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Home My WebLink About14-4885 r Supreme Court,of Pennsylvania . \ Cour I€if Coixiiri:on Pleas CO�`E'T Sl3eet For Protlronotan,Erse 00r- Cumberland' Coaiu[)T I�oeit '. \ F'� The information collected on this form is used solely for court administration Pur poses. This form does not Supplement or replace thefiling and service ofpleadings or other papers as required by I",or rules o court. Commencement of Action: Ci ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: JPMC SPECIALTY MORTGAGE LLC TERRI A.SHIRLEY C ALAN D. SHIRLEY T I Dollar Amount Requested within arbitration limits 0 Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney:KML Law Group,P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARYCASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: C Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute:Other T ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RCP. 205.5 updated 11112011 KML LAW GROUP, P.C. SUITE 5000-BNY MELLON INDEPENDENCE CENT I J-1z P t - i-I t' 701.MARKET STREET F IL- 1'A i 10 y PHILADELPHIA,PA 19106 r ; (866)413-2311 `'j A U6 1$ ' JPMC SPECIALTY MORTGAGE LLC Ie�IISERLA N 3 Coo,';TIP THE COURT OF COMMON PLEAS e c/o 3415 Vision Driv -NNIS YL 1J�.V i Columbus, OH 43219 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION-LAW TERRI A. SHIRLEY ALAN D. SHIRLEY ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 213 South Penn Street � N's Shippensburg,PA 17257 �;1 V�..AC. �- (V r Defendant(s) TION:MORTGAGE NOTICE FORECOSow You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 1.7013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades a otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 6L, :b 115• � a (�it-f--/-) 4 ?!19 9 cln SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 1.7013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.gVx. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Horne Retention options. 6). Foreclosure Resource Center: http://wwwv.ph.iIadelpli.iafed.orp/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a2kmllawcroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed.if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.Please reference our Attorney File Number of 13432217C. Para information en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. f COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMC SPECIALTY MORTGAGE LLC, c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s)and property address(es)of the Defendant(s) is/are TERRI A. SHIRLEY, 213 South Penn Street, Shippensburg,PA 17257 and ALAN D. SHIRLEY, 213 South Penn Street, Shippensburg,PA 17257, who is/are the mortgagor(s) and record owner(s)of the mortgaged premises hereinafter described. 3. On November 23, 2004 mortgagor(s)made, executed and delivered a mortgage upon the.Property hereinafter described to AMERIQUEST MORTGAGE COMPANY,which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on December 07, 2004 as Book#: 1890 Page: 2022. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC by assignment of Mortgage recorded on June 25, 2007 as Book#: 0738, Page 0031. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit "C". Plaintiff and Defendant entered into a loan modification agreement and a true and correct copy is attached as Exhibit "D". The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 2014 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of July 17, 2014: PrincipalBalance........................................................................................$110,637.23 Interest from 02/01/2014 through 06/30/2014 ........................................ ..$3,683.30 AccruedLate Charges........................................................................................$197.48 EscrowAdvance................................................................................................$710.89 BPO/Appraisals.................................................................................................$310.00 PropertyInspections...........................................................................................$312.50 Reasonable Attorney's Fee.............................................................................$1,650.00 $117,501.40 7. If the Mortgage is reinstated prior to a Sheriff's Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further,Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing,title searches,recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability(or an "in personam"judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Plaintiff sent Defendants the notice as required by 35 P.S. Section 1680.401 et. seq. (Act 91 of 1983) or by 41 P.S. Section 403 (Act 6 of 1974) or as required by the Mortgage ("Notice"). A true and correct copy of the Notice is attached and incorporated as Exhibit"B". WHEREFORE,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$117,501.40, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW GR C. Michael.Mc e ver Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Pennsylvania Verification Sharon Ray , hereby states that he/she is Vice President of JPMC Specialty Mortgage LLC the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 1� 7 Sharon Ray Vice President Date: 07/30/14 JPMC Specialty Mortgage LLC Borrower: Alan D Shirley and Terri A Shirley Property Address: 213 S Penn St, Shippensburg, PA 17257 County: Cumberland Last Four of Loan Number:0745 EythibitA ALL the following described real estate lying and being situate in the Borough of Shippensburg,Cumberland County Pennsylvania,more particularly described as follows: TRACT No. 1:ON the West formerly by an extension of South Penn Street,now South Penn Street,and a public road leading to the farm now or formerly of the Borough of Shippensburg;on the South by lands,being Tract No.2 herein;on the East by an alley,on the North by a lot of ground now or formerly of Wallace Holtry, said lot having a depth from Penn Street to the alley on the East of 256 feet,more or less,and in breadth on the West along Penn Street,50 feet,more or less,whereon now is erected