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Home My WebLink About14-4263 Supreme Court-of Pennsylvania Court;o¢ C.ommo'fi-Tleas -, 1�'r .. For Prothonotary Use Only: G1,M1tCovef;�h,eet CUIYI$ERI�AN=Ds `; County Docket No: D e The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service o leadin s or other papers as required by law or rules of court. S Commencement of Action: ❑D Complaint ❑ Writ of Summons ❑Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: JPMORGAN CHASE BANK, Lead Defendant's Name: JERRY J. BENDER T N.A., S/B/M CHASE HOME FINANCE, LLC j Are money damages requested? El Yes 0 No Dollar Amount Requested: Elwithin arbitration limits 0 .(Check one) 9 outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes ❑x No Name of Plaintiff/Appellant's Attorney: Michael Dingerdissen,Esq., Id.No.317124,Phelan Hallinan, LLP A ❑ 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 ❑Product Liability(does not S include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑Zoning Board C ❑ Other: T j MASS TORT ❑ Other: 0 ❑Asbestos N ❑ Tobacco ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑Common Law/Statutory Arbitration $ ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑Dental ❑ Partition ❑ Replevin ❑Legal ❑ Quiet Title ❑ Other: ❑Medical ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 940636 ,j �.> i `P�o i C� JUS 2 r /40 PHELAN HALLINAN,LLP Michael Dingerdissen,Esq.,Id.No.317124 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 Michael.Dingerdissen@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,N.A., SB/M CHASE HOME FINANCE, LLC COURT OF COMMON PLEAS 1111 POLARIS PARKWAY COLUMBUS, OH 43240 CIVIL DIVISION PlaintiffTERM V. 04 JERRY J.BENDER, in his capacity as Heir of JOSEPH NO ql�b 5 C.BENDER,Deceased CUMBERLAND COUNTY 1115 WANSFORD RD MECHANICSBURG,PA 17050-7615 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER JOSEPH C.BENDER,DECEASED 299 ALLENDALE WAY CAMP HILL,PA 17011-8403 Defendants CIVIL ACTION-LAW COMPLAINT IN MORTGAGE FORECLOSURE File#: 940636 30S� � I. Plaintiff is JPMORGAN CHASE BANK,N.A., SB/M CHASE HOME FINANCE, LLC 1111 POLARIS PARKWAY COLUMBUS, OH 43240 2. The name(s) and last known address(es) of the Defendant(s) are: JERRY J.BENDER, in his capacity as Heir of JOSEPH C.BENDER,Deceased 1115 WANSFORD RD MECHANICSBURG,PA 17050-7615 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER JOSEPH C.BENDER,DECEASED 299 ALLENDALE WAY CAMP HILL,PA 17011-8403 who is/are the real owner(s) of the property hereinafter described. 3. On 11/18/2005 JOSEPH C. BENDER made, executed and delivered a mortgage upon the premises hereinafter described to JPMORGAN CHASE BANK,N.A. , which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1934, Page 2452. By Assignment of Mortgage recorded 01/06/2010 the mortgage was assigned to CHASE HOME FINANCE, LLC , which Assignment is recorded in Assignment of Mortgage Instrument No. 201000379. Said Mortgage was modified as set forth in a modification agreement effective 02/01/2013, which is unrecorded. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves JPMORGAN CHASE BANK,N.A., S/B/M CHASE HOME FINANCE, LLC from its obligations to attach documents to pleadings if those documents are of public record. File#: 940636 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 06/10/2014: Principal Balance $184,437.53 Interest from $3,074.00 08/01/2013 through 05/31/2014 Late Charges $118.00 Property Inspections $42.00 Escrow Advance $3,695.05 TOTAL $191,366.58 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s)has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974,Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to File#: 940636 meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. Mortgagor JOSEPH C. BENDER died on 10/25/2013, and upon information and belief, his surviving heirs are JODY M. YARNEVICH and JERRY J. BENDER. 10. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. 11. By executed waiver, JODY M. YARNEVICH waived her right to be named as a defendant in the foreclosure action. Said waiver is attached as Exhibit"A ". 12. Plaintiff hereby releases JOSEPH C. BENDER, from liability for the debt secured by the mortgage. 13. Plaintiff does not hold the named Defendant, JERRY J. BENDER, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendant in the aforesaid real estate only, and the Defendant has been named in accordance with the requirements of Pa R.C.P. I I44(a)(2) and 20 Pa.C.S.A. § 301(b). WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $191,366.58,together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: MichUl Dinger issen, Esq., Id.No.317124 Attorney for Plaintiff File 4: 940636 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the easterly side of Allendale Way, which point is eight hundred fifty-four and ninety-seven one-hundredths (854.97) feet in a northerly direction from the northeast corner of Allendale Way and Fieldstone Road at the dividing line between Lots Nos. 322 and 323 of the hereinafter mentioned Plan; thence by Allendale Way on an arc curving to the left having a radius of seven hundred thirteen and five one-hundredths (713.05) feet ninety (90) feet to a point at the dividing lines between Lots Nos. 