HomeMy WebLinkAbout14-3817 Court of Common Pleas For Prothonotary Use Only:
Civil Cover Sheet
Docket No:
Cumberland County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required hy 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: Bethanne M.Trowbridge
C National Association a/k/a Bethanne M.Klippel
T
Dollar Amount Requested: 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
E] Zoning Board
C El Other:
T ❑ Other:
I ❑ Other:
O MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort-DES
❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
B
F-1ToxicWaste El Ejectment [-] Common Law/Statutory Arbitration
❑ 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 1/1/2011
SHAPIRO&DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,ATTORNEY I.D.NO. 78447 ,, $ �� ,iri yCAITLIN M. DONNELLY,ESQUIRE, ATTORNEY I.D.NO. 311403 ter,
BRADLEY J. OSBORNE,ATTORNEY I.D.NO. 312169 `� 4P,' 9
CHANDRA M.ARKEMA, ATTORNEY I.D.NO. 203437
ry1 �D C(;
3600 HORIZON DRIVE, SUITE 150 �$YL V41 wi l y
KING OF PRUSSIA,PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 14-045934
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY .
VS.
NO: N, 39 / /
` !vl
Bethanne M. Trowbridge a/k/a Bethanne M.
Klippel
85 Oneida Road
Camp Hill, PA 17011
DEFENDANT '
COMPLAINT-CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE
FOLLOWING PAGES,YOU MUST TAKE ACTION WITHIN TWENTY(20)DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED,BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
C )
b IS-1?d
Q a&
A10=216 l
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE(20)DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA 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. 14-045934
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS. '
NO:
Bethanne M. Trowbridge a/k/a Bethanne M.
Klippel
85 Oneida Road
Camp Hill, PA 17011 ;
DEFENDANT ;
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 C &
F Mortgage Corporation, its successors and assigns
Mortgagore (s): Bethanne M. Trowbridge
(b) Date of Mortgage: March 26, 2010
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County Document ID# 201008517
Date: April 6, 2010
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 C & F
Mortgage Corporation, its successors and assigns
Assignee: JPMorgan Chase Bank,National Association
Date of Assignment: January 30, 2014
Recording Date: February 5, 2014
Instrument No.: 201402610
The Assignment(s) is/are a matter a matter of public record and are therefore
incorporated herein as provided by Pa. R.C.P. No. 1019(g).
2. Plaintiff is the current holder of the mortgage by operation of law.
3. The real property that is subject to the Mortgage is generally known as 85 Oneida Road,
Camp Hill, PA 17011 and is more specifically described as attached as part of Exhibit
"A".
4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Promissory Note"). A true and correct copy of the Promissory Note is
attached and marked as Exhibit "B".
5. The name and mailing address of the Defendant is: Bethanne M. Trowbridge a/k/a
Bethanne M. Klippel, 85 Oneida Road, Camp Hill, PA 17011.
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 December 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 June 6, 2014:
Principal Balance Due $117,586.00
Interest Currently Due and Owing at 5.625% $3,858.26
From November 1, 2013 through May 31, 2014
Late Charges $77.52
Escrow Advances $169.80
TOXAL $121,691.58
9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff
may incur other expenses, costs and charges collectible under the Promissory Note and
Mortgage.
10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be
sought by Plaintiff and included in any request for judgment.
11.Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403
commonly known as Act 6 and demand for payment was sent to each individual Defendant
by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C".
12. The Mortgage is insured by the Federal Housing Administration under Title II of the
National Housing Act (12 U.S.C. § 1707-1715z-18). Accordingly, the Homeowners'
Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable.
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: a"
BY: 0'cj�
A torneys for lamtiff
CAITLIN M.D01, +3ELLY,ESQ
S &D File No. 14-045934
Return To:
Parcel Number: 13-23-0555-098
Space Above This Line For Recording betel
FHA Case No.
Commonwealth ofPonnsylvania - MORTGAGE imi
MIN
THIS MORTGAGE("Security Instrument")is given on Match 26, 2010
The Moilgagor is BEIHANNE M. 7ROWBRIDGE, UNW=
("Borrower"). This Security Instrument is given to Mortgage Electronic Registrallon Syslems, Inc.
("MERS"), (solely as nominee for Lender,as liereinafter defined,and Lender's successors and assigns),as
mortgagee.MERS is organized and existing under the laws of Delaware,and has an address and telephone
number of P.O.Box 2026,Flint,M148501-2026,tel.(888)670-MERS.
C & F MOI2T>JAGE CORPORATION, A VIRGINIA CORPORATION
("Lender")is organized and existing under the laws or VIRGIlJIA and
has an address of 1400 ALNERSER rR rVE, MIDLOTHIM, VA 23113
.Borrower owes Lender the principal sum of
One Hundred Twenty Three Th=sand Mne HMdred Mu ty One and no/100
Dollars(U.S.$]23,931.00 )•
FHA Peonsyivaeia Mortgage with MFRS-4196
4N(PA)tota7l Amed 02
Page 1 of 70 NAV 07/02 e,Nbtl...
VMP MOR70AGC FORMS•8001521.7201
1
r
This debt is evidenced by Borrower's note dated the same dale as this Securily Instrument
("Note"),which provides for monthly payments,with the full debt,if not paid earlier,due and payable
on April 1, 2040 .This Security Instrument secures to Lender:(a)the
repayment of the debt evidenced by the Note,with Interest,and all renewals,extensions and niodiRca(lons
of the Note; (b) the payment of all other sums, with Interest, advanced under paragraph 7 to protect
the security of this Security Instrumenl; and (c) the performance of Borrower's covenants and
agreements under this Security Instrument and the Note. For this purpose, Borrower does
hereby mortgage,grant and convey to MERS(solely as nominee for Lender and Lender's successors and
assigns) and to the successors and assigns of MERS, the following described property Iocated in
CUMBERLAND County,Pennsylvania:
SEB ATTACHED LEGAL DESCRIFITON
which has the address of 85 ONEIDA ROAD Isireetl
CAS HILL Icliyl,Pennsylvania 17011 IZJpCode]
("Property Address");
TOGETHER WITH all the Improvements now or hereafter erecled on Ilse properly, and all
easements, appurtenances and fixtures now or hereafter a part of the properly. All replacements and
additions shall also be covered by this Security Inslrumenl. All of the foregoing Is referred to In this
Security Instrument as die"Property."Borrower understands and agrees that MERS holds only legal title
to the Interests granted by Borrower in this Security Instrument;but,if necessary to comply with law or
custom, MERS, (as nominee for Lender and Lender's successors and assigns),has the right:to exercise
any or all of those interests,including,but not limited to,the right to foreclose and sell the Property;and
to Wke any action required of Lender Including, but not limited to,releasing or canceling this Security
Instrument.
BORROWER COVENANTS that Borrower Is lawfully seized of the estate hereby conveyed and has
the right to mortgage,grant and convey die Properly and that the Property is unencumbered,except for
encumbrances of record.Borrower warrants and wIll defend generally the title to the Properly 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.
FA
41M-4N(PA)(om7) reyo z or ro
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS.
