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Home My WebLink About14-5207 6 Supreme hurt-of Pennsylvania Gt�ui ` f�zQ�t Pleas Sheet For Prothonotarr VW 011t 1 : � ) C.I2D �t1Iltl� r COdiltf[ Docket ~lex: a �f . The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiling and service ofpleadings or other p9pers as required bylaw or rules of court. - Commencement of Action: Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: JPMORGAN CHASE BANK,NATIONAL RAELYN A.ZINICOLA 1C, ASSOCIATION Dollar Amount Requested within arbitration limits O Are money Damages requested?: ❑ Yes No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO i Name of Plaintiff/appellant's ellant's Attorne KML Law Group,P.C.: PP Y� ❑ Check here if you are a Self-Represented Pro Se Litigant _. _ _.. Nature of the:Case !;Place;an "X":to the:jeft the'-ONE case categoy.thatmost;accurately describes your 1°RIMARY CASE.,If you are making more than cine type of claim, check the.one that you consider most nnportant TORT (do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer'Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections. Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other mass tort) ❑ Employment dispute: ❑ Slander/Libel Defamation Discrimination > ❑ Employment Dispute:Other ❑ Other ❑ Other: MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste �► ❑ Other ❑ Eminent-Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 11112011 4 KML LAW GROUP, P.C. SUITE 5000-BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 (866)413-2311 WWW.KMT,I,AWGROITP.COM JPMORGAN CHASE BANK,NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION c/o 3415 Vision Drive OF Cumberland COUNTY Columbus, OH 43219 Plaintiff CIVIL ACTION-LAW vs. RAELYN A. ZINICOLA ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 281 Clark Street -A V1L ACTION.-MORTGAGE Lemoyne,PA 17043 FOC�S�i Defendant(s) 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION e-) n, c 2 Liberty Avenue r ' Carlisle, PA 17013 MM r LEGAL SERVICES INC r- _CD 8 Irvine Row � _ Carlisle,PA 17013 717-243-9400 -t cil AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas erg las paginas siguientes,usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. , 'P ckz` 77ss-9 SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://w,�vw.phfa.oriz/consumers/homeowners/real aspx. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://wNvw.phiIadelpli.iafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionEakmllawgroup.com. Call Seth-at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 21-5-825-6418. Please reference our Attorney File Number of 135117FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop-it. ti COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is/are RAELYN A. ZINICOLA, 281 Clark Street, Lemoyne, PA 17043, who is/are the mortgagor(s)and record owner(s)of the mortgaged premises hereinafter described. 3. On November 25, 2008 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR CAPITAL ONE HOME LOANS, LLC, OPERATING SUBSIDIARY OF A NATIONAL BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on December 29, 2008 as Instrument#: 200840605. The mortgage has been assigned to: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION by assignment of Mortgage recorded on July 07, 2014 as Instrument#: 201414650. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit "C". The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 101.9(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 01, 2014 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more,the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of August 13, 2014: PrincipalBalance........................................................................................$105,257.08 Interest from 03/01/2014 through 07/31/2014 .............................................