323 and 324 on Plan of Section 5; thence by the same South eighty-nine (89) degrees twenty-nine (29)minutes twenty-seven (27) seconds East one hundred forty-eight and fifty-two one-hundredths (148.52) feet to a point; thence South eight(8) degrees zero (0)minutes West one hundred eighteen (118) feet to a point at the dividing lines between Lots Nos. 322 and 323 of the Plan; thence by the same North seventy-eight(78) degrees fourteen (14) minutes West one hundred thirty-nine and three one- hundredths (139.03) feet to a point on the easterly line of Allendale Way, the Place of BEGINNING. PROPERTY ADDRESS: 299 ALLENDALE WAY, CAMP HILL,PA 17011-8403 PARCEL#13-25-0010-070. File#: 940636 Exhibit "A" WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I,JODY M. YARNEVICH, Heir of JOSEPH C. BENDER,Deceased, hereby acknowledge that I may have an ownership interest in the property located at 299 ALLENDALE WAY, CAMP HILL, PA 17011-8403, in accordance with Section 301(b)of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. Section 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa.R.C.P. 1141 et seq., which may be instituted by JPMORGAN CHASE BANK, N.A., S/B/M CHASE HOME FINANCE,LLC, involving said property, which property was owned by the decedent at the time of his death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Sheriff's sale of the mortgage premises. Date: JO M. ARN CH, Heir of 10SEPH C. BENDER, Deceased PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)320-0007,Ext. 1241 Fax:215-563-3352 April 20, 2014 JODY M.YARNEVICH,Heir of JOSEPH C.BENDER,Deceased 116 VICTORIA DR MECHANICSBURG,PA 17055-3526 JERRY J.BENDER,Heir of JOSEPH C.BENDER,Deceased 1115 WANSFORD RD MECHANICSBURG,PA 17050-7615 RE: JOSEPH C.BENDER;299 ALLENDALE WAY, CAMP HILL,PA 17011-8403; JPMORGAN CHASE BANK,NATIONAL ASSOCIATION;PH#940636 Dear Sir/Madam(s): Kindly be advised that the Law Offices of Phelan Hallinan, LLP represent JPMORGAN CHASE BANK, N.A., SB/1\4 CHASE HOME FINANCE, LLC, the holder of the mortgage against the above-referenced mortgaged premises. Our office has been retained to bring a foreclosure action. Our office has been informed of JOSEPH C. BENDER's unfortunate death. We are sorry for your loss. As a possible heir of JOSEPH C. BENDER, you may have a vested ownership interest in the mortgaged premises upon his death under 20 Pa.C.S.A. §301(b). As such, Pennsylvania law requires that you be included as a defendant solely in your capacity as heir in order to complete the foreclosure. Please be advised that you are not personally liable for the debt,as you did not execute the mortgage or note. This letter serves to afford you an opportunity to waive your right to be named as a defendant in the foreclosure action. Please find attached-a Waiver which-1 would appreciate your executing and returning to the undersigned within fourteen (14) days of the date of this correspondence. If the Waiver is timely returned it will not be necessary to name you as a defendant in the foreclosure action. However, if the Waiver is not timely returned and it is believed that you are an heir of the decedent, then our office may have no choice but to name you as a defendant in the action in order to divest any ownership interest you may have in the property. *This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. Our Office also requests that you please provide us with any additional heir information for JOSEPH C. BENDER, Deceased. Thank you for your cooperation in this regard. Please note that this waiver does not preclude you from attempting to sell the subject premises and recovering any possible equity in the mortgaged premises prior to the completion of the foreclosure action. We would encourage you to contact your own attorney in regard to this matter. If you would like to request a payoff or reinstatement figure,please call (215)563- 7000,and ask for the Foreclosure Resolution Department. If you have any other questions regarding this letter,please contact a representative of our firm's Decedent Department at (215)320-0007,Ext. 1241 Sincerely, Adam H. Davis,Esq., Id. No.203034 Attorney for Plaintiff Cc: *This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy,we are only proceeding against the real estate secured by the mortgage. 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. Reb B' sham Vice Presid nt Date: 07/08/14 JPMorgan Chase Bank,N.A Borrower: JOSEPH C BENDER Property Address: 299 ALLENDALE WAY, CAMP HILL, PA 17011 County: CUMBERLAND Last Four of Loan Number:6031 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF IZE OFTHE SHEFIFF F iLED-L1i' i ? THE PROTHONGG.1A r 2014 AUG 19 AMID: 20 CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. vs. Jerry J Bender, Unknown Heirs, Successors, Assigns, and all Persons Case Number 2014-4263 SHERIFF'S RETURN OF SERVICE 07/29/2014 06:20 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jerry J Bender, Unknown Heirs, Successors, Assigns, and all Persons, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 299 Allendale Way, Lower Allen, Camp Hill, PA 17013. Residence is vacant. 