HomeMy WebLinkAbout14-5205 Court of Common Pleas
Civil Cover Sheet For Prothonotary Use Only:
Docket No:
Cumberland County
The information collected on this form is used solely for court administration purposes. This form does not
upplement or replace thefiling and service ofpleadings or other papers as required by I",or rules of court.
Commencement of Action:
Z Complaint F] Writ of Summons r_1 Petition
S F1 Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff's Name: JPMorgan Chase Bank, Lead Defendant's Name: Brian Rogers
C National Association successor by merger to Chase
Home Finance LLC successor by merger to Chase
T
-Manhattan Mortgage Corporation
I Dollar Amount Requested: El within arbitration limits
0 Are money damages requested?: El Yes ® No (Check one) outside arbitration limits
N
Is this a Class Action Suit? EI Yes Z No Is this an MDJ Appeal? F-1 Yes M No
A
Name of Plaintiff/Appellant's Attorney: Christopher A.DeNardo,Esquire
❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant)
Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑ Intentional E] Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution El Debt Collection:Credit Card F] Board of Assessment
E] Motor Vehicle 0 Debt Collection: Other E] Board of Elections
R Nuisance El Dept.of Transportation
E] Premises Liability El Statutory Appeal: Other
S F-1 Product Liability (does not El Employment Dispute:
include mass tort) Discrimination
E F-1 Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
C FI Other:
T El Other:
E] Other:
0 MASS TORT
N F1 Asbestos
R Tobacco
F1 Toxic Tort-DES
El Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
F-1 Toxic Waste E] Ejectment E] Common Law/Statutory Arbitration
B 171 Other: [] Eminent Domain/Condemnation El Declaratory Judgment
E] Ground Rent F-1 Mandamus
E] Landlord/Tenant Dispute F-1 Non-Domestic Relations
E Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY [I Mortgage Foreclosure: Commercial [I Quo Warranto
171 Dental [-] Partition El Replevin
❑ Legal E] Quiet Title El Other:
F1 Medical E] Other:
n Other Professional:
Updated 11112011
SHAPIRO &DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE,ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE,ATTORNEY I.D.NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase CUMBERLAND COUNT
Manhattan Mortgage Corporation U/
PLAINTIFF NO: �(� 5;�OS7
�erlnvs.
MCI)
Brian Rogers
615 3rd Street r- -•c:
i <=
New Cumberland, PA 17070
DEFENDANT
COMPLAINT-CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE
FOLLOWING PAGES,YOU MUST TAKE ACTION WITHIN TWENTY(20)DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED,BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
,e
3/0.39
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A LISTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE(20)DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI LISTED NO SE DEFIENDE,LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. LISTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA LISTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
SHAPIRO&DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,ATTORNEY I.D.NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D.NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 14-044904
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase CUMBERLAND COUNTY
Manhattan Mortgage Corporation
PLAINTIFF NO:
VS.
Brian Rogers
615 3rd Street
New Cumberland, PA 17070
DEFENDANT
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, JPMorgan Chase Bank,National Association successor by merger to Chase
Home Finance LLC successor by merger to Chase Manhattan Mortgage Corporation, the address
of which is, 3415 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage
foreclosure upon the following cause of action:
1. (a) Parties to Mortgage:
Mortgagee: Chase Manhattan Mortgage Corporation
Mortgagor(s): Brian Rogers
(b) Date of Mortgage: November 20, 2001
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County Mortgage Book 1740, Page 896
Date: November 27, 2001
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
2. Plaintiff is either the original Mortgagee named in the Mortgage, the legal successor in
interest to the original Mortgagee, or is the present holder of the mortgage by operation of
law.
3. The real property that is subject to the Mortgage is generally known as 615 3rd Street,
New Cumberland, PA 17070 and is more specifically described as attached as part of
Exhibit "A".
4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Promissory Note"). A true and correct copy of the Note is attached
and marked as Exhibit "B".
5. The name and mailing address of the Defendant is: Brian Rogers, 615 3rd Street,New
Cumberland, PA 17070.
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both.
7. The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of September 1,
2013 and have not been paid, and upon failure to make such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of May 07, 2014:
Principal Balance Due $98,239.31
Interest Currently Due and Owing at 6.875% $5,065.47
From August 1, 2013 through April 30, 2014
Escrow Advances $1,898.73
T—( TAL $105,203.51
9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff
may incur other expenses, costs and charges collectible under the Note and Mortgage.
10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be
sought by Plaintiff and included in any request for judgment.
11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403
commonly known as Act 6 and demand for payment was sent to each individual Defendant
by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C".
12. The Mortgage is insured by the Federal Housing Administration under Title II of the
National Housing Act (12 U.S.C. § 1707-1715z-18). Accordingly, the Homeowners'
Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 8 and 9, together
with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note
and Mortgage and for the foreclosure and sale of the mortgaged premises.
S IRO & DeNARDO, LLC
Date:
BY:
ttorneys or la' tiff
C )N M.DON LLL,Psi
S & D File No. 14-044904
i
Record and Return to:
CHASE MANHATTAN MORTGAGE CORPORATION
1500 N 19TH STREET
MONROE LA 71201 COUNTY-PA
ATTUNTION: FINAL CERTIFICATIONS
K� '01 NOV 27 PM 36
&W of Pet,usyivanin mq ff CTerAL
atj'h Csso No.
THIS MORTOAGZ(1Socurity Irtstrvratnt")is given on November 2p, 2001
The Mortgagor is
BRIAN ROGERS, MARRIED
Whose address is
615 3RD STFZZT, NEW CUMBERLAND, HA 17070
CHASE MANHATTAN MORTGAGE CORPORATION ("BOMWer"). This SeWritylnstmnvatisglvento
whlch is organized and 0x1141119 under the laws of the State Of New d'ersey
address Is 393 TRORNALL STREET ,and whose
EDTSQN, NJ 08837
One Hundred Nineteen Thousand, seven Huridr d Ninety,Se en a lcnci00/1 rinoipal etunof
Dollars(U.S.$ Z19,797,00 Ninety,Seven and O4ajo u
lmtnrrt i(,Note"),which provides for tnontbl) Titi1 debt is evt seined debt,
,If not paid
Note dated the same date sa this Security
December 1, 2031 This Sy unity'"WO i t$ to 1 if Got paid aarller,duo and payable on
the Note,with interest,and all renewals,OxtenalOw and roodincatfons of the Nom der: (a)the repsymcat of the debt evidenced by
advanced uOderparagraph 7 to protect the security of this Security Instrutruyt:and�(Nihoe payment of all Other stuns,With interest,
89f0w ats under this Security bwtru=t and the Note. Por this purpose,Borrower d performance Borrower's covenants and
Lender,the following desoribcd property located la y gage,grant and convey to
CUMBERLAND County,Poanaylvania:
See Attached Legal Description
which has the address of
615 3RD STREET, NEW CUMBZ;RLAND, PA 17070
TOOMMER WITH all the imprrovontcote now or hereafter eroctcd On the property,and all easetnenly,appurtenaam,aad
fixtures now or hereafter 8 ptut Of the property. All replacements and odditlolw
All of the foregoing is ref=cd to In this Security Inatraareat as the"property," shall also be covered by this security Iaetrumatt.
BORROWER COVENANTS that Borrower is Iawfully seised of the estate hereby conveyed and has the light to mortgage,
grant and convey the property and that We Prnperry ie wteacumbered, ax
will defend generally the title to the pro rept for encumbrances of record. Borrower warrants and
Perry against all rolaima and dwwuds,subject to ante enctunbrances of record.
�;(7nIt",i�01) � , AGS I ops OKI 7 4 U PG 0 8 9 6 r
Tltu Ssctaxrrr IttMURUMcombines uniformcoveaants for natlonal use and cert
by Jurisdiction to constitute a uniform security in
vtnunent Counlformroovenante with 1lmlted variations
real property.
Borrower And Lender oovenant and agm as follows:
UNIFORM COVENANTS;
1. Payment"Principal,Intot'est And Lato Charge. Borrower shall pay when duo the principal of,and interest on,the
debt evidenced by the Note and late obargee due under the Note,
2. Ilxonthly Payment of Taxes,Insurance,and Other Charges, Borrower shall)acludo in each monthlyps moot,together
Withevied the principal and interest aS set Porth in the Note and any late charges,a sum for(s)taxes and special assessments levied or to
P It groPh against the�riy,(b)leasehold payments or ground routs on the Proporty,and(c)premiums for insuram required under
Y Year is which the Leader must pay a mortgage Insurance pramlutta to the Secretary of Housing sad Urban
Uevelopmeat(^Secretary^), or in any yen In which such prerrtluru would have been
fi t' each monthly Peyntxmt shall.also include either; I a earn for the annual mort�g if still held the Socini
Lender to the Secretary,or(li)a monthly Charge instead of a mOrt age ga8e i isuranCe premium
to be paid by
Secretary, in a treasonable account to be determined by the g g insurance premium if this Security butrument Is held by the
RM called"J3sarow 71ema"and the sours paid to Lander eras maty. Except for the monthly charge by the Secretary,these Items
Leader may,at any time,COI)ect and hold annals for jUarrow Itemssiinan aggregate t s to ex
amount that tray be required for Borrower's escrow account under tie Real)Istata Settlenteat Procedures amounAct,of 4,o,maximum
5 2601 gl i g.twd implemontfng regulations,24 CFR Part 35x;1),as they may be amended from Nine to tune(°R6SPA"),except that
the cushion or reserve permitted by RESPA for unantiei
paW available In the amount may not be based onartrounta duo for c�b oote or disburaoactits before the Borrower's payments are
If the amounts held by Lander for Escrow Items oxoeal the Mortgage
eaInsurance plum,
to Borrower for the excess funds as required by RBSPA. If the amounts of funds hold Permitted tby Lando o be heldby
any time are not auffloiont to
Pal'the Bacrow Items whoa duo,Leader may notify the Borrower and Y MPA,Lender Pe account
RLSPA, require Borrow t0 melte Up the shottegc at Pe
by
Tho)escrow Funds are plcdgod as additional security for all aures secured b
to Lender the full Payment of all such stuns,Borrower'a account shall be ereditod with 16esb ice remain or all lnarower ttouders
(a), (b)and(c)and any mortgage ices Nodso prerui»m installment that Lender has not b000me obligated to pay to the Sooretaly,and
by Items
Ler ,shall promptly refund any excess e t to Boerower, hiamccilate[y Prior to a foreclosure sale of the Pro
by Lender,Borrower's account shall be credited widt any balance reraainfag for all lnaudlnoents for hours aPCrtyan (acquisJtioa
3. Application of payments, All payments under Paragraphs 1 and 2 shall be applied by Londa as follows:
h ,to the mortgage iueurauca prMW=to be paid by.under to the Sacrctary or to the monthly charge by the Secretary
inatead of the monthly mortgage insurance premium"
promlw
Second,to any taxes.spacial assessments,leasehold payments or ground r
X,as required; ears,and fire,flood and other hazard insurance
D-3 ,to Interest due under the Note,
ZQU—h,to amortization of the principal of the Note;and
Ea,to late charges due under the Note.
4. lirfre,Flood and Other Huard Insurance. Borrower shall insure all improvements on the Property,whether now In
existence or aubaoquently erected, agahrat any hazards, casualties and cotnttogen cs, including ii the
for which Leader requires
all Lma ra This insurance shall be mniatalaod is the ataounls and or the poriods that Lerdor nequlres. Borrower shall PICO insure
all lmprovemeata on the Property,whether now In axlStonce or aub
by the Secretary. All tasurance shall be carried with co nates Se4cendy steered,against lnsa by floods to the extent require[
be bold by Lender and shall Include lose payable claim In favorr of, d The inattr0" Policies and any re n ro shall
In the avert of loss,Renewer shall glue Lander lmmaltate notice b mail,occeptable to.Lender.