1.Payment of Principal,Interest and Late Charge.Borrower shall pay when due the principal of,
and Interest on,die debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each
monthly payment,together with die principal and interest as set forth in(he Note and any late charges,a
sum for (a) taxes and special assessments levied or to be levied against the Properly, (b) leasehold
payments or ground rents on the Property,and(c)premiums for insurance required under paragraph 4, In
any year In which the Lender must pay a mortgage Insurance premium to the Secretary of housing and
Urban Development ("Secretary"),or in any year in which such premium would have been required if
Lender still held[he Security instrument,each monthly payment shall also Include either:(1)a sum for the
annual mortgage Insurance premium to be paid by Lender to the Secretary,or(10 a monthly charge instead
of a mortgage Insurance premium if[his Security Instrument Is held by the Secretary, In a reasonable
amount to be determined by the Secretary. Except for the monthly charge by the Secretary,these Items are
called"Escrow Items"and the sums paid to Lender are called"Escrow Funds."
Lender may,at any lime,collect acid hold amounts for Escrow Items In an aggregate amount not 10
exceed[he maximum amount that may be required for Borrower's escrow account under the Real Estate
Settlement Procedures Act of 1974,12 U.S.C.Section 2601 ct seq.and implementing regulations,24 CFR
Pari 3500, as they may be amended from lime to (late("RESPA"), except that the cushion or reserve
permitted by RESPA for unanticipated disbursements or disbursements before The Borrower's payments are
available In the account may not be based on amounts due for the mortgage Insurance premium.
If[lie amounts held by Lender for Escrow hems exceed die amounts permitted to be held by RESPA,
Lender shall account to Borrower for(lie excess funds as required by RESPA. If the amounts of funds
held by Lender at any time are not sufficient to pay the Escrow Hems when due.Lender may notify(he
Borrower and require Borrower to make up the shortage as permitted by RESPA,
The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument.
If Borrower lenders to Lender the full payment of all sudi sums,Borrower's account shall be credited with
the balance remairdng for all installment Items (a), (b), and (c) and any mortgage Insurance premium
installment that Lender has not become obligated to pay[o the Secretary,and Lender'shall promptly refund
any excess funds to Borrower. Immediately prior(o a foreclosure sale of the Property or its acquisition by
Lender,Borrower's account shall be credited with any balance remaining for all installments for Items(a),
(b),and(c).
3.Application of Payments, All payments under paragraphs 1 and 2 shall be applied by Lender as
follows:
FIM to[lie mortgage insurance premium to be paid by Lender to(lie Secretary or to the monthly
charge by the Secretary instead of the monthly mortgage insurance premium;
Secondto any taxes,special assessments,leaseliold payments or ground rents, and fire, flood and
other hazard Insurance-premiums,as required;
drd,to interest due under the Note;
Fourthto amortization of die principal of die Note;and
Fifth,to late charges due under the Note.
4. Fire, Flood and Other Hazard Insurance. Borrower shall Insure all improvements on the
Properly, whether now In existence or subsequently erected, against any hazards, casualties, and
contingencies, including fire,for which Lender requires Insurance.This insurance shall be maintained in
imuate�
.4N(PA)co2m) Pg.a.110
the amounts and for the periods that Lender requires.Borrower shall also insure all improvements on(he
Property,whether now In existence or subsequently erected,against loss by floods to the extent required
by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance
policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of.and in
a form acceptable to,Lender.
In the event of loss,Borrower shall give Lender Immediate notice by mail.Lender may make proof of
loss If not made promptly by Borrower. Each Insurance company concerned Is hereby authorized and
directed to make payment for such loss directly to Lender,Instead of to Borrower and to Lender Jointly.
Ali or any part of the Insurance proceeds may be applied by Lender, at Its option, either (a) (o (he
reduction of the Indebtedness under the Note and this Security Instrument,first to any delinquent amounts
applied in the order In paragraph 3,and Alen to prepayment of principal,or(b)to the restoration or repair
of the damaged Property.Any application of the proceeds(o the principal shall not extend or postpone the
due date of the monthly payments which are referred to In paragraph 2, or change the amount of such
payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness
under(he Note and(his Security Instrument shall be paid(o the entity legally entllled thereto.
In the event of foreclosure of Ads Security Instrument or other transfer of title to the Property that
extinguishes the Indebtedness,all right,title and interest of Borrower In and to Insurance policies in force
shall pass to the purchaser.
5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application;Leasebolds. Borrower shall occupy,establish,and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument(or within sixty days of a later
sale or transfer of the Property).and shall continue to occupy the Properly as Borrower's principal
residence for at least one year after the dale of occupancy,unless Lender determines that requirement will
cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond
Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not
commit waste or destroy,damage or substantially change the Property or allow the Property to deteriorate,
reasonable wear and tear excepted.Lender may inspect the Properly if the Properly is vacant or abandoned
or the loan Is in default. Lender may take reasonable ac(fon to protect and preserve such vacant or
abandoned Property. Borrower shall also be In default If Borrower,during the loan application process,
gave materially false or Inaccurate information or statements to Lender(or failed to provide Lender with
any material Information)In connection with the loan evidenced by the Note,including,but not limited to,
representations concerning Borrower's occupancy of the Properly as a principal residence.If this Security
Instrument is on a leasehold,Borrower shall comply with lite provisions of the lease.If Borrower acquires
fee title to(he Property,the leasehold and fee title shall not be merged unless Lender agrees to the merger
In writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, In
connection with any condemnation or other taking of any part of the Properly,or for conveyance In place
of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the
Indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such
proceeds(o the reduction of the Indebtedness under the Note and this Security Instrument, first to any
delinquent amounts applied in the order provided in paragraph 3,and then to prepayment of principal.Any
application of the proceeds to the principal shall not extend or postpone (ire due date of the monthly
payments, which are referred to in paragraph 2,or change (he amount of such payments. Any excess
proceeds over an amount required to pay all outstanding Indebtedness under the Note and(his Security
Instrument shall be paid to the entity legally entitled(hereto.
e.u�m
(0-0N(PA)town Pse a a iw
7.Charges to Borrower and Protection of Lender's Rights In the Property.Borrower shall pay all
governmental or municipal charges,Imes and impositions that are not included In paragraph 2.Borrower
shall pay these obligations on lime directly to the entity which is owed the payment.If failure to pay would
adversely affect Lender's interest in the Properly, upon Lender's request Borrower shall promptly furnish
to Lender receipts evidencing these payments.
If Borrower falls to make these payments or the payments required by paragraph 2, or fails to
perform any other covenants and agreements contained in this Security Instrument, or there is a legal
proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in
bankruptcy,for condemnation or to enforce laws or regulations),then Lender may do and pay whatever Is
necessary to protect the value of the Properly and Lender's rights in the Property,including payment of
faxes,hazard Insurance and other items mentioned In paragraph 2.