a two-story frame weather boarded dwelling house. j TRACT No.2:Being all that certain piece of ground situate on the East side of South Penn Street,and being South of Tract No. 1 herein.as follows;ON the West by South Penn Street;on the South by lands now or formerly of the heirs of William Melly;on the East by an alley,and on the North by Tract No. 1 herein,said lot having a frontage on South Penn Street of 32 feet,and a depth to the alley of 256 feet,more or less. Parcel#33-34-2415-170 i i I I i Eyv,hibit �B *Exhibit has been redacted to remove all personally identifiable information or non-public information P.O.Box 183205 Columbus,OH 43218 USPS CERTIFIED MAIL Tm For Undeliverable Mail On1y 9214 8901 0754 4636 4491 69 004519-1 of 5 NSPOHDLA-CA 71314237 0000000 ALAN D SHIRLEY 213 S PENN ST SHIPPENSBURG PA 17257 Chase(OH4-7399) CHASE !t P.O.Box 183205 Columbus,OH 43218 For Undeliverable Mail Only 05/07/2014 CERTIFIED MAIL: Return Receipt Requested and First Class Mail ALAN D SHIRLEY 213 S PENN ST SHIPPENSBURG,PA 17257 Act 91 Notice Account: ******0745 (the"Loan") Property Address: 213 S PENN ST SHIPPENSBURG,PA 17257(the"Property'') Dear ALAN D SHIRLEY: On the following page,you will find a notice regarding your home as required by Pennsylvania law. Cert'rfied Article#:9214 8901 0754 4636 4491 69 004519-2 o1 5 NSPOHDLA-CA J 1314237 0000000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help,you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (331 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 800-342-2397 (Persons with impaired hearing can call 717-780-1869.1 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AF ECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): ALAN D SHIRLEY TERRI A SHIRLEY PROPERTY ADDRESS: 213 S PENN ST SHIPPENSBURG,PA 17257 LOAN ACCOUNT NUMBER: 60745 ORIGINAL LENDER: AMERIQUEST MORTGAGE COMPANY CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A. Certified Article#:9214 8901 0754 4636 4491 69 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30)days from the date of this Notice (plus three(3)days for mailing).During that time,you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE(33)DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE.YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty (30)days after the date of this meeting. The names_addresses,and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out,sign,and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE HEMAPAPPLICATIONAS SOON AS POSSIBLE.IF YOU HAVEA MEETING WITHA COUNSELING AGENCY WITHIN THIRTY-THREE(33)DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY(30)DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTIONAGAINS T YOUR PROPERTY,AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE." YOUHAVE THE RIGHT TO FILE HEMAP APPLICA TION EVEN BEYOND THESE TIME PERIODS.A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSUREACTION,BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED ATANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Certified Article#:9214 8901 0754 4636 4491 69 004519-3 of 5 NSPOHDLA-CA J 1314237 0000000 AGENCY ACTION--Available fiords for emergency mortgage assistance are very_ limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60)days to make a decision after it receives your application. During that time,no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to datel. NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located at: 213 S PENN ST,SHIPPENSBURG,PA 17257 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 03/01/2014; $1,052.92 04/01/2014; $1,052.92 05/01/2014; $1,052.92 Other charges: Late Charges: $98.74 Insufficient Funds(NSF)Fees: $0.00 Other Fees: $0.00 Advances: $0.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $3,257.50 HOW TO CURE THE-DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS $3,257.50,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)-DAY PERIOD.Payments must be made by cash.cashier's check.certified check or money order made pavable and sent to: Overnight/Regular Mail: Chase Mail Code: OH4-7133 3415 Vision Drive Columbus,OH 43219-6009 Certified Article#:9214 8901 0754 4636 4491 69 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30) DAYS of the date of this Notice,the lender intends to exercise its rights to accelerate the mortgage debt.This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY(30)DAYS,the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to $ 0.00.However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs.If jou cure the default within the THIRTY(30)-DAY period, jou will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale,and any other costs connected with the Sheriff's Sale as specified in writing by the lender,and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice.A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Chase Address: Mail Code: OH4-7384 P.O.Box 41275 Jacksonville,FL 32203-1275 Telephone Number: 800-848-9380 Fax Number: 614-500-4605 Contact Person: Bruno Mejia E-mail Address: state.programs.intake@jpmchase.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You X may or_may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges,and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Cert'rfied Article#:9214 8901 0754 4636 4.491 69 004519-4 of 5 NSPOHDLA-CA J 1314237 0000000 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER.,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Cert'rfied Article#:9214 8901 0754 4636 4491 69 CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY PHONE ADDRESS CITY ZIP CODE Advantage Credit Counseling 888-511-2227 2000 Linglestown Road Harrisburg 17102 Service/CCCS of Western PA Community Action Commission of 717-232-9757 1514 Derry Street Harrisburg 17104 Capital Region Housing Alliance of York/Y Housing 717-855-2752 290 West Market Street York Resources 17401 Maranatha 717-762-3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community 717-334-1518 40 E.High Street Gettysburg 17325 Programs,Inc. PHFA 717-780-3940 211 North Front Street Harrisburg 17110 800-342-2397 Certified Article#:9214 