PromptiY by Borrower, Asch insuruoce eoarpaey coacemed is hereby authorizod sad directed may make proof of foes iP not made
to Conder.instead of to Borrower and to lCnder Jointly. AJI or any part of the insurance W racks Payment for such loss directly
option,either(a)to the teductian of the indebtodarea under the Nate and this insSecurl Proceeds UMy he applied by Leader,at Its
applied in the order in Paragraph 3,and then to ptopayane er t e Noteal,or(b)to the rty jn r repair a!r of tto he damaged delinquent aux. to
Any application 2,lite proceeds to the principal shall not extend or postpone the due date mf We tnontlil Property.
to st nding itidaph 2, or change the amount of such PaYawats. Any exce4a InsurszCe r Y PSYmentS which aro referred
outstanding indebtedness under the Note and this Security Instrrtrrteat shall be paid to Pr entity ver M 61 hied trequired ro pay all
In the event of foreclosure of this Security Insltumont or other transfer of tilde to the property that ex
Indebtedness,ail light,title end Interest of Borrower In and to InsurancC policies in forco shall pass to the purrhasor,
S Occapanoy,Prescrvatieu,Maintenance and Protection of the Pro thrgoishes the
Borrower aball OCCUPY,establtali,and neo the Prortpni Borrowers Loan Appuimtlonl Leaveholds.
this Security Inatrutntnt(or within sixty days of a later or trransfer of the Pm ncipal ideate within sixty days after thu he Property of
as Bor7owces principal residence for at least one year.after the date of occupancy,unless Lendatl d ortthi mss that uPY the Property
Cause Undue hardship for Borrower,or unless extenuatingciroumstnaoes exist which aro roqulttmeat will
notify Leadets of any Mounting cirwmstaneea. Borrower shall not comma deyotuJ Borrower's control.,mower shall
Property or allow the Property to deteriorate,reasonablo wear and tear ex Commit or destroy,damage or substantially cbange the
is vacant or abandoned or the loan is In default. Lander may Lender intpec!Wo property if the Property
Property' Borrower Shall also be fn default If Borrowr,daring tthheaIOantts aejoona O Prot Preserve such vaoant orgbandonod
informmlon or statements to Lender(or failed 10 provide lender with An Process-gave materially false or inaccurate
by the Note,including,but not limited to y Modal information)In conaectiou with the loan evidenced
If this seenrlty Inatramcttt to On a Ieasebo]d Bonrowernahati comply concern
Borrower's occupaney of the Pro
to the Property,the Icacehold and fee tide shall not be merged Un es )mer provisions of the
ie&� I fJ w�rineJpal residence.
6. Condermautton..The proceeds of 8 to Ne merger to writing, aC9uues foo title
COndenuuilion or other taking of any part of the Property,omaward or claim for damages, direct or consegtteatlat,is COMCCtfon with any
be paid to Lender to the extent of the full amour,of the Indebtedness(bat�ce in Place of coademastion,aro hereby assigned and shall
Lender shall apply such proceeds to the reduction of the indebtedness under the Note id Under
rtbIs 3ec�ty Iinss Security
first aUy
delinquent ampuula applied in the order provided In Para rah 3 and Ihar to r a
Proceeds to the principal shall not extend oro g p ' PCP Yrneat of principal. Any appllrxdon of the
of change the amount of Such Postpone Pr due tints of the monthly Pay�ts,which ate referred to in Paragrapb 2.
PIs. Any excess proceeds coot au amount required tO pay all Outstanding indebtedness under
PHNNSYr,VAN1A t'ttA MOA'raA06
C-3701 (7M) (RaP14=IM)PAGE 2 OA 5 6K 17 4 0 PG 0 8 9 7
tits Note and this Security Instru nent shall be paid to the antity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's Rights in the Property, Borrower shall pay all govertnnental or
municipal charges,fines and impositions that are not included in Paragraph 2. Borrower shall pay these obligations on(taco directly
to the entity which Is owed the payment, If failure to pay would adversely affect Lender's Interest In the Property,upon Lender's
request Borrower shall promptly furnish to Lender roWpu evidencing these payments.
If Borrower falls to make these payments or the paytnants required by PoMrsph 2,or falls to perform any other covottants
and agreements contained in this Socutity instrument,or there Is a legal proceeding that may signifiearWy affect Leader's rights in
the Property(such as a procooding In bauk uptcy,for condemnation or to enforce laws or regulations),then Ixudor may do and pay
whatever is necessary to protect the value of the Property and Lender's rights In the Property, Including payment of taxes,hazard
insumnoo and other items mentioned In Paragraph 2.
Any amounts disbursed by Conder under this Paragraph shall become an additional debt of Borrower and be secured by dile
Security Instrument. Three amounts shall tear interest from the date of disbursornerd.at the Note rate,and at the option of the
Lender,shall be Immediately due and payable.
Borrower shall promptly discharge any lien which bas priority over this Security Instrument unless Borrower;(a)agrees in
wilting to the payment of the oblignttou setnued by the lion In a manner acceptable to Leader;(b)contests in good faith the lion by,
or defends against onforcemeat of the lion in,legal proceedings which in the Leader's opinion operate to pmvenl the enforcement
of the lien;or(c)secures from tho holder of the Ilan an agreement satisfnatary to Lender subordinating the lien to this Security
Inottumcm, If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security
Instrument,Lender may give Borrower a notice identifying the lion.'Borrower shall satisfy the lien or take one or more of the actions
set forth above within l0 days of the giving of notice.
S. Foes, Lender may collect fees and charges authorizod by the Secretary.
9. Grormds for Acceleration of Debt.
(a)Default. Lender may,except as limited by regulations issued by the Secretary to the case of payment defaults,
require Immediate payment in full of all sums secured by this Security Instrutomi if:
(t) Borrower defaults by failing to pay In tall any monthly payment required by this Security instrumant
prior to or on the duo date of the next monthly paymeut,or
(H)Borrower defaults by falling,for a period of thirty days,to perform any other obligations ooruained
is this Security In"meat,
(b)Sale Without Credit Approml, Lender shall,if permitted by applicable law(Including section 341(d)of the
Cam-St Germaht Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d))and with the prior approval of the
Secretary,requite immediate payment In fall of all sums secured by this Security Instrument if;
0) All or part of the Property,or a beneficial lnterest in a trtut owning all or part o f the Property,is sold
or otherwise transferred(other than by devise or descent),and
(li)'Ihe property Is not occupied by the purchaser or grantee as his or her principal residenco,or the
purchaser or granleo does so occupy the Property, but-Ids or her credit has not been approved in
accordance with the requirements of the Secretary,
(c)No Waiver. If circumstances occur that would permit Lander to require immediate payincm in full,but Lender
does not require such payments,Lender does not valve Its rights with respect to subsequent events.
(d)Regalattow of JIM Secretary. In many ohoumstanow regulations lssucd by the Secretary will limit Lender's
rights in the case of payment defaults to requite immediate payment in full and foreclose If not paid, Ibis Security
Instrument does not authorize acceleration or foreclosure if not penuftted by regulations of the Secretary.
(e)Mortgage Not ifnsured. Borrower agrees that if this Security Instrunnent and the Note are not determined to
be eligible for insurance under the National Housing Act within 60 days from the date hereof,Conder may,at Its
option require immediate payment in dill of all stuns secured by this Security Instrument. A written statement of
any authorized agent of the Secretary dated subsequent to 60 days from the date hereof,declining to insure this
Somrity Instrument and the Note,shall be deemed enclusive proof of such indiglbulty. Notwithstanding the
foregoing,this option may not be exercised by Lender wlton the unavollabilltyof inswaacc Is solely due to Lender's
failure to remit a mortgage insurance premium to the Socretary.
10. Reinatotement. Borrower bas a right to be reinstated if Louder has required Imtnedlaia payment in•fidl because of
Borrower's fatlurc to pay an amount due under the Newer this Security Instrument. This right applies even after forceloeum
proceedings aro instituted, To Mnnm the Security Instrument,Borrower shall tender in a lump sum all amounts requited to bring
Borrower's account current Including,to the extent they are obligations of Borrower under this Security Inshtttnent,foreclosure costs
and treasonable and customary attorney's firs and expenses properly associated with the foroclosur s proceeding. Upon reinstatement
by Borrower,this Security Instiu vont and the obligations that it secures shall remain in effect as if Lander had not required immediate
payment in fall. However, Lender is not required to perurft reinstatement If: (1) lender has accepted reimstateamt after the
commwttoomeat of forcelosurr proopodlugs within two years imrnetlSaicly preceding tho commencanent of a current foreclosure
proceeding,(i)relaetatement will preclude foreclosure on different grounds in the talars,or(llf)reinstatement will adversely affect
the priority of the lien created by ills Security Instrument.
11. Borrower not Released;Forbearance by Leader not a Walver. Uevion of the time of payment or modification
of amortization of the now secured by this Security Instrument granted by Leader to any successor in luterasl of Borrower"not
operate to release the liabliftyof the original Borrower or Borrower's successor in lateral. Lender shall not be required to eomttenco
proceedings against any successor In interest or refuse to extend tints for payment or otherwise modify amortization of the sums
secured by this Security Ingtrwnemt by reason of any den3W mado by the original Borrower or BormwWo successors in interest,
Any forboaranee by Leader In exorcising any right or remedy shall not be a walverof or preclude the exercise of any right or remedy. .
12. Successors and Assigns Boundi Joint and Severn!L1abil yl Cosignors. 'no covenants and agreements of this
Security Instruamt shall bind and benefit the successors and assigns of Leader and Borrower,subject to tha provisions of Paragraph
9(b). Borrower's covenants and agreamtots shall be joint and several. Any Borrower who co-signs this Security Instrument but does
not execute the Note:(a)Is co-signing this Security Instrument ordy to mortgage,grant and convey that Borrower's interest in the
Property under the terms of this Seourity Instrument; (b)1a not personally obllgated to pay the sutras secured by this Security
Instrument;and(o)agrees that Lender and any other Borrower may agrsa to extend,modify,forbear or make any accom modadons
with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13, Notices. Any notice to Borrower provided for In this Security Instrument ohail be given by delivering It or by malling
It by first doss mall unless applicable law requires use of another method. The notice shall be directed to tho Property Address or
any other address Borrower designates by notice to Lender. Any notice to Leudor shall be given by fast class mall to Larder's
Address stated heroin or any address Lender designates by notice to Borrower, Any notice provided for in this Security Instrument
PRNNSYI,VANrA P1IA MORMOB g�{ 7 q F6 0 8 9 8
C-3701 (7/W (Uplaea 1 M)PAGE 3 OF 5
shall be deemed to have been given to Bormwor or Lender when given as provided in thia Paragraph,
14. GtoYaWng Lawl Severability. This Security Inshumoat shall be governed by Pateral law and the law of the
Jurisdiction In which the property is located. In the event that any provision or clause of this Security Instrument or the Note wnfilcts
with applicable law,such conflict shall not affeot other provisions of this Security Instrument or the Note which can be given effect
without the conflicting provision, To this end the provisions of this Security Instrument and the Noto aro declared to bo severable.
15. Borrower's Copy. Borrower shall be given one confotmcd copy of the Note ad of this Security Instrument.
145. ltlawrdous Subetattoce. Borrower ahell not owe or permit the presence,use,disposal,storage,or release of any
Hazardous$ubstaucea on or in the Property, Borrower shall not do,nor allow anyotro oleo to do,anything affecting the Property
that is in violation of my Environmental Law. The preceding two sentences shall not apply to the presence,use,or storage on the
Property of small Quantities of Hazardous Substances that aro generally recognized to be appropriate to uomhal residential usce and
to maintenance of tho property.
Borrower shall promptly give Lendor.written notice of any Investigation,cladah, demand,lawsuit or other action by any
governmental or regulatory agency or private party involviug the Property and any hazardous Substance or Environmental Law of
which Bornowor hes actual knowledge, If Borrower hares,or is notified by say goverrunental or regulatory authority, that any
removal or othor romedlation of any Hazardous Substances affecting the Property is noceeaary,Borrower shalt promptly take all
necessary remedial neocare In accordance with Environ trcntal Law.