Any amounts disbursed by Lender under fids paragraph shall become an additional debt of Borrower
and be secured by this Security instrument. These amounts shall bear interest from the date of
disbursement,at the Note rale,and at the option of Lender,shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower:(a)agrees in writing to Ilse payment of the obligation secured by the lien in a manner acceptable
to Lender; (b) contests In good faith the lien by, or defends against enforcement of the lien in, legal
proceedings which in the Lender's opinion operate to prevent the enforcement of the lien;or(c)secures
from the holder of the lien an agreement salisfaclory to Lender subordinating the lien to this Security
Instrument.If Lender determines that any parr of the Property is subject to a lien which may allain priority
over this Security Instrument, Lender may give Borrower a notice Idenfifylng the lien. Borrower shall
satisfy the lien or lake one or more of the actions set forth above within 10 days of the giving of notice.
S.Pees.Lender may collect fees and charges authorized by the Secretary.
4.Grounds for Acceleration of Debt.
(a)Default.Lender may,except as limited by regulations Issued by the Secretary,in the case of
payment defaults, require Immediate payment in full of all sums secured by lids Security
Instrument if-
(0 Borrower defaults by failing to pay in full any monthly payment required by this Security
Instrument prior to or on the due date of The next monthly payment,or
(H)Borrower defaults by failing,for a period of Thirty days•to perform any other obligations
contained in this Security Instrument.
(b)Sale Without Credit Approval. Lender shall, if permitted by applicable law (including
Section 341(4) of the Gern-SI. Germain Depository Insll(utlons Act of 1982, 12 U.S.C.
1701)-3(d))and with the prior approval of the Secretary,require immediate payment in full of all
sums secured by this Security Instrument if:
(1) All or part of the Property, or a beneficial interest In a trust owning all or part of the
Property,Is sold or otherwise transferred(other than by devise or descent),and
(it)The Property Is not occupied by the purchaser or grantee as his or her principal residence,
or the purchaser or grantee does so occupy the Property but his or her credit has not been
approved in accordance with the requirements of the Secretary.
(c)No Waiver.If circumstances occur that would permit Lender to require Immediate payment In
full,but Lender does not require such payments,Lender does not waive Its rights with respect to
subsequent events,
Inual::
4Qe,4N(PA)Woo» of 10
(d)Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary
will limit Lender's rights, in the case of payment defaults,to require immediate payment in full
and foreclose if not paid.This Security Instrument does not authorize acceleration or foreclosure if
not permitted by regulations of the Secretary.
(e)Mortgage Not Insured.Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under The National Housing Act within 60 days from the
date hereof,Lender may,at its option, require Immediate payment in full of all suns secured by
Oils Security Instrument. A written statement of any authorized agent of the Secretary dated
subsequent to 60 days from the date hereof,declining to insure[his Security Instrument and the
Note,shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing,(his
option may not be exercised by Lender when the unavailability of insurance is solely due to
Lender's failure to remit a mortgage insurance premium to(lie Secretary.
10.Reinstatement.Borrower has a right to be reinstated if Lender has required Immediate payment
In full because of Borrower's failure to pay an amount due under the Note or this Security Instrument.This
right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument,
Borrower shall lender in a lamp sum all amounts required to bring Borrower's account current including,
to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and
reasonable and customary attorneys'fees and expenses properly associated with(he foreclosure proceeding.
Upon reinstatement by Borrower,tails Security Instrument and the obligations(hat it secures shall remain
in effect as If Lender had not required Immediate payment in full. However, Lender is not required to
permit reinstatement if: (I) Lender has accepted reinstatement aller the commencement of foreclosure
proceedings witldn Iwo years Immediately preceding die commencement of a current foreclosure
proceeding, (10 reinstatement will preclude, foreclosure on different grounds in The future, or (Ili)
reinstatement will adversely affect the priority of[be lien created by this Security Instrument.
11. Borrower Not Released; Forbearance By Leader Not a Waiver. Extension of the time of
payment or modification of amortization of the sums secured by(his Security Instrument granted by Lender
to any successor in Interest of Borrower shall not operate to release the liability of the original Borrower or
Borrower's successor in interest. Lender shall not be required to commence proceedings against any
successor in Interest or refuse to extend lime 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 Borrower's
successors in Interest.Any forbearance by Lender in exercising any right or remedy shall not be a waiver
of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound;Joint and Several Liability; Co-Signers. The covenants and
agreements of this Security instrument shall bind and benefit the successors and assigns of Lender and
Borrower,subject to the provisions of paragraph 9(b).Borrower's covenants and agreements shall be Joint
and several.Any Borrower who co-signs this Security Instrument but does not execute The Note: (a) is
co-signing this Security Instrument only to mortgage,grant and convey that Borrower's interest in die
Properly under the terns of this Security Instrument; (b) is not personally obligated to pay the suns
secured by this Security Instrument; and(c) agrees that Lender and any other Borrower may agree to
extend,modify,forbear or make ally accommodations with regard to the terms of this Security Instrument
or the Note without that Borrower's consent. ++
4o-noR. f 1
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13.Notices. Any notice to Borrower provided for In this Security Instrument shall be given by
delivering it or by malting it by first class mail unless applicable law requires use of another method.The
notice shall be directed to the Property Address or any other address Borrower designates by notice to
Lender.Any notice to Lender shalt be given by first class mail to Lender's address stated herein or any
address Lender designates by notice to Borrower.Any notice provided for In this Security Instrument shall
be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
14. Governing Law, Severability. This Security Instrument shall be governed by Federal law and
the law of the Jurisdiction in which lite Properly Is located.In the event that any provision or clause of this
Security instrument or the Note conflicts with applicable law,such conflict shall not affect other provisions
of tints Security Instrument or the Note which can be given effect without the conflicting provision.To this
end the provisions of this Security Instrument and the Note are declared to be severable. i
15.Borrower's Copy.Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Hazardous Substances. Borrower shall not rause or permit Ilse presence.use,disposal,storage,
or release of any Hazardous Substances on or in the Property.Borrower shall not do,nor allow anyone
else to do,anything affecting the Property that is In violation of any Environmental Law. The preceding
two sentences shall not apply to the presence, use, or storage on the Properly of small quantities of
Hazardous Substances That are generally recognized to be appropriate to normal residential uses and to
maintenance of die Property.
Borrower shall promptly give Lender written notice of any investigation,claim, demand,lawsuit or
other action by any governmental or regulatory agency or private party Involving the Properly and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, if Borrower teams,
or is notified by any governmental or regulatory authority, that any removal or other remediation of any
Hazardous Substances affecting die Property Is necessary, Borrower shall promptly lake all necessary
remedial actions in accordance willn Environmental Law.
As used in [his paragraph 16, "Hazardous Substances" are those substances defined as toxic or
hazardous substances 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. As used in this paragraph 16,
"Environmental Law"means federal laws and laws of the Jurisdiction where the Property is located that
relate to health,safety or environmental protection.
NON-UNIFORM COVENANTS.Borrower and Lender further covenant and agree as follows:
17.Assignment of Rents.Borrower unconditionally assigns and transfers to Lender all the rents and
revenues of the Properly.Borrower authorizes Lender or Lender's agents to collect the rents and revenues
and hereby directs each tenant of the Property to pay lite rents to Lender or Lender's agents.However,
prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement In the Security
Instrument,Borrower shall cotiect and receive all rents and revenues of the Property as trustee for the
benefit of Lender and Borrower.This assignment of rents constitutes an absolute assignment and not an
assignment for additional security only.
