence along lands now or formerly of Barner, South 85 degrees 36 minutes 35 seconds West a distance of 118.84 feet to a point; thence by same, North 05 degrees 26 minutes 30 seconds West, a distance of 219.92 feet to a point, the place of beginning. TOGETHER WITH a right of way in favor of the within described premises over other lands now or formerly of Bruce L. and Lois A. Barner, said right of way being 15 feet in width and extending Southwardly from the Southern dedicated right of way line of Sandbank Road to the above described premises. PARCEL No. 40-32-2334-063 BEING the same premises which Robert W. Schriver, widower, by Deed dated June 30, 2008 and recorded July 1, 2008 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 200822391, granted and conveyed unto William L. Woodside, Jr. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.cepa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. WILLIAM L. WOODSIDE, JR. WRIT OF EXECUTION NO 14-3305 Civil Term CIVIL ACTION — LAW 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: $96,209.14 L.L.: $.50 Interest NOVEMBER 1, 2014 TO MARCH 4, 2015 IS $2,206.51 Atty's Comm: Atty Paid: $200.66 Plaintiff Paid: Date: 11/25/14 Due Prothy: $2.25 Other Costs: >5, at.,,:o< David D. Buell, Prothonotary (Seal) By: 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 1D No. 312169 Deputy SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 7844'7'' BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169'<+ CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY William L. Woodside, Jr. DEFENDANT NO:14-3305 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $96,209.14 in favor of the Plaintiff and against the Defendant, 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: $85,476.86 $7,212.15 $0.00 $1,491.38 $140.00 $1,888.75 $96,209.14 BRADL BOR ESQ. Attorney for Plaintiff A. � J. • - AND NOW, judgment is entered in favor of the P ff and as ainst De erg nt and damages are assessed as above in the sum of $96,209.14. Pro;-Prothy. 14-045619 to .0 etikk C I(/ ) / 4t Jei7 -4_ 3139dg 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 O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS 3415 Vision Drive CUMBERLAND COUNTY Columbus, OH 43219 PLAINTIFF 14-3305 VS. William L. Woodside, Jr. 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: /I/2-1///1-1 Sworn to and subscribed before me this Di day , 2014. Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Denise L. Semetti, Notary Public Upper Merton Twp., Montgomery County My Commission Expires July 22. 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES SHAPIRO & DeNARDO, LLC BY: /Mt? Att:'or Plaintiff EY J. OSBORNE, ESQ. Department of Defense Manpower Data Center Status Report Pursuant t to Seriicernem ers Civil Relief Act. Last Name: WOODSIDE First Name: WILLIAM Middle Name: L. Active Duty Status As Of: Nov -24-2014 Results as of : Nov -24.2014 05:01:48 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 . - - No NA This response This response reflects the individuals' active duty status based on the Active Duty Status Dale Left Active Duty Within 367 Das of Active Duty Status Date 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 Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her 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. Ttfi-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/PC09SLDR.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: 1 FTDWECC405D930 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 O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-3305 William L. Woodside, Jr. DEFENDANT CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, November 10, 2014 to the following Defendants: William L. Woodside, Jr., 219 West Pine Street, Mount Holly Springs, PA 17065 heresa Besle Legal A 'istant to Christopher DeNardo, Esquire for Shapiro & DeNardo, LLC 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 O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 14-3305 William L. Woodside, Jr. DEFENDANT NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: William L. Woodside, Jr. DATE OF NOTICE: November 10, 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 haber tornado la accion requirida de su parte en este caso. Al no tom.ar la accion debi.da dentro de un termino de diez (10) dias de la. fecha. de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in conte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perdcr bienes y otros derechos importantes. Debe llevar esti notificacion a un abogado immediata.mente, Si usteci no tiene abogado o si no tiene dinero suliciente para tal servicio, vaya en persona o flame por telefono a la oficina cuya. direceion se encuentra escrita abajo para averiguar donde se puedee-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: William L. Woodside, Jr., 2.19 West Pine Street, Mount Holly Springs, PA 1 7065 Date: k1 `o BY: SHAPIRO & DeNARDO, :LLC A torneys for Plaii SARAH K. McCAFFER SQ. -r 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 O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY William L. Woodside, Jr. DEFENDANT NO:14-3305 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: William L. Woodside, Jr., 219 West Pine Street, Mount Holly Springs, PA 17065 Date Mailed: Date: \va\\v\ BY: SHAPIRO & DeNARDO, LLC At B for Plaintiff Y J. OSBORNE, ESQ. 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 O. 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. 14-045619 JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY William L. Woodside, Jr. DEFENDANT NO:14-3305 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 address of the judgment debtor (Defendant) is: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 Date: 14-045619 BY: SHAPIRO & DeNARDO, LLC s for Plaintiff Y J. OSBORNE, ESQ. 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: William L. Woodside, Jr. 219 West Pine Street Mount Holly Springs, PA 17065 JPMorgan Chase Bank, National Association PLAINTIFF VS. William L. Woodside, Jr. DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-3305 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 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. 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. 14-045619 JPMorgan Chase Bank, National Association PLAINTIFF VS. William L. Woodside, Jr. DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:14-3305 CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Cori Haas, 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 January 5, 2015, 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: t 14-045619 By: • SHAPIRO & DENARDO, LLC eOaA") Cori Haas Legal Assistant U.S. POSTAGE» PITNEY BOWES 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 ❑ Recorded Delivery (International) 0 COD 0 Registered 0 Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail 0 Signature Confirmation ❑ Insured Affix Stamp Here T tiff, i��►- (If issued as a l'+` �� ��� certificate of mailing, #�� ; ZIP 19406 $ 002.820' or /or additional , 02 1ry copies of this bill) 0001387362 JAN. Postmark and Date of Receipt 05 2015 Article Number Addressee (Name, Street, City State, & ZIP Code) Postage Fee Handling Actual Value if Insured Due Sender DC SC SH RD RR Charge Registered Value if COD Fee Fee Fee Fee Fee 1. Cumberland County Domestic Relations 13 North Hanover Street 14-045619 MW Carlisle, PA 17013 Midland Funding, LLC 8875 Aero Drive 2 Suite 200 San Diego, CA 92123 Portfolio Recovery Associates, LLC 120 Corporate Blvd. 3. Norfolk, VA 23502 Commonwealth of Pennsylvania, Bureau of Compliance Lien Section P.O. Box 280948 Harrisburg, PA 17128 4. Tenant or Occupant 219 West Pine Street r... Mount Holly Springs, PA 17065. 5 , PA Department of Revenue . Bureau of Compliance13 Box 281230 bP.O. Q j Harrisburg, PA 17128-1230 ":1 _= ',-• .° P4 6.' rination onfirma n i GOA ;.• U c: 7.I Cr?C :ry Conti ;nature O ,*M� 8. ?