08/11/2014 05:54 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Jerry J Bender, Unknown Heirs, Successors, Assigns, and all Persons at 1115 Wansford Road, Hampden Township, Mechanicsburg, PA 17050. ami IE DIMARTLE, DEPUTY SHERIFF COST: $66.25 SO ANSWERS, August 12, 2014 RONI'fY R ANDERSON, SHERIFF (c) CountvSute Sheriff, Teleosoft. Inc. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, N.A., S/B/M CHASE HOME FINANCE, LLC Plaintiff v. JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED Defendant 1 . Jr t 1:10V 19ir110:20 ' coif!" y COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-4263 CUMBERLAND COUNTY PRAECIPE TO RELEASE PARTY DEFENDANT AND CORRECT CAPTION AND AFFIDAVIT OF RELEASE OF LIABILITY PURSUANT TO Pa. R.C.P. RULE 1144(b) Plaintiff, JPMORGAN CHASE BANK, N.A., S/B/M CHASE HOME FINANCE, LLC by and through its counsel, Phelan Hallinan LLP, hereby releases JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased, as a Party Defendant in the within foreclosure action in accordance with Pa. R.C.P., Rule 1144(b), as JERRY J. BENDER has executed a Waiver by Heir of Right to be Named as Defendant in the Foreclosure Action. Said Waiver is attached hereto and marked as Exhibit "A". 940636 10,NA- 4q. SbPj C,L* (-1--)6 70") `�� 21.3.96 4 � Because JERRY J. BENDER is released as a Party Defendant, please remove him from the case caption accordingly. Dated: 940636 By: PHELAN HALLINAN, LLP Jonah Lobb, Esq., Id. No. 312174 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, N.A., S/B/M CHASE HOME FINANCE, LLC Plaintiff v. JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED Defendant COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-4263 CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Correct Case Caption and Release defendant JERRY J. BENDER was sent via first class mail to the following on the date listed below: JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased 1115 WANSFORD RD MECHANICSBURG, PA 17050-7615 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED 299 ALLENDALE WAY CAMP HILL, PA 17011-8403 Dated: 940636 /lig bY By: PHELAN HALLINAN, LLP Jonathi Lobb, Esq., Id. No. 312174 ttorney for Plaintiff EXHIBIT "A" C WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, JERRY J. BENDER, Heir of JOSEPH C. BENDER, Deceased, hereby acknowledge -that T mayhave an ownership interest in the property located at 299 ALLENDALE WAY, CAMP HILL, PA 17011-8403, in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. Section 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa.R.C.P. 1141 et seq., which may be instituted by JPMORGAN CHASE BANK, N.A.. S/B/M CHASE HOME FINANCE, LLC, involving said property, which property was owned by the decedent at the time of his death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Sheriff's sale of the mortgage premises. In the event, I, the undersigned, file a Chapter 7 or Chapter 13 bankruptcy case prior to disposition of the foreclosure action to be filed with respect to the mortgaged premises; I agree that I will not contest any motion for relief from the automatic stay, or will in the alternative, clearly indicate in my bankruptcy schedules that I am surrendering any interest in the mortgaged premises. 1°. Date: 19 JERRY J. BEND€R,Heir of JOSEPH C. BENDER, Deceased 47.6,3‘ Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff Zai DEC -0 f, 10: 26 CU ;:':r ni., :,0 COUNT 1` YLVANIA JPMORGAN CHASE BANK, N.A., SB/M CHASE HOME FINANCE, LLC Plaintiff v. JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14-4263 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute BAYVIEW LOAN SERVICING, LLC as successor Plaintiff for the originally named Plaintiff. Date: The material facts on which the right of succession and substitution are based as follows: BAYVIEW LOAN SERVICING, LLC is the current holder of the mortgage by virtue of that certain Assignment of Mortgage, which Assignment was recorded on 09/17/2014 in Instrument No. 201421044 of the Recorder of Deeds Office in and for CUMBERLAND County. Kindly amend the information on the docket accordi 1-0 By: �% ��M, U , Robert P. Wendt, Esq., Id. No.89150 Attorney for Plaintiff PH # 940636 y cur,A,A sq.bpecbdu (104 Jui--71,-)1 12._*Lc 3� Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff JPMORGAN CHASE BANK, N.A., S/B/M CHASE HOME FINANCE, LLC Plaintiff v. JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14-4263 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of BAYVIEW LOAN SERVICING, LLC. Date: X2'3-ly PH # 940636 PHELA , •�� LINAN, LLP By: Robert P. endt, Esq., Id. No.89150 Attorney for Plaintiff iii Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff JPMORGAN CHASE BANK, N.A., SB/M CHASE HOME FINANCE, LLC Plaintiff v. JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14-4263 CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Plaintiffs Praecipe for Substitution of Party Plaintiff and Entry of Appearance were served by regular mail on the person(s) on the date listed below: JERRY J. BENDER, in his capacity as Heir of JOSEPH C. BENDER, Deceased 1115 WANSFORD RD MECHANICSBURG, PA 17050-7615 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER JOSEPH C. BENDER, DECEASED 299 ALLENDALE WAY CAMP HILL, PA 17011-8403 Date: ljq?'—/ PHELAN A INAN, LLP By: Robert P. Wendt, Esq., Id. No.89150 Attorney for Plaintiff