If Lender gives notice of breach to Borrower: (a)all rents received by Borrower shall be held by
Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security
Instrument;(b)Lender shall be entitled to collect and receive all of lite rents of the Propgrly�;,pnd Sc)each
INtiafe l
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4
tenant of the Properly shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written
demand to lite tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act
that would prevent Lender from exercising its rights under this paragraph 17.
Lender shall not be required to enter upon,lake control of or maintain the Properly before or after
giving notice of breach to Borrower.However,Lender or a judicially appointed receiver may do so at any
time there Is a breach.Any application of rents shall not cure or waive any default or Invalidate any other
• right or remedy of Lender.This assignment of rents of lite Properly shall terminate when[lie debt secured
by theSecurity Instrument is paid In full.
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9,
Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to
collect all expenses incurred in pursuing the remedies provided in this paragraph 18, Including,but
not limited to,attorneys'fees and costs of title evidence.
If the Lender's interest In this Security Instrument is held by the Secretary and the Secretary
requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial
power of sale provided in the Single Family Mortgage Foreclosure Act of 1994("Act")(12 U.S.C.
3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence
foreclosure and to sell the Property as provided in the Act.Nothing is the preceding sentence shall
deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or
applicable law.
19. Release.Upon payment of all sums secured by this Security Instrument,this Security Instrument
and We estate conveyed shall terminate and become vold.After such occurrence,Lender shall discharge
and satisfy This Security Instrument without charge to Borrower. Borrower shall pay any recordation
costs.
20. 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 slay of execution,extension of time,exemption from attachment,levy and sale,
and homestead exemption.
21. Reinstatement Period. Borrower's Time to reinstate provided in paragraph 10 shall extend to
one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to Oils Security
Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to,the Properly,this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that the interest rale payable after a judgment
Is entered on Ore Note or in an action of morlgage foreclosure shall be the rate payable from time to time
under the Note.
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and
recorded togedter with Oils Security Instrument,the covenants of each-such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if Ole rider(s)
were a part of Otis Security Instrument.(Check applicable box(es)).
M Condominium Rider El Growing Equity Rider other Ispeclfy)
0 Planned Unit Development Rider E-1 Graduated Payment Rider
tin>au���
4N(PA)w2w) Pape a oI to
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained In this Security
Instrument and In any rider(s)executed by Borrower and recorded with It.
Witnesses:
SEIHAME M. lFDMMZ.IDGE L Borrower
(Seat)
-Borrower
(Seal) (Seal)
-Borrower -Bower
(Seal) (Seal)
.Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
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Certificate of Residence
1,SUSAN BSN do hereby cert*that
(lie correct address of the within-named Mortgagee Is P.O.Box 2026,Flint,MI 48501-2026.
Witness my)land this 26th day of March 2010
SUSAN BARAN Agent of Mortgagee
COMMONWEALTH OF PENNSYLVANIA, C Lt..W1�"ej(j.k,- C1 County ss:
On(his, 26th day of Maxch 2010 ,before me,die undersigned officer,
personally appeared BEIHAM M. TROWBRIDGE
known to me(or satisfactorily proven)to be the
person(s)whose name(s) (stare subscribed to the within instrument and acknowledged that he/slie/tbey
executed the some for the purposes herein contained.
IN WITNESS WHEREOF,I hereun(o set my hand and official seat.
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA ��
Notarial Sea)
Susanne K.Sather,Notary Public, /�
Camp Hai Bono, xplre aAug County �n L 0
My Commission F.xplrea Aug,26 2018 J'
Member,Pennsylvarda A$"ClA9tfil @r troll a9 Tine of 01111cer
INllah.1 -/��
(Ej>4N(PA)(0207) P.J.10 of ro
EXHIBIT A
• Y
ALL THAT CERTAIN tractor parcel of land and premises, situate, lying and being in
the Township of Lower Allen, in the County of Cumberland and Commonwealth of
j Pennsylvania more particularly described as follows:
i
BEGINNING at a point on the western side of Oneida Road, 118.08 feet North of the
northwest corner of Oneida Road and Seneca Avenue; said point also being at the
dividing line between Lots Nos.25 and 26 on Plan of Lots hereinafter mentioned;thence
South 58 degrees 40 minutes West along said dividing line and along the dividing line
between Lots Nos,24-and 26 on said Plan, 125.13 feet to a point on line of Lot No. 23 on
said Plan; thence North 31 degrees 20 minutes West along same, 62.5 feet to a point;
thence North 58 degrees 30 minutes East, 100.58 feet to a point on the western side of
Oneida Road;thence South 59 degrees 32 minutes 30 seconds East along same,67.5 feet
to a point,the place of BEGINNING.
BEING Lot No. 26 on Plan of Lots known as"Keewaydin"which plan is recorded in the
Office of the Recorder of Deeds in and for Cumberland County in Plan Book 4,Pages 42
and 87.
BEING thereon erected a one story frame dwelling known and numbered as 85 Oneida
Road.
I
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ROBERT P. ZIEGLER
RECORDER OF DEEDS ,
CUMBERLAND COUNTY
1. COURTHOUSE SQUARE -- `
CARLISLE,PA 1.701.3 - , `
71.7-240-6370
Instrument Number-20100$517
Recorded On 4/6/2010 At 2:34:30 PM *Total Pages-12
*Instrument Type-MORTGAGE
Invoice Number-63490 User ID-RZ
*Mortgagor-TROWBRIDGE,BETHANNE M
*Mortgagee-MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
A Customer-MIDSTATE ABSTRACT
*FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $25.50
RECORDER OF DEEDS This page is now part
PARCEL CERTIFICATION $10.00
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $76.00
I Certify this to be recorded
in Cumberland County PA
o?��
V.
cu�e�9�"i P
RECORDER O D EDS
1760
-Information denoted by an asterisk may change during
the verlfication process and may not be reflected on this page.
OOOPT9
III 11111111111111 llllllll 111
Multistate NOTE
March 26, 2010
(Date]
85 ONEMA ROAD ,CNAP IUTX.,PA 17011
(Property Addrml
1.PARTIES
"Borrower"means each person signing at the end of this Nola,and the person's successors and assigns."Lender"means
C & F MORTGAGE CORPORATION, A V WINIA CDRPMM70N
and its successors and assigns.
2.BORROWER'S PROMISE TO PAY;INTEREST
In return for a loan received from Lender,Borrower promises to pay the principal sum of One Huridred Twenty
Three Thousand Nine Htmdred Thirty One and m/100
Dollars JU-S,S 123,931.00 ),plus Interest,to the order of Tender.Interest will be charged on unpaid principal,
from the date of disbursement of the loan proceeds by Lender,at the rate of Five and Five / Eighths
percent( 5.6250 %)per year until the full amount of principal has been paid.
3.PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage,deed of bust or similar security Instrument that is dated the same date
as this Note and called the"Security Instrument."The Security Instrument protects the Lender from losses which might result if
Borrower defaults under lids Note.
4.(MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
May 1 . , 2010 .Any principal and interest remaining on the first day of April
2040 ,will be due on that date,which Is called the"Maturity Date."
(B) Place
Payment shall be made at 1400 ALVMZSER DRIVE, MIDILTH AN, VA 23113
or at such place as Lender may designate in writing
by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S.$773.42 This amount
will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, Interest and
other Items in the order described in the Security Instrument.
