HomeMy WebLinkAbout14-3868 i
t
Court of Common Pleas
Civil Cover Sheet For Prothonotary Use Only:
Docket No: (,1
Cumberland County x
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 by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff's Name: JPMorgan Chase Bank, Lead Defendant's Name: Unknown Heirs, Successors,
C National Association Assigns and All Persons, Firms or Associations
T Claiming Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
I Dollar Amount Requested: ❑ within arbitration limits
p Are money damages requested?: ❑ Yes ® No (Check one) ® outside arbitration limits
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
❑ Zoning Board
C ❑ Other:
T ❑ Other:
I ❑ Other:
O MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort-DES
❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
B ❑ Toxic Waste El Ejectment E] 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 11112011
SHAPIRO &DeNARDO,LLC
BY: CHRISTOPHER A.DeNARDO,ESQUIRE, ATTORNEY I.D.NO. 7844T ',,'r- t
CAITLIN M. DONNELLY, ESQUIRE,ATTORNEY I.D.NO. 311403 `` `� ' lf�Q ?p jf k,
BRADLEY J. OSBORNE, ATTORNEY I.D.NO. 312169 20/4 JUL _2 �����'
CHANDRA M. ARKEMA,ATTORNEY I.D.NO. 203437 CG�tt3R1 ^
3600 HORIZON DRIVE, SUITE 150 4�1,Etl COU1,1.Y
KING OF PRUSSIA,PA 19406 PErgtNS YCVANI,'
TELEPHONE: (610)278-6800
S &D FILE NO. 14-045739
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTYr1,11
- •�
vs. ; 1 �(�8
NO: 1�'
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
1008 East.Lisburn Road
Mechanicsburg, PA 17055
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<
Q.
163 � �
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 LISTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE(20)DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
SHAPIRO &DeNARDO,LLC .
BY: CHRISTOPHER A. DeNARDO,ESQUIRE,ATTORNEY I.D.NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403
BRADLEY J. OSBORNE,ATTORNEY I.D.NO. 312169
CHANDRA M. ARKEMA,ATTORNEY I.D.NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO:
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased ;
1008 East Lisburn Road
Mechanicsburg, PA 17055
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 First
Horizon Home Loans, a Division of First Tennessee Bank,N.A., its successors
and assigns
Mortgagor(s): Holland D. Bentley, Jr.
(b) Date of Mortgage: May 2, 2008
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County Document ID# 200814865
Date: May 6, 2008
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Loan Modification:
Recorder of Deeds
Cumberland County
Date Executed: June 18, 2013
Date Recorded: July 19, 2013
Instrument No. 201323846
The Loan Modification 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 Loan
Modification is attached hereto and marked as Exhibit "B".
(e) Assignments:
Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for First
Horizon Home Loans, a Division of First Tennessee Bank,N.A., its successors
and assigns
Assignee: JPMorgan Chase Bank,National Association
Date of Assignment: January 15, 2013
Recording Date: January 22, 2013
Instrument No.: 201302096
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 1008 East Lisburn
Road, Mechanicsburg, PA 17055 and is more specifically described as attached as part of
Exhibit "A".
4. Holland D. Bentley, Jr. executed a note as evidence of the debt secured by the Mortgage
(the "Promissory Note"). A true and correct copy of the Promissory Note is attached and
marked as Exhibit "C".
5. The names and mailing addresses of the Defendants are: Unknown Heirs, Successors,
Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or
under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road, Mechanicsburg, PA
17055.
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. Holland
D. Bentley, Jr. passed away on or about November 29, 2013, thereby vesting title of the
mortgaged property unto Unknown Heirs, Successors, Assigns and All Persons, Firms or
Associations Claiming Right, Title or Interest from or under Holland D. Bentley, Jr.,
deceased.
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 October 1,
2013 and have not been paid, and upon failure to make such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of May 3, 2014:
Principal Balance Due $140,160.46
Interest Currently Due and Owing at 3.5% $3,270.40
From September 1, 2013 through April 30, 2014
Late Charges $366.97
Escrow Advances $2,319.50
Property Inspection $14.00
TOTAL $146,131.33
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 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 "D".
12. The Mortgage is insured by the Federal Housing Administration under Title lI 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: tH
BY:
Attorneys for Plaintiff
CHMMPHM A DWARDO,ESQUIRE
S & D File No. 14-045739
t •
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE �' '
CARLISLE,PA 17013
717-240-6370
Instrument Number-200814865
Recorded On 5/6/2008 At 1:24:19 PM *Total Pages-12
*Instrument Tyre-MORTGAGE
Invoice Number-20307 User ID-AF
*Mortgagor-BENTLEY,HOLLAND D JR
*Mortgagee-MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
•Customer-SEM PLE SECURE LAND TANSFER
FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $10.00
JUSTICE DO NOT DETACH
RECORDING FEES — $25.50
RECORDER OF DEEDS This page is now hart
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00 of this legal document.
ROD ARCHIVES FEE $3.00
TOTAL PAID M52.50
I Certify this to be recorded
in Cumberland County PA
�y a¢cvge�
o �f/J
— ° RECORDER O D EDS
»go
*-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
OOOPD3
IIl IIII[IIIIIIIII I IIII 111 111
X
r
Prepared By:
FIRST HORIZON HOME LOANS,
A DIVISION OF FIRST TENNESSEE BANK N.A.
4076 MARKET STREET
CAMP HILL, PA 17011
Return To:
FHHL - POST CLOSING MAIL ROOM
1555 W WALNUT HILL LN #200 MC 6712
IRVING, TX 75038
Parcel Number: County:
City:
Premises: 1008 E LISBURN ROAD
Mechanicsburg, Pennsylvania 17055
[Space Above This Line For Recording Data]
Commonwealth of Pennsylvania
PURCHASE MONEY MORTGAGE
THIS MORTGAGE("Security Instrument")is given on May 2, 2008
The Mortgagor is HOLLAND D BENTLEY JR /
("Borrower").This Security Instrument is given to Mortgage Electronic Registration Systems,Inc.('HERS"),
(solely as nominee for Lender,as hereinafter defined,and Lender's successors and assigns),as mortgagee.
MFRS is organized and existing under the laws of Delaware, and has an address and telephone
number of P.O.Box 2026,Flint,MI 48501-2026,tel.(888)679-MERS.
FIRST HORIZON HOME LOANS, A DIVISION OF FIRST TENNESSEE BANK N.A. ,
("Lender")is organized and existing under the laws of THE UNITED STATES OF AMERICA ,and
has anaddress of 4000 HORIZON WAY,
IRVING, TEXAS 75063
FHA Pennsylvania Mortgage with MERS•4196
Wolters Kluwer Financial Services
age®a ocpA,t07e8,.e1 Amended 6102 11111111111111 III Illll IIII 1111 1111
J
Borrower owes Lender the principal sum of ONE HUNDRRD FORTY SMN THOUSAND
BIGHT HUNDRED THIRTY ONE & 00/100 Dollars(U.S.$ 147,831.00 ).
This debt is evidenced by Borrower's note dated the same date as this Security Instrument("Note"),which
provides for monthly payments, with the full debt, if not paid earlier, due and payable on
,TUNE 1, 2038 ✓ This Security Instrument secures to Lender.(a)the
repayment of the debt evidenced by the Note,with interest,and all renewals,extensions and modifications of
the Note;(b) the payment of all other sums,with interest,advanced under paragraph 7 to protect the security
of this Security Instrument; 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
MFRS(solely as nominee for Lender and Lender's successors and assigns)and to the successors and assigns
of MFRS,the following described property located in Cumberland
2 n kaebnnRIVa , or parcel of land as shown on Schedule "A" attached
hereto which is incorporated herein and made'a part hereof.
which has the address of 1008 E LISBURN ROAD /"� [Sweet]
Mechanicsburgll___,� [cityl,Pennsylvania 17055 [Zip Code]
("Property Address");
TOGETHER WITH all the improvements now or hereafter erected on the property,and all easements,
appurtenances and fixtures now or hereafter a part of the property.All replacements and additions shall also
be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property." Borrower understands and agrees that NMS holds only legal tide to the interests granted by
Borrower in this Security Instrument;but,if necessary to comply with law or custom,NMS,(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 take 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 the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands,subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property
VMP®-4N(PA)10708y.ot Page 2 of 10
J
ALL that certain lot of land situate in the Township of Upper
Allen, County of Cumberland and State of Pennsylvania, more
particularly bounded and described as follows, to-wit:
BEGINNING at a point in the road leading from Lisburn to
Bowmansdale at corner of lands now or late of Glenn L. Heller and
Martha A. Heller, his wife; thence in said road and along lands now
or late of Earl Hoffman and Sara Hoffman, His wife, South 61 degrees
35 minutes East 50 feet; thence along other lands of the same South 0
degrees 50 minutes East 484 feet to a point; thence along lands of
the same North 61 degrees 35 minutes West 50 feet to a point at the
corner of lands now or late of Glenn A. Heller and Martha A. Heller,
his wife; thence by said last mentioned lands North 0 degrees 50
minutes West 484 feet to a point in said road, the place of
Beginning.
1 '
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,the 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 the principal and interest as set forth in the Note and any late charges,a sum
for(a) taxes and special assessments levied or to be levied against the Property,(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 the Security Instrument, each monthly payment shall also include either. (i) a sum for the annual
mortgage insurance premium to be paid by Lender to the Secretary, or (irk a monthly charge instead of a
mortgage insurance premium if this 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 time, collect and hold amounts for Escrow Items in an aggregate amount not to
exceed the 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 et seq. and implementing regulations,24 CFR
Part 3500, as they may be amended from time to time ('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 the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA,
Lender shall account to Borrower for the excess funds as required by RESPA.If the amounts of funds held
by Lender at any time are not sufficient to pay the Escrow Items when due,Lender may notify the 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 tenders to Lender the full payment of all such sums,Borrower's account shall be credited with the
balance remaining for all installment items(a),(b),and(c)and any mortgage insurance premium installment
that Lender has not become obligated to pay to the Secretary,and Lender shall promptly refund any excess
funds to Borrower. Immediately prior to 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
3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as
follows:
EL=to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge
by the Secretary instead of the monthly mortgage insurance premium;
Second,to any taxes,special assessments,leasehold payments or ground rents,and fire,flood and other
hazard insurance premiums,as required;
Third,to interest due under the Note;
Fourth,to amortization of the principal of the Note;and
Fifth,to late charges due under the Note.