8901 0754 4636 4491 69 004519-5 of 5 NSPOHDLA-CA J1314237 0000000 If you are represented by an attorney,please refer this letter to your attorney and provide us with the attorney's name,address,and telephone number. To the extent your original obligation was discharged,or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation.However,a secured party retains rights under its security instrument,including the right to foreclose its lien. IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service,you may be eligible for benefits and protections 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 877469-0110. AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS As stated in the"Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan"distributed by the Obama Administration, `Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan,especially if they require a fee in advance."Loan modification scams should be reported to PreventLoan Scam s.org,or by calling 888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge (i.e.,no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay,the fewer options you may have. BR860 Certified Article#:9214 8901 0754 4636 4491 69 P.O.Box 183205 Columbus,OH 43218 USPS CERTIFIED MAIL TM For Undeliverable Mail Only I 111111 11 11 1 9214 8901 0754 4636 4491 76 004520-1 of 5 NSPOHDLA-CA 71314237 0000000 TERRI A SHIRLEY 213 S PENN ST SHIPPENSBURG PA 17257 Chase(OH4-7399) CHASE Cp P.O.Box 183205 Columbus-OH 43218 For Undeliverable Mail Only 05/07/2014 CERTIFIED MAIL: Return Receipt Requested and First Class Mail TERRI A SHIRLEY 213 S PENN ST SHIPPENSBURG,PA 17257 Act 91 Notice Account: ******0745 (the "Loan") Property Address: 213 S PENN ST SHIPPENSBURG,PA 17257 (the"Property") Dear TERRI A SFURLEY: On the following page,you will find a notice regarding your home as required by Pennsylvania law. Certified Article#:9214 8901 0754 4636 4491 76 004520-2 of 5 NSPOHDIA-CA J 1314237 0000000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (33� DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address, and bhone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll-free at 800-342-2397. (—Persons with impaired hearing can call 717-780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): ALAN D SHIRLEY TERRI A SHIRLEY PROPERTY ADDRESS: 213 S PENN ST SHIPPENSBURG,PA 17257 LOAN ACCOUNT NUMBER: 745 ORIGINAL LENDER: AMERIQUEST MORTGAGE COMPANY CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A. Certffied Article k:9214 8901 0764 4636 4491 76 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30)days from the date of this Notice(plus three(3)days for mailing). During that time,you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE(33)DAYS OF THE DATE OF THIS NOTICE.IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty (30)days after the date of this meeting. The names-addresses and telephone numbers of designated Consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign,and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE HEMAPAPPLICATIONASSOONASPOSSIBLE.IF YOUHAVEA MEETING WITHA COUNSELING A GENCY WITHIN THIRTY-THREE(33)DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICA TION WITH THE PHFA WITHIN THIRTY(30)DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTIONAGAINSTYOUR PROPERTY,AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORAR Y STA Y OF FORECLOSURE." YOUHA LE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE TIME PERIODS.A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTINGA FORECLOSUREACTION,BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED ATANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Cert'rfled Article#:9214 8901 0754 4636 4491 76 004520-3 of 5 NSPOHDLA-CA J 1314237 0000000 AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60)days to make a decision after it receives your application. During that time,no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located at: 213 S PENN ST,SHIPPENSBURG,PA 17257 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 03/01/2014; $1,052.92 04/01/2014; $1,052.92 05/01/2014; $1,052.92 Other charges: Late Charges: $98.74 Insufficient Funds(NSF)Fees: $0.00 Other Fees: $0.00 Advances: $0.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $3,257.50 HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS $3,257.50,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30)-DAY PERIOD. Payments must be made by cash cashier's check certified check or monev order made payable and sent to: Overnight/Regular Mail: Chase Mail Code: 01-14-7133 3415 Vision Drive Columbus,OH 43219-6009 Certified Article k:9214 8901 0754 4636 4491 76 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30) DAYS of the date of this Notice,the lender intend to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY(30)DAYS,the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriffto pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to$50.00.However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. If you cure the default within the THIRTY(30)-DAY period, jou will not be required to pay attorney's fees OTHER LENDER REMEDIE --The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured tine default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender,and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice.A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Chase Address: Mail Code: OH4-7384 P.O.Box 41275 Jacksonville,FL 32203-1275 Telephone Number: 800-848-9380 Fax Number: 614-500-4605 Contact Person: Bruno Mejia E-mail Address: state.programs.intake@jpmchase.