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments Is executed by Borrower together with this Note,the covenants of
the allonge shall be incorporated into and shall amend and supplement the covenants of ids Note as If the allonge were a part of
this Note.(Check applicable box]
QGroduated Payment Allonge Growing Equity Allonge❑Other[specify]
ntowsamas Mag r�
FHA Wft—Aced Roto Naetogs
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5.BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note,In whole or In part,without charge or penally,on the first
day of any month.Lender shad accept prepayment on other days provided that Borrower pays interest on the amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of die Secretary.If Borrower makes a
partial prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in
writing to those changes.
6.BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument,as described in Paragraph
4(C)of this Note,by the end of fifteen calendar days after die payment is due,Lender may collect a late charge in the amount
of Four' percent( 4.0000 9b)of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay In fail any monthly payment,Then Lender may,except as limited by regulations
of the Secretary in the case of payment defaults,require immediate payment in full of the principal balance remaining due and
all accrued interest.Lender may choose not to exercise this option without waiving its rights In die event of any subsequent
default.In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in
full in the case of payment defaults.This Note does not authorize acceleration when not permitted by HUD regulations.As used
in Oils Note,"Secretary"means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required Immediate payment in full,as described above,Lender may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable
taw,Such fees and costs shall bear interest from die date of disbursement at the same rale as the principal of this Note.
7.WAIVERS
Borrower and any other person who has obligations under Ihis Note waive the rights of presentment and notice of
dishonor."Presentment"means the right to require Lender to demand payment of amounts due."Notice of dishonor"means the
right to require Lender to give notice to other persons that amounts due have not been paid.
9.GIVING OF NOTICES
Unless applicable law requires a different method,any notice that must be given to Borrower under this Note will be given
by delivering it or by mailing it by first class mail to Borrower at the property address above or al a different address If
Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in
Paragraph 4(B)or al a different address if Borrower is given a notice of that different address.
9.OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs lids 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 tidngs.Any person who takes over these obligations,including the obligations of a guarantor,surely
or endorser of this Note,Is also obligated to keep all.of the promises made in this Note.Lender may enforce Its rights under Olds
Note against each person individually or against all signatories together.Any one person signing this Note may be required to
pay all of the amounts owed under this Note.
TROWS60988 2WM 1
VMPM�utUsrote F7"ea Rate Nile r�'VMP,R(a90gA0
WOO—Klu—Fift dal SMIM Pig"20/7
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BY SIGNING BELOW,Borrower accepts and agrees he terms and covenants contained in this Note.
H' eal) (Seal)
BMTf1*M M. TRaM=GE ower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
Qui to IWGRW 0t:
Without nk,
JPMorgan
BY,
11WAREESE AS 9TAM
TROW860988 860981
FHA MUIUfmto Ftred Rete Nom c
1 VMPI v�060� ;
Woft-10—F,n.CW,Sa*O \ !to
PAY 70 7KC ORDER OF
1PRORyCAN CRASC BANK, N.A.
0171VOLU RCCOURSC
C&lz 11OR79AsC CORPORA71ON
flay f . W(UZ
VICE PX XD&V7
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL J"1
For Undeliverable Mail Only
9214 8901 0754 4635 1779 64
001132-I of 4 NSPOHDLA-CA J0544988 0000000
BETHANNE M KLIPPEL
85 ONEIDA RD
CAMP HILL PA 17011
I�
1
Chase(OH4-7399) CHASE !i
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
03/25/2014
BETHANNE M KLIPPEL
85 ONEIDA RD
CAMP HILL,PA 1.7011
NOTICE OF INTENT TO FORECLOSE MORTGAGE
Account: --
Property Address: 85 ONEIDA RD
CAMP HILL,PA 17011 (the"Property")
Dear BETHANNE M KLIPPEL:
Under the terms of the Mortgage or Deed of Trust("Security Instrument")securing your Loan,JPMorgan
Chase Bank,N.A.("Chase"),as servicer of your loan,hereby notifies you of the following:
1. You are in default because you have failed to pay the required monthly installments commencing
with the payment due 12/01/2013 for the mortgage held by JPMorgan Chase Bank,National
Association.
2. As of 03/25/2014,total monthly payments(including principal,interest,and escrow if
applicable),late fees,insufficient funds(NSF)fees,and other fees and advances due under the
terms of your loan documents in the total amount of$3,876.48 are past due.This past-due amount
is itemized below.If applicable,your account may have additional escrow amounts that have
been paid out and are due on the Loan.
3. If you have any questions about the amounts detailed below,please contact us as soon as possible
at 800-848-9380.
Total Monthly Payments $3,876.48
Late Fees $0.00
NSF Fees $0.00
Other Fees and Advances* $0.00
Advances* $0.00
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and/or permitted by applicable law, or that were authorized for services
rendered.If you need additional in formation regarding any of these amounts,please
contact us at the number provided below.
Certified Article#:9214 8901 0754 4635 1779 64 001132-2 of 4 NSPOHDLA-CA J0544988 0000000
You arc also responsible for paying any amounts that become due from the date of this letter
through the expiration date of 04/27/2014 set forth in Paragraph 4 below. These amounts may
include,but are not limited to,taxes,insurance,inspection fees and other fees,as permitted by
applicable law.
If you have any reason to dispute the past-due amount listed above,or if you believe your Loan is
current,please contact us at the number provided below.
4. If you are unable to pay your account current within 33 days,we intend to exercise our right to
accelerate the mortgage payments.This means that whatever is owed on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in monthly installments.If full payment of the amount of default is not made within 33
days,we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged
property. If the mortgage is foreclosed,your mortgaged property will be sold by the sheriff to pay
off the mortgage debt.If we refer your case to our attorneys,but you cure the default before they
begin legal proceedings against you,you will still have to pay the reasonable attorney's fees,
actually incurred,up to$50.00.However,if legal proceedings are started against you,you will
have to pay the reasonable attorney's fees even if they are over$50.00. Any attorney's fees will be
added to whatever you owe us,which may also include our reasonable costs.If you cure the
default within the 33-day period,you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage.
5. You have the right to cure the default,or anyone acting on your behalf,and pay your account
current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other
judicial sale,not more than three times in any calendar year.To do so,you must:
a) Pay or tender in the form of cash,cashier's check or certified check all sums that
would have been due at the time of payment or tender in the absence of default and
the exercise of acceleration;
b) Perform any other obligation which you would have been bound to perform in the
absence of default or the exercise of acceleration;
c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to
foreclosure that were actually incurred up to and including the date the debtor cures
the default,as specified in writing by the mortgagee;
d) Pay any reasonable late penalty,if outlined in the mortgage.
Action required to cure the default:You must pay the Total Monthly Payments listed in
Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees,
NSF fees,and other fees and advances are still valid and will need to be repaid under the terms of
your loan documents.
6. If you fail to cure the default on or before 04/27/2014,Chase may accelerate the maturity of the
Loan,declare all sums secured by the Security Instrument immediately due and payable,and
commence foreclosure by judicial proceeding and sale of the Property.If this happens,Chase will
be entitled to collect its expenses incurred in pursuing the remedies provided in the Security
Instrument,which may include,but not be limited to,allowable foreclosure/attorney fees and
other expenses permitted by your loan documents or applicable law.