4.Fire,Flood and Other Hazard Insurance.Borrower shall insure all improvements on the Property,
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
initials'_ a
VMPn-4N(PA)1070e).01 Page 3 of 10
1 I
the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the
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.All or any
part of the insurance proceeds may be applied by Leander, at its option, either (a) to the reduction of the
indebtedness under the Note and this Security Instrument,fust to any delinquent amounts applied in the order
in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged
Property.Any application of the proceeds to 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 the Note and this
Security Instrument shall be paid to the entity legally entitled thereto.
In the event of foreclosure of this 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.
S. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. 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 Property as Borrower's principal residence for at
least one year after the date 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 Property if the Property is vacant or abandoned or the loan is in default.
Lender may take reasonable action 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 Property as a principal residence.If this Security Instrument is on a leasehold,Borrower
shall comply with the provisions of the lease.If Borrower acquires fee title to the 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 Property,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 to 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 the due date of the monthly
payments,which are referred to in paragraph 2,or change the amount of such payments.Any excess proceeds
over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall
be paid to the entity legally entitled thereto.
lnitlats:J
VMP&.4N(PA)tomst.oi Page 4 of 10
e
7.Charges to Borrower and Protection of Lender's Rights in the Property.Borrower shalt pay all
governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower
shall pay these obligations on time directly to the entity which is owed the payment.If failure to pay would
adversely affect Lender's interest in the Property,upon Lender's request Borrower shall promptly furnish to
Lender receipts evidencing these payments.
. If Borrower fails 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 Property and Lender's rights in the Property, including payment of taxes,hazard
insurance and other items mentioned in paragraph 2.
Any amounts disbursed by Lender under this 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 rate,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 the 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 satisfactory to Lender subordinating the lien to this Security Instrument.If Lender
determines that any part of the Property is subject to a lien which may attain priority over this Security
Instrument,Lender may give Borrower a notice identifying the lien.Borrower shall satisfy the lien or take
one or more of the actions set forth above within 10 days of the giving of notice.
S.Fees.Lender may collect fee's and charges authorized by the Secretary.
9.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 this Security Instrument
(i) 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
(ii)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(d)of the Garn-St.Germain Depository Institutions Act of 1982,12 U.S.C. 1701j-3(d))and with
the prior approval of the Secretary,require immediate payment in full of all sums secured by this
Security Instrument if:
(i)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
(ii)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.
Initlals:
VMPO.M(PA)t=el.ot Pages of 10
n
i
13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by
delivering it or by mailing 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 shall 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 the Property 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
this 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.
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 cause or permit the 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 Property of small quantities of Hazardous
Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of
the 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 Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge.If Borrower learns,or
is notified by any governmental or regulator; authority, that any removal or other remediation of any
Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law.
As used in this 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 Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues
and hereby directs each tenant of the Property to pay the 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 collect 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) Lander shall be entitled to collect and receive all of the rents of the Property; and (c) each
Inhlals:_
VMP3 4N(PA)t070et.01 Page 7 o1 10
tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written
demand to the 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, take control of or maintain the Property 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 the Property shall terminate when the debt secured by
the Security 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 in 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 the estate conveyed shall terminate and become void.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;he extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instrument,and hereby waives the benefit of any present or
future laws providing for stay of execution,extension of time,exemption from attachment,levy and sale,and
homestead exemption.
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 this 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 Property,this Security Instrument shall be a purchase money mortgage.
23.Interest Rate After Judgment.Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under
the Note.
24.Riders to this Security Instrument.If one or more riders are executed by Borrower and recorded
together with this 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 the rider(s)were a part
of this Security Instrument[Check applicable box(es)].
Condominium Rider ❑Growing Equity Rider Q Other[specify]
Planned Unit Development Rider El Graduated Payment Rider
VMPGAN(PA)(0708).01 Page a 01 10
1
i
This is a contract under seal and may be enforced under 42 PA.C.S.Section 5529(b).
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:
e— - (Seal)
HOLLAND D BENTLEY—n Borrower
(Seal)
-Borrower
1:
(Seal) (S--ai)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
VMP@.4N(PA)(one(.0f Page 9 of 10
c
COMMONWEALTH OF PENNSYLVANIA, CUMBERLAND County ss:
On this, Z day of rY)aq t ZOOS ,before me,the undersigned officer,
personally appeared HOLLAND D BIMMEIY JR
known to me(or satisfactorily proven)to be the
person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that he/she/they
executed the same for the purposes herein contained.
IN WITNESS Wl E EOF,I hereunto set my hand and official seal.
My Commission Expires: ` -,�. p,�
Com MONWBALTU 9F2as-YLi ANIA
NoteriaiSeat
Stacy M.Omer Notary Public
tower Allen 7wp.,aumbedand County Title of Officer
My Commission E7rplres Nov 2,2008
Member,Pennsylvania Associatlan of Notaries
. I.
Certificate of Residence
I, �j'C do hereby certify that
the correct address of y�a within-named Mortgagee is P.O.Box 2026,Flint,MI 48501-2026.
Witness my hand this Z^ day of m" I 200K
Agent of Mortgagee
OMMONWBALTU.QE LENNSYLVANTA
NotarialSeol
Stacy NL Omer,Notary Public
LowerAilen Up.,Cumberland County
My Commission Expires Nov 2,2008
Member,Pennsylvania Association of Notaries
Initials: /-0,9
VMP®-4N(PA)(o7oe)•o1 Page 10 0110
Recording Requeelad BylRet:rn Ta:
JPMORGAN CHASE BANK,
CHASE RECORDS CEN'T'ER
RE:COLLATERAL TRAILING
DOCUMENTS
PO BOX BUBO
MONROE,LA 71203 a a
(800)848-9380
Ttlfa I11901LIaMant Pttapared 13y.
JPMORGAN CHASE(SANK,N.A.
3419 VISION DRIVE
COLUMBUS,OHIO 43219.6009
Parcel Identification Number:
42302128031
(Space Above This Line For Recording Date]
LOAN MODIFICATION AGREEMENT
Burrower(1')': HOLLAND D BENTLEY JR
Lender("Lender"):JPMORCAN CHASE BANK,N.A.
Date of First Lien Security Instrument("Mortgage")and Note("Nola"):MAY 02,2008
Loam Number: 1955473135("Coen")
Property Address: 1008 E LISBURN RD,MECHANICSBURG,PENNSYLVANIA 17035("pmperiy")
Modification Effective Date: JULY U1,2013
0rlglnal Mortgage Amount: $147,831.00
LEGAL DESCRIPTION;
TRACT NO,1 AT AI,L THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF UPPER
ALLEN, COUNTY OF CUMBERLAND,STATE OF PENNSYLVANIA,MORE PARTICULARLY
BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT:AT BEGINNING AT A POINT IN THE ROAD
LEADING FROM LISBURN TO SOWMANSDALE AT CORNER OF LANDS NOW OR LATE OF
GLENN L.HELLER AND MARTHA A.HELLER,HI$WIFE:THENCE IN SAID ROAD AND ALONG
LANDS NOW OR LATE OF EARL HOFFMAN AND SARA HOFF'MAN,WS WIFE,SOUTH til
DEGREES 35 MINUTES EAST,50,00 FEET,THENCE ALONG OTHER LANDS NOW OR
FORMERLY OF THE SAME,SOUTH 00 DEGREES 50 MINUTES FAST,41114,00 FEET TO A POINT;
THENCE ALONG LANDS NOW OR FORMERLY OF THE SAME,NORTH 61 DEGREES 35
MINUTES WEsT,50.00 FEET TO A POINT AT THE CORNER OF LANDS NOW OR LATE OF
GLE14N A.HELLER AND MARTHA A.HELLER,HIS WIFE;THENCE BY SAID LAST MENTIONED
LANDS,NORTH 00 DEGREES 50 MINUTES WEST,484.00 FEET TO A POINT IN SAID LOAD,
THE PLACE OF BEGINNING.AT TRACT NO.2 AT ALI,THAT CERTAIN LOT OF LAND SITUATE
1 R tom IN mals Bien one @answer or Martgsper necupnt we document,each Is teterMd to as T,For purposes of Ihle wtumenl w9ft
09rdMnp dra slnpulor(such es M)shap rpqude the plural(auch 4S*we*)and'41ce varse More spplspilere.
WF1OH IOAN MOPIFICATION AOREEMLNT-CRAMP vor.06_15 2D13 11 01_13
• Page i d8 pages
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• Inst. 20`132a846-page 1 of 10
i
IN THE TOWNSHIP OF UPPER ALLEN.COUNTY OF CUMISRRLAND,AND STATE OF
PENNSYLVANIA,BEING MORE PARTICULARLY BOUNDED AND DESCRIISEDi AS FOLLOWS,
TO WIT:AT BI~OMING AT AN IRON PIN IN THE ROAD LEADING FROM LiSBURN TO
SOWMANSDALE AT THE CORNER OF LANDS NOW OR LATE OF RAYMOND MILLER;THENCE
IN SAID ROAD AND ALONG OTHER LANDS NOW OR FORMERLY OF EARL W.HOFFMAN AND
SARAH F.HOFFMAN,HIS WIFE,SOUTH 61 DEGREES 35 MINUTES EAST 85.8 FEET TO A
POINT 1N aSAiD ROAD;THENCE ALONG OTHER LANDS NOW OR FORMERLY OF EARL,W.