$2,631.45 AccruedLate Charges........................................................................................$195.45 EscrowAdvance.............................................................................................$1,159.90 Reasonable Attorney's Fee.............................................................................$1,650.00 $110,893.88 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability(or an"in personam"judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Plaintiff sent Defendants the notice as required by 35 P.S. Section 1680.401 et. seq. (Act 91 of 1983) or by 41 P.S. Section 403 (Act 6 of 1974) or as required by the Mortgage ("Notice"). A true and correct copy of the Notice is attached and incorporated as Exhibit`B". WHEREFORE,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$110,893.88, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW GROU C. Michael McKe ve Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 lvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Pennsylvania Verification Rebecca J. Bingham , hereby states that he/she is Vice President of JPMorgan Chase Bank, N.A. the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Re ecca J. Bi am Vice Preside t Date: JPMorgan Chase Bank, N.A Borrower: RAELYN A ZINICOLA Property Address: 281 CLARK ST.,LEMOYNE, PA 17043 County: CUMBERLAND Last Four of Loan Number:3792 hiblot A ALL THAT CERTAIN LOT Or ANI)SITUATED JN THE BOROt1GH'OF LEMOYNE(FORMERLY LOWER ALLEN TOWNSHIP), CUMBERLAND-COUNTY,PENNSYLVAN.LA;`BOU.NDED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT'ON THE NORTHERLY LINE OF CLARK STREET AS,SHOWN ON THE PLAN OF LOWER.WALTON AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 1, PAGE 104;SAID POINT.BEING 248:9.FEET MEASURED ALONG'THE NORTHERN LINE OF CLARK STREET IN A.NORTHEASTERLY DIRECTION FROM THE NORTHEAST CORNER FROM ROSSMOYNE(NOW THIRD STREET) AND CLARK STREETS;THENCE IN.A NORTHEASTERLY DIRECTION ALONG THE NORTHERLY LINE OF CLARK STREET 25.00 FEET TO A Pd. THENG.E:,IN.A NORTHWESTERLY DIRECTION ON A LINE-AT. INE-AT RIGHT ANGLES TO CLAR1t T AND ALONG PROPERTY NOW OR FORMERLY OF FOSTER EICHELBERGE.R.217. 8 FEET TO A POINT;THENCE IN A SOUTHWESTERLY DIRECTION ON A LINE..PARALLEL.WITH CLARK STREET AND ALONG PROPERTY NOW OR LATE OF MARY A.MAY 25.00 FEET TO A POINT;THENCE IN A SOUTHEASTERLY DIRECTION ON A LINE AT RIGHT ANGLES TO CLARK STREET AND.THROUGH THE CENTER OF THE PARTITION WALL BETWEEN HOUSE NOS.281 AND 283 CLARK STREET,217.8 FEET TO CLARK STREET',THE PLACE OF BEGINNING. TAX ID#: 12-22-0M.72.70 BEING ALL AND.THE SAME LANDS AND,PREMISES CONVEYED TO RAELY,N A.,ZINICOLA MARRIED WOMAN BY LAURIE A.WILLIAMS IN A DEED EXECUTED 27252005 AND RECORDED 3/1/2005 IN BOOK 267, PAGE 3665 OF THE CUMBERLAND COUNTY; PENNSYLVANIA LAND RECORDS Exthibit (B *Exhibit has been redacted to remove allpersonally identifiable information or non-public information P.O.Box 183205 Columbus,OH 43218 USPS CERTIFIED MAIL- For AIL-For Undeliverable Mail Only 9214 8901 0754 4637 2101 19 043343-1 of 4 NSPOHDLA-CA]1777963 0000000 RAELYN A ZM' COLA - r 281 CLARK ST ' LEMOYNE PA 17043 a i CpChase(OH4-7399) CHASE P.O.Box 183205 Columbus,OH 43218 For Undeliverable Mail Only 06/03/2014 RAELYN A ZINICOLA 281 CLARK ST LEMOYNE,PA 17043 NOTICE OF INTENT TO FORECLOSE MORTGAGE Account: ******3792 (the "Loan") Property Address: 281 CLARK ST LEMOYNE,PA 17043 (the"Property") Dear RAELYN A ZINICOLA: 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 04/01/2014 for the mortgage held by JPMorgan Chase Bank,National Association. 