7. If permitted by your loan documents or applicable law,you have the right to reinstate after
acceleration of the Loan and the right to bring a court action to assert the nonexistence of a
default or any other defense to acceleration,foreclosure,and sale.However,the amount required
to reinstate maybe higher than what is owed under Paragraph 2 above due to additional fees and
charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law,
related to any foreclosure action we initiate.
Certified Article#:9214 8901 0754 4635 1779 64
i
8. Kindly remit the total amount due,shown in Paragraph 2 above,to the remittance address listed
below.Please note that Chase policy requires certified funds if two insufficient funds(NSF)
payments have been received in the last six months. In this event,Chase will not accept a Direct
Check,FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches.
Please refer to the addresses below for payment information or contact us if you have any questions.
Regular Mail: CHASE
PO BOX 78420
PHOENIX,AZ 85062-8420
Overnight Mail: CHASE
PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH
PHOENIX,AZ 85034-9700
Except as required by law,we are under no obligation to accept less than the full amount owed. if
you send us less than the full amount owed,we may in our sole discretion apply such partial
payment to your Loan without waiving any default or waiving our right to accelerate the Loan and
continue with foreclosure proceedings in accordance with Paragraph 4 above.
9. If you are unable to pay the amount past due,Chase has a variety of homeowners'assistance
programs that might help you resolve your default and keep your home;however,we need to talk
with you to discuss these options and determine which of them might be appropriate for your
circumstances.Please call us as soon as possible at 800-848-9380.
10. While the Loan remains in default,we will perform certain tasks to protect our interest in the
Property,including visits to your Property at regular intervals during the default.This will be done
to determine,as of the date of the inspection the property condition,occupancy status,and,possibly,
your plans for curing the default and paying this Loan on time. You should anticipate that any costs
incurred by Chase will be added to the amount you now owe if permitted by your loan documents or
applicable law.
11. You have additional rights to help protect your interest in the property.You have the right to sell the
property to obtain money to pay off the mortgage debt or to borrow money from another lending
institution to pay off this debt.You may have the right to sell or transfer the property subject to the
mortgage to a buyer or transferee who will assume the mortgage debt,provided that all the
outstanding payments,charges and attorney fees and costs are paid prior to or at the sale(and that
the other requirements under the mortgage are satisfied). Contact us to determine under what
circumstances this right may exist.You have-the right to have this default cured by any third party
acting on your behalf.
Chase offers homeownership counseling services to borrowers in some areas.Counseling is also available
through a variety of nonprofit organizations experienced in homeownership counseling and approved by the
Secretary of Housing and Urban Development(HUD).A listing of such organizations may be obtained by
calling HUD toll-free at 800-569-4287 or at www.hud.gov.
Sincerely,
Chase
800-848-9380
800-582-0542 TDD/Text Telephone
www.chase.com
Enclosure
-Federal Trade Commission Pamphlet
Certified Article#:9214 8901 0754 4635 1779 64 001132-3 of 4 NSPOHDLA-CA J0544988 0000000
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service,you may be eligible for benefits and
protections under the federal Servicemembers Civil Relief Act(SCRA).This includes protection from
foreclosure or eviction.You may also be eligible for benefits and protections under state law. SCRA and
state military benefits and protections also may be available if you are the dependent of an eligible
servicemember.
Eligible service may include:
• Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or
• Active service as a commissioned officer of the National Oceanic and Atmospheric
Administration,or
• Active service as a commissioned officer of the Public Health Service,or
• Service with the forces of a nation with which the United States is allied in a war or military
action,or
• Service with the National Guard of a state militia under a state call of duty,or
• Any period when you are absent from duty because of sickness,wounds,leave,or other lawful
cause.
For more information,please call Chase Military Services at 866-840-5826,
An important reminder for all our customers: As stated in the"Questions and Answers for
Borrowers about the Homeowner Affordability and Stability Plan"distributed by the Obama
Administration,"Borrowers should beware of any organization that attempts to charge a fee for
housing counseling or modification of a delinquent loan,especially if they require a fee in advance."
Loan modification scams should be reported to PreventLoanScams.org or by calling
888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge(i.e.,no
modification fee required).Please call us immediately at 866-550-5705 to discuss your options.The
longer you delay,the fewer options you may have.
We are attempting to collect a debt,and any information obtained will be used for that purpose.
If you are represented by an attorney,please refer this letter to your attorney and provide us with
the attorney's name,address and telephone number.
To the extent your original obligation was discharged,or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or
informational purposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation. However,a secured party retains rights under its security
instrument,including the right to foreclose its lien.
BR840
Certified Article#:9214 8901 0754 4635 1779 64
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Facing foreclosure? Scammers are targeting people having trouble paying their mortgages.
Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan
modifications — for a fee. The Federal Trade Commission, the nation's consumer protection
agency,wants you to know how to avoid scams that could make your housing situation go from bad
to worse.
Don't Get Hit by a Pitch. Imitations = Frustrations.
"We can stop your foreclosure!" Some con artists use names,phone numbers,
"97%success rate!" and websites to make it look like they're part
"Guaranteed to save your home!" of the government.If you want to contact a
These kinds of claims are the tell-tale signs of government agency,type the web address
a foreclosure rip-off. Steer clear of anyone directly into your browser and look up any
who offers an easy out. address you aren't sure about. Use phone
numbers listed on agency websites or in other
Don't Pay for a Promise. reliable sources,like the Blue Pages in your
Don't pay any business, organization, or phone directory. Don't click on links or open
person who promises to prevent foreclosure or any attachments in unexpected emails,
get you a new mortgage. These so-called
"foreclosure rescue companies"claim they Talk to a HUD-Certified Counseling
can help save your home, but they're out to Agency - For Free.
make a quick buck. Some may request hefty If you're having trouble paying your mortgage
fees in advance—and then stop returning your or you've already gotten a delinquency notice,
calls. Others may string you along before free help is a phone call away. Call 1-888-995
disclosing their charges. Cut off all dealings if -HOPE for free personalized advice from
someone insists on a fee. housing counseling agencies certified by the
U.S.Department of Housing and Urban
Send Payments Directly. Development(HUD). This national hotline—
Some Scammers offer to handle financial open 24/7—is operated by the
arrangements for you,but then just pocket Homeownership Preservation Foundation,a
your payment. Send your mortgage payments nonprofit member of the HOPE NOW
ONLY to your mortgage servicer, Alliance of mortgage industry members and
HUD-certified counseling agencies. For free
Don't Pay for a Second 00inlon. guidance online,visit www.hopenow.com.
Have you applied for a loan modification and For free information on the President's plan to
been turned down?Never pay for a"second help homeowners,visit
opinion." www.makinghomeaffordable.gov.