As used In this paragraph 16, 'Hazardous Substances" are those substances defined as(axle or hazardous substances by
Bnvimmncrrta)Law and the following oubstanocst gasoline,kerosene,other tlm amble or toxic petroleum products,toxic pestioldes
and herbicides,volatile solvents,materials containing asbestos or formaldohyde,and radloactive materials. As used the paragraph
16, "Environwatal LAW moans federal laws and laws of the Jurisdiction wham the Property Is located that rolm io health,safety
or onvimatnatal protection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Anslgtuunent of Rents. Borrower unconditionally asaigna and transfers to Leader all the roots end revenues of the
Property. Borrower authorizes Lender or Lender's agents to collect the rents and mveauos and boreby directs tach tenant of the
Property to pay tho rents to Lender or Leader's agents. However,prior to Lender's notice to Borrower of Borrower's breach of any
covenant or agreement In the Soeudty Instrument,Borrower shall collect sad receive all rents and revenues of the property as trustee
for tho benofit of Leader and Borrower, This assignment of runts constitutes an absolute assignment and act an assignment for
additional security only.
If Lender gives notloo of broach to Borrower.(a)all rents received by Borrower shat be held by Borrower as trustee for
benefit of Lender only,to be applied to the sums poured by the Security Instrument;(b)Lender shall bo added to collect and receive
all of the rents of the property;and(c)each tenant of the Properly shall pay all rents due and unpaid to Lender or Leader's agent
an Lender's written demand to the tenant.
Borrower has not executed any prior assigm=t of the roots and has nut and will not perform any act that would prevent
Leader from oxerclsing Its rlgbu under this Pangraph 17,
Lendcr shall not be required to cater upon,take control of or maintain the Property before or alter giving notice of breach
to 9ormwer, However,Lender or a Judicially appointed receivor may do so at any time thereto a breach, Any application of rents
shall not onto or waive any default or invalidate any other right or rearedy of Lender. This assignment of rents of the Property shall
tarmirrato when the debt secured by tho Security Instrument is paid in fled.
16. Foreclosure Proocdum, 1U Lender requires Immediate payment In full under paragraph 9,Lender may foreclose
this Security Insbumoul by judicial proemllag. Lender shall be entitled to collect all expense Incurred in pursuing the
mnodit s provided in this paragraph 18,including,but not thnited to,attorneys'fees and oasts of title evidence to the exteol
permitted by applicable law,
If.rho I.tnder's lateral In this Security Instrument Is held by The Secretary and the 64reGuy r'equlrea bmtredlate
payment in full under Paragraph 9,the Secretary way Invoke the norljudidal power of We provided In the Single FhmUy
Mortgage Woreclosure Act of 1994("Act")(12 U,S.C.3751 A-M.)by requesting a foreclosure commissioner designated under
the Act to commence foreclosure and to aeU the Property as provided In the Act. Nothing in the preceding awlenvo sball
deprive the Secretary of any tights otherwise available to a Louder under this Paragraph 18 or applicable law,
19. Release, Upon payment of all earns secured by this Security,letim moat,this Security Instrument and the estato
conveyed shalt tembato and become void. After such occurrence,Lender shat discharge and sitiery this Security Instrument without
charge to Borrower. Borrower ellen pay any recordation coats.
20, Waivers. Borrower,to the oxtent permitted by applicablo law,waives and releases any error or defeats in proceedings
to enforce this Security[nattwiaart,and hereby waives the benefit of any present or fixture laws providing for stay of execution,
extension of time,exemption from attachment,levy and sato,and homestead exemption.
21. Reluutatermmt l'edod. Batrower's time to roinstato provided In paragraph l0 shall cxtmd to one dour prior to the
commencanent of bidding at a sheriffs sale or other sale pursuant to this Security Instrument
22, Purchase Money Mortgage. U arty of the debt seevrod by this Security Instr unsnt is Joni to Borrower to acquire title
to the Proporty,this Security bmnu=t shall be a purchase money mortgage,
23. luterest Rate After Judgment. Borrower agrom that the Interest rata payable after a Judgn=t is entered on the Note
or In an action of mortgage foreclosure shall be the two payable from time to time under tho Now,
24. Riders to this SwArity lastnunent. If one or more riders are excculed by Borrower and recorded together with this
Security lnstntnent,the covenants and agreemenia of each such rider shall be Ineorporatod Into and shall ennead and supplement the
covenants andagfaynents of this Security Iaatnnmsat u if tbgrider(a)wea part of(his Security Instrument.
The _Fallowing riders are attaC e
NO RIDBRS ATTACHl3D
rsRt MVANU+NU MOMAQU �K 17 4 0�G fl$g
C•3701 (7196) (R*Isca 1198)PA08 40415
BY SIGNING BELOW,Borrower accepts and agrees to the terms contained in this Security Instrument and in any riders)
executed by Borrower and recorded with It,
'Me Borrower certifies that a true copy of the mortgage hoe been received.
WITNESS
'a
T AS Ro0H s
COMMONWEALTH OP PEM8YLVANIA
ea; ,
COU1QT OF CUMBERLAND
Orr this 20th day of November, 2001 ,before ma,the
subscriber,a Notary Publio iopbndfor the Grramonweaith of.Penasylvanta,realding in
BRIANaROOER$r,�RIE� '
and aclmowledgod the within iadenture of Mortgage to be their bol and deed,and desired the same to be recorded as-such.
V4TNMS my hand and scat,the day and year aforeasid,
My eorrumissicn arpires
NOTgRI,&BEAT.
PATMONIA 1.YOTM,N*q Public
Near Gimbal W nota(✓u *leid Cb.
W Oornmis M Nov.16 2902
;J.
1 Certify this to be recorded
11, C;unll)criand ('01111tY PA
8K 1740PGO900 •
PBNNBYr,VANfA FHA MOIrrOAM
•' "
G3703 (7/a6) tnlCylacea 1196)AAOlt 5 OP 5
11/07/2001 09:54 -------- STCJW LAP`A11ER'-SHEkCE PAGE 05
• Commonweaft
i ,L.{MV,oVNritTM�ranT .
I COMMON4WiU3'H(ANO TIM)MURAt4(%QVMPANY
LWAL DR3CR3:P*6N
IaP 4r4,apaRC,�C.T,O1C7.,,G:..CagT.Ileo t9,4L:31�OQ'S EI r.IiA^.„I h7itCC1,1„�IRl1f•IRY,f'.w.`3 it 7G i`i pf 9n r..�ws.'t AIA�n160t
ALL THOSE TWO CERTAIN lots sr part:els of ground sltvata and bakV to Uary W,ButteriPa Addition to the
9oreugh of New Cumberland,Cumberland County.Pennsylvania end knrnnt and numbered an said Pia►as lois
Nos. 7 and 8,31ock'H and more perticul4rly bounded and descr)tnd u follows,to wit:
81FOINNING at a point on the northern side of Third Street,Which print it 040"d(t00)feet fast of the '
Northeast corner of Third Sirsat and Rosmni Amut:tftttree in art trtterly'diret:tfon sionj the tine of said Third
Sheet,filly 160I list to a point on the&ding Ilhe betwatn Leta Na,8 W 7,thence Will;along said dividing Gee
isetwaart lots Nos,4 and 7.and at tight angles wish Third Stroh,ON hw*vd forty(1401 fast to Alviv AVR610;
thence West along the sold flfvrr Avenut and parallot Wilt the sold TWO Street,fifty 001 feet to a point on ilia
dividing line between tots Plea.8 and 9.,thence In u Southerly dtractivo 0"srid dlridtag Nne between lots Not.8
and 9,one hundred Duty(140)feet to Third Street the pfaov of BEGINNING.-
HAVING THEREON ERE050 a dupl+x d"Iffn house end gera<gv known and ri mbirtd as 610 Thrd Street,New
Cuinbaviand County,Pisirivenir,
BRING TFIB SAM PREMISES which St:epben J. Thompson and Julio L. Thompaon
by their dead dated October 30. 2000, and recorded October 31, 2000, in
Deed Book 232, page 1064, In Cumberland County, ?annoylvania, granted axed
convoyed unto Brian Rogers, Mortgagor herain.
t Crm R�op BR(/
17 4 Q PG O 9 a 1
NOU 07 101 10,29 O� �naoaa peer. nr
NOTE FHA Case No.
November 20, 2001 0w
615 3RD STREET, NEW CUMBERLAND, PA 17070
rim naaRs.
1. PARTIES
"Borrower" means each person signing at the end of this Note,and the person's successors and assigns, "Lender" means
CHASE MANHATTAN MORTGAGE CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sumNinetyof
One Hundred Nineteen Thousand, Seve; P�s d eredst to the order of LenderSeven . Ineres�will a charged on
Dollars(U.S. $ 119,797.00
unpaid principal,from the date of disbursement of the loan proceeds by Lender, at the rate of
Six and Seven-Eighths %)per year until the full amount of principal has been paid.
percent( 6.875
3. PROMISE TO PAY SECURED
mortgage,deed of trust or similar security instrument that is dated the same date as
Borrower's promise to pay is secured by a
this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which might result if
Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
January 1, 2002 . Any principal and interest remaining on the first day of
December, 2031 ,will be due on that date,which is called the maturity date.
(B) Place
Payment shall be[Wade at 200 OLD WILSON BRIDGE ROAD
WORTHINGTON, OH 43085
or at such other place as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 786.98
Seven Hundred Eighty-Six and 98/100
This amount will be part of a larger monthly payment required by the Security Instrument,that shall be applied to principal,
interest and other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note,the covenants of the allonge
shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note.
5. BORROWER'S RIGHT TO PREPAY
is Note,in whole or in part,without charge h penalty,on the first
Borrower has the right to pay the debt evidenced by thrrower pays interest on th
day of any month. Lender shall accept prepayment on other days provided that bo
e amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a
partial prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing
to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument,as described in Paragraph 4(c)of this
Note by the end of fifteen calendar days after the payment is due,Lender may collect a late charge in the amount of
4%
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment,then Lender may, except as limited by regulations oft e
Secretary in the case of payment defaults,require immediate payment in full of the principal balance remaining due and all accrued
interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many
circumstances regulations issued by the Secretary will limit Lender's right to require immediate payment in full in the case of payment
defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note,"Secretary"means
the Secretary of Housing and Urban Development or his or her designee.
•
FHA MULTISTATE FIXED RATE NOTE
C-7302(11196)Page 1 of 2 (Replaces 1196)
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full,as described above,Lender may require Borrower to pay costs and expenses
including reasonable and customary attorney's fees for enforcing this Note to the extent not prohibited by applicable law. Such
fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment"means the right to require Lender to demand payment of amounts due. "Notice of dishonor"means the right to require
Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
applicable law requires a different method,any notice that must be given to Borrower under this Note will be given y
Unless appr Borrower at the property address above or at a different address if Borrower has
delivering it or li mailing by first class mail to
given Lender a notice of Borrower's different address.
be given by
Any notice that must be given to Lender under this Note will first class mail to Lender at the address stated in
e of that different address.
Paragraph 4(B)or at a different address if Borrower is given a notic
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in this
Note,including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations,Including the obligations of a guarantor;surety or endorser
of this Note,is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against
each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the
amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
4
BRIAN ROGE
WITNESS
IR mM uC00RSE PAYM
THE ORDM 0F:
C�3SFE t1B�Pi101YgA{�
DIORTC. PQM l , yn
LINDA E.MYERS
ASSISTANT SECRETARY
FHA MULTISTATE FIXED RATE NOTE
C-7302(t 1/96)Page 2 of 2 (Reptacea 1/96)
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL TM
For Undeliverable Mail Only
9214 8901 0754 4631 3341 18
003351-1 of4 NSPOHDLA-CA 70463869 0000000
BRIAN ROGERS
615 3RD ST
NEW CUMBERLAND PA 17070
x •
I � '
Chase(OH4-7399) CHASE !