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You X may or,__may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges,and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Certified Article#:9214 8901 0754 4636 4491 76 004520-4 of 5 NSPOHDLA-CA J1314237 0000000 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Cert'rfied Article#:9214 8901 0754 4636 4491 76 CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY j LAND COUNTY PHONE ADDRESS CITY ZIP CODE e Credit Counseling 888-511-2227 2000 Linglestown Road Harrisburg 17102 CCS of Western PA y Action Commission of 717-232-9757 1514 Derry Street Harrisburg 17104 ion lliance of York/Y Housing 717-855-2752 290 West Market Street York naa 17401 717-762-3285 43 Philadel hia Avenue Wa nesboro 17268 Pennsylvania Interfaith Community 717-334-1518 40 E. High Street Gettysburg 17325 Programs,Inc. PHFA 717-780-3940 211 North Front Street Harrisburg 17110 800-342-2397 Certified Article#:9214 8901 0754 4636 4491 76 004520-5 of 5 NSPOHDLA-CA J 1314237 0000000 If you are represented by an attorney,please refer this letter to your attorney and provide us with the attorney's name,address,and telephone number. To the extent your original obligation was discharged,or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation.However,a secured party retains rights under its security instrument,including the right to foreclose its lien. IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service,you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act(SCRA). This includes protection from foreclosure or eviction.You may also be eligible for benefits and protections under state law. SCRA and state Military benefits and protections also may be available if you are the dependent of an eligible Servicemember. Eligible service may include: • Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration,or • Active service as a commissioned officer of the Public Health Service,or • Service with the forces of a nation with which the United States is allied in a war or Military action,or • Service with the National Guard of a state militia under a state call of duty,or • Any period when you are absent from duty because of sickness,wounds,leave,or other lawful cause. For more information,please call Chase Military Services at 877-469-0110. AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS As stated in the"Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan"distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan,especially if they require a fee in advance."Loan modification scams should be reported to PreventLoan Scams.org,or by calling 888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge (i.e.,no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay,the fewer options you may have. BR860 Certified Article#:9214 8901 0754 4636 4491 76 E..x.. hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information Prepared B,, and Return To:Dan Callahan GOLD13ECK McCAFFERTy&McKEEVER Mellon Independence Center-Suite 5000 ROBERT P. Z l E G L E R 701 Market Street RECORDER O F DEEDS Philadelphia,PA 19106-1532 C°J M 9 E-91-41 l9 C O II T Y- 215-627-1322 Parcel ID#: 33-34-2415-170 ASSIGNMENT OF MORTGAGE AMERIQUEST MORTGAGE COMPANY (Assignor), for and inconsideration of the sum of Ten Dollars($10.00)and other good and valuable consideration, the receipt of which is acknowledged,does grant,bargain,sell,assign and transfer to VM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE. WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE all of its right,title and interest,as holder of in,and to the following described m (Assignee), described and the indebtedness secured b the mortgage: ° may the property Y Executed TERRI A.SHIRLEY and ALAN D.SHIRLEY,Mortgagor(s);to AMERIQUEST MORTGAGE COMPANY. Bearing date of November 23,2o64;Amount Secured: $109,800.00; Recorded on December 07,2004;in Rook 1890,Page 2022;in the Recorder of Deeds Office of Cumberland County,Commonwealth of Pennsylvania("Mortgage") Property:213 S.Penn Street,ShippensburgXA 17257 AS FURTHER DESCRIBED IN EXHIBIT"A",ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,(^Note")and all moneys due and to become due on the Note and Mortgage,with interest. Assignee its successors,legal j representatives and assigns shall hold all rights under the Note and Mortgage forever,subject however,to the right and equity of redemption,if any,of the maker(s)of the Mortgage,their heirs and assigns forever. Assignor,AMERIQUEST MORTGAGE COMPANY,by its appropriate gate officers,has executed Assignment of Mortgage on this day of JUNE.2007. and seated with its corporate seal this O0738P6003 i AMERIQUEST MORTGAGE COMPANY By AMC MORTGAGE SERVICES INC.AS AUTHORIZED AGENT (Affix Corporate Sea]) (SEAL) Name:Tamara Price Title: Vice President (SEAT-) Name:Dana A.Rosas Title:Authorized Agent ss: STATE OF CALIFORNIA)COUNTY OF SAN BERNARDINO) BE IT REMEMBERED,that on this L day of JUNE. 2007,before me,the subscriber,a Notary Public personally appeared Tamara Price,Vice President for AMERIQUEST MORTGAGE COMPANY BY AMC MORTGAGE SERVICES INC.AS AUTHORIZED AGENT;and Dana A.Ross,Authorized Agent of AMERIQUEST MORTGAGE COMPANY BY AMC MORTGAGE SERVICES INC.AS AUTHORIZED AGENT;officers of Assignor,AMERIQUEST MORTGAGE COMPANY,who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed,sealed with the corporate seal and delivered the same as such officersaid,and that the within instrument is the voluntary act and deed of such corporation made by of a Dlution of its Board of Directors. No I hereby certify the address of the Assignee is: plA mom t ARAGM 50 W Suite 100,Orange,CA 92868ca,rna r«, t e"m omnge caw* 61mVCaVmE)pkmjan19.201 Loan No. :0100660745 Case#:53167FC I BKO738PG0032 Conestoga Title Insurance Company $CHEDME C PROPERTY DE3CP PTION The land referred to in this Policy is described as follows: ALL the following.described real estate lying and being situate in the Borough of Shippensburg, Cumberland County,Pennsylvania,more particularly described as follows: TRACT No. 1:ON the West forrnedy by an extension of South Penn Street,now South Penn Street,and a pubhc road leading to the farm now or formerly of the Borough of Stipperrsburg; on the South by lands, being Tract No..2 herein;on they by an alley;on.the North by a ict of ground now or to mierty of Wallace Hoary, said lot having a depth from Penn Street to the alley on the East of 256 feet, more or less, and in breadth on the West along Penn Street, 5o feet, more or less, whereon now is erected a two-story frame weather boarded dwelling house. TRACT No.2: Being all'that certain piece of ground situate on the East side of South Penn Street, and being-South of Tract No. 1 herein, as follows;ON the West by South Penn Street;on the South by lands now or formerly of the heirs of William Melly; on the East by an alley;and on the North by Tract No. 1 herein, said lot having a frontage on South Penn Street of 32#eet, and a depth to the alley of 256 feet, more or less. Parcel#33-34-2415-170 i i «: Eye recorded i-'and County PA 7`r of Deeds ALTA Policy SdhadLAe C (20041102I&PFDreoo4110218125) 0738PG0033 EAftifift ........... ............ *Exhibit has been redacted to remove all personally identifiable information or non-public information Loan Number =45 LOAN MODIFICATION AGREEMENT Borrower("I"}': ALAN D SHIRLEY and TERRI A SHIRLEY Lender("Lender"): JPMORGAN CHASE BANK, N.A. Date of First Lien Security Instrument("Mortgage")and Note("Note"): NOVEMBER 23,2004 Loan Number: 100660745("Loan") Property Address: 213 S PENN ST, SHIPPENSBURG, PENNSYLVANIA 17257 ("Property") If my representations in Section 1 continue to be true in all material respects, then the provisions of Section 2 of this Loan Modification Agreement("Agreement")will, as set forth in Section 2, amend and supplement (i) the Mortgage on the Property, and (ii) the Note secured by the Mortgage. The Mortgage and Note together, as may previously have been amended, are referred to r the .Loan Documents." Capitalized terms used in this Agreement have the meaning given to them in the Loan Documents. I have provided confirmation of my financial hardship and documents to permit verification of all of my income to determine whether I qualify for the offer described in this Agreement. This Agreement will not take effect unless and until the Lender signs it. 1. My Representations. I represent to the Lender and agree: A. I am experiencing a financial hardship, and as a result, am either in default under the Loan Documents or a default is imminent. B. The Property is neither in a state of disrepair, nor condemned. C. There has been no change in the ownership of the Property since I signed the Loan Documents. D. I am not a party to any litigation involving the Loan Documents, except to the extent I may be a defendant in a foreclosure action. E. I have provided documentation for all income that I earn. F. All documents and information I provide pursuant to this Agreement are true and correct. 2. The Modification. The Loan Documents are hereby modified as of-MARCH 01,2014 ("Modification Effective Date"), and all unpaid late charges are waived. The Lender agrees to suspend any foreclosure activities so long as I comply with the terms of the Loan Documents, as modified by this Agreement. The Loan Documents will be modified, and the first modified payment will be due on the date set forth in this Section 2: A. The Maturity Date will be: JUNE 01,2042. If there i s more than one Borrower or Mortgagor executing this document,each is referred to as"I".For purposes of this document words signifying the singular(such as"r)shall include the plural(such as"we")and vice versa where appropriate. WF101 LOAN MODIFICATION AGREEMENT-CHAMP ver.02 03_2014_11 01 44 — Page 1 of 6 pages 12.2013CR4063c CR40W CR4127c WF101 'I�Ili�t'•�6 �'8ri'�j ` y � �j1W r Loan Number 5 B. The modified principal balance of my Note will include all amounts and arrearages that will be past due (excluding unpaid late charges) and may include amounts toward taxes, insurance, or other assessments. The new principal balance of my Note is $110,637.23 ("New Principal Balance"). C. The Interest Bearing Principal Balance will re-amortize over 340 months. Interest will begin to accrue as of FEBRUARY 01, 2014. The first new monthly payment on the New Principal Balance will be due on MARCH 01,2014, and monthly on the same date thereafter. My payment schedule for the modified Loan is as follows: I promise to pay interest on the New Principal Balance at the rate of 7.990% annually. I promise to make consecutive monthly payments of principal and interest in the amount of $822.84, which is an amount sufficient to amortize the New Principal Balance over a period of 340 months. The above terms in this Section 2.0 shall supersede any provisions to the contrary in the Loan Documents, including, but not limited to, provisions for an adjustable or step interest rate. D. I agree to pay in full (i) the New Principal Balance, and (ii) 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 Balance, or the Maturity Date. E. I will be in default if I do not (i) pay the full amount of a monthly payment on the date it is due, or(ii)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 default, the interest that will be due on the New Principal Balance will be the rate set forth in Section 2.C. 3. Additional Agreements. 1 agree to the following: A. B. That this Agreement shall supersede the terms of any modification, forbearance, or workout pian, if any,that I previously entered into with the Lender. C. To comply, except to-the extent that they are modified by this Agreement, or by the U.S. Bankruptcy Code, with all covenants, agreements, and requirements of the Loan Documents, including my agreement to make all payments of taxes, insurance premiums, assessments, impounds, and all other payments, the amount of which may change periodically over the term of my Loan. This Agreement does not waive future escrow requirements. If the Loan includes collection for tax and insurance premiums, this collection will continue for the life of the Loan. That the Loan Documents are composed of valid, binding agreements, enforceable in accordance with their terms. WF101 LOAN MODIFICATION AGREEMENT-CHAMP ver.02-03_2014 11 01 44 — — Page 2 or 6 pages 12.2013CR4063c CR4064c CR4127c WF101 MIN Loan Number =45 D. That all terms and provisions of the Loan Documents, except as expressly modified by this Agreement,or by the U.S. Bankruptcy Code, remain in full force and effect; nothing in this Agreement shall be understood or construed to be a satisfaction 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 modified 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 