HomeMy WebLinkAbout14-6001 Supreme Court of Penuisylvania
Cou �.of
r> Comii`autt Pleas
S�
7d°C€rer Syeet For Prothonot&T Use oaf,..
Cumberland Count Docktt Va:
The information collected on this form is used solely for court administration purposes. This form does not
Supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking_
E Lead Plaintiff Name: Lead Defendant's Name:
C U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE, STEVEN G.DELP
SUCCESSOR IN INTEREST TO BANK OF AMERICA, NICOLLE L.DELP
NATIONAL ASSOCIATION AS TRUSTEE SUCCESSOR
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
Name of Plaintiff/appellant's Attorney:KML Law Group,P.C.
❑ Check here if you are a Self-Represented(Pro Se Litigant
Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your
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.APPEAL
❑ IntentionaI ❑ 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 13 Statutory Appeal: Other
1E mass tort) ❑ Employment dispute:
❑ Slander/Libel Defamation Discrimination
T ❑ Other ❑ Employment Dispute: Other
❑ Other:
I
0 MASS TORT ❑ Other
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort-Implant ❑ Ejectment
❑ Toxic Waste � ❑ Common Law/Statutory
❑ 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.R C.P. 205.5 Updated 11112011
KML LAW GROUP,P.C.
SUITE 5000-BNY MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
(866)413-2311
Www.KNli, •AWGRO(iP.COM
U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE, IN THE COURT OF COMMON PLEAS
SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR OF Cumberland COUNTY
BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION,AS TRUSTEE FOR CERTIFICATE CIVIL ACTION-LAW
HOLDERS OF BEAR STEARNS ASSET BACKED
SECURITIES I LLC ASSET BACKED CERTIFICATES, ACTION OF MORTGAGE FORECLOSURE
SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219 No./Y -4,00/ C
Plaintiff v`
vs. 1
STEVEN G.DELP C1 V1L.�C1"1()1�j•.
NICOLLE L.DELP MORT(GAGF,
Mortgagor(s)and Record Owner(s) FORBUOMij
107 Kim Acres Drive
Mechanicsburg, PA 17055
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
n
2 Liberty Avenue C--
Carlisle,PA 17013 .O:r
rncu ca �
zrn n _
r-
c�
LEGAL SERVICES INC -<> CD
8 Irvine Row
C-0 -�z
Carlisle, PA 17013 _ c�
717-243-9400
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte torriara medidas y puede continuar la demanda en contra suya sin previo aviso o notification.
O&S 7s � �
st
mac, (�?—
.343
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 T1ENE 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.
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://www.phfa org/consumers/homeowners/real aMxx.
5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www philadelphiafed ori/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretention(a)kmllawarou com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 131409FC.
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.
COMPLAINT IN MORTGAGE FORECLOSURE !
1. Plaintiff is U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN INTEREST j
TO BANK OF AMERICA,NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY MERGER
TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS
OF BEAR STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED CERTIFICATES,
SERIES 2004-2, c/o 3415 Vision Drive, Columbus, OH 43219.
2. The name(s)and property address(es)of the Defendant(s)is/are STEVEN G. DELP, 107 Kim Acres
Drive, Mechanicsburg, PA 17055 and NICOLLE L. DELP, 107 Kim Acres Drive, Mechanicsburg, PA .
17055,who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter
described. I!
3. On July 26, 2002 mortgagor(s)made,executed and delivered a mortgage upon the Property hereinafter
described to WILMINGTON FINANCE,INC.,which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County on September 13,2002 as Book#: 1773 Page: 0205. The
mortgage has been assigned to: LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR
CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC ASS ET,jvne
BACKED CERTIFICATES, SERIES 2004-2 by assignment of Mortgage recorded onarg 25,2007
as Book 0738,Page 0080. 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 1019(g);which Rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public
record. A loan modification was executed on May 15, 2010 and attached hereto as Exhibit"D".
i
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A"("Property").
f
�
i 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for December 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in j
such payments for a period of one month or more,the entire principal balance and all interest due and
iother charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage as of August 14, 2014:
Principal Balance
........................................................................................$131,628.85
Interest from 11/01/2013 through 07/31/2014
........$7,404.12
Accrued Late
Charges. .............................................................................. .$164.52
EscrowAdvance.............................................................................................$4,179.71
Suspense Balance................................................. ........... ($297.80)
Reasonable Attorney's Fee................................................................. :$1.650.00
$144,729.40
7. If the Mortgage is reinstated prior to a Sheriff s Sale,the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. Plaintiff reserves the right to request
additional attorney's fees if the complexity of the action results in fees in excess of the amount
demanded. Further,Plaintiff will request recovery of all costs incurred in this action including,but not
j 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.