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
12/04/2013
BRIAN ROGERS
615 3RD ST
NEW CUMBERLAND,PA 17070
NOTICE OF INTENT TO FORECLOSE MORTGAGE
Account: (the"Loan")
Property Address: 615 3RD ST
NEW CUMBERLAND,PA 17070(the"Property")
Dear BRIAN ROGERS:
Under the terms of the Mortgage or Deed of Trust("Security Instrument")securing your Loan,JPMorgan
Chase Bank,N.A.("Chase"),as servicer of your loan,hereby notifies you of the following:
1. You are in default because you have failed to pay the required monthly installments commencing
with the payment due 09/01/2013 for the mortgage held by JPMorgan Chase Bank,National
Association.
2. As of 12/04/2013,total monthly payments(including principal,interest,and escrow if
applicable),late fees,insufficient funds(NSF)fees,and other fees and advances due under the
terms of your loan documents in the total amount of$7,615.93 are past due. This past-due amount
is itemized below. If applicable,your account may have additional escrow amounts that have
been paid out and are due on the Loan.
3. If you have any questions about the amounts detailed below,please contact us as soon as possible
at 800-848-9380.
Total Monthly Payments $4,619.09
Late Fees $2,996.84
NSF Fees $0.00
Other Fees and Advances* $0.00
Advances* $0.00
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and/or permitted by applicable law, or that were authorized for services
rendered. Ifyou need additional information regarding any of these amounts,please
contact us at the number provided below.
Certified Article#:9214 8901 0754 4631 3341 18 003351-2 of 4 NSPOHDfA-CA J0463869 0000000
You are also responsible for paying any amounts that become due from the date of this letter
through the expiration date of 01/06/2014 set forth in Paragraph 4 below. These amounts may
include,but are not limited to,taxes, insurance,inspection fees and other fees,as permitted by
applicable law.
If you have any reason to dispute the past-due amount listed above,or if you believe your Loan is
current,please contact us at the number provided below.
4. If you are unable to pay your account current within 33 days,we intend to exercise our right to
accelerate the mortgage payments. This means that whatever is owed on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in monthly installments.If full payment of the amount of default is not made within 33
days,we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged
property. If the mortgage is foreclosed,your mortgaged property will be sold by the sheriff to pay
off the mortgage debt. If we refer your case to our attorneys,but you cure the default before they
begin legal proceedings against you,you will still have to pay the reasonable attorney's fees,
actually incurred,up to$50.00.However,if legal proceedings are started against you,you will
have to pay the reasonable attorney's fees even if they are over$50.00.Any attorney's fees will be
added to whatever you owe us,which may also include our reasonable costs. If you cure the
default within the 33-day period,you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage.
5. You have the right to cure the default,or anyone acting on your behalf,and pay your account
current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other
judicial sale,not more than three times in any calendar year. To do so,you must:
a) Pay or tender in the form of cash,cashier's check or certified check all sums that
would have been due at the time of payment or tender in the absence of default and
the exercise of acceleration;
b) Perform any other obligation which you would have been bound to perform in the
absence of default or the exercise of acceleration;
c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to
foreclosure that were actually incurred up to and including the date the debtor cures
the default,as specified in writing by the mortgagee;
d) Pay any reasonable late penalty,if outlined in the mortgage.
Action required to cure the default: You must pay the Total Monthly Payments listed in
Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees,
NSF fees,and other fees and advances are still valid and will need to be repaid under the terms of
your loan documents.
6. If you fail to cure the default on or before 01/06/2014, Chase may accelerate the maturity of the
Loan,declare all sums secured by the Security Instrument immediately due and payable,and
commence foreclosure by judicial proceeding and sale of the Property. If this happens, Chase will
be entitled to collect its expenses incurred in pursuing the remedies provided in the Security
Instrument,which may include,but not be limited to,allowable foreclosure/attorney fees and
other expenses permitted by your loan documents or applicable law.
7. If permitted by your loan documents or applicable law,you have the right to reinstate after
acceleration of the Loan and the right to bring a court action to assert the nonexistence of a
default or any other defense to acceleration,foreclosure,and sale.However,the amount required
to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and
charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law,
related to any foreclosure action we initiate.
Certified Article#:9214 6901 0754 4631 3341 18
8. Kindly remit the total amount due,shown in Paragraph 2 above,to the remittance address listed
below. Please note that Chase policy requires certified funds if two insufficient funds(NSF)
payments have been received in the last six months. In this event,Chase will not accept a Direct
Check,FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches.
Please refer to the addresses below for payment information or contact us if you have any questions.
Regular Mail: CHASE
PO BOX 78420
PHOENIX,AZ 85062-8420
Overnight Mail: CHASE
PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH
PHOENIX,AZ 85034-9700
Except as required by law,we are under no obligation to accept less than the full amount owed. If
you send us less than the full amount owed,we may in our sole discretion apply such partial
payment to your Loan without waiving any default or waiving our right to accelerate the Loan and
continue with foreclosure proceedings in accordance with Paragraph 4 above.
9. If you are unable to pay the amount past due, Chase has a variety of homeowners'assistance
programs that might help you resolve your default and keep your home;however,we need e talk
with you to discuss these options and determine which of them might be appropriate for your
circumstances. Please call us as soon as possible at 800-848-9380.
10. While the Loan remains in default,we will perform certain tasks to protect our interest in the
Property, including visits to your Property at regular intervals during the default.This will be done
to determine,as of the date of the inspection the property condition,occupancy status,and,possibly,
your plans for curing the default and paying this Loan on time. You should anticipate that any costs
incurred by Chase will be added to the amount you now owe if permitted by your loan documents or
applicable law.
11. You have additional rights to help protect your interest in the property.You have the right to sell the
property to obtain money to pay off the mortgage debt or to borrow money from another lending
institution to pay off this debt.You may have the right to sell or transfer the property subject to the
mortgage to a buyer or transferee who will assume the mortgage debt,provided that all the
outstanding payments,charges and attorney fees and costs are paid prior to or at the sale(and that
the other requirements under the mortgage are satisfied). Contact us to determine under what
circumstances this right may exist.You have the right to have this default cured by any third party
acting on your behalf.
Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available
through a variety of nonprofit organizations experienced in homeownership counseling and approved by the
Secretary of Housing and Urban Development(HUD).A listing of such organizations may be obtained by
calling HUD toll-free at 800-569-4287 or at www.hud.gov.
Sincerely,
Chase
800-848-9380
800-582-0542 TDD/Text Telephone
www.chase.com
Enclosure
-Federal Trade Commission Pamphlet
Certified Article a:9214 8901 0754 4631 3341 18
003351-3 of 4 NSPOHDLA-CA J0463869 0000000
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service,you may be eligible for benefits and
protections under the federal Servicemembers Civil Relief Act(SCRA). This includes protection from
foreclosure or eviction,You may also be eligible for benefits and protections under state law. SCRA and
state military benefits and protections also may be available if you are the dependent of an eligible
servicemember.
Eligible service may include:
• Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or
• Active service as a commissioned officer of the National Oceanic and Atmospheric
Administration,or
• Active service as a commissioned officer of the Public Health Service,or
• Service with the forces of a nation with which the United States is allied in a war or military
action,or
• Service with the National Guard of a state militia under a state call of duty,or
• Any period when you are absent from duty because of sickness,wounds,leave,or other lawful
cause.
For more information,please call Chase Military Services at 866-840-5826.
An important reminder for all our customers: As stated in the"Questions and Answers for
Borrowers about the Homeowner Affordability and Stability Plan"distributed by the Obama
Administration, "Borrowers should beware of any organization that attempts to charge a fee for
housing counseling or modification of a delinquent loan,especially if they require a fee in advance."
Loan modification scams should be reported to PreventLoanScams.org or by calling
888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge(i.e.,no
modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The
longer you delay,the fewer options you may have.
We are attempting to collect a debt,and any information obtained will be used for that purpose.
If you are represented by an attorney,please refer this letter to your attorney and provide us with
the attorney's name,address and telephone number.
To the extent your original obligation was discharged,or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or
informational purposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation.However,a secured party retains rights under its security
instrument,including the right to foreclose its lien.
BR840
Certified Article#:9214 8901 0754 4631 3341 18
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>>
Facing foreclosure? Scammers are targeting people having trouble paying their mortgages.
Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan
modifications — for a fee. The Federal Trade Commission, the nation's consumer protection
agency,wants you to know how to avoid scams that could m
to worse. ake your housing situation go from bad
Don't Get Hit by a Pitch. Imitations = Frustrations.
"We can stop your foreclosure!"
"97%success rate!" Some con artists use names,phone numbers,
"Guaranteed to save your home!" and websites to make it look like they're part
These kinds of claims are the tell-tale si ns of of the government. If you want to contact a
a foreclosure rip-off. Steer clear of anyone government agency, type the web address
who offers a easy out. Y directly into your browser and look up any
address you aren't sure about. Use phone
numbers listed on agency websites or in other
Don't Pay for a Promise.
reliable
Don't pay any business, organization, or pho edirectory,Don't click on 1 nkslo your
or
person who promises to prevent foreclosure or any attachments in unexpected emails.
get you a new mortgage. These so-called
"foreclosure rescue companies"claim they Talk to a HUD-Certified Counseling
can help save your home, but they're out to
make a quick buck. Some may request he Agency - For Free.
fees in advance—and then stop returning hefty If You're having trouble paying your mortgage
calls. Others advance
and
Your or you've already gotten a.delinquency notice,
Y g you along before free help is a phone call away. Call 1-888-995
disclosing their charges. Cut off all dealings if -HOPE for free personalized advice from
someone insists on a fee. housing counseling agencies certified by the
Send Payments Directly. U.S. Department of Housing and Urban
a financial Development(HUD). This national hotline
Some scammers offer to hand —
arrangements for you, but then just pocket
your payment. Send your mortgage Homeoopen wnership Preservation Foundation, a
payments nonprofit member of the HOPE NOW
ONLY to your mortgage servicer. Alliance of mortgage industry members and
Don't Pay for a Second Opinion. guidance tonline,ed ovis t ww v.hopenow.comencies. For ee
Have you applied for a loan modification and For free information on the President's plan to
been turned down?Never pay for a"second help homeowners, visit
opinion," www.makinghomeaffordable.gov.
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Certified Article#:9214 8901 0754 4631 3341 18
003351-4 of 4 NSPOHDLA•CA J0463869 0000000
Call
1 -888-995-HOPE
for free personalized guidance from housing counseling agencies certified
by the U.S. Department of Housing and Urban Development. The
Homeowner's HOPETM Hotline - open 24/7 - is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD-certified counseling agencies. Or visit
www . hop enow . com
For free information on the President's plan to help homeowners, visit
www . makin homeaffordable . ov
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Certified Article N:9214 8901 0754 4631 3341 19
I
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Chase(OH4-7399) CHASE !i
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
12/04/2013
003352-1 of 3 NSPOHDLA-ZA J0463869 0000000
BRIAN ROGERS
615 3RD ST
NEW CUMBERLAND,PA 17070
NOTICE OF INTENT TO FORECLOSE MORTGAGE
Account: (the"Loan")
Property Address: 615 3RD ST
NEW CUMBERLAND,PA 17070(the"Property")
Dear BRIAN ROGERS:
Under the terms of the Mortgage or Deed of Trust("Security Instrument")securing your Loan,JPMorgan
Chase Bank,N.A.("Chase"),as servicer of your loan,hereby notifies you of the following:
1. You are in default because you have failed to pay the required monthly installments commencing
with the payment due 09/01/2013 for the mortgage held by JPMorgan Chase Bank,National
Association.