HOFFMAN AND SARAH F.HOFFMAN, HiS WIFE:,SOUTH 00 DEGREES 50 MINUTES EAST,
484,00 FM TO A PiN;THENCE BY THE SAME,NORTH 81 DEGREES 35 MINUTES MST,
90.104 FORT TO A PIN;THENCE BY THE SAME,NORTH 00 DEGREES 50 MINUTES WEST,
484.00 FEET TO A POINT IN SAID ROAD FiRST ABOVE MENTIONED;THENCE?IN SAID ROAD
ALONG LANDS NOW OR LATE OF RAYMOND MILLER,SOUTH 61 DEGRIIES 36 MINUTE8
EAST,34.1 FEET TO A PIN AT THE POINT OF PLACE;OF BEGINNING.AP NO,42302120031
REFERENCE NUMDEcRS OF DOCUMENTS MODIFiED.,
RECORDED MAY 06,2008 INSTRUMENT NO.200814065
Tax Parcel No:42302120031
If my representations In Section 1 continue to be true in all material inspects, then the pruvigions of
5eation 2 of this Loan Modification Agreemtant("Agreement")will,as set forth in Section 2,arr.nnd and
supplement (i) the Mortgag9 on tha Property, and (11) the Note secured by the Mortgage, The
Mortgage and Note together, as may previously have been emended, are referred to as the "Loan
Documents."Capitalized terms used in this Agreement have the meaning given to them In the Loan
Documents_
I have provided confirmation ur my tirltincial hardship and documents to permit verification of all of my
Income to determine whether I qualiry for the offer described in this Agreement.This Acjree;ent will
not take effect unless and until the Lender signs it.
1. My Representations.I represent to the Lender.and agree:
A i am experlenalig a financial hardship,and as a result, 5m aither in default under the Loan
Documents or a default is ImmInent.
B. The Property Is neither in a state of disrepair, nor oondemngd.
C. Th®re has been no ohange in the ownership of the Property since 1 signed the Loan
Documents.
D. I am not a party to any litigation involving the Loan Doouments,except to the extent i may be
e defendant In a foreclosure action.
E. 1 have provided dooumentation for alt incame that i earn,
F, All documents and Information I provide pursuant to this Agreement are true and correct.
WF101 LOAN MODIFICATION AGREEMENT—CHAMh ver.(>#�1Q ZDt3_t1_D1_13 Page 2o apages
11MVINN 10,0104,111"11
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2. The Nladifieation.The Loan Documents are hereby mndtfied as of JULY 01,2013
Efrvcff►e Date"), and 811 unpaid late charges are Valved. as Lender �od��lon
foreeclosure antivlfies so long as 1 comply with the terms of the Loan Do mements,as modified bsusend any
this Agreement.The Loan Documents will be modified,and the first modified payment will be due
on the Oft set forth in this Section 2:
A. The Maturity Date wdl be:JUNE 01,2043,
B. The modeled principal balance of my Notts will include all remounts and arrearages that will be
Past due(excluding unpaid late changes)and tray include amounts toward taxes, insurance,
or other assessments. The:new prina)p
sclerae"). a]balance of my Note is$140,827.30("New Principal
C. The Interest Bearing Principal Balance WR re-amortize over 360 months.
Interest will begin to Accrue as of JUNE 01, 2013. The first new monthly payment on the New
Principal Balance will be due on JULY 01,2013,and monthly on the snme dato thereafter.
My payment schedule for the modified Loan is as follows;
1 promise to pay Interest on the New Principal Balance at the rate of 3.5004/4 unnu:rlly, i
promise to make consecutive monthly payments of principal and interest In the amount of
$632.38,which is an amount sufficient to amortize the New Principal Balance over 13 perlod Of
360 months,
The above terms In tiffs Sectlori 2.0 shInIl supersede any provisions to the contrary In the Loan
Documents,Including,but not limited to,provisions for an adjustable or step Interest rate.
D. 1 agree to pay in full (f)the New Principal Balance, and(11)any other amounts still owed under
the Loan Documents, by the earliest of the date I sell or transfer an Interest in the Property,
subject to Section 3.E below,the date I pay the entire New Principal Balaneo,or the Maturity
Date,
E. I will be In default if I do not(1)pay the full amount of a monthly payment on the date it Is due,
or f1l) comply with the terms of the Loan Documents, as modified by this Agreement. If a
default rate of interest is permitted under the current Loan Documents, then in the event of
dofault,the interest that will be due op the New Prinripal Balance will be the rate set forth in
Section 2.C.
3. Ad,ditlonal Agroaments,i agree to the following:
A. That this Agreement shell supersede thrn terms of any modification, forbearance, or
workout plan,if any,that I previously entered into with the Lender,
B. To comply, except to the extent that they aro modlfie3d by this Agreement,or by the W.S.
Bankruptcy Code, vAth all oavehents, agreements, and requirements of 0* Loan
Documents,including my agreement to make all payments of taxes,insurance premiums,
WFtOt LOAN MDDIFICATON At3AEEMENT CHAMP ver,05_16 2013 1101 13 Pape 3 of a pages
35MV2014 0:$5:04.AM CUMBERLAND COUNTY InstA 201323846-Page 3 of 10
aQ=Ossmerlts, impounds, and all other payment$, the amount of which may change
periodically over the term of my Loan. This Agreement does not waive future escrow
requirsmants. If the Loan Includes collection for tax and Insurance premiums, this
collection will continue for the lye of the Loan,
C. That the Loan Documents are composed of valid, binding agreements, enforceable in
acoardenoe with their terms.
D. That all terms and provisions of the Loan Documents, except as expressly modified by
this Agreement,or by the tJ.S.Bankruptcy Code,remaln In full force and effect;nothing In
this Agreement shall i)0 understood or oonstrued to be a sak sfadjcn or release in whole
or in part of the obligations contained In the Loan Documents; and that except as
otherwise specifically provided in,and as expressly modlf1ed by,this Agreement,or by the
U.S, Bankruptcy Code,the Lender and I will be bound by, and will comply with, all of the
termsand provisions of the Loan Documents.
E. That, as of the Modifientlan Effedtkve Date, notwitlislandincg any other provision of the
Loan Documents,t agree as follows:If ell or any part of the Property or any Interest in it is
sold or transferred without the Lander's prior written consent, the Lander may, at its
option, require Immediate payment In full of all sums socured by the Mortgage.However,
the Lender shall not exercise this option if federwl law prohibits the exercise of such option
as of thn date of such salo or transfer.If the Lender exercises this optlon,the Lender shell
give me notice of acceleration.The notice shall provide a perlod of not less than thirty(ao)
days from the date the notice is'dellvered or mailed wfthln which I must pay all sums
secured by the Mortgage. If I fall to pay these sums prior to the expiration of this perlocl,
the Lender may invoke any remedies permitted by the Mortgage without further notice or
domand on me.
F. That, as of the Modification Effective Date;a buyer or transfcroa of the Property will not be
permitted, under any clrcumstande, to assume the Loan. 1n any event, this Agreement
may not be easlgned to,or assumed by,a buyur of the Property.
G. if any document is lost,misplaoed, misstated or Inaccurately reflects the true and correct
terms and conditions of the Loan Documents as amended by this Agreement,within ten
(10)days after my receipt of the Lenders request,I will execute,acknowledge, initiol,and
deliver to the tender any documentation the Lender deems necessary to replace or
correct the lost,misplaced,misstated or Inaccumto document(s). If I fall to do so, 1 will be
liable for any and all loss or damage which the Lender reasonably sustains as a result of
my failure,
H. All payment amounts specifled In this Agreement assume that payments will be made 29
scheduled.
I. That,if the Borrower Is in bankruptcy upon execution of this doeumvnt,the Borrower will
cooperate fully with the Londer In obtaining any required bankruptcy court and trustee
approvals in accordance wlth Zonal Court rules and procedures.The Borrower understands
that If such approvals are not received, than the terms of this Agreement wilt be null and
WF141 JOAN MODIF1CAYION AGREEMENT-CHAMP vat,06„18„,2013 i 1_01_19 Page 4 d 8 pages
ones M4 VVIONEM111
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' ;
vdd. if this Agreement becomes null and void,the terms of the orfginal Loan Documents
Shall c t lnue in full force and effect, and such terms shall not be modil9ad by this
Agreement.
J. If the Sorrower(s) received a discharge in a ChOpter 7 bankruptcy subsequent to the
execution of the Loan Documents,the Leakier agrees that such Borrower(a)will not have
personal liability on the debt pumuent to this Agreement.
K. That in agreeing to the changes to the originel Loan Documents as reflected in this
Agreement,the Lender has relied upon the truth and accuracy of all of the r®presentations
mads by the 8orrower(e),both In this Agreement and In any documentation provided by or
on behalf of the Bonnmgs) in connection with this Agreement. tf the Lender
subsequently determines that such representations or documentation were not truthful or
accurate, the tender may, Ot its option, rescind this Agreement and reinstate the original
terms of the Loan Documents as If this Agreement never occurred.
L I acknoWedge and agree that if the Lender executing this Agreement is not the
current holder or owner of the Note and Mortgage, that such party Is the authorized
servicing agent for such holder or owner, or its successor In Interest, and has full powa-r
and authority to bind Itsolf and such fioldar and owner to the terms of this modification.
TH18 WRITTEN LOAN AGREEMENT REPRESENTS THE FiNAL AGREEMENT BETWEEN THE
PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR,
CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE_
ARE NO UNWRiTTE;N ORAL,AGREEMENTS BETWEEN THE.PARTMS.
(SIGNATURES CONTINUE ON FOLLOWING PAGES)
W F701 LOAN MODIFICATION AGREEMENT CHAMP ver,05 18„2018 1Ijojja Page a of a PGOBS
MINI-IN M.
05/02/2014 e:t3M AM CUMBERLAND COUNTY insto 2ol sma4a.pane 5 ar io
TO BE SIGNED SY BORROWER ONLY
BORROWER SIGNATURE PAGE TO MODIFICATION AGREEMENT BETWEEN JPMQRGAN CHASE
BANK,N.A.And HOLLAND D BENTLEY JR,LOAN NUMBER 1955478135 WITH A MODIFICATION
EFFECTIVE:DATE OF July 01,2013
In Witness Whereof,ft Borrower(a)hava executed this agreement
Execution Data: b L5
Borrower. HOLLAND D BENTLEY JR
State PEf�MSYLVA�v[A O
County
0f
Qn t s,the day pF ,Wore me,
G4__ _ _ _ __ _,thr•.and usi0hod officer,personally appeared
HC! ND D BENTLEY known to me (or sliiafa fu�iiy proven)to he tho porson(S)whose name(s) Isdare
subshribed to the within Instrument, And manovvAedged that he/shelthey axecuted the same for the purposes
theraln contained.