Itecleral Trode Gornmissii n
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Certified Article#:9214 8901 0754 4635 1779 64 001132-4 of 4 NSPOHOLA-CA J0544988 0000000
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Call
1 -888-995-HOPE
for free personalized guidance from housing counseling agencies certified
by the U.S. Department of Housing and Urban Development. The
Homeowner's HOPETM Hotline - open 24/7 - is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD-certified counseling agencies. Or visit
www . hopenow. com
For free information on the President's plan to help homeowners, visit
www. makinghomeaffordable . gov
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Pennsylvania Verification
Paul Burrier , 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.
p��
Paul Burrier
Vice President
Date: 06/17/14
JPMorgan Chase Bank,N.A
Borrower: KLIPPEL, BETHANNE
Property Address: 85 ONEIDA RD CAMP HILL PA 17011
County: CUMBERLAND
Last Four of Loan Number:8430
FORM 1
IN THE COURT OF COMMON PLEAS OF
JPMorgan Chase Bank,National Association CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff(s)
VS.
co
Bethanne M. Trowbridge a/k/a Bethanne M.
Klippel
85 Oneida Road - '
Camp Hill, PA 17011 �( ' y U CD
U -c C 7 c
"T1
DEFENDANT
71-n '
Defendant(s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
� d
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
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 ❑ Listing Date: Price:$
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
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
' •First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount:$ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the Loan in Bankruptcy? Yes 0 No 0
If yes,provide names, location of court, case number& attorney
Assets Amount Owed Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1: Model: Year:
Amount Owed: Value:
Automobile#2: Model: Year:
Amount Owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount Owed: Value:
Monthly Income:
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses:(Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2° Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. Payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/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 0 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 in 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
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.
Bethanne M. Trowbridge a/k/a Bethanne M.
Klippel
85 Oneida Road
Camp Hill, PA 17011
DEFENDANT
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
FORM 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS.
Defendant(s) Civil
CASE MANAGEMENT ORDER
AND NOW,this day of , 20 , 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 at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference,the
defendantiborrower 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 may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within 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
who participates in the Conciliation Conference must possess the actual authority to
reach a mutually acceptable resolution, and counsel for 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 a 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
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff(s)
VS.
Defendant(s) Civil
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:
Date [Signature of Counsel for Plaintiff]
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:
CUSTOMERJPRIMARY
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household How Long?
• C • " • '
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 ❑ No ❑
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 paving)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortage Food
2°d Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. Payment
Install. Loan Payment Cable TV
Child Su ort/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 in 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
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)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff i r
Qt�rtar of t.�wimber/4�� �� j ��J%t ^ 1
Jody S Smith f 2314 JUL
Chief Deputy 14 Pil -,,
Richard W Stewart- UMBER/.
Solicitor
OFFICE OF TH„. sF?.RirrPENNSYLVANIA
L 4 N C G �ii"+� T y
�ENNS YLVA NIA
JPMorgan Chase Bank, National Association
vs.
Bethanne M Trowbridge
SHERIFF'S RETURN OF SERVICE
Case Number
2014-8 7
3Yr7
07/03/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as "Not Served" at 85 Oneida Road, Lower Allen, Camp
Hill, PA 17011. There were no occupants other than the defendant Bethanne Trowbridge.
07/03/2014 05:20 PM - 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:
Bethanne M Trowbridge at 85 Oneida Road, Lower Allen, Camp Hill, PA 17011.
R N BURGETT, DEPU
SHERIFF COST: $54.95 SO ANSWERS,
July 07, 2014 RONNW R ANDERSON, SHERIFF
(c) CountySuite Sheriff, TeleosoTt, Inc.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO.
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. 14-045934
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT
78447 1 Sfp 17 41111: 09
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-3817
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $126,549.85 in favor of the Plaintiff and against
the Defendant, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within
20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the
Complaint:
Principal of Mortgage Debt Due and Unpaid
Interest Accrued
Late Charges
Escrow Advances
Property Inspection
Attorney Fees & Costs of Foreclosure
TOTAL
BY:
AND NOW, judgment is entered in favor of
damages are assessed as above in the sum of $126,549.85:
i.iu.,3,D..Csi2, £ QUE
aintiff ar against the Dndant and
$117,586.00
$5,511.80
$77.52
$2,067.78
$28.00
$1,278.75
$126,549.85
attorney for Plaintiff
14-045934
Pro. Prbtliy. 4
'111).1)11'el
czAk-sittc/9-
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. 14-045934
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
PLAINTIFF 14-3817
VS.
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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: /Ib/l4
Sworn to and subscribed
before me this (U day
of ,1(,i1/jb-riv, 2014.
BY:
SHAPIRO & DeNARDO, LLC
ys for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jennifer M. Sharkey, Notary Public
Upper Merion Twp., Montgomery County
My Commission Expires Oct. 19, 2014
Member. Pennsylvania Association of Notaries
Department of Defense Manpower Data Center
Status Report
Pursuant to Servicemembers Civil Relief Act.
Last Name: TROWBRIDGE
First Name: BETHANNE
Middle Name: M.
Active Duty Status As Of: Sep -16-2014
Results as of : Sep -16-2014 04:49:02 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 --s -. 4-
- r No"
NA
This response reflects the individuals' active dutstatus based on the Active Duty Status Date
•v .A
i
Left Active Duty Within 367 Das of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA -
t - - No"'� i '
NA
This response reflects where the individual left active duty status within 387 days preceding the Active Duty Status Date
The Member or HisMer Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA .
- No.
NA
This response reflects whether the individual or his/her unit has received'eady notificatioh to report for active duty
•
--C
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 Defdnse Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
"`i2eporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (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: MDI5V986E060ACO
Department of Defense Manpower Data Center
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: KLIPPEL
First Name: BETHANNE
Middle Name:
Active Duty Status As Of: Sep -16-2014
Results as of : Sep -16-2014 04:48:16 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 reflect; -the individuals' active duty status based on the Active Duty Status Date
.ti
Left Active Duty Within 367 Day s of Active Duty Status Date
Active Duty Start Date
Active Duty End Date1
StatusA
Service Component
NA
NAS \
— N .
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Dirty Status Date
The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
. NA `. ` -
- f '•No' I
NA
This response reflects whether the individual or his/her unit has received earlynotification to report for active duty
%,
- :r
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (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 DefCnse Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
'—'Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiersand 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 (0 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: PDZEP966A05F8D0
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. 14-045934
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14-3817
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
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,
September 3, 2014 to the following Defendants:
Bethanne M. Trowbridge a/k/a Bethanne Klippel, 85 Oneida Road, Camp Hill, PA 17011
heresa Bes e egal Assistant
to Christopher A. DeNardo, Esquire for
Shapiro & DeNardo, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY ID. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY ID. 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. 14-045934
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14-3817
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Bethanne M. Trowbridge a/k/a Bethanne Klippel
DATE OF NOTICE: September 3, 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
717-249-3'166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en
este caso. Al no tomar la accion debida dentro de un termino de diez (10) Bias de la fecha de esta
notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba
alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes.
Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o Si no
tiene dinero suficiente para tal servicio, vaya en persona o name por telefono a la oficina cuya
direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Bethanne M. Trowbridge alk/a Bethanne Klippel, 85 Oneida Road, Camp Hill, PA 17011
Date: q- 5- (
BY:
RO & DeNARDO, LLC
ii orneys for P.