2. As of 12/04/201.3,total monthly payments(including principal,interest,and escrow if
applicable),late fees,insufficient funds(NSF)fees,and other fees and advances due under the
terms of your loan documents in the total amount of$7,615.93 are past due. This past-due amount
is itemized below. If applicable,your account may have additional escrow amounts that have
been paid out and are due on the Loan.
3. If you have any questions about the amounts detailed below,please contact us as soon as possible
at 800-848-9380.
Total Monthly Payments $4,619.09
Late Fees $2,996.84
NSF Fees $0.00
Other Fees and Advances* $0.00
Advances* $0.00
Amount Held in Suspense $0.00
*Other Fees and Advances include those amounts assessed in accordance with your loan
documents, and/or permitted by applicable law, or that were authorized for services
rendered. If you need additional information regarding any of these amounts,please
contact us at the number provided below.
You are also responsible for paying any amounts that become due from the date of this letter
through the expiration date of 01/06/2014 set forth in Paragraph 4 below. These amounts may
include,but are not limited to,taxes,insurance,inspection fees and other fees,as permitted by
applicable law.
If you have any reason to dispute the past-due amount listed above,or if you believe your Loan is
current,please contact us at the number provided below.
4. If you are unable to pay your account current within 33 days,we intend to exercise our right to
accelerate the mortgage payments. This means that whatever is owed on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in monthly installments. If full payment of the amount of default is not made within 33
days,we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged
property. If the mortgage is foreclosed,your mortgaged property will be sold by the sheriff to pay
off the mortgage debt. If we refer your case to our attorneys,but you cure the default before they
begin legal proceedings against you,you will still have to pay the reasonable attorney's fees,
actually incurred,up to$50.00.However,if legal proceedings are started against you,you will
have to pay the reasonable attorney's fees even if they are over$50.00.Any attorney's fees will be
added to whatever you owe us,which may also include our reasonable costs. If you cure the
default within the 33-day period,you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage.
5. You have the right to cure the default,or anyone acting on your behalf,and pay your account
current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other
judicial sale,not more than three times in any calendar year. To do so,you must:
a) Pay or tender in the form of cash,cashier's check or certified check all sums that
would have been due at the time of payment or tender in the absence of default and
the exercise of acceleration;
b) Perform any other obligation which you would have been bound to perform in the
absence of default or the exercise of acceleration;
c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to
foreclosure that were actually incurred up to and including the date the debtor cures
the default,as specified in writing by the mortgagee;
d) Pay any reasonable late penalty, if outlined in the mortgage.
Action required to cure the default:You must pay the Total Monthly Payments listed in
Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees,
NSF fees,and other fees and advances are still valid and will need to be repaid under the terms of
your loan documents.
6. If you fail to cure the default on or before 01/06/2014, Chase may accelerate the maturity of the
Loan,declare all sums secured by the Security Instrument immediately due and payable,and
commence foreclosure by judicial proceeding and sale of the Property.If this happens,Chase will
be entitled to collect its expenses incurred in pursuing the remedies provided in the Security
Instrument,which may include,but not be limited to,allowable foreclosure/attorney fees and
other expenses permitted by your loan documents or applicable law.
7. If permitted by your loan documents or applicable law,you have the right to reinstate after
acceleration of the Loan and the right to bring a court action to assert the nonexistence of a
default or any other defense to acceleration,foreclosure,and sale.However,the amount required
to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and
charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law,
related to any foreclosure action we initiate.
8. Kindly remit the total amount due,shown in Paragraph 2 above,to the remittance address listed
below.Please note that Chase policy requires certified funds if two insufficient funds(NSF)
payments have been received in the last six months. In this event,Chase will not accept a Direct
Check,FastPay or SpeedPay payment.Payments cannot be made at Chase retail bank branches.
Please refer to the addresses below for payment information or contact us if you have any questions.
Regular Mail: CHASE
PO BOX 78420
PHOENIX,AZ 85062-8420
Overnight Mail: CHASE
PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH
PHOENIX,AZ 85034-9700
Except as required by law,we are under no obligation to accept less than the full amount owed. If
you send us less than the full amount owed,we may in our sole discretion apply such partial
payment to your Loan without waiving any default or waiving our right to accelerate the Loan and
continue with foreclosure proceedings in accordance with Paragraph 4 above.
9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance
programs that might help you resolve your default and keep your home;however,we need to talk
with you to discuss these options and determine which of them might be appropriate for your
circumstances.Please call us as soon as possible at 800-848-9380.
10. While the Loan remains in default,we will perform certain tasks to protect our interest in the
Property, including visits to your Property at regular intervals during the default.This will be done
to determine,as of the date of the inspection the property condition,occupancy status,and,possibly,
your plans for curing the default and paying this Loan on time. You should anticipate that any costs
incurred by Chase will be added to the amount you now owe if permitted by your loan documents or
applicable law.
11. You have additional rights to help protect your interest in the property.You have the right to sell the
property to obtain money to pay off the mortgage debt or to borrow money from another lending
institution to pay off this debt.You may have the right to sell or transfer the property subject to the
mortgage to a buyer or transferee who will assume the mortgage debt,provided that all the
outstanding payments,charges and attorney fees and costs are paid prior to or at the sale(and that
the other requirements under the mortgage are satisfied). Contact us to determine under what
circumstances this right may exist.You have the right to have this default cured by any third party
acting on your behalf.
Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available
through a variety of nonprofit organizations experienced in homeownership counseling and approved by the
Secretary of Housing and Urban Development(HUD).A listing of such organizations may be obtained by
calling HUD toll-free at 800-569-4287 or at www.hud.gov.
Sincerely,
Chase
800-848-9380
800-582-0542 TDD/Text Telephone
www.chase.com
Enclosure
-Federal Trade Commission Pamphlet
003352.2 of 3 NSPOHDLA•Z4 J0463869 0000000
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service,you may be eligible for benefits and
protections under the federal Servicemembers Civil Relief Act(SCRA). This includes protection from
foreclosure or eviction.You may also be eligible for benefits and protections under state law. SCRA and
state military benefits and protections also may be available if you are the dependent of an eligible
servicemember.
Eligible service may include:
• Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or
• Active service as a commissioned officer of the National Oceanic and Atmospheric
Administration,or
• Active service as a commissioned officer of the Public Health Service,or
• Service with the forces of a nation with which the United States is allied in a war or military
action,or
• Service with the National Guard of a state militia under a state call of duty,or
• Any period when you are absent from duty because of sickness,wounds,leave,or other lawful
cause.
For more information,please call Chase Military Services at 866-840-5826.
An important reminder for all our customers: As stated in the"Questions and Answers for
Borrowers about the Homeowner Affordability and Stability Plan"distributed by the Obama
Administration,"Borrowers should beware of any organization that attempts to charge a fee for
housing counseling or modification of a delinquent loan,especially if they require a fee in advance."
Loan modification scams should be reported to PreventLoanScams.org or by calling
888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge(i.e.,no
modification fee required). Please call us immediately at 866-550-5705 to discuss your options.The
longer you delay,the fewer options you may have.
We are attempting to collect a debt,and any information obtained will be used for that purpose.
If you are represented by an attorney,please refer this letter to your attorney and provide us with
the attorney's name,address and telephone number.
To the extent your original obligation was discharged,or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or
informational purposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation.However,a secured party retains rights under its security
instrument,including the right to foreclose its lien.
BR840
An E ;t��rtant.rr���<��w w fe'Un'3 the Fc e d2.Tra de cornrmss on '
Facing foreclosure? Scammers are targeting people having trouble paying their mortgages.
Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan
modifications — for a fee. The Federal Trade Commission, the nation's consumer protection
agency,wants you to know how to avoid scams that could make your housing situation go from bad
to worse.
Don't Get Hit by a Pitch. Imitations = Frustrations.
"We can stop your foreclosure!" Some con artists use names,phone numbers,
"97%success rate!" and websites to make it look like they're part
"Guaranteed to save your home!" of the government. If you want to contact a
These kinds of claims are the tell-tale signs of government agency,type the web address
a foreclosure rip-off. Steer clear of anyone directly into your browser and look up any
who offers an easy out. address you aren't sure about. Use phone
numbers listed on agency websites or in other
Don't Pay for a Promise. reliable sources, like the Blue Pages in your
Don't pay any business, organization, or phone directory. Don't click on links or open
person who promises to prevent foreclosure or any attachments in unexpected emails.
get you a new mortgage. These so-called
"foreclosure rescue companies" claim they Talk to a HUD-Certified Counseling
can help save your home, but they're out to Agency - For Free.
make a quick buck. Some may request hefty If you're having trouble paying your mortgage
fees in advance—and then stop returning your or you've already gotten a delinquency notice,
calls. Others may string you along before free help is a phone call away. Call 1-888-995
disclosing their charges. Cut off all dealings if -HOPE for free personalized advice from
someone insists on a fee. housing counseling agencies certified by the
U.S. Department of Housing and Urban
Send Payments Directly. Development(HUD). This national hotline—
Some scammers offer to handle financial open 24/7—is operated by the
arrangements for you, but then just pocket Homeownership Preservation Foundation,a
your payment. Send your mortgage payments nonprofit member of the HOPE NOW
ONLY to your mortgage servicer. Alliance of mortgage industry members and
HUD-certified counseling agencies. For free
Don't Pay for a Second Opinion. guidance online, visit www.hopenow.com.
Have you applied for a loan modification and For free information on the President's plan to
been turned down?Never pay for a"second help homeowners, visit
opinion." www.makinghomeaffordable.gov.
�E,Prat TrS�cie Ctlhbrtui siov
ftc.c,0e/M i eyNlatters
003352-3 of 3 NSPOHDLA-ZA J0463869 0000000
Call
1 -888-995-HOPE
for free personalized guidance from housing counseling agencies certified
by the U.S. Department of Housing and Urban Development. The
Homeowner's HOPETM Hotline - open 24/7 - is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD-certified counseling agencies. Or visit
www . hopenow. com
For free information on the President's plan to help homeowners, visit
www. makin homeaffordable . g ov
g
.. . . . . . . . .
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MAKING- .0 E-..ATT0R . LI Uo°a:
Pennsylvania Verification
Paul Burrier , hereby states that he/she is Vice President of
JPMorgan Chase Bank, N.A. the Plaintiff
in this matter, and is authorized to make this Verification. The statements of fact
contained in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of my information, and belief. I understand that this statement
is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
CLIA-- •
Paul Burrier
Vice President
Date: 05/19/14
JPMorgan Chase Bank,N.A
Borrower: ROGERS, BRIAN
Property Address: 615 3RD ST NEW CUMBERLAND PENNSYLVANIA 17070
County: CUMBERLAND
Last Four of Loan Number: 1429
FORM 1
JPMorgan Chase Bank,National Association IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY,
successor by merger to Chase Home Finance LLC
successor by merger to Chase Manhattan Mortgage PENNSYLVANIA
Corporation
Plaintiff(s) �., 4--1
V S.
n� cra
- F
Brian Rogers -
615 3rd Street
New Cumberland, PA 17070
DEFENDANT >,c:- C"n'
Defendant(s) X 5V09Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,
you may be able to participate in a court-supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer,you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20)days of your receipt of this notice, you must contact
MidPerm Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and
request appointment of a legal representative at no charge to you. Once you have been appointed a legal
representative, you must promptly meet with that legal representative within twenty(20) days of the
appointment date. During that meeting,you must provide the legal representative with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal representative
will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the
Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your
lender in an attempt to work out reasonable arrangements with your lender before the mortgage
foreclosure suit proceeds forward.
If you are represented by a lawyer,you and your lawyer must take the following steps to be
eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for
the appointment of a legal representative. However,you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
S PIRO&DeNARDO,LLC
Date
ttorneys for Plain iff
4^A'TLIN M.DONNELI.Y,E
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Date
Financial Worksheet
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
neRNE91 I . . . . .