In vAttims whereof,I hereunto set my hand and otfloial Bests,
P
My Commission Expires: T 10'14 Title o Officer:
COM+IO L OF PgNNMVAW
r MMI Seal
Teresa L.Ofter,Natary Pubila
My 0 mRbs m 14 2414
MMttrpr, n Assn atloH or Notartas
WF101 LOAN MODIFICATION AGREEMENT-.CHAMPver,pb�15 2013,11 01,f Pape 8 of 8 pages
05/0712014 9:55:04 AM Otpv MILAND COUNTY lost.#201328846•Page 8 of 10
I;
TO BE 8IIGNED BY LENoER ONLY , •
LENDER SIGNATURE PA{3E TO MODIFICATION AGREEMENT BETWEEN^011GAN CHASE BANK,
N.A.And HOLLAND D BENTLEY JR,LOAN NUMBER 1965473135 WITH A MODIFICATION EFFECTIVE
DATE OF July 01,2013
to Witness Whereof,the Lender has executed this Agreemera,
Lender
21111108GAN CHASE @MIS.N&
,X
BY:
Printed Name: arenda Nevam-Quiroga
"Ca prealdt«tlt
Execution Date:
WF141 LOAN MODIFICATION AWMEMENT-CHAMP Ver.U5_iS_1043 17_Dt_19 Page 7 of a pages
ww
2M 11
05M=014 9:58 AM CUMBERLAND COUNTY Inst*291323849,Papa 7 of 10
Stele of COLORADO ,
Countyo(DENVER
�In Instrumer waa gaktlowfed before me this day of
by CBnds iVevar x U(r , Vice Prosldent JPMORGAN CHA811 BANK,
N.A.,a net�onat banking assoclatlon,
s' Of Iserson taking edgmant)
(SEAL) F Anted Name,
rank)ran
r�rn
+ serial number,fl any)
My CommISslon expires:
1,,!i4LIALYOST0
NOTARY PUBLIC
STATE OF COLORADO
NMARY1020136og6792 201T
My COMMISSION EoWaS APRILM
WFi01 LOAN MODIMCATIONAGIREEMENT—CHAMIY ver,OS�i5„xp78 17 Qt_13 P adB
� pages
�WHOI 2911111
)5!0212014 9:66:04 AM CUMBERLAND COUNTY InsL*201323846 Page 8 of 10
Certlfkate of Residence
I,John E Cox,do hereby certify that the precise address of the wfthin named
Mortgagee is JRMOrgan Chase Bank,NA,3415 Vision Drive,Columbus,on.
Uvitness my hand this`12th day of July_,2013.
�L.
Sfgn . John E Cox
W02l2014 9:55:04 AM CUMBERLAND COUNTY Irmll 201323848-Pago 9 of 10
ROBERT P.ZIEGLEP,
RECORDER OF DEEDS
CUMBERLAND CQUIYTX
1 COURTHOUSE SQUARE
CARLISLE,PA 17013 - � .' .
717-240-65370
bstruvmt Number-201323846
.Recorded On 7/19/2013 At 1:03:29 PM *Tote)Pages-10
Imtirument Type-MODIi+'lCATION OF MORTGAGE
Invoice Number-147,418 TJN r ID-B1VII11
,Mortgegor-BENTLEY,IIOLLAND D JR
".Morfgagcc-JPN.ORGAN CITASE 13ANK N,A,
CustoMer-.C11ASE
*h"EES
STATE WRIT TAX $0.50 Certification page
RECoRDIRc3 FEES — $21.50
RECORDER Or DEEDS DQ NOT DETACH
PARCEL CERTIFICAT:roN $1.5..00
FEES
COUNTY A.RCXZVES FEE $2.00 This page is now part
Roo ARcaavzo z&E $-$.00 of this legal document.
TOTAL PAID $42 00
I Certify this to be recorded
in Cumberland County PA
�CQRbER 4 D EDS
Tofbnastioa¬ed by an Asterisk m*y change drring
tee vera intion process end tnuy not be reflected on this page,
55=2014 M04 04 Apt CUMBERLAND COUNTY
lnStiS 201323846•page 10 of 10
Multistate NOTE
May 2nd, 2008
[Date]
1008 E LISBURN ROAD, Mechanicsburg, Pennsylvania 17055
[Property Address]
1.PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
FIRST HORIZON HOME LOANS, A DIVISION OF FIRST TENNESSEE BANK N.A.
and its successors and assigns.
2.BORROWER'S PROMISE TO PAY;INTEREST
In return for a loan received from Lender,Borrower promises to pay the principal sum of
ONE HUNDRED FORTY SEVEN THOUSAND EIGHT HUNDRED THIRTY ONE & 00/100
Dollars(U.S.$ 147,831.00 ),plus interest,to the order of Lender.Interest will be charged on unpaid principal,
from the date of disbursement of the loan proceeds by Lender,at the rate of FIVE AND ONE-HALF
percent( 5.500 %)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 trust 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 this 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
July 1st , 2008 .Any principal and interest remaining on the fust day of June
2038 ,wiIl be due on that date,which is called the"Maturity Date."
(B) Place
Payment shall be made at PO BOX 809, MEMPHIS, TN 38101
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.$ 839.37 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 this Note as if the allonge were a part of this
Note.(Check applicable box)
❑Graduated Payment Allonge OGrowing Equity Allonge ❑Other(specify)
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 penalty,on the first day
of any month.Lender shall 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 the 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.
FHA Multistate Fixed Rate Note-10195
-1R(0210).01 Illlllllllllllllllllllllllllllllll
® vMP Mortgago solutions(800)521.7291
Page 1 0l 2 Initials:
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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 the payment is due, Lender may collect a late chafge in the amount of
FOUR percent( 4.00 '%)of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full 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 the 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 this 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 law.
Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7.WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require 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.
8.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 fust class mail to Borrower at the property address above or at 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 at 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 this Note,each person is fully and personally obligated to keep all of the promises made in this
Note,including the promise to pay the full amount owed.Any person who is a guarantor,surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or
endorser of this Note,is also obligated to keep all of the promises made in this Note.Lender may enforce its rights under this 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.
BY SIGNING BELOW',B'orrower accepts and agrees to the terms and covenants contained in this Note.
.44t -J6_-,CLP a (Seal) (Seal)
HOLLAND D BE LEY JR -Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
-1 R tozf ol•or Page 2 of 2
pay tothe order of
Without Recourse
First Horizon Horne Loans,a dl*lon of
First 7annossae Bank N.A.
Belinda DeArman,Senior Vice President
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL x
For Undeliverable Mail Only
. III I 111111 11 1 111
9214 8901 0754 4631 2478 21
050112-1 of 4 NSPOHDLA-CA J0462352 0000000
HOLLAND D BENTLEY JR
1008 E LISBURN RD
MECHANICSBURG PA 17055
�n
X < <
Chase(OH4-7399) CHASE Cp
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
12/02/2013
HOLLAND D BENTLEY JR
1008 E LISBURN RD
MECHANICSBURG,PA 17055
NOTICE OF INTENT TO FORECLOSE MORTGAGE
Account: NIMPAIM
Property Address: 1008
MECHANICSBURG,PA 17055 (the"Property")
Dear HOLLAND D BENTLEY JR:
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 10/01/2013 for the mortgage held by JPMorgan Chase Bank,National
Association.
2. As of 12/02/2013,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$2,186.87 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 $2,024.50
Late Fees $162.37
NSF Fees $0.00
Other Fees and Advances* $0.00
Advances* $0.00
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and/or permitted by applicable law, or that were authorized for services
rendered.If you need additional information regarding any of these amounts,please
contact us at the number provided below.
Certified Article>f:9214 8901 0754 4631 2478 21 050112-2 of 4 NSPOHDLA-CA J0462352 0000000
You are also responsible for paying any amounts that become due from the date of this letter
through the expiration date of 01/04/2014 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 01/04/2014,Chase may accelerate the maturity of the
Loan,declare all sums secured by the Security Instrument immediately due and payable,and
commence foreclosure by judicial proceeding and sale of the Property.If this happens,Chase will
be entitled to collect its expenses incurred in pursuing the remedies provided in the Security
Instrument,which may include,but not be limited to,allowable foreclosure/attorney fees and
other expenses permitted by your loan documents or applicable law.
7. If permitted by your loan documents or applicable law,you have the right to reinstate after
acceleration of the Loan and the right to bring a court action to assert the nonexistence of a
default or any other defense to acceleration,foreclosure,and sale.However,the amount required
to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and
charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law,
related to any foreclosure action we initiate.
Certified Article N:9214 8901 0754 4631 2478 21
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 1 Text Telephone
www.chase.com
Enclosure
-Federal Trade Commission Pamphlet
Certified Article#:9214 8901 0754 4631 2478 21 050112-3 of 4 NSPOHDLA-CA J0462352 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 4631 2478 21
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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,
1197%success rate!" and websites to make it look like they're part
"Guaranteed to save your homel" 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 Promisereliable 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 Opinion. guidance online,visit www.bopenow.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.
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Certified Article N:9214 8901 0754 4631 2478 21 050112-4 of 4 NSPOHOLA-CA J0462352 0000000
r
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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Certified Article#:9214 8901 0754 4631 2478 21
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL T`'
For Undeliverable Mail Only
9214 8901 0754 4631 2478 38
050113.1 of 4 NSPOHM,A-CA 70462352 0000000
HOLLAND D BENTLEY JR
1008E LISBURN RD
MECHANICSBURG PA 17055
Chase(OH4-7399) CHASE Cp
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
12/02/2013
HOLLAND D BENTLEY JR
1008E LISBURN RD
MECHANICSBURG,PA 17055
NOTICE OF INTENT TO FORECLOSE MORTGAGE
Account:
Property Address: 1008E LISBURN RD
MECHANICSBURG,PA 17055(the"Property")
Dear HOLLAND D BENTLEY JR:
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 10/01/2013 for the mortgage held by JPMorgan Chase Bank,National
Association.