2-. As of 06/03/2014,total monthly payments(including principal,interest,and escrow if applicable),late fees,insufficient-funds(NSF)fees,and other fees and advances due under the terms of your loan documents in the total amount of$3,048.78 are past due. This past-due amount is itemized below. If applicable,your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below,please contact us as soon as possible at 800-848-9380. Total Monthly Payments $2,931.51 Late Fees $117.27 NSF Fees $0.00 Other Fees and Advances* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and/or permitted by applicable law, or that were authorized for services rendered If you need additional information regarding any of these amounts,please contact us at the number provided below. Certified Article#:9214 8901 0754 4637 2101 19 043343-2 of 4 NSPOHDLA-CA J1777963 OOOOOOD You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 07/06/2014 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. AL1 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. Loan,declare all sums secured by the Security.Instrument 6. If you fail to cure the default on or before 07/06/2014, Chase may accelerate the maturity of the Instrument ' due and payable,and commence foreclosure by judicial proceeding and sale of the Property. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies-provided in the Security Instrument,which may include,but not be-limited to,allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law,you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration,foreclosure,and sale.However,the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan,including attorney fees,if permitted by law, related to any foreclosure action we initiate. Certified Article#:9214 8901 0754 4637 2101 19 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 fluids if two insufficient funds(NSF) payments have been received in the last six months. In this event,Chase will not accept a Direct Check,FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX,AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX,AZ 85034-9700 Except as required by law,we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed,we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home;however,we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at 800-848-9380. 10. While the Loan remains in default,we will perform certain tasks to protect our interest in the Property,including visits to your Property at regular intervals during the default. This will be done to determine,as of the date of the inspection the property condition,occupancy status,and,possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property.You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt.You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments,charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist.You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development(HUD). A listing of such organizations may be obtained by calling HUD toll-free at-800-569-4287 or at www.hud.gov. Sincerely, Chase 800-848-9380 800-582-0542 TDD/Text Telephone www.chase.com Enclosure -Federal Trade Commission Pamphlet Certified Article#:9214 8901 0754 4637 2101 19 043343-3 of 4 NSPOHDLA-CA J1777963 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 4637 2101 19 A6 1 p.orvaht.r6ess_.n!F' tf'()??'?iY r �L.'�ff�,d. 'c7rl�' t f?:3 i1•J /f 1: Facing foreclosure? Stammers 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 stammers offer to handle financial open 24n—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. Svc eral Ti de.Cbirnrnis.sion: ftp.cci�11RciJ eylviatirrs Certified Artide#:9214 8901 0754 4637 2101 19 043343-4 of 4 NSPOHDLA-CA J1777963 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 ISO, MAKING HOME,AFFORDABLE, . - zt<gf cyj$ df,>e.Cd <t^7•1se(w..,,r• Sr Cendied Article#:9214 8901 0754 4637 2101 19 Ex,hifiit *Exhibit has been redacted to remove allpersonally identifiable information or non-public information Prepared By%Return To: jartay D Ashford . ,JFMorgan 'Chase Bank,N.A.,780 Kansas.Lane, Suite.A,Monroe,LA,71203 Loan#3792 ao��Gg Tae Cod0PIN1IIPI.