Borrower name(s):
Property Address:
City:
Is the property for sale? State: Zip:__
Yes ❑ No ❑ Listing Date:__
Realtor Name: price:$
Borrower Occupied? Yes ❑ No ❑ Realtor Phone:
Mailing Address (if different):
City:
Phone Numbers: State: Zip:
Home: Office:
Email:
Cell: Other:
# of people in household How Long?
• : • � � •
Mailing Address:
City:
State: Zip:_
Phone Numbers:
Home: Office:
Email: Cell: Other:
# of people in household How Long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount:$
Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the Loan in Bankruptcy? Yes 0 No 0
If yes, provide names, location of court, case number & attorney
Assets Amount Owed Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount Owed: Value:
Automobile #2: Model: Year:
Amount Owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount Owed: Value:
Monthly Income:
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses:(Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortage Food
2° Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. Payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
• a
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No 0
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ❑ No 0
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating m financial situation for possible mortgage options. I/We
understand that I/We am/are under no obligation to use the services provided by the
above named
Borrower Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting
documentation
(hardship letter)
Listing agreement (if property is currently on the market)
FORM 3
: IN THE COURT OF COMMON PLEAS OF
JPMorgan Chase Bank,National Association CUMBERLAND COUNTY, PENNSYLVANIA
successor by merger to Chase Home Finance LLC
successor by merger to Chase Manhattan Mortgage
Corporation
Plaintiff(s)
vS.
Brian Rogers
615 3rd Street
New Cumberland, PA 17070
DEFENDANT
Defendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this
mortgage foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
FORM 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s) Civil
CASE MANAGEMENT ORDER
AND NOW, this day of , 20 , the defendant/borrower in the
above-captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference,the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the time
frame set forth herein or such other date as agreed upon by the parties in writing or
ordered by the Court,the case.shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone during
the course of the Conciliation Conference. The representative of the plaintiff/lender
who participates in the Conciliation Conference must possess the actual authority to
reach a mutually acceptable resolution, and counsel for the plaintiff/lender must
discuss resolution proposals with the authorized representative in advance of the
Conciliation Conference. If the duly authorized representative of the plaintiff/]ender is
not available by telephone during the Conciliation Conference, the Court will schedule
another Conciliation Conference and require the personal attendance of the authorized
representative of the plaintiff/lender at the rescheduled Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT
J.
'
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny F{Ander»on, ril.10-OFFICE
Sheriff OTHE PROTHONOTARY
CAM
_~^
Jody S Smith
1
Chief 2~''v°' ^w AM w' up
__—--,
SolicitorPENNSYLVANIA
Richard W Stewart
CUMBERLAND COUNTY
JP Morgan Chase Bank
vs.
Brian Rogers
Case Number
2014-5205
SHERIFF'S RETURN OF SERVICE
09/19/2014 Deputy Dawn Kell, 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
copytoapersonnepnenentingthemoe|veahobeKhstinRogem.whonccepbadas^Adu|tPeraonin
Charge" for Occupant at 615 Third Street, New Cumberland Borough, New Cumberland, PA 17070.
5-‘) own
DAWN KELL, DE UTY
09/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to Iaw, states he made diligent search and inquiry
for the within named Defendant to wit: Brian Rogers, Rogers, but was unabie to Iocate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 615 Third Street, New
Cumberland Borough, New Cumberland, PA 17070. Deputies were advised by Kristin Rogers,
defendant's wife, that the defendant has moved to Oregon, but she was unable to provide a good
forwarding address.
SHERIFF COST: $68.21 SO ANSWERS,
October 02, 2014 RONR ANDERSON, SHERIFF
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-044904
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
PLAINTIFF
VS.
Brian Rogers
DEFENDANT
OF THE r1 J I H NO TAfI
I.D. NO. 78447 21314 N `' --5 pai ; 03
PENH SYL'AIr,A
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14-5205 CIVIL
MOTION FOR SERVICE PURSUANT
TO COURT ORDER
Plaintiff, by its counsel, Shapiro & DeNardo, LLC moves this Honorable Court for an
Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting alternative service of the
Complaint and any other document or pleading requiring original process upon Defendant, Brian
Rogers, by sending a true and correct copy by simultaneous certified and regular mail; and by
posting a true and correct copy on the mortgaged property that is the subject of the above -
captioned mortgage foreclosure action; and in support thereof avers the following:
1. On September 5, 2014, Plaintiff filed its complaint in mortgage foreclosure
against the above -captioned Defendants for the property located at 615 3rd Street, New
Cumberland, PA 17070 (hereinafter "Property").
2. Plaintiff forwarded the Complaint to the Cumberland County Sheriff in order to
effectuate personal service upon Defendant, Brian Rogers.
3. The Cumberland County Sheriff's attempts to serve Defendant, Brian Rogers,
with the Complaint have been unsuccessful, as reflected on the Sheriff's Return of Service,
attached hereto as Exhibit "A," and made a part hereof.
4. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to locate
Defendant, Brian Rogers. An Affidavit of Good Faith Investigation, which sets forth the specific
inquiries made and the results thereof, is attached hereto as Exhibit "B" and made a part hereof.
5. The Affidavit of Good Faith Investigation reflects that 615 3rd Street, New
Cumberland, PA 17070 is a valid address for Defendant, Brian Rogers. See Ex. "B."
6. However, the Cumberland County Sheriff's Return of Service for such address
states otherwise. See Ex. "A."
7. A Request for Change of Address or Boxholder, pursuant to 36 C.F.R.
265.6(d)(6)(ii), completed and certified by the New Cumberland Pennsylvania Postmaster
reflects the following: "Good as address/No change of address order on file." A true and correct
copy thereof is attached hereto as Exhibit "C" and made a part hereof.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order
allowing Plaintiff to serve the Complaint and any other document or pleading requiring original
process on Defendant, Brian Rogers, by (1) sending a true and correct copy thereof by
simultaneous certified and regular mail to the last known address located at 615 3rd Street, New
Cumberland, PA 17070; and (2) posting a true and correct copy thereof on the mortgaged
property located at 615 3rd Street, New Cumberland, PA 17070 by the Sheriff or any competent
adult.
Date: ',• 4 •'4
S&D: 14-044904
BY:
Attorneys for Plaintiff
CHANDRA M. ARKEMA, ESQUIRE
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
JP Morgan Chase Bank
vs. Case Number
Brian Rogers 2014-5205
SHERIFF'S RETURN OF SERVICE
09/19/2014 Deputy Dawn Kell, 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 Kristin Rogers, who accepted as "Adult Person in
Charge" for Occupant at 615 Third Street, New Cumberland Borough, New Cumberland, PA 17070.
�0+4�t.31'1
DAWN KELL, Di UTY
09/19/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Brian Rogers, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 615 Third Street, New
Cumberland Borough, New Cumberland, PA 17070. Deputies were advised by Kristin Rogers,
defendant's wife, that the defendant has moved to Oregon, but she was unable to provide a good
forwarding address.
SHERIFF COST: $68.21 SO ANSWERS,
October 02, 2014
) Gougtwile Shentf, Tot g Qft Inc.
RONNY ANDERSON, SHERIFF
vqtProf
L
Confidential
Investigative
Services, Inc.
ATTENTION: Theresa Besley
Shapiro & DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
File #: 14-044904
Plaintiff: JPMorgan Chase Bank, National Association
County: Cumberland
vs.
Term #: 14-5205 Civil
Defendant: Brian Rogers
Locate: Brian Rogers
Address Given: 615 3'd Street, New Cumberland, PA
AFFIDAVIT OF GOOD FAITH INVESTIGATION
LAST KNOWN ADDRESS
615 3rd Street, New Cumberland, PA 17070
SEARCH OF INVESTIGATIVE DATABASE SOURCES
Investigative database sources report the most current address of the subject is 615 3rd Street, New
Cumberland, PA 17070.
INQUIRY OF THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
The Penns lvania Department of Transportation — Division of Motor Vehicles reports driver's license
number is issued to Brian Steven Rogers of 615 Third Street, New Cumberland, PA 17070.
The subject's license is current and is not due to expire until April 1, 2017.
INQUIRY OF U.S. POST OFFICE (FOIA)
Requests have been forwarded to the United States Post Office.
SEARCH OF LOCAL TELEPHONE DIRECTORIES & PHONE COMPANY OPERATOR CONTACT
The telephone company operator reports is issued to the subject at 615 3rd Street in New
Cumberland, PA.
CONTACTS
No neighbors with published listings could be reached to confirm the subject's residency at 615 3rd
Street in New Cumberland, PA.
Contact could not be made at■
as the listing is not in service.
I CERTIFY UNDER PENALTY OF PERJURY, THAT THE FOREGOING IS TRUE AND CORRECT, TO THE BEST OF MY KNOWLEDGE. I
UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
235 South 13th Street
Philadelphia, PA 19107
(215) 546-7400
(800) 503-7400
Fax (215) 985-0169
AFFIANT:
DIANE AN, CLI
SW :UBSCRIBED BEFORE ME THIS
O , 2014 C.Oi1KMON" PH OF PENNSYLVANIA
NOTARIAL SEAL
ROBERTSON, Notary Public
ty Philp phis Phila. County
my Carom u$u. exp res ember 10, 2014 •
BRIAN $ ROGERS,
SSN:
Issued: 11......11
D te of Blrth
DOB:
Age: 1.1
Address History
615 3RD ST, NEW CUMBERLAND, PA 17070-2018 (CUMBERLAND COUNTY) (12/2000 to 07/05/2014)
1045 BRENTWATER RD, CAMP HILL, PA 17011-1608 (CUMBERLAND COUNTY) (02/1998 to 06/2000)
Subdivision Name: COUNTRY CLUB PARK
1 Current Private Phone
Current Privte one at address
- BAER, TERESA
Clitilbt to
PAGE 1
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
BUREAU OF DRIVER LICENSING
BASIC DRIVER INFORMATION
OCT 17 2014
DRIVER: BRIAN STEVEN ROGERS DRIVER LICENSE NO .
615 THIRD STREET DATE OF BIRTH
NEW CUMBERLAND, PA 17070 SEX
RECORD TYPE : REG LICENSE
VETERAN STATUS : NOT DECLARED
DRIVER LICENSE (DL) COMMERCIAL DRIVER LICENSE (CDL)
LICENSE CLASS : C
LICENSE ISSUE DATE: MAR 11 2013
LICENSE EXPIRES : APR 01 2017
ORIG ISSUE DATE : JUN 28 1982
MED RESTRICTIONS : NONE
LEARNER PERMITS .
LICENSE STATUS
CDL LICENSE CLASS .
CDL LICENSE ISSUED :
CDL LICENSE EXPIRES:
CDL ENDORSEMENTS : NONE
CDL RESTRICTIONS : NONE
CDL LEARNER PERMITS:
CDL LICENSE STATUS :
SB ENDORSEMENT
PROBATIONARY LICENSE (PL)
PL LICENSE CLASS
PL LICENSE ORIG ISS :
PL LICENSE ISSUED .
PL LICENSE EXPIRES .
PL LICENSE STATUS .
OCCUPATIONAL LIMITED LICENSE (OLL)
OLL LICENSE CLASS .
OLL LICENSE ISSUED .
OLL LICENSE EXPIRES :
OLL LICENSE STATUS .