2. As of 12/02/2013,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$2,186.87 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 $2,024.50
Late Fees $162.37
NSF Fees $0.00
Other Fees and Advances* $0.00
Advances* $0.00
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and/or permitted by applicable law, or that were authorized for services
rendered.If you need additional information regarding any of these amounts,please
contact us at the number provided below.
Certified Anicle C 9214 8901 0754 4631 2478 38 050113-2 of 4 NSPOHDLA-CA J0462352 0000000
You arc also responsible for paying any amounts that become due from the date of this letter
through the expiration date of 01/04/2014 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 01/04/2014,Chase may accelerate the maturity of the
Loan,declare all sums secured by the Security Instrument immediately due and payable,and
commence foreclosure by judicial proceeding and sale of the Property.If this happens,Chase will
be entitled to collect its expenses incurred in pursuing the remedies provided in the Security
Instrument,which may include,but not be limited to,allowable foreclosure/attorney fees and
other expenses permitted by your loan documents or applicable law.
7. If permitted by your loan documents or applicable law,you have the right to reinstate after
acceleration of the Loan and the right to bring a court action to assert the nonexistence of a
default or any other defense to acceleration,foreclosure,and sale.However,the amount required
to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and
charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law,
related to any foreclosure action we initiate.
Certified Article#:9214 8901 0754 4631 2478 38
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 4631 2478 38 050113.3 014 NSPOHDLA-CA J0462352 0000000
r
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.
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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 yourforeclosure!" Some con artists use names,phone numbers,
1197%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 Opinion. 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.
Feeleral Trade:C6r"rn ssiori ,
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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
Rebecca J. Bingham , 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.
r
Re cca J. Bi h m
Vice Presid t
Date: 06/11/14
JPMorgan Chase Bank,N.A
Borrower: HOLLAND D BENTLEY JR
Property Address: 1008 E. LISBURN RD., MECHANICSBURG,PA 17055
County: CUMBERLAND
Last Four of Loan Number:3135
FORM 1
: IN THE COURT OF COMMON PLEAS OF
JPMorgan Chase Bank,National Association ; CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff(s)
VS.
Unknown Heirs, Successors, Assigns and
All Persons, Firms or Associations Claiming c>
Right, Title or Interest from or under c�
Holland D. Bentley, Jr., deceased
1008 East Lisburn Road f c 'A�=>,
Mechanicsburg, PA 17055 `P-� y
DEFENDANT
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:
SHAPIRO&DeNARDO,LLC
Date Attorneys for Plaintiff
CHRISTOPHER A.DeNARDO,ESQUME
t,
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 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 ❑ 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)
i
FORM 3
: IN THE COURT OF COMMON PLEAS OF
JPMorgan Chase Bank,National Association CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs)
VS.
Unknown Heirs, Successors, Assigns and
All Persons, Firms or Associations Claiming
Right, Title or Interest from or under
Holland D. Bentley, Jr., deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
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
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO.
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. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
I.D. NO. 78
21/4474/4 /
311403 CU/184-R(
NitiS Y/, °U6TY
V41V14
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14-3868 CIVIL
MOTION FOR SERVICE PURSUANT
TO SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Shapiro & DeNardo, LLC, moves this Honorable Court for an
Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all
subsequent pleadings that require personal service only, upon the above -captioned Defendant,
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
Title or Interest from or under Holland D. Bentley, Jr., deceased by publication and by posting of
the subject premises located at 1008 East Lisburn Road, Mechanicsburg, PA 17055 and, in
support thereof avers the following:
1. Plaintiff believes, and therefore avers, that Holland D. Bentley, Jr. died on or
about November 29, 2013. Plaintiff, by and through its agents, has reviewed the appropriate
public records to determine if an estate has been created and, if so, whether a personal
.•
representative has been appointed. The review of these public records indicates that no estate
exists for Holland D. Bentley, Jr.
2. Any attempts at personal service of the Complaint in Mortgage Foreclosure would
not be successful.
3. Service of process by publication is permitted by Pennsylvania Rule of Civil
Procedure 430(b).
4. Pennsylvania Rule of Civil Procedure 430 (b) (2) provides: "When service is
made by publication upon the heirs and assigns of a named former owner or party in interest, the
court may permit publication against the heirs or assigns generally if it is set forth in the
Complaint or an affidavit that they are unknown."
5. In the case at bar, the Complaint in Mortgage Foreclosure as filed indicates that
the heirs of Holland D. Bentley, Jr., deceased Real Owner and Mortgagor, are unknown to
Plaintiff, despite a good faith investigation of the probate records as set forth in the Affidavit
attached hereto and incorporated herein as Exhibit "A."
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in
Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service
only, upon the Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations
Claiming Right, TItle or Interest from or under Holland D. Bentley, Jr., deceased, by publication'
in a legal publication designated by the Court for the publication of legal notices and in one
newspaper of general circulation within Cumberland County, and by posting the subject
premises located at 1008 East Lisburn Road, Mechanicsburg, PA 17055.
SHAPIRO & DeNARDO, LLC
Date: 1-10rVX BY:
At • "eys for Plaintiff
CAITLIN M. DONNELLY, ESQ
CONFIDENTIAL
INVESTIGATIVE
SERVICES INC
Lauren Vendali
Shapiro & DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, Pennsylvania 19406
Your File No.: 14-045739—Bentley
Dear Ms. Yandoli:
May 6, 2014
Pursuant to your request, effort was made to determine if an Estate was raised in Cumberland
County, PA regarding Holland D. Bentley, Jr.
Prior to conducting the search, I did perform a search of the Social Security Administration
Death Index and it was learned that Holland Bentley passed away on November 29, 2013.
A request was then forwarded to the Cumberland County Register of Wills to determine if an
Estate had been raised. A response was received indicating no Estate opened as of May 1, 2014. Please
see enclosed correspondence from the Cumberland County Register of Wills office.
Should you have any questions, please do not heslate to contact me.
Very truly yours,
Diane L. Cowan, CLI, CCDI
Enclosure
DLC/jn
235 South 13th Street
Philadelphia, PA 19107
(215) 546-7400
(800) 503-7400
Fax (215) 985-0169
I"K
Lisa M. Grayson
Register of Wills &
Clerk of Orphans' Court
Marjorie A. Wevodau
First Deputy
Wayne M. Pecht, Esq.
Solicitor
Register
One Courthouse Square
Carlisle, PA 17013
Phone: 1-888-697-0371 x 6345
717-240-6345
Fax 1-888-697-0371 x 7797
OFFICES OF
of Wills and Clerk of the Orphans' Court
County of Cumberland
RESPONSE TO RESEARCH REQUEST
May 1, 2014
D1; t ;
�q ,. d ear h
U
for
AN ESTATE WAS LOCATED
Decedent Name:
Estate No.:
Date Filed:
Date Granted:
Personal Representative:
Address:
City, State, Zip:
Attorney Name:
Address:
City, State, Zip:
Telephone:
�rX�N:07ES�1'►A'TE(QRENEI7�
O NO RECORD OF MARRIAGE
❑ NEED MORE INFORMATION TO CONDUCT SEARCH
❑ FEE REQUIRED.
Please forward a check in the amount of $5 per name to be searched. Make check
payable to Register of Wills and included a self-addressed stamped envelope..
0 4R
imowna§314,4 Lo
• COMMENTS:
NOTE: The fee to file a claim against an estate is $10. See our website for the Notice
of Claim form. (www.ccpa.net - search for Notice of Claim.
JPMorgan Chase Bank, National Association
vs.
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
TItle or Interest from or under Holland D. Bentley, Jr., deceased
VERIFICATION
Catlin M. Donnelly, Esquire, hereby states that she is the Attorney for the Plaintiff in this
action, that she is authorized to make this Verification, and that the statements made in the
foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true
and correct to the best of his knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the penalties of
18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date:
S&D: 14-045739
BY:
SHAPIRO & DeNARDO, LLC
Atto eys for Plaintiff
CAITLIN M. DOLLY, ESQ
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. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14-3868 CIVIL
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
If service cannot be made under the applicable rule, the Plaintiff may move the
court for a special order directing the method of service. The motion shall be
accompanied by an affidavit stating the nature andextent of the investigation
which has been made to determine the whereabouts of the defendant and the
reasons why service cannot be made.
In real property actions, such as the instant action in mortgage foreclosure, Pennsylvania
Rule of Civil Procedure, 410 (c), sets forth the manner in which service shall be made pursuant
to an Order of Court under Pa R.C.P. 430 (a):
The court shall direct one or more of the following methods of
service: (1) publication as provided by Rule 430 (b),(2) posting a
copy of the original process on the most public part of the
property, (3) registered mail to the defendant's last known address,
and (4) such other methods, if any, as the court deems appropriate
to serve notice to the defendant.
Pennsylvania Rule of Civil Procedure 430 (b) (2) provides: "When service is made by
publication upon the heirs and assigns of a named former owner or party in interest, the court
may permit publication against the heirs or assigns generally if it is set forth in the Complaint or
an affidavit that they are unknown."
As both the Complaint in Mortgage Foreclosure as filed and a good faith investigation of
the probate records as set forth in the Affidavit make clear the heirs of Holland D. Bentley, Jr.
are unknown to Plaintiff, and no estate has been raised. As such, it is impossible for Plaintiff to
properly server everyone on behalf of Defendant.
In order to complete service on the Defendant, Unknown Heirs, Successors, Assigns and
All Persons, Firms or Associations Claiming Right, TItle or Interest from or under Holland D.
Bentley, Jr., deceased, so as to move this action forward to ultimate disposition, the Plaintiff
respectfully requests that this Honorable Court, pursuant to Pennsylvania Rule of Civil
Procedure 430, grant a special Order directing service of the Complaint in Mortgage Foreclosure,
Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant,
by publication in a legal publication designated by the Court for the publication of legal notices
and in one newspaper of general circulation within Cumberland County, and by posting the
subject premises located at 1008 East Lisburn Road, Mechanicsburg, PA 17055 by the Sheriff,
competent adult, or other party allowed by law.