#: 12-22-0822-270 111111 IIIII IIVI IIIII IIIII Nlll IIIII Ilill IIIII IlI1111111111 ASSIGNMENT OF MORTGAGE Contact JPMORGAN CHASE BANK,N.A."'for.this instrument 780 Kansas-Lane,Suite A,Monroe,LA 71203,telephone#(866)756.8747,which Is responsible for receiving payments. FOR GOOD AND VALUABLE CONSIDERAI�ON;.t1 sufficiency of-W is hereby.acknowledged, the undersiggned, MORTGAGE ELECTRONIC -RF.GIS`TRATION SYSTEMS, .INC. AS NUMII�IEE FOR CAPTTAL ONE HOME LOANS, LLC. OPERATING SUBSIDIARY OF A NATIONAL BANK;;ITS .SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS P.O. BOX 2026, FLINT, W.- 48501.2026, (ASSIGNOR),(MERS Address: 1901 E Voorhees Street,Suite.C,Danville,IL 61834).by,these presents does convey, grant, assign, transfer and,set over the described Mortgage therein together with ali interest secured thereby, ali liens, and any rights due,or do become due thereon t0 JPMORGAN CHASE BANK,NATIONAL. ASSOCIATION WHOSE ADDRESS LS 7t1(I KANSAS LANE, MC 8000;.MONROE, LA 71203;.ITS SUCCESSORS�ND ASSIGNS,(ASSIGNEE}. Said Mortgage is dated 1112512008, in .the amount of X123,781:00 made b RLYN A_7TNICA .to. OL MORTGAGE ELECTRONIC REGISTRA"T'IUN SYSTEMS; W� AS NOMINEE FOR CAPITAL ONE HOME LOANS,LLC OPERATING SUBSIDIARY OF A NATIONAL BANK,ITS SUCCESSORS AND' ASSIGNS, .recorded on ,12J2912008, in the Office of the Re66rder of. Deeds of CUMBERLAND County, Pennsylvania,in Book,Page,and/or Document#200840605. . Property is catii_mc•i��uly knuwn as:281 CLARK STREEI"BORO,OF LEMOYNE,LFMOYNE-PA 17043. Dated on t� (MM/DD/YYYY) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC AS NOMINEE FOR CAPITAL ONE HOME LOANS,LLC OPERATING.SUBSIDIARY OF A NA'T'IONAL BANK,ITS SUCCESSORS.AND ASSIGNS Y anay Ashford ASST:SECRETARY PAGI1 1PC'AS 23867075 --CHASE 131 MIN 100393220082003218 MERS:PHONE 1-888-679-6377.•-NERS Address: 190I E Voorhees St.,Suite C,Danville,IL 61834 or P.O.Boz 2026,Flint,MI 48501-2026 724].4065$09 FRMPA I milli I�l III�III�IIWdI11�Lf�.IVlI�IDf� °D00065 278• • r Loanill 1111111 HE111111111111111111111111Ill STATE OF LOUISIANA PAR[SH OF OUACHITA On �(�/ 'L!y / 2�/ (MM/DD/YYYY), before iiie ap"cd to me personally known, who did say that he/she/they is/are the ASST.9ECRPTARY of MORTGAGE.ELECTRONIC REGISTRATION SYSTEMS,INC.AS NOMINEE FOR CAPITAL ONE HOME LOANS, LLC OPERATING SUBSIDIARY OF A NATIONAL BANK, ITS SUCCESSORS AND ASSIGNS and that the instrumcnt was signet]vn behalf of the corporation(or association), by authority from its board of directors, and that he/she/they acknowledged the instrument to be the free act and deed of the corporation(or association). / TODD G'SYLVESTER NOTARY PUBLIC#062367 TODD C SYLVE 7 OUACHITA PARISH LOUISIANA Notary Public-State of LOUISLANA MY COMMISSION IS FOR LIFE Commission expires:Upon My Death Assignment of Mortgage�from: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR CAPITAL ONE HOME LOANS,LLC OPERATING SUBSIDIARY OF A NATIONAL BANK,.ITS SUCCESSORS AND ASSIGNS, WHOSE ADDRESS IS P.O. BOX 2026, FLINT, All, 48501-2026; (ASSIGNOR), .(mEKS Address:1901 E Voorhees Street,Suite C,Danville,IL 61834) to: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,WHOSE ADDRESS IS 700 KANSAS.LAND'~;, MC 8000,MONROE,LA 71203,ITS SUCCESSORS AND ASSIGNS,(ASSIGNEE) Mortgagor.RAELYN A.ZINICOLA When Recorded Return To: JPMvrgan Chase Bank;NA C/O Nationwide Title Clearing,Inc.2100 All. 19 North Palm Harbor,FL 34683 All that certain lot.o. piece of ground situated in Mortgage Premise:281 CLARK STREET BORO.OF LEMOYNE L.EMOYNE,PA 17043 CUMBERLAND (Borough or Township,if stated),Commonwealth of Pennsylvania. Being more particularly described in said Mortgage. I, Ire ay correct:D Ashford assrgnme are correct: hereby.certify that the below information and address