*** END OF RECORD ***
Brian S Rogers
615 3rd St New Cumberland PA 17070-2018 not in service
Home
Albert Chambers
605 3rd St New Cumberland, PA 17070-2018 answering machine
Home
Tiffany L Moore
607 3rdt New Cumberland PA 17070-2018 answering machine
Home
William G Hodges Jr
603 3rd St New Cumberland, PA 17070-2018 answering machine
Home
Donald B Lane Jr
611 3rd iiiiiiderland, PA 17070-2018 answering machine
Home
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
October 16, 2014
Postmaster
NEW CUMBERLAND, PA 17070
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or name and street address (if a boxholder) for the following:
NAME & ADDRESS: Brian Rogers--
ADDRESS:
ogersADDRESS: 615 3rd Street
New Cumberland, PA 17070
NOTE: The name and last known address are required for change of address information. The name, if known, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee or providing change of address information is waived in accordance with 39 CFR
265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of Requester (e.g. process server, attorney, party representing himself): ATTORNEY.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation acting pro se must cite statute(s): N/A
3. The names of all known parties to this litigation:
JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC successor by
merger to Chase Manhattan Mortgage Corporation vs. Brian Rogers
4. The court in which the case has been or will be heard: The Court of Common Pleas of CUMBERLAND
County
5. The docket or other identifying number if one has been issued: 14-5205 CIVIL
6. The capacity in which this individual is to be served (e.g. defendant or witness): DEFENDANT
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER.._
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT fN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR
IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5
YEARS, OR BOTH (TITLE 18 U.S.C. §1001).
t the above in!'Q '4
or p •spectivdli .a/n. �
tion is true and that the address information is needed and will be used solely for service of legal process in connection
ature
Theresa Besley
Legal Assistant
ADDRESS: Shapiro & DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
S&D File Number 14-044904
USE ONLY
FOR POST OFFICE
Good As Addressed/No change of address order on file
Not known at address given
Moved, left no forwarding address
No such address
NEW ADDRESS or 13 ER'S POSTMARK
NAME and TREET D ,S
)11-- D'Itv;
VERIFICATION
Chandra Arkema, Esquire, hereby states that she is the Attorney for the Plaintiff in
this action, that she is authorized to make this Verification, and that the statements made in
the foregoing MOTION FOR SERVICE OF THE COMPLAINT IN MORTGAGE
FORECLOSURE PURSUANT TO COURT ORDER are true and correct to the best of her
knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Fffate: Thtt
CHANDRA M. ARKEMA, ESQUIRE
S&D: 14-044904
SHAPIRO & DeNARDO, LLC
BY: crarcovoyttv
VV/�
Attorneys for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule the
Plaintiff may move the Court for a special Order directing
the method of service. The Motion shall be accompanied
by an Affidavit stating the nature and extent of the
investigation which has been made to determine the
whereabouts of the Defendant and the reasons why service
cannot be made.
Note
A Sheriffs Return of "Not Found" or the fact that a
Defendant has moved without leaving a new forwarding
address is insufficient evidence of concealment. Gonzales
vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice
of intended adoption mailed to last known address requires
a "good faith effort" to discover the correct address.
Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976).
An illustration of a good faith effort to locate the Defendant
includes (1) inquiries of postal authorities including
inquiries pursuant to the Freedom of Information Act, 39
C.F.R. Part 265, (2) inquiries of relatives, neighbors,
friends and employers of the Defendant and (3)
examinations of local telephone directories, voter
registration records, local tax records, and motor vehicle
records.
As reflected on the attached Sheriff's Return of Service, the Cumberland County
Sheriffs attempts to serve Defendant, Brian Rogers, with the Complaint have been
unsuccessful. See Ex. "A.".
Good faith efforts to discover the whereabouts of Defendant, Brian Rogers, have
been made, as evidenced by the numerous inquiries set forth in the attached Affidavit of
Good Faith Investigation. See Ex. "B." The Affidavit of Good Faith Investigation
reflects that 615 3rd Street, New Cumberland, PA 17070 is a valid address. See Ex. "B."
However, the Sheriffs Return of Service for that address states otherwise. As reflected
in the Affidavit of Good Faith Investigation, inquiries have been made to the following
persons and entities:
1. Defendant's creditors;
2. Directory Assistance;
3. Defendant's neighbors;
4. United States Postal Service;
5. Pennsylvania Department of Transportation, Driver and Vehicle Services;
and
6. Pennsylvania State Vital Records Office. See Ex. "B."
Inquiries have also been made to public record databases on the Internet, the
County voter registration records, and the County tax assessment records. See Id.
Despite all of the foregoing inquiries, Plaintiff has not been able to determine Defendant,
Brian Rogers' present location. Based on the foregoing, it is more likely than not that
Defendant, Brian Rogers is avoiding and/or evading personal service of the Complaint.
Plaintiff respectfully requests this Honorable Court enter an Order allowing
Plaintiff to serve the Complaint and any other document or pleading requiring original
process on Defendant, Brian Rogers, by (1) sending true and correct copies thereof by
simultaneous certified and regular mail to the last known address located at 615 3rd
Street, New Cumberland, PA 17070; and (2) posting a true and correct copy thereof on
the mortgaged property located at 615 3rd Street, New Cumberland, PA 17070 by the
Sheriff or any competent adult.
Date: 1 14 1 '+
BY:
SHAPIRO & DeNARDO, LLC
Attorneys for Plaintiff
CHANDRA M. ARKEMA, ESQUIRE
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the Motion for Service
Pursuant to Court Order, Verification, Memorandum of Law, and proposed Order on
Nov.14101'4- to all parties named herein at their last known address or upon their
attorney of record as below listed by regular mail, postage prepaid:
Brian Rogers, 615 3rd Street, New Cumberland, PA 17070
SHAPIRO & DeNARDO, LLC
Date: I \11-q 1 BY: _ • •• IP
!' ,
Attorneys for Plaintiff
CHANDRA M. ARKEMA, ESQUIRE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
JPMorgan Chase Bank, National Association NO: 14-5205 CIVIL
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
rn
PLAINTIFF 7-73
CD
VS. r -
<CD -2g f
r—=)
cz..)
Brian Rogers
DEFENDANT
ORDER
7,c)
AND NOW, this 10 day of Adt-arce" , 2014, upon consideration of
Plaintiffs Motion for Service Pursuant to Court Order, Affidavit of Good Faith Investigation and
Memorandum of Law is support thereof, and any response thereto, it is hereby
ORDERED AND DECREED that Plaintiff may serve the Complaint and any other
document or pleading requiring original process on Defendant, Brian Rogers, by (1) sending true
and correct copies thereof by simultaneous certified and regular mail to the last known address
located at 615 3rd Street, New Cumberland, PA 17070; and (2) posting a true and correct copy
thereof on the mortgaged property located at 615 3rd Street, New Cumberland, PA 17070 by the
Sheriff or any competent adult.
Service of the aforementioned mailings is effective upon the date of mailing and is to be
effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a Certificate of
Service as to such mailings
BY THE COURT:
eive„„dra &kei4
eel& i
01>
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above -captioned matter.
Date: 1 12S
SHAPIRO & DeNARDO, LLC
BY:
SARAH K. M ' - Y, ESQ.
Attorneys for Plaintiff
11 'ISpa a�
C'k��# I yiYalial 8
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEA
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
AFFIDAVIT OF SERVICE
I, Theresa Besley, the undersigned, being duly sworn according to law, hereby depose and
say that on the
day of /C,(rk01/2, , 2014, pursuant to the attached
Order of Court, attached as Exhibit "A", I served a true and correct copy of the Complaint in
Mortgage Foreclosure in the above captioned matter to the Defendant by certified and regular
mail, to their last known address of:
Brian Rogers, 615 3rd Street, New Cumberland, PA 17070
SH ' IRO & DeNARDO, LLC
BY:
SWORN AND SUBSCRIB D
Before me�iis ay of''"
20jtit .
Notary Public
S & D FILE NO. 14-044904
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Denise L. Semetti. Notary Public
Upper Merion Twp., Montgomery County
My Commission Expires July 22. 2018
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
heresa Besley
Legal Assistant to Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION r s.
•r T ,
JPMorgan Chase Bank, National Association NO: 14-5205 CIVIL,- , - -' -,
successor by merger to Chase Home Finance ` "r"w
LLC successor by merger to Chase Manhattan _ _ .0 r:
Mortgage Corporation
PLAINTIFF „r2a ,
VS.
Brian Rogers
DEFENDANT
ORDER
AND NOW, this /0ci day of 71 q i / , 2014, upon consideration of
Plaintiffs Motion for Service Pursuant to Court Order, Affidavit of Good Faith. Investigation and
Memorandum of Law is support thereof, and any response thereto, it is hereby
ORDERED AND DECREED that Plaintiff may serve the Complaint and any other
document or pleading requiring original process on Defendant, Brian Rogers, by (1) sending true
and correct copies thereof by simultaneous certified and regular mail to the last known address
located at 615 3rd Street, New Cumberland, PA 17070; and (2) posting a true and correct copy
thereof on the mortgaged property located. at 615 3rd Street, New Cumberland, PA 17070 by the
Sheriff or any competent adult.
Service of the aforementioned mailings is effective upon the date of mailing and is to be
effectuated by Plaintiffs attorney,who will file with the Prothonotary's Office a Certificate of
Service as to such mailings
u�
BY THE COURT:
•
J.
y-oouqol
Projects Server
Page 1 of 2
SDLLC Certified Desktop 1.12
SendSuite Live View 2.1 TX
SendSuite Live View 1.11
Search Selected Shipment Details
Recipent Details
Shipped To Address:
Brian Rogers
615 3RD ST
NEW CUMBERLAND
PA
17070-2018
US
Billed To Address:
Package ID
Waybill #
Status
Attention To
Receiver Phone
3945 71901213551010026776 Processed
http://logsegpb01 /SendSuite%20Live/projects/projects.aspx?proj ectid=16&groupid=1 12/3/2014
Shipment Details
Order #:
PO#:
Shipment ID: 3945
Shipped Date: 12/03/2014
Status: Processed
Partial Status: ["' j
Host Updated: '
ASN Sent: C
Shipped Via: USPS Server
First -Class Mail®
Customer:
Shipping Cost:O.48 0.48
Accessorial: 3.30 3.30
Other: 0.00 0.00
Total Cost: 3.78 3.78
1 • Shipment Options
Void Complete Shipment
Reprint Documents
Package ID
Waybill #
Status
Attention To
Receiver Phone
3945 71901213551010026776 Processed
http://logsegpb01 /SendSuite%20Live/projects/projects.aspx?proj ectid=16&groupid=1 12/3/2014
Name and Address of Sender
Shapiro & DeNardo, LLC
3600 Horizon Drive
Suite 150
King of Prussia, PA 19406
Check type of mail or service:
❑ Certified
❑ COD
❑ Delivery Confirmation
❑ Express Mail
❑ Insured
O Recorded Delivery (International)
❑ Registered
❑ Return Receipt for Merchandise
❑ Signature Confirmation
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional
copies of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City State, & ZIP Code) •
Postage
Fee
Handling
Charge
Actu
if Re
14-044904 It
7\
6
8.
Total Number of Pieces Total Number of Pieces
Listed by Sender \ Received at Post Office
P- S Form 3877, February 2002 (Page 1 of 2)
Brian Rogers
615 3rd Street
New Cumberland, PA 17070
U.S. POSTAGE >> PITNEY BOWES
n
ZIP 19406 $ OO1.300
02 1YY
0001387362 DEC. 03. 2014
ostmaster, Per ( ame . -ceiving employee)
ewriter, Ink or Ball Point Pen
anK
Special Hlandling
Restricted Delitcry
See Privacy Act Statement on Reverse
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
'a1 DEC 15 PI1 3: t
CUMBERLAND
PENNSYLVANIAACOUNTY
JP Morgan Chase Bank
vs. Case Number
Brian Rogers 2014-5205
SHERIFF'S RETURN OF SERVICE
12/09/2014 04:25 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Notice
of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Brian Rogers, pursuant to Order of Court by "Posting" the premises
located at 615 Third Street, New Cumberland Borough, New Cumberland, PA 17070 with a true and
correct copy according to law.
SHERIFF COST: $53.21 SO ANSWERS,
December 10, 2014 RONNY R ANDERSON, SHERIFF
cuntySuite Sheriff, Teleosoft, I.�e,
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO:14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $114,098.88 in favor of the Plaintiff and against
the Defendant, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within
20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the
Complaint:
Principal of Mortgage Debt Due and Unpaid
Interest Accrued
Late Charges
Escrow Advances
Property Inspection
Attorney Fees & Costs of Foreclosure
TOTAL
BY:
$98,239.31
$9,568.11
$0.00
$4,763.96
$42.00
$1,485.50
$114,098.88
CHRISTOPHER A. DeN -! O, ES ' Atto', .. for Plaintif
AND NOW, judgment is entered in favor of the Plaintiff an.; . gains , e D - ° dant an
damages are assessed as above in the sum of $114,098.88.