Date: i-1 l yN BY:
L
Respectfully Submitted,
SHAPIRO & DeNARDO, LLC
A orneys for Plain f
CAITLIN M. DONNELLY, ESQ
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. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14-3868 CIVIL
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the Motion For Service
—41q
Pursuant to Special Order Of Court on
to all parties named herein at their
last known address or upon their attorney of record as below listed by regular mail, postage
prepaid:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
TItle or Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road,
Mechanicsburg, PA 17055
Date: �I I
BY:
SHAPIRO & DeNARDO, LLC
eys for Plain
CAITLIN M. DONNELLY, ESQ
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 LD. 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. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY -r-InD
rn
f rl
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO: 14-3868 CIVIL cr)
.r>
CD
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
f=
C77)
ORDER
AND NOW, this Ie. day of (7,i7 , 2014, upon
consideration of Plaintiffs Motion For Service Pursuant To Special Order Of Court and the
Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the
Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require
personal service only, on Defendant, Unknown Heirs, Successors, Assigns and All Persons,
Firms or Associations Claiming Right, TItle or Interest from or under Holland D. Bentley, Jr.,
deceased, shall be complete when Plaintiff or its counsel or agent has published a true and
correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent
pleadings in the legal publication designated by the Court for the publication of legal notices and
in one newspaper of general circulation within Cumberland County and the Sheriff has posted a
true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale and or any
subsequent pleadings on the most public part of the mortgaged premises located at 1008 East
Lisburn Road, Mechanicsburg, PA 17055.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith '" I ;; 7R
Chief Deputy
Richard W Stewart 1'° I ,� i v; i
Solicitor ..5rr �.g',-4,-', =RrF= ; 1"'IS`�L`�
�.t e i® 6 , t t..:,.
JPMorgan Chase Bank, N.A.
vs. Case Number
Unknown Heirs, Successors,Assigns and All Persons, Firms 2014-3868
SHERIFF'S RETURN OF SERVICE
07/10/2014 02:20 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Brian Opsitnick, Occupant, wh accepted as"Adult
Person in Charge"for Occupant at 1008 E. Lisburn Road, Upper Allen, Mech c g, PA 17055.
/ ......___:._
LIAM IN , DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
July 14, 2014RONNYR ANDERSON, SHERIFF
., . ^i,,,u C he.'.*I 7cSCft
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 784340k
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 6'046, r�
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 - -R( f U 8 if, ,
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 S,;4/0 , , /
3600 HORIZON DRIVE, SUITE 150 '`I1'l,1�"'
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14-3868 CIVIL
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above -captioned matter.
A
Date: 9q/l/G% BY:
SHAPIRO & DeNARDO, LLC
,A
.
L:
s for Plaintiff
aim -1- ill. 7Spla�
CLQ /I/b dc,,4
2# aDotodLi
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
'> THE PROTHON,
Sheriff , �
� i., 1t
Jody S Smith
Chief Deputy _ 2014AUG `5 :. j
Richard W Stewart r CUMBERLAND COUNTY
Solicitor Fr146(,7F T;+RIFF PENNSYLVANIA
JPMorgan Chase Bank, N.A. Case Number
vs.
Unknown Heirs, Successors, Assigns and All Persons, Firms 2014-3868
SHERIFF'S RETURN OF SERVICE
07/29/2014 05:42 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Unknown Heirs, Successors, Assigns and All Persons, Firms, pursuant to
Order of Court by "Posting" the premises located at 1008 E. Lisburn Road, Upper Allen, Mechanicsburg,
PA 17055 with a true and correct copy according to law.
Luz,
DAWN KELL, DEPUTY
SHERIFF COST: $45.30 SO ANSWERS,
July 30, 2014
(c) CountySuite Sheriff, Teleoseft, Inc.
RONR ANDERSON, SHERIFF
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Finns or Associations Claiming
Right, Tltle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
COURT OF COMMON PLEAS`j-4-� -
.'C) 0c
r.,
CIVIL DIVISION
CUMBERLAND COUNTY -ems
NO: 14-3868 CIVIL
AFFIDAVIT OF SERVICE
I, Meghan Williams, the undersigned, being duly sworn according to law, hereby depose and say
that on the day of A/ 4, 2014, pursuant to the Order of Court,
attached as Exhibit "A," I served a true and correct copy of the Complaint in Mortgage Foreclosure in the
above -captioned matter to the Defendant(s) listed below at the address provided by publication in a legal
publication designated by the court for the publication of legal notices and in one newspaper of general
circulation within Cumberland County. Proof of said publications are attached as Exhibit "B."
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Tltle or
Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road, Mechanicsburg, PA
17055
SHAPIRO & DeN
BY:
rOalo
Meghan Williams,
Legal Assistant to
Attorney for Plaintiff
I hereby verify that the statements made herein are true and correct to the best of my knowledge,
information and belief and that this Affidavit of Service is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
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. 14-045739
JPMorgan. Chase Bank, National Association COURT OF COMMON PLEAS�i&-
PLAINTIFF CIVIL DIVISION F
VS. CUMBERLAND COUNTY
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO: 14-3868 CIVIL 1
Right, TItle or Interest from or under Holland >
D. Bentley, Jr., deceased
DEFENDANT
ORDER
AND NOW, this �ciay of Je.&....Ls./ , 2014, upon
consideration of Plaintiffs Motion For Service Pursu rt To Special Order Of Court and the
Affidavit of Good. Faith. Investigation attached hereto, it is hereby ORDERED that service of the
Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require
personal service only, on Defendant, Unknown Heirs, Successors, Assigns and All Persons,
Firms or Associations Claiming Right, TItle or Interest from or under Holland. D. Bentley, Jr.,
deceased, shall be complete when Plaintiff or its counsel or agent has published a true and
correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent.
pleadings in the legal publication designated by the Court for the publication of legal notices and
in one newspaper of general circulation within Cumberland County and the Sheriff has posted a
true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale and or any
subsequent pleadings on the most public part of the mortgaged premises located at 1008 East
Lisburn Road, Mechanicsburg, PA 17055.
BY THE COURT:
9
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid,
being duly sworn, deposes and says that THE SENTINEL, a newspaper of general
circulation in the Borough of Carlisle, County and State aforesaid, was established
December 13th, 1881, since which date THE SENTINEL has been regularly issued in said
County, and that the printed notice or publication attached hereto is exactly the same as
was printed and published in the regular editions and issues of
August 4, 2014.
COPY OF NOTICE OF PUBLICATION
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Affiant further deposes that he/ she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement as
to time, place and character of publication
are true.
Sworn to and subscribed before me this
day of f Uc\u si- .
.4 . T ,PIS'
Notary Public
My commission expires:
COMMONWEALTH QP RIVNSSYLVANIA
Notarial Seal
Bethany M. Holtry, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Sept. 26, 2015
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
August 8, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Lisa Marie Co ne, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of August, 2014
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE 80RO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018
•
CUMBERLAND LAW JOURNAL
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action—Law
No. 14-3868 CIVIL
JPMorgan Chase Bank,
National Association,
Plaintiff
vs.
Unknown Heirs, Successors,
Assigns and All Persons, Firms or
Associations Claiming Right, Title
or Interest From or Under Holland
D. Bentley, Jr., Deceased,
Defendant(s)
To: the Defendant(s), Unknown
Heirs, Successors, Assigns and
All Persons, Firms or Associations
Claiming Right, Title or Interest
From or Under Holland D. Bent-
ley, Jr., Deceased
TAKE NOTICE THAT THE Plaintiff,
JPMorgan Chase Bank, National As-
sociation has filed an action Mortgage
Foreclosure, as captioned above.
NOTICE
IF YOU WISH TO DEFEND, YOU
MUST ENTER A WRITTEN APPEAR-
ANCE PERSONALLY OR BY ATTOR-
NEY AND FILE YOUR DEFENSES OR
OBJECTIONS WITH THE COURT.
YOU ARE WARNED THAT IF YOU
FAIL TO DO SO THE CASE MAY PRO-
CEED WITHOUT YOU AND A JUDG-
MENT MAY BE ENTERED AGAINST
YOU WITHOUT FURTHER NOTICE
FOR THE RELIEF REQUESTED BY
THE PLAINTIFF. YOU MAY LOSE
MONEY OR PROPERTY OR OTHER
RIGHTS IMPORTANT TO YOU. YOU
SHOULD TAKE THIS NOTICE TO
YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER GO TO
OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN
8
PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER. IF YOU
CANNOT AFFORD TO HIRE A LAW-
YER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OF-
FER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County
Lawyer Referral Service
Cumberland County Bar Assoc.
32 S. Bedford St.
Carlisle, PA 17013
CHRISTOPHER A. DeNARDO,
ESQUIRE
CAITLIN M. DONNELLY,
ESQUIRE
BRADLEY J. OSBORNE,
ESQUIRE
CHANDRA M. ARKEMA,
ESQUIRE
SHAPIRO & DeNARDO, LLC
Attys. for Plaintiff
3600 Horizon Dr.
Ste. 150
King of Prussia, PA 19406
(610) 278-6800
Aug. 8
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. Na37184:4DI 23 r.::11:I I
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
FILED-CiF,FICE
OF
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
rtiMriERL AND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-3868 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $153,302.15 in favor of the Plaintiff and against
the Defendant, jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage
Foreclosurewithin 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:
$140,160.46
$5,314.40
$366.97
$5,235.83
$70.00
$2,154.49
$153,302.15
AND NOW, judgment is entered in favor o
h nti f and ag
damages are assessed as above in the sum of $153,302.
14-045739
1x1ke
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
14-3868 CIVIL
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: /0/22//Li
Sworn to and subscribed
before me this a) --
of ,20.14.
BY:
SHAPIRO & DeNARDO, LLC
Atto for Plaintiff
EY J. OSBORNE, ESQ.
COMMO WEALTH OF PENN
NOTARIAL SEAL
Jennifer M. Sharkey, Notary Public
Upper Merlon Twp., Montgomery County
My Commission Expires Oct. 19, 2018
NSYLVAN ASSOCATION OF NOTA IES
Y V
8
- Department of Defense Manpower Data Center
Status Report
Pursuant to Service/numbers Civil Relief Act
Last Name: BENTLEY
First Name: HOLLAND
Middle Name: a
Active Duty Status As Of: Oct -22-2014
Results as of : Oct -22-2014 05:31:43 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 N..