terms and provisions of the Loan Documents. E. That, as of the Modification Effective Date, notwithstanding any other provision of the Loan Documents, I agree as follows: If all or any part of the Property or any interest in it is sold or transferred without the Lender's prior written consent, the Lender may, at its option, require immediate payment in full of all sums secured by the Mortgage. However, the Lender shall not exercise this option if federal law prohibits the exercise of such option as of the date of such sale or transfer. If the Lender exercises this option,the Lender shall give me notice of acceleration. The notice shall provide a period of not less than thirty(30) days from the date the notice is delivered or mailed within which I must pay all sums secured by the Mortgage. If I fail to pay these sums prior to the expiration of this period, the Lender may invoke any remedies permitted by the Mortgage without further notice or demand on me. F. That, as of the Modification Effective Date, a buyer or transferee of the Property will not be permitted, under any circumstance, to assume the Loan. In any event, this Agreement may not be assigned to,or assumed by, a buyer of the Property. G. If any document is lost, misplaced, misstated or inaccurately reflects the true and correct terns and conditions of the Loan Documents as amended by this Agreement, within ten (10) days after my receipt of the Lender's request, I will execute, acknowledge, initial, and deliver to the Lender any documentation the Lender deems necessary to replace or correct the lost, misplaced, misstated or inaccurate document(s). If I fail to do so, I 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 specified in this Agreement assume that payments will be made as scheduled. i I. That, if the Borrower is in bankruptcy upon execution of this document, the Borrower will cooperate fully with the Lender in obtaining any required bankruptcy court and trustee approvals in accordance with local court rules and procedures. The Borrower understands that-if-such approvals are not received, then the terms of this Agreement will be null and void. If this Agreement becomes null and void, the terms of the original Loan Documents shall continue in full force and effect, and such terms shall not be modified by this Agreement. J. If the Borrower(s) received a discharge in a Chapter 7 bankruptcy subsequent to the execution of the Loan_Documents, the Lender agrees that such Borrower(s) will not have personal liability on the debt pursuant to this Agreement. K. That in agreeing to the changes to the original Loan Documents as reflected in this . Agreement, the Lender has relied upon the truth and accuracy of all of the representations WF101 LOAN MODIFICATION AGREEMENT-CHAMP ver.02_03—2014—11—01_44 Page 3 of 6 pages 12.2013CR4063c CR4064c CR4127c W F101 1111109, 'Ifi�L � lfitrr�ti' Loan Number 5 made by the Borrower(s), both in this Agreement and in any documentation provided b or on behalf of the Borrower(s) in connection with this Agreement. If the Lender subsequently determines that such representations or documentation y accurate, the Lender may, at its option, rescind this Agreement and reinstate'Ofby terms of the Loan Documents as if this Agreement never occurred. I L. I acknowledge and agree that current holder or if the Lender executing this Agreement is not the owner of the Note and Mortgage, that such party servicing agent for such holder or owner, or its successor in interest and has fullauthorized power and authority to bind itself and such holderand owner to the terms of this modification. THIS WRITTEN LOAN AGREEMENT REPRESENTS THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTRADICTED BY CONTEMPORANEOUS, OR SUBSEQUENT ORAL EVIDENCE E PRIOR, ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES F THE PARTIES_ THERE (SIGNATURES CONTINUE ON FOLLOWING PAGES) WF101 LOAN MODIFICATION AGREEMENT-CHAMP ver.02 03 2014_11_01 44 Page 4 of&Pages 12.2013CR4063c CR44064 CR4127c WF101 gag �F,f1rti11 'I�II InTO BE SIGNED BY BORROWER ONLY Loan Number BORROWER SIGNATURE PAGE TO BANK, W And ALAN D SHIRLEYODIFICA BANK.MODIFA.An EFFECT" LEY and TERRI A SH RLEY LOAN NUMBER 100 6074 DATE OF March 01, LOAN NUMBER 10066D745 WJPMO�CHASE In Witness W 2D14 hereof, the Borrowerfs)have executed this agreement. Borrower_ SHIRLEY -' Date: 1.21 Borrower_TERRI A SHI Date: WF101 LOAN MODIFICATION AGREEMENT-CHAMP ver.02 03 2014 11 01 — _ 44 12.2Page CPage S o16 pages R4064c CR4127c WF101 �Ma Loan Number TO BE SIGNED BY 9*5 ENDER ONLY LENDER SIGNATURE PAGE TO N.A.And ALAN p SHIRLEYODIFICATION EFFECTIVE DATE OF LEY and TERRI A SHIRLEY AGREEMENT BETWEEN JP Manch 01,2014 ' LOAN NUMBER 100660745 WITH CHASE In Witness W A MODIFICATION ON � hereof, the Lender has executed Lender this Agreement. I JPMORGM CHASE BAtNtG,N.A. By. Printed Name: ashler Griffiths '*"'C()PrOSident Execution Date: JL WF1o1 LOAN MODIFICATION AGREEMENT-CHAMP ver,02_03_2014-1 1_01_44 12.2013CR4063c CR4 e 6 of 6 Pages 064c CR4127c WF101 Iii,{• �� ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �� i�F r Sheriff THE PROTNOt ��l i'i ' Jody S Smith Chief Deputy Richard W Stewart Solicitor 2014 SEP -9 PM 3: 26 CUMBERLAND COUNTY PENNSYLVANIA JPMC Specialty Mortgage LLC vs. Terri A Shirley (et al.) Case Number 2014-4885 SHERIFF'S RETURN OF SERVICE 08/29/2014 06:05 PM - Deputy Jason Kinsler, 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 Terri Shirley, wife, who accepted as "Adult Person in Charge" for Alan D Shirley at 213 S Penn Street, Shippensburg Borough, Shippensburg, PA 17257. /hi; —/ Area_ J ON KINSLER DEPUTY 08/29/2014 06:05 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Terri A Shirley at 213 S Penn Street, Shippensburg Borough, Shippensburg, PA 17257. JASON KINSLER, DEPUTY SHERIFF COST: $66.60 SO ANSWERS, September 03, 2014 (C) CcuntySu .e Sherif;, TelCQsCft, Inc. RONFR ANDERSON, SHERIFF In the Court of Common Pleas of Cumberland County JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 14-4885 CIVIL' 0 • THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against TERRI