14-044904
Piro::.Prtthy.
and -616 We/ a6
4/&/-/ /ya agye
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation 14-5205 CIVIL
CHE - JPMorgan Chase Bank, National
Association
3415 Vision Drive
Columbus, OH 43219
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PLAINTIFF
VS.
Brian Rogers
DEFENDANT(S)
STATE OF: Pennsylvania
COUNTY OF: Montgomery
AFFIDAVIT OF NON-MILITARY SERVICE
Affiant has performed a search of the records maintained by the Department of Defense,
Defense Manpower Data Center (DMDC), and has determined that according to DMDC records
(attached hereto as Exhibit "A") Defendant Brian Rogers is not presently engaged in active duty
military service as contemplated by the Servicemembers Civil Relief Act at 50 U.S.C. App. §521.
Date: ICIlt(
Sworn to and subscribed
before me this i 3 of J
day
,2015.
Public
BY:
SHAPIRO & DeNARDO, LLC
Attorneys for Plaintiff
CHRISTOPHER A. DeNARDO, Esq.
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Jennifer M. Sharkey. Notary Public
Upper Merlon Twp., Montgomery County
My Commission Expires Oct. 19, 2018
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIEt
Department of Defense Manpower Data Center
V
Status Report
Pursuant to rServicemembcrs Civil. Relief Act
Last Name: ROGERS
First Name: BRIAN
Middle Name:
Active Duty Status As Of: Jan -13-2015
Results es of: Jan -13.2015 05:05:41 AM
SCRA 3.0
r
' On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Dale
Status
Service Component
NA
NA
No
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Wlttrin 367 Das of Active Outy Status Date
Da
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This re ponse reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This
response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOM, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (OMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
loRep6rting 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 duly 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: C140YB6DX123Y30
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase CUMBERLAND COUNTY
Manhattan Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for
the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of
record, if any, after the default occurred and at least (10) days prior to the date of the filing of the
Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,
December 30, 2014 to the following Defendants:
Brian Rogers, 615 3rd Street, New Cumberland, PA 17070
Leslie Thomas, 'Legal Assistant
to Sarah McCaffery, Esquire for
Shapiro & DeNardo, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association ' COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase CUMBERLAND COUNTY
Manhattan Mortgage Corporation
PLAINTIFF NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Brian Rogers
DATE OF NOTICE: December 30, 2014
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections :o the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
V
NoTinCACION IMPORTANTE
Listed sc encuentra en estado de rebeldia nor no haber tornado la accion requirida de so parte en
este caso. Al no tomm In aecion debida denim de on knnino de diez (10) dims de la feeha de esta
notilicacion, ci tribuna podra, in necesidad de comparareecr usled in code o escuchar preuba
algtma, dietar sentencia CO so contra. Usted puede perder bicoes 'y otros derechos importantes.
Debe Ilcvnr esta noLifleacion a on abogad° immedituttmeole, Si usled no Ilene abogado 0 si no
time diner() suliciente pam ml servicio, vayn en persona o llame por telt:Tom) a In oficina coy
dircecion sc encuentra cserita abajo para averiguar donde se puede conseguir assitencia legal:
CUM berialld County Lawyer Referral Service
Cumberland County I3ar Association
32 South Bedford Street
Carlisle. PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW HRM IS DEEMED 'FO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEI3T, ANY INFORMATION OBTAINED WILL
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237 I NOTICE SENT TO:
Brian Rocers. 615 3rd Street. New Cunmbcrinnd. PA 17070
Date:
BY:
SHA PRO & DeNARDO, LLC
ii Plan -0'11T
. OSBORNE, ESQ.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO:14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
CERTIFICATE OF SERVICE
I, Christopher A. DeNardo, Esquire, Attorney for the Plaintiff, hereby certify that I have
served by first class mail, postage prepaid, true and correct copies of the attached papers upon the
following person(s) or their attorney of record:
Brian Rogers, 615 3rd Street, New Cumberland, PA 17070
Date Mailed: )4,,315—
Date:
BY:
SHAPIRO & DeNARDO, LLC
Attorneys for Plaintiff
CHRISTOPHER A. DeNARDO, ESQ.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 •
SARAH K. McCAFFERY, ATTORNEY I.D. NO: 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
successor by merger to Chase Home Finance CIVIL DIVISION
LLC successor by merger to Chase Manhattan CUMBERLAND COUNTY
Mortgage Corporation
PLAINTIFF NO:14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance LLC
successor by merger to Chase Manhattan Mortgage Corporation
c/o CHE - JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
and that the last known address of the judgment debtor (Defendant) is:
Brian Rogers
615 3rd Street
New Cumberland, PA 17070
Date:
14-044904
BY:
SHAPIRO & DeNARDO, LLC
CHRISTOPHER A. DeNARDO, ESQ.
Attorneys for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
TO: Brian Rogers
615 3rd Street
New Cumberland, PA 17070
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
PLAINTIFF
VS.
Brian Rogers
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-5205 CIVIL
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Default
[ ] Judgment for Possession
[ ] Judgment on Award of Arbitration
[ ] Judgment on Verdict
[ ] Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610)278-6800.
414 IS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
PLAINTIFF
vs.
Brian Rogers
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
() Confessed Judgment
() Other
File No. 19 - 'Sam S
Amount Due $114,098.88
Interest January 1, 2015 to June 3, 2015 is
$3,309.61
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account
based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act
7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date:
Signature:
Print Name: Christopher A. DeNardo, Esquire
Address: 3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 78447
440i
ekJ/VOA voa
R.14 --11)(F)
Pr
ALL THOSE TWO CERTAIN lots or parcels of ground situate and being in George W.
Buttorll's Addition to the Borough of New Cumberland, Cumberland County, Pennsylvania, and
known and numbered on said Plan as Lots Nos. 7 and 8, Block "H", and more particularly
bounded and described as follows, to wit:
BEGINNING at a point on the northern side of Third Street, which point is one hundred (100)
feet East of the Northeast corner of Third Street and Rosemont Avenue; thence in an easterly
direction along the line of said Third Street, fifty (50) feet to a point on the dividing line between
Lot Nos. 6 and 7; thence North along said dividing line between Lots Nos. 6 and 7, and at right
angles with third Street, one hundred forty (140) feet to River Avenue; thence West along the
said River Avenue and parallel with the said Third Street, fifty (50) feet to a point on the dividing
line between Lots Nos. 8 and 9; thence in a Southerly direction along said dividing line between
Lots Nos. 8 and 9, one hundred forty (140) feet to Third Street the place of BEGINNING.
HAVING THEREON ERECTED a duplex dwelling house and garage known and numbered as
615 Third Street, New Cumberland Borough, Cumberland County, Pennsylvania.
PARCEL No. 25-25-0006-116
BEING THE SAME PREMISES which Stephen J. Thompson and Julie L. Thompson, husband
and wife, by deed dated 10/30/2000 and recorded 10/31/2000 in the office of the recorder of
deeds in and for the county of Cumberland, in deed book 232, page 1064 granted and conveyed
unto Brian Rogers, married man.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO,
ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D.
NO. 312169
CHANDRA M. ARKEMA, ATTORNEY
I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D.
NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D.
NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
PLAINTIFF
VS.
Brian Rogers
DEFENDANT
• isiiS 711C:10 '1,411
28i5 4 G
Sl i .11. 33
,n .
r)L`i J, J1. 1 •'1) COUNr
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14-5205 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, National Association successor by merger to Chase Home
Finance LLC successor by merger to Chase Manhattan Mortgage Corporation, Plaintiff in the
above action, sets forth, as of the date the praecipe for the writ of execution was filed, the
following information concerning the real property located at 615 3rd Street, New
Cumberland, PA 17070.
1. Name and address of Owner(s) or Reputed Owner(s)
Brian Rogers
615 3rd Street
New Cumberland, PA 17070
2. Naive and address of Defendant in the judgment:
Brian Rogers
• 615 3rd,Street
New Cumberland, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
615 3rd Street
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
SHAPIRO & DeNARDO, LLC
BY:
14-044904
Christopher A. DeNardo, Esquire
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144
SARAH K. McCAFFERY, ATTORNEY I.D. NO. 311728
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S&D FILE NO. 14-044904
JPMorgan Chase Bank, National Association
successor by merger to Chase Home Finance
LLC successor by merger to Chase Manhattan
Mortgage Corporation
PLAINTIFF
'�.'_`: S ACUU';1 y
tA
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14-5205 CIVIL
VS.
Brian Rogers
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Brian Rogers
615 3rd Street
New Cumberland, PA 17070
Your house (real estate) at:
615 3rd Street, New Cumberland, PA 17070
25-25-0006-116
is scheduled to be sold at Sheriffs Sale on June 3, 2015 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:OOAM to enforce the court judgment of $114,098.88 obtained by JPMorgan Chase Bank,
National Association successor by merger to Chase Home Finance LLC successor by merger to
Chase Manhattan Mortgage Corporation against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to JPMorgan Chase Bank, National
Association successor by merger to Chase Home Finance LLC successor by merger to
Chase Manhattan Mortgage Corporation the amount of the judgment plus costs or the
back payments, late charges, costs, and reasonable attorneys fees due. To find out how
much you must pay, you may call:(610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610)278-6800.
6. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
9. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
10. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)
days after the date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
14-044904
r
ALL THOSE TWO CERTAIN lots or parcels of ground situate and being in George W.
Buttorll's Addition to the Borough of New Cumberland, Cumberland County, Pennsylvania, and
known and numbered on said Plan as Lots Nos. 7 and 8, Block "H", and more particularly
bounded and described as follows, to wit:
BEGINNING at a point on the northern side of Third Street, which point is one hundred (100)
feet East of the Northeast corner of Third Street and Rosemont Avenue; thence in an easterly
direction along the line of said Third Street, fifty (50) feet to a point on the dividing line between
Lot Nos. 6 and 7; thence North along said dividing line between Lots Nos. 6 and 7, and at right
angles with third Street, one hundred forty (140) feet to River Avenue; thence West along the
said River Avenue and parallel with the said Third Street, fifty (50) feet to a point on the dividing
line between Lots Nos. 8 and 9; thence in a Southerly direction along said dividing line between
Lots Nos. 8 and 9, one hundred forty (140) feet to Third Street the place of BEGINNING.
HAVING THEREON ERECTED a duplex dwelling house and garage known and numbered as
615 Third Street, New Cumberland Borough, Cumberland County, Pennsylvania.
PARCEL No. 25-25-0006-116
BEING THE SAME PREMISES which Stephen J. Thompson and Julie L. Thompson, husband
and wife, by deed dated 10/30/2000 and recorded 10/31/2000 in the office of the recorder of
deeds in and for the county of Cumberland, in deed book 232, page 1064 granted and conveyed
unto Brian Rogers, married man.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suitel00 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
SUCCESSOR BY MERGER TO CHASE HOME FINANCE
LLC SUCCESSOR BY MERGER TO CHASE MANHATTAN
MORTGAGE CORPORATION
Vs. NO 2014-05205 Civil Term
CIVIL ACTION — LAW
BRIAN ROGERS
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $114,098.88 L.L.: $.50
Interest JANUARY 1, 2015 TO JUNE 3, 2015 IS $3,309.61
Atty's Comm:
Atty Paid: $293.92
Plaintiff Paid:
Date: 1(14!15
(Seal)
Due Prothy: $2.25
Other Costs:
David D. Bu -11, Prothonotary
Deputy
REQUESTING PARTY:
Name: CHRISTOPHER A. DENARDO, .ESQUIRE
Address: 3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 78447