NA
This response reflects the Individual's.' active duly status based on'the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
. No .
NA
This response reflects where the individual lett active duty status within 367 days preceding the/Active Duty Status Date
The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA '•• ' ..
.." No
NA
This response reflects whether the individual Or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the -Uniformed Services (Army, Navy, Marine Corps, Air Force, NOM, 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
4"- The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DOD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the 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/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 (NOM 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: KENOVCBBX086U30
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. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14-3868 CIVIL
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Tltle or Interest from or under Holland
D. Bentley, Jr., deceased
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,
October 7, 2014 to the following Defendants:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
TItle or Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road,
Mechanicsburg, PA 17055
4
Theresa Besl , Lega 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 LD. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14-3868 CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland D. Bentley, Jr., deceased
DATE OF NOTICE: October 7, 2014
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections to the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE,A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en
este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta
notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba
alguna, dictar sentencia en su contra. listed puede perder bienes y otros derechos importantes.
Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o sill°
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:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
Title or Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road,
Mechanicsburg, PA 17055
Date: 10/1/1q
BY:
SHAPIRO & DeNARDO, LLC
s fo Iwutif
CPSILIS r.t
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO:14-3868 CIVIL
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
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:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
Title or Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road,
Mechanicsburg, PA 17055
Date Mailed:
Date:
BY:
SHAPIRO & DeNARDO, LLC
s for Plaintiff
DLEY J. OSBORNE, ESQ.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY T.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO:14-3868 CIVIL
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
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 43219
and that the last known address of the judgment debtor (Defendant) is:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right,
TItle or Interest from or under Holland D. Bentley, Jr., deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
Date: '16 -aa -
14 -045739
BY:
SHAPIRO & DeNARDO, LLC
Att
or Plaintiff
EY J. OSBORNE, ESQ.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming
Right, Tltle or Interest from or under Holland D. Bentley, Jr., deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming Right,
TItle or Interest from or under Holland D.
Bentley, Jr., deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-3868 CIVIL
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
jo J231/q
[ ] 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.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
() Confessed Judgment
()Other ' ,
File No. I�
7 0
Amount Due $153,302.15
Interest October 1, 2014 to March 4, 2015 is
$2,278.50
Atty's Comm
Costs
.r,
x(1
CD
c-�
C1.)
C
The undersigned hereby certifies that the below does not arise out of a retail installment safe, �dontract, or account
based on a confession of judgment, but if it does, it is based on the appropriate original proceeding fired 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: 1 6'ad'' Signature:
AirPrint Name: Br.Osborne
Address: 3 00 orizon Drive, Suite 150
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 312169
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Tract No. 1
ALL THAT CERTAIN lot of land situate in the Township of Upper Allen, County of
Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point in the road leading from Lisburn to Bowmansdale at corner of lands now
or late of Glenn L. Heller and Martha A. Heller, his wife; thence in said road and along lands
now or late of Earl Hoffman and Sara Hoffman, his wife, South 61 degrees 35 minutes East,
50.00 feet; thence along other lands now or formerly of the same, South 00 degrees 50 minutes
East, 484.00 feet to a point; thence along lands now or formerly of the same, North 61 degrees 35
minutes West, 50.00 feet to a point at the corner of lands now or late of Glenn A. Heller and
Martha A. Heller, his wife; thence by said last mentioned lands, North 00 degrees 50 minutes
West, 484 feet to a point in said road, the place of beginning.
Tract No. 2
ALL THAT CERTAIN lot of land situate in the Township of Upper Allen, County of
Cumberland, State of Pennsylvania, being more particularly bounded and described as follows, to
wit:
BEGINNING at an iron pin in the road leading from Lisburn to Bowmansdale at the corner of
lands now or late of Raymond Miller; thence in said road and along other lands now or formerly
of Earl W. Hoffman and Sarah F. Hoffman, his wife, South 61 degrees 35 minutes East, 55.9 feet
to a point in said road; thence along other lands now or formerly of Earl W. Hoffman and Sarah
F. Hoffman, his wife, South 00 degrees 50 minutes East, 484.00 feet to a pin; thence by the same,
North 61 degrees 35 minutes West, 90.10 feet to a pin; thence by the same, North 00 degrees 50
minutes West, 484.00 feet to a point in said road first above mentioned; thence in said road along
lands now or late of Raymond Miller, South 61 degrees 35 minutes East, 34.10 feet to a pin at the
point and place of beginning.
UNDER AND SUBJECT to rights of way, easements, restrictions, conditions, building setback
lines, notes and matters set forth on prior deeds of record.
Tract 1 and Tract 2 being known and numbered as 1008 East Lisburn Road, Mechanicsburg,
Pennsylvania.
PARCEL No. 42-30-2120-031
BEING the same premises which Glenn L. Heller and Jane W. Heller, husband and wife, by
Deed dated June 2, 2008 and recorded June 10, 2008 in the Cumberland County Recorder of
Deeds Office as Deed Instrument No. 200819342, granted and conveyed unto Holland D.
Bentley, Jr., married man.
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
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, Title or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
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riliTe•T‘f
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LjIciflitliA
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-3868 CIVIL
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 1008 East Lisburn Road, Mechanicsburg, PA 17055.
Name and address of Owner(s) or Reputed Owner(s)
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland D. Bentley, Jr., deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
2. Name and address of Defendant in the judgment:
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland D. Bentley, Jr., deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
Cumberland County Adult Probation
1 Courthouse Square
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
1008 East Lisburn Road
Mechanicsburg, PA 17055
Commonwealth of Pennsylvania
Department of Revenue, Inheritance Tax Division
1131 Strawberry Square, 6th Floor
Harrisburg, PA 17128
Internal Revenue Service
WM S. Moorehead Federal Bldg. Advisory
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
Department of Public Welfare
Estate Recovery Program
PO Box 8486
Willow Oak Bldg
Harrisburg, PA 17105
Commonwealth of Pennsylvania
Department of Revenue
Inheritance Tax Division
Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128
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:
14-045739
SHAPIRO & DeNARDO, LLC
f
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 7844
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY LD. NO. 85144 '�/ kir ''
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO: 14-3868 CIVIL
Right, Tltle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations
Claiming Right, TItle or Interest from or under Holland D. Bentley, Jr.,
deceased
1008 East Lisburn Road
Mechanicsburg, PA 17055
Your house (real estate) at:
1008 East Lisburn Road, Mechanicsburg, PA 17055
42-30-2120-031
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:OOAM to enforce the court judgment of $153,302.15 obtained by JPMorgan Chase Bank,
National Association against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, National
Association the amount of the judgment plus costs or the back payments, late charges,
costs, and reasonable attorney's fees due. To find out how much you must pay, you may
call: (610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4
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.
14-045739
Tract No. 1
ALL THAT CERTAIN lot of land situate in the Township of Upper Allen, County of
Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point in the road leading from Lisburn to Bowmansdale at corner of lands now
or late of Glenn L. Heller and Martha A. Heller, his wife; thence in said road and along lands
now or late of Earl Hoffman and Sara Hoffman, his wife, South 61 degrees 35 minutes East,
50.00 feet; thence along other lands now or formerly of the same, South 00 degrees 50 minutes
East, 484.00 feet to a point; thence along lands now or formerly of the same, North 61 degrees 35
minutes West, 50.00 feet to a point at the corner of lands now or late of Glenn A. Heller and
Martha A. Heller, his wife; thence by said last mentioned lands, North 00 degrees 50 minutes
West, 484 feet to a point in said road, the place of beginning.
Tract No. 2
ALL THAT CERTAIN lot of land situate in the Township of Upper Allen, County of
Cumberland, State of Pennsylvania, being more particularly bounded.and described as follows, to
wit:
BEGINNING at an iron pin in the road leading from Lisburn to Bowmansdale at the corner of
lands now or late of Raymond Miller; thence in said road and along other lands now or formerly
of Earl W. Hoffman and Sarah F. Hoffman, his wife, South 61 degrees 35 minutes East, 55.9 feet
to a point in said road; thence along other lands now or formerly of Earl W. Hoffman and Sarah
F. Hoffman, his wife, South 00 degrees 50 minutes East, 484.00 feet to a pin; thence by the same,
North 61 degrees 35 minutes West, 90.10 feet to a pin; thence by the same, North 00 degrees 50
minutes West, 484.00 feet to a point in said road first above mentioned; thence in said road along
lands now or late of Raymond Miller, South 61 degrees 35 minutes East, 34.10 feet to a pin at the
point and place of beginning.
UNDER AND SUBJECT to rights of way, easements, restrictions, conditions, building setback
lines, notes and matters set forth on prior deeds of record.
Tract 1 and Tract 2 being known and numbered as 1008 East Lisburn Road, Mechanicsburg,
Pennsylvania.
PARCEL No. 42-30-2120-031
BEING the same premises which Glenn L. Heller and Jane W. Heller, husband and wife, by
Deed dated June 2, 2008 and recorded June 10, 2008 in the Cumberland County Recorder of
Deeds Office as Deed Instrument No. 200819342, granted and conveyed unto Holland D.
Bentley, Jr., married man.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION
Vs. NO 14-3868 Civil Term
CIVIL ACTION — LAW
UNKNOWN HEIRS, SUCCESSORS, ASSIGNS
AND ALL PERSONS, FIRMS OR ASSOCIATIONS
CLAIMING RIGHT, TITLE OR INTEREST FROM OR
UNDER HOLLAND D. BENTLEY JR., DECEASED
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $153,302.15 L.L.: $.50
Interest OCTOBER 1, 2014 TO MARCH 4, 2015 IS $2,278.50
Atty's Comm:
Atty Paid: $o? SS. 10
Plaintiff Paid:
Date: 10/23/2014
(Seal)
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
Due Prothy: $2.25
Other Costs:
124,ee- tLee__
David D. Bue 1, Prothonotary
Deputy
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. 14-045739
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming NO: 14-3868 CIVIL
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
AFFIDAVIT OF SERVICE
I, Sandra Marshall, the undersigned, being duly sworn according to law, hereby depose and say
that on the 5th day of December, 2014, pursuant to the Order of Court, attached as Exhibit "A," I served a
true and correct copy of Notice of Sale in the above -captioned matter to the Defendant(s) listed below at
the address provided by publication in a legal publication designated by the court for the publication of
legal notices and in one newspaper of general circulation within Cumberland County. Proof of said
publications are attached as Exhibit "B."
Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Tltle or
Interest from or under Holland D. Bentley, Jr., deceased, 1008 East Lisburn Road, Mechanicsburg, PA
17055
SHAPIRO & DeNARDO, LLC
BY:
`'ndra Marshall,
Legal Assistant to
Attorney for Plaintiff
I hereby verify that the statements made herein are true and correct to the best of my knowledge,
information and belief and that this Affidavit of Service is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
SHAPIRO. & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY 1.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. 14-045739
JPMorgan. Chase Bank, National Association
PLAINTIFF
VS.
Unknown-Heirs,Successors, Assigns arid All.
Persons, Firms or Associations Claiming
Right, Tltle or Interest from or under Holland
D: Bentley, Jr., deceased
DEFENDANT
AND NOW, this ay of
•
7 esz
COURT OF COMMON PLEASE %rn
c
CIVIL DIVISION r
CUMBERLAND COUNTY c,
r-•`
NO: 14-3868,C1VIL
ORDER
, 2014, upon.
consideration of Plaintiffs Motion For Service Pursua t To Special Order Of Court and. the
Affidavitof Good Faith Investigation attached hereto, it is hereby ORDERED that service of the
Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require
personal service only, on Defendant, Unknown Heirs, Successors, Assigns and All Persons,
Firths or Associations Claiming Right, Title or Interest froin or under Holland D. Bentley, Jr.,
deceased, shall be complete when Plaintiff or its counsel or agent' has published a -true and
correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent
pleadings m the legalpublication designated by the Court for the publication of legal notices; and:
in one newspaper of general circulation within Cumberland County and the Sheriff has posted a
true;and correct copy of the Complaint -in.Mortgage Foreclosure, Notice. of Sale and or:any
subsequent pleaditgs:on the most public part of the mortgaged premises iodated at 1008 East
LisburnRoad, Mechanicsburg, PA 17055..
BY THE COURT:
4S_FgatA-e:tN-J‘I--
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND•
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
December 5, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
isa Marie Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
5 day of December, 2014
Notary
COMMONWEALTH -OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO., CUMBERLAND.CNTY
My Commission Expires Apr 28, 2018
e` /- d 13"
CUMBERLAND LAW JOURNAL
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action—Law
No. 14-3868 CIVIL
JPMorgan Chase Bank,
National Association,
Plaintiff
vs.
Unknown Heirs, Successors,
Assigns and All Persons, Firms or
Associations Claiming Right, Title
or Interest From or Under Holland
D. Bentley, Jr., Deceased,
Defendant(s)
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: Unknown Heirs, Successors,
Assigns and All Persons, Firms
or Associations Claiming Right,
Title or Interest From or Under
Holland D: Bentley, Jr., Deceased,
Defendant(s), Whose Last Known
Address Is 1008 East Lisburn
Road, Mechanicsburg, PA 17055
Your house (real estate) at: 1008
East Lisburn Road, Mechanicsburg,
PA 17055, 42-30-2120-031, is sched-
uled to be sold at Sheriff's Sale on
March 4, 2015, at 10:00 A.M. at
Cumberland County Sheriff's Of-
fice, 1 Courthouse Sq., Carlisle, PA
17013, to enforce the court judgment
of $150,302.15, obtained by JP -
Morgan Chase Bank, National Asso-
ciation (the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS—
YOU MAY BE ABLE TO PREVENT
THIS SHERIFF'S SALE
To prevent this Sheriff's Sale
you must take immediate action:
1. The sale will be cancelled if you
pay back to JPMorgan Chase Bank,
National Association, the amount of
6
the judgment plus costs or the back
payments, late charges, costs and
reasonable attorneys 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 judg-
ment 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 below on how to
obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE
YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE
SHERIFF'S SALE DOES TAKE PLACE
5. If the Sheriff's Sale is not
stopped, your property will be sold
to the highest bidder. You may fmd
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 prop-
erty. 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.
CUMBERLAND LAW JOURNAL
This schedule will state who will be
receiving the money. The money will
be paid out in accordance with this
schedule unless exceptions (rea-
sons 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 Assoc.
32 S. Bedford St.
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 COL-
LECT A DEBT. ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
CHRISTOPHER A. DeNARDO
BRADLEY J. OSBORNE
CHANDRA M. ARKEMA
LEEANE O. HUGGINS
SHAPIRO & DeNARDO, LLC
Attys. for Plaintiff
3600 Horizon Dr.
Ste. 150
King of Prussia, PA 19406
(610) 278-6800
Dec. 5
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Cathy Clark, Advertising Director, of The Sentinel, of the County and State aforesaid,
being duly sworn, deposes and says that THE SENTINEL, a newspaper of general
circulation in the Borough of Carlisle, County and State aforesaid, was established
December 13th, 1881, since which date THE SENTINEL has been regularly issued in said
County, and that the printed notice or publication attached hereto is exactly the same as
was printed and published in the regular editions and issues of
November 29, 2014.
COPY OF NOTICE OF PUBLICATION
•
h - rt
siir4044-. vitt fra)
44,114.11 kseG
a7,ym-
Affiant further deposes that he/she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement as
to time, place and character of publication
e true.
Sworn to and subscribed before me this
3r01
C. �erQrn) ( a0 .
in. Oki
Nogtry Public
My commission expires:
COMMONWEALTH ();' PENNSYLVANIA
�
alan Notarial Seal
e
Bthan M. Holby, Notary Public
My Commission Cumberland County
Expires
MEMBER PENNSv, v 6A,L CS TION OF NOTARIES
•
I In The Court of Common Pleas
Of Cumberland County, Pennsylvania
I Civil Action -Law
No. 14-3868 CIVIL
• Notice of Action in Mortgage Foreclosure
JPMorgan Chase Bank, National Association, Plaintiff vs. Unknown Heirs, Successors, Assigns, and All persons firms
or Associations Claiming Right, Title or Interest from or under Holland D.1Bentley, Jr., deceased, Defendant(s) .
• NOTICE OF SHERIFF'S SALE QE REAL PROPERTY
TO: Unknown Heirs,'Successors, Assigns; and All persons firms or Associations Claiming Right, Title or Interest from
or under Holland D. Bentley, Jr., deceased, Defendant(s), whose last known address is 1008 East Lisburn Road,
Mechanicsburg, PA 17055. •
Your house (feat estate) at: 1008 East Lisburn Road, Mechanicsburg, PA 17055, 42-30-2120-031,,is scheduled to be
sold at Sheriff's Sale on March 4, 2015, at 10:OOAM, at Cumberland County Sheriffs Office, 1 Courthouse Sq.,
Carlisle, PA 17013, to enforce the coutt judgment ofholl $150,302.15, obtained by JPMorgan Chase Bank, National
Association (the mortgagee) against you. - NOTICE OF OWNER'S RIGHTS - YOU MAY BE ABLE TO PREVENT
THIS SHERIFF'S SALE -To prevent ttis Sheriff's Sale you must take immediate action: 1. The sale will be cancelled
if you pay back to JPMorgan Chase Bank, National Association, the amount of the judgment plus costs or the back
payments, late charges, costs, and reasonable attorneys 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 below on how to
obtain an attorney.) - YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES 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 titae;`'the buyer may bring legal proceedings to evict
"you. 10. You may be entitled to a share of the money, which was,paid foryour house. A schedule of distribution of
the money bid for your house will.be-filetfby the -Sheriff no later than thirty days after the Sheriff Sale. This schedule
will state who will be receiving the money. The money will tie 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 CANNOTAFFORD 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 Assoc., 32 S. Bedford St., 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.
Christopher A. DeNardo, Bradley J. Osborne, Chandra M. Arkema & Leeane O. Huggins, Attys. for Plaintiff
SHAPIRO & DeNARDO, LLC
3600 Horizon Dr., Ste. 150
King of Prussia, PA 19406
610.278.6800
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,
ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO.
312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO.
203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO.
85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO.
311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-045739
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Unknown Heirs, Successors, Assigns and All
Persons, Firms or Associations Claiming
Right, TItle or Interest from or under Holland
D. Bentley, Jr., deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-3868 CIVIL
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.
SHAPIRO & DENARDO, LLC
Date: \, Q 15 By: CAO\A: A4361
Cori Haas
Legal Assistant
14-045739
U.S. POSTAGE >> PITNEY BOWES,
If v
Name and Address of Sender
Shapiro & DeNardo, LLC
3600 Horizon Drive
Check type of mail or service:
0 Certified 0 Recorded Delivery (International)
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional
"Riii,.1 "V MINIMMF .,M,
4
ZIP 19406 $ 003 76Q
-.... ":," :'k 0002011137362 JAN. 05.. 2015.
Suite 150
King of Prussia, PA 19406
0 COD 0 Registered
0 Delivery Confirmation 0 Return Receipt for Merchandise
0 Express Mail 0 Signature Confirmation
0 Insured
copies of this bill)
Postmark and.
Date of Receipt
_ .
.
Article Number
Addressee (Name, Street, City State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value if
Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
RR
Fee
1.
14-045739 MW
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
Cumberland County Adult Probation
Square
2.
1 Courthouse
Carlisle, PA 17013
Tenant or Occupant
1008 East Lisburn Road
Mechanicsburg, PA 17055
3.
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
4'
Commonwealth of Pennsylvania
Department of Revenue, Inheritance Tax Division
1131 Strawberry Square, 6th Floor
Harrisburg, PA 17128
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Internal Revenue Service
Moorehead Federal Bldg. Advisory r
W M S.s
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
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Department of Public Welfare
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Estate Recovery Program
PO Box 8486
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Willow Oak Bldg
Harrisburg, PA 17105
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Commonwealth of Pennsylvania
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Department of Revenue
Inheritance Tax Division
Bureau of Compliance
Dept. 280946
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Harrisburg, PA
17128
•-•" 4
Total Number of Pieces
Listed by Sender 8
Total Number of Pieces
Received at Post Office
Postmaster, er
e of rec'
•ving empl
-
See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 1 of 1)
omp