A. SHIRLEY and ALAN D. SHIRLEY by default for want of an Answer. Assess damages as follows: $117,501.40 Debt Interest from 11/18/2014 to Date of Sale per diem at $24.22 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or del'vered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occ ',ed . at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 i AND NOW By: XML LAW GROU', ' C. _Michael McKeever Pa. 1 u 56129 Jay E. Kivitz Pa. ID 26769 _Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _David Fein Pa ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 _Salvatore Filippello Pa. ID 313897 _Alyk L. Otlazian Pa. ID 312912 Jennifer Lynn Freebie Pa ID 316160 Attorneys for Plaintiff JPMC SPECIALTY MORTGAGE LLC and against TERRI A. SHIRLEY and an Answer and damages assessed in the sum of $117,501.40 as per the above Judgm .:.. ' entered in fav by defaul gth a otary of a.nt1 s/(0. Sty? CL -#7s'/7/7 r t - ins .• / / 'D 41- ql'?/AA?i Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, 01143219 TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagors and Record Owner(s)) 213 South Penn Street Shippensburg, PA 17257 Plaintiff vs. Defendant(s) No. 14-4885 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Sre Carlisle, PA 1701,a Prothonotary By; If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 134322 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TERRI A. SHIRLEY SHIRLEY, TERRI A. 213 South Penn Street Shippensburg, PA 17257 JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 Plaintif vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) 213 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: TERRI A. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 DATE OF THIS NOTICE: October 30, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-4885 CIVIL IMPORTANT NOTICE 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 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 1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 KML L GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attomeys for Plaintiff 134322 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: ALAN D. SHIRLEY SHIRLEY, ALAN D. 213 South Penn Street Shippensburg, PA 17257 JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) 213 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: ALAN D. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 DATE OF THIS NOTICE: October 30, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-4885 CIVIL IlVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER. A WRI1ThN 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 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: I r u KML LAW G6UP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oilazia n Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMC SPECIALTY MORTGAGE LLC Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Defendant(s) NO. 14-4885 CIVIL VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): TERRI A. SHIRLEY, has a last known residence of 213 South Penn Street, Shippensburg, PA 17257. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date 1 1 " By: KML LAV' ROUP, P.C. Michael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P. Jenkins Pa. ID 306588 lyk L. Oflazian Pa. ID 312912 `/Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant. to Servicern Civil Relief Act. Last Name: SHIRLEY First Name: TERRI Middle Name: A Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17.2014 08:56:32 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Dirty Start Date Active Duty End Date Status Service Component NA NA }f;- {- h i.:.... .. -� `,.., . f`.'. . N . ,,, NA This response reltectu ttheandiviiluats active-di.ty status based on the Ai:'vetDu`ty;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 it .i7 ;NA �a. . f ,.,a: 9 . ' i. . '1 _// ~:No:.7` i,!t1 NA This response reflects where the individual -left acme dulStatus within`367 days preceditII the'Aaive Duty Status Date Upon searching the data banks of the Department of Defense ManpoweriData Center; based os;tt a 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, er_vices,(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Stan Date Order Notification End Date Status Service Component NA � -S- NA '�:r = a {;-No?�`. `' NA ...: . Vim, � This response reflects whether, lhe rndrvidual or .. - unit has reeervetl early not cat on to iepo t for active duty Upon searching the data banks of the Department of Defense ManpoweriData Center; based os;tt a 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, er_vices,(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. h 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(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds, All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: ZFJ5L8CA305FQC0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMC SPECIALTY MORTGAGE LLC Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Defendant(s) NO. 14-4885 CIVIL VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.millappj/scra/scraHome.do) for the following individual(s): ALAN D. SHIRLEY, has a last known residence of 213 South Penn Street, Shippensburg, PA 17257. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. By: At GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Fi l ippello Pa. ID 313 897 Jill P. Jenkins Pa. ID 306588 /Alyk L. Oflazian Pa. ID 312912 / Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant. to Service Last Name: SHIRLEY First Name: ALAN Middle Name: D Active Duty Status As Of: Nov -17-2014 Civil ReliefA Results as of: Nov -17-2014 08:57:00 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty Enct Date Status Service Component NANA ,,,e,i:i: ;:i .;:,..,,,, 4.,,,; -4'-.7.A...!,:,-,'"'r ::. ::.r,ii;,,,.. NA This response reflecMihe'ihrirv';c1Mats' activ6 iiitlytiatus'ha'sed on the "iMtiVellituti Status Date /j. (?, Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Dam Active Duty End Date Status Service Component NA ,I.,.;..r7 ,14o 1 NA This response reflects vvhermthe individual leftaCtive Whit:sterns iiiiittiii887;cidY; preceding ta'Active" ' bitty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .,NA,; :-q,:i.,; ';-.;:,.. 