CAITLIN M. DONNELLY,
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. 14-045934
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Bethanne M. Trowbridge a/k/a Bethanne
Klippel NO:14-3817
DEFENDANT
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:
Bethanne M. Trowbridge a/k/a Bethanne Klippel, 85 Oneida Road, Camp Hill, PA 17011
Date Mailed:
Date:
SHAPIRO & DeNARDO, LLC
ys for Plaintiff
EZQ
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. 14-045934
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Bethanne M. Trowbridge a/k/a Bethanne
Klippel NO:14-3817
DEFENDANT
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
and that the last known address of the judgment debtor (Defendant) is:
Bethanne M. Trowbridge a/k/a Bethanne Klippel
85 Oneida Road
Camp Hill, PA 17011
Date:
14-045934
SHAP RO & DeNARDO, LLC
BY: 4/ELferl
�Setf
ys for .yP� Plaintiff p ! I
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: Bethanne M. Trowbridge a/Ida Bethanne Klippel
85 Oneida Road
Camp Hill, PA 17011
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Bethanne M. Trowbridge a/Ida Bethanne
Klippel
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-3817
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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
JPMorgan Chase Bank, National Association
PLAINTIFF
vs.
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
( ) Other ILI 'jr(-)1
File No.
Amount Due $126,549.85
r --‘z
Interest September 1, 2014 to Mar1i..4,
2015 is $3,608.06 m co cc)
Fri rrl
Atty's Comm
Costs
r--
0 •
CD
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account
based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act
7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date: oorN
1)4,10A dEtas.50)Da
st- as C -r -Cc -
10'7, ) (
/(P
Signature:
Print Name.(ins' y J Osborne
Address: 160li Horizon Drive, Suite 150
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 312169
(1).
e)04- Ple,Dvva6
3Iii,A
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the
Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania
more particularly described as follows:
BEGINNING at a point on the Western side of Oneida Road, 118.08 feet North of the Northwest
corner of Oneida Road and Seneca Avenue; said point also being at the dividing line between
Lots Nos. 25 and 26 on Plan of Lots hereinafter mentioned; thence South 58 degrees 40 minutes
West along said dividing line and along the dividing line between Lots Nos. 24 and 26 on said
Plan, 125.13 feet to a point on line of Lot No. 23 on said Plan; thence North 31 degrees 20
minutes West along same, 62.5 feet to a point; thence North 58 degrees 30 minutes East, 100.58
feet to a point on the Western side of Oneida Road; thence South 59 degrees 32 minutes 30
seconds East along same, 67.5 feet to a point, the place of beginning.
BEING Lot No. 26 on Plan of Lots known as "Keewaydin" which plan is recorded in the Office
of the Recorder of Deeds in and for Cumberland County in Plan Book 4, pages 42 and 87.
BEING thereon erected a one story frame dwelling known and numbered as 85 Oneida Road.
PARCEL No. 13-23-0555-098
BEING the same premises which Pamela Ann Curran, single person, by Deed dated July 28,
2005 and recorded July 20, 2005 in the Cumberland County Recorder of Deeds Office in Deed
Book 270, page 551, granted and conveyed unto Bethanne M. Trowbridge, single person.
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. 14-045934
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT
ETio.ki:10 F
tioN
CON
I.
1: /0
Ofir y
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-3817
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 85 Oneida Road, Camp Hill, PA 17011.
Name and address of Owner(s) or Reputed Owner(s)
Bethanne M. Trowbridge a/k/a Bethanne Klippel
85 Oneida Road
Camp Hill, PA 17011
2. Name and address of Defendant in the judgment:
Bethanne M. Trowbridge a/k/a Bethanne Klippel
85 Oneida Road
Camp Hill, PA 17011
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
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH
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
85 Oneida Road
Camp Hill, PA 17011
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:
14-045934
SHAP RO & DeNARDO, LLC
Bra iE11 3 Osborne
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
- `<`
.-- t 1 -
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. 14-045934 -57 (9
JPMorgan Chase Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Bethanne M. Trowbridge a/k/a Bethanne
Klippel NO: 14-3817
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
n a Bethanne M. Trowbridge a/k/a Bethanne Klippel
85 Oneida Road
Camp Hill, PA 17011
Your house (real estate) at:
85 Oneida Road, Camp Hill, PA 17011
13-23-0555-098
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 $126,549.85 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:
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.
14-045934
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the
Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania
more particularly described as follows:
BEGINNING at a point on the Western side of Oneida Road, 118.08 feet North of the Northwest
corner of Oneida Road and Seneca Avenue; said point also being at the dividing line between
Lots Nos. 25 and 26 on Plan of Lots hereinafter mentioned; thence South 58 degrees 40 minutes
West along said dividing line and along the dividing line between Lots Nos. 24 and 26 on said
Plan, 125.13 feet to a point on line of Lot No. 23 on said Plan; thence North 31 degrees 20
minutes West along same, 62.5 feet to a point; thence North 58 degrees 30 minutes East, 100.58
feet to a point on the Western side of Oneida Road; thence South 59 degrees 32 minutes 30
seconds East along same, 67.5 feet to a point, the place of beginning.
BEING Lot No. 26 on Plan of Lots known as "Keewaydin" which plan is recorded in the Office
of the Recorder of Deeds in and for Cumberland County in Plan Book 4, pages 42 and 87.
BEING thereon erected a one story frame dwelling known and numbered as 85 Oneida Road.
PARCEL No. 13-23-0555-098
BEING the same premises which Pamela Ann Curran, single person, by Deed dated July 28,
2005 and recorded July 20, 2005 in the Cumberland County Recorder of Deeds Office in Deed
Book 270, page 551, granted and conveyed unto Bethanne M. Trowbridge, single person.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
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JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
Vs. NO 14-3817 Civil Term
CIVIL ACTION — LAW
BETHANNE M. TROWBRIDGE a/k/a BETHANNE KLIPPEL
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(I) 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: $126,549.85 L.L.: $.50
Interest SEPTEMBER 1, 2014 TO MARCH 4, 2015 IS $3,608.06
Atty's Comm: Due Prothy: $2.25
Atty Paid: $203.70 Other Costs:
Plaintiff Paid:
Date: 9/17/14
Day
(Seal) By:
Deputy
REQUESTING PARTY:
Name: BRADLEY J. OSBORNE, ESQUIRE
Address: SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 312169
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,
ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO.
312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO.
203437
LEEANE 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. 14-045934
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Bethanne M. Trowbridge a/k/a Bethanne
Klippel
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-3817
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: \ M, J' By:
1
14-045934
SHAPIRO & DENARDO, LLC
rri Haas
Legal Assistant
U.S. POSTAGE *PITNEY BOWES
simmwol
Name and Address of Sender
Shapiro & DeNardo, LLC
3600 Horizon Drive
Suite 150
King of Prussia, PA 19406
Check type of mail or service:
0 Certified 0 Recorded Delivery (International)
0 COD 0 Registered
13 Defivery Confirmation 0 Return Receipt for Merchandise
0 Express Mail 0 Signature Confirmation
0 Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional
copies of this bill)
Postmark and
Date of Receipt i
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02 14
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14-045934 MW
Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Tenant or Occupant
85 Oneida Road
Camp Hill, PA 17011
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
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