for the 3PMORGAN CHASE BANK,NATIONAL ASSOCIATION,WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000,MONROE,LA 71203,ITS SUCCESSORS AND ASSIGNS,(ASSIGNEE) By: D fanav D AshfordASST.SECRETARY PGE *23867075* JPCAS 23867475 __CHASE NJ MIN 100393220082003218 MERS PHONE 7-888-679-6377 2 MERS Address: 1901 E Vooitrees-St.,Suite C,Danville,IL 61834 or P.O.Box 2026,Flint M148501-2026 T'2414065809 [C-2]IIFRMPAl *D00065"278* FTAMMY SHEARER RECORDER OF DEEDS r CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 - Inct—ment Number-.201414650 Recorded On 7/7/2014 At 2:18:51 PM * .. *Instrument Type-ASSIGNMENT OF MORTGAGE T0tal.Pages-3: Invoice Number-164174 ITscr ID-JM' *Mortgagor-ZINICOLA,RAELYN.A *Mortgagee-JPMORGAN CHASE BANK N A * Customer-NATIONWIDF,TITLE CLEARING *FEES STATE WRIT TAX $o.5Q Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 DO NOT DETACH, RECORDER .OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal 4ocument couNTy ARCHIVES FES $2.60, ROD ARCHIVES FEE $3.00 TOTAL PAID $55.50 I Certify this to be recorded. in Cumberland County PA a au e 0 v c, RECORDER OF DEEDS *-Information denoted by nn asteriik may change.during the verification process'arid.may not be reflected on thi3:page. 004'1 G9 lllllllll�l�llllf Illlll Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED -OFFICE ICE OF THE PPO T HONG TAR`i' 2014 OCT 21 P11 2: 58. CUMBERLAND COUNTY PENNSYLVANIA JP Morgan Chase Bank vs. Case Number Raelyn A Zinicola 2014-5207 SHERIFF'S RETURN OF SERVICE 09/19/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Raelyn A Zinicola, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Served" at 281 Clark Street, Lemoyne Borough, Lemoyne, PA 17043. Neighbors advised that the defendant is deceased but it is believed that her son still resides at the address. 10/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 281 Clark Street, Lemoyne Borough, Lemoyne, PA 17043. The residence is believed to be vacant per neighbors, it was believed that the defendant's son was residing at this address but no one has been seen at this address for over two weeks. SHERIFF COST: $85.16 SO ANSWERS, October 16, 2014 (U CountySuito Sheri(.'. Teieosoft, Inc. RONR ANDERSON, SHERIFF KML Law Gro.pp, P.C. Suite 5000 - BY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 2Gi5J. - ft;'; IC: 314 ATTORNEY FOR PLAINTIFF . 1Y .;:SYCVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs. RAELYN A. ZINICOLA Mortgagor(s) and Record Owner(s) 281 Clark Street Lemoyne, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUGGESTION OF DEATH Term No. 14-5207 TO THE PROTHONOTARY: It is respectfully suggested that Defendant Raelyn A Zinicola is deceased, having departed this life on November 27th 2013. By: KML LAW ROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa, ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 / Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs. ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW RAELYN A. ZINICOLA Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 281 Clark Street Lemoyne, PA 17043 Defendant(s) Term No. 14-5207 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Suggestion of Death was sent by first class mail, postage pre -paid, upon the following on the date listed below: Joseph Manley, Solely in His Capacity as Heir of Raelyn A. Zinicola, Deceased 281 Clark Street Lemoyne, PA 17043 Kenneth Manley, Solely in His Capacity as Heir of Raelyn A. Zinicola, Deceased 127 E Emaus Street Middletown, PA 17057 Keaton Manley, Solely in His Capacity as Heir of Raelyn A. Zinicola, Deceased 127 E Emaus Street Middletown, PA 17057 Raeann Black, Solely in Her Capacity as Heir of Raelyn A. Zinicola, Deceased 640 Vine Street Middletown, PA 17057 Date: KML LAW GROUP, P.C. By: f v V KML LAW GROUP, P.C. Nick Barone Telephone: (215) 627-1322