7::, . ''".. 31,;'?':-Ilet;;,ir : .-,-' ';'/. NA 4V.:..i.,' This response reflects vvheitterVM.inddual oPhiMier unit has received -earlynoitfication toTeport for active duty Upon searching the data banks of the Department of Defense MaripOwerbetaCentei,sbaseeOn;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 Liniforrited:Seiyices,:(Atny, Navy, Marine Corps, Air Force, NORA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq. as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 1 FX3Q84AM05EIA0 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record owner(s)) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 14-4885 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor of JPMC SPECIALTY MORTGAGE LLC, and against TERRI A. SHIRLEY and ALAN D. SHIRLEY for failure to file an Answer in the above action within (20 ay41 m the date of service of the Complaint, in the sum of $117,501.40. II 4 By: KML LAW GROUP P.c. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Jlyk L. Oflazian Pa. ID 312912 ennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 and that the name(s) and last known address(es) of the Defendant(s) is/are TERRI A. SHIRLEY, 213 South Penn Street i,.pensburg, PA 17257 and ALAN D. SHIRLEY, 213 South Penn Street Shippensburg, PA 17257; By: KML LAW GROUP P. . Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 )11yk L. Oflazian Pa. ID 312912 (Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $110,637.23 Interest from 02/01/2014 through $3,683.30 06/30/2014 Reasonable Attorney's Fee $1,650.00 Late Charges $197.48 Escrow Advance BPO/ Appraisals Property Inspections AND NOW, this 14-4885 CIVIL/134322FC By: $710.89 $310.00 $312.50 $117,5040'\ n KML LAW GRQUF, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313 897 Alyk L. Oflazian Pa. ID 312912 /Jennifer Lynn Frechie Pa. ID 316160 4 Attorneys for Plaintiff day of IN, ;.2014 damages are assessed as above. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Mortgagor(s) and Record Owner(s) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 14-4885 CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due SdeSqj lob 1.D eiu �l s•1Sci uit Sa,Lo Interest from 11/18/2014 to Date of Sale per diem at $24.22 (Costs to be added) By: r KML LAW GROUP,E'P.. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 hhAndrew F. Gornall Pa. ID 92382 Cb. Salvatore Filippello Pa. ID 313897 `j q► �, Alyk L. Oflazian Pa. ID 312912 CS . SC? V. Jennifer Lynn Frechie Pa. ID 316160 780/ 7 Attorneys for Plaintiff Ahq if KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff i ; • 11* 15 F f JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) i L‘I/ANiA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 14-4885 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 JPMC SPECIALTY MORTGAGE LLC, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 213 South Penn Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): TERRI A. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 South Penn Street Sbippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: TERRI A. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Bureau of Compliance Dept. 280948, Harrisburg, , PA 17128-0948 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 213 South Penn Street Shippensburg, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: \\\\--i\v By: A KML LAW IGRROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha. Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313 897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff !. KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff 14-4885 CIVIL JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Mortgagor(s) and Record Owner(s) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 14-4885 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHIRLEY, TERRI A. TERRI A. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 Your house at 213 South Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $117,501.40 obtained by JPMC SPECIALTY MORTGAGE LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE LLC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 1 14-4885 CIVIL 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 IR THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of Cumberland County at 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 14-4885 CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD' S website www.hud.gov for. Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(c�kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 134322FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106. (215) 627-1322 Attorney for Plaintiff F-iiOTHONO {i3",`( 201 NOV 19 /-t,r 11: 9 5 CUMt E F L,`-'; 0 COUNTY PENNSYLVANIA 14-4885 CIVIL JPMC SPECIALTY MORTGAGE LLC c/o 3415 Vision Drive Columbus, OH 43219 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Mortgagor(s) and Record Owner(s) 213 South Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 14-4885 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE -ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHIRLEY, ALAN D. ALAN D. SHIRLEY 213 South Penn Street Shippensburg, PA 17257 Your house at 213 South Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $117,501.40 obtained by JPMC SPECIALTY MORTGAGE LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE LLC, the back payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 14-4885 CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmilawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 134322FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMC SPECIALTY MORTGAGE LLC Vs. TERRI A. SHIRLEY ALAN D. SHIRLEY WRIT OF EXECUTION NO 14-4885 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $117,501.40 L.L.: $.50 Interest FROM 11/18/2014 TO DATE OF SALE PER DIEM AT $24.22 Atty's Comm: Due Prothy: $2.25 Atty Paid: $227.35 Plaintiff Paid: Date: 11/19/2014 Other Costs: Davi : uell, Protonotary (Seal) By: Deputy REQUESTING PARTY: Name: JENNIFER LYNN FRECHIE, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 316160