. i
i
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8. Plaintiff is not seeking a judgment of personal liability (or an "in personam"judgment)against the i
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". I
is
WHEREFORE,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$144,729.40,
together with interest,costs, fees and charges collectible under the Note and Mortgage including but not limited
to attorney's fees and costs, and for the foreclosure and sale of the mortgage property.
By: f
KML LA W GR P, C.
- Michael Mc eever 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 2.05047 I
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897 j
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
I
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VERIFICATION OF COMPLAINT I'
i
The undersigned,Rebecca J.Bingham , does hereby certify that he/she is
Vice President of JPMorgan Chase Bank,N.A. ("Chase"), and that Chase has been duly
nominated and appointed by the Plaintiff as its mortgage servicing agent in regard to the
mortgage loan which is the subject of this action (the "Mortgage"). Plaintiff lacks sufficient
information to make this verification because Plaintiff is not the entity that maintains the
business records for the Mortgage. Chase, in its capacity as mortgage servicing agent for
I
or the Mortgage, and therefore, as an employee of
Plaintiff, maintains the business records f
Chase, I have sufficient information to make this verification in accordance with Pa.R.C.P.
1024(c)(1).
I am authorized to make this Verification on Plaintiff's behalf and do hereby verify that
the facts as set forth in the foregoing Complaint are true and correct to the best of my
information and belief. I have access to and have reviewed the business records of Chase for and
relating to the Mortgage,and I make this Verification based on my review of those records,
which are maintained by Chase in the course of its regularly conducted business activities and
are made at or near the time of the event, by or from.information transmitted by a person with
knowledge.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904 relating to unsworn falsification to authorities.
Dated: o2 9 o2Q/�1 By; 1,Vi
Name: ecca J. i ham
Vice President, J organ Ch Bank,N.A.
Loan No.XXX- 8988
i
hibitA
Al. . THAT C1,ic'1'AIN Int of ground situate. in t1ac 7'nu�i�ship of 1,;i';)rr A1:C.It, �s7vnty or Cu:7t1icr1and
et ti[� ;jF�i.0 of t'.nrc6bCt1 al fallatitis, tv wit'
BEGINNING at :t print iso ti,e 501V11'".11
line t�C:t iju1)1jc road knoVrn as ;Citta Acrr—v Orivc (5C ;cct
t
wide'), Which poillC I's, r
in the divisics-i linc }, tu'een Lots 10 and 11 t.)n the 1wreinafter mrrii[Sl�td
Plan of Lots; 11•enc.c :jjung the. division line brtwccri Lots 10 3.-t(1 11, $o:lth :l drbrocs 30
minutes rs;st, � ci:s;a�,rr. ,-jr 145 fe=t to . pcint ill t1le :livitiiati Jim- bciwcen 1.0"s 1l, fir! 1rj' ari
sasd Plan; t17e1;Ce -dont t.1:c idi�,�isic�:) lin: t?rtti+;eesi Lots 11 and 'Of and 1.ais 11 sl.�c� z13, 1'i9rth 78 I
dc,gTCC-' 0Ca Cii11�+t#cS E;,.�t, a klist=C.0 of t)() f-ct to a feint Ll the divisio Ln- l} t aen Lcts Z 1 :;d
12; LhttlCe a:Oar; 1he satllC, NOT91 11 degrcrs 30 nni►vatcs N)le5t, a dist:k re of 145 fcct t;) a point
ill ibe sout�)crn airs, Tr K:t:, !luta Drive, thnx?ce along -,he nouther.n]inn of kirn
Acres Drive, Zio%ldl '178 t;�,l;rCCS . 0 tninulen West, a diatance of 90 fib et to a 1�i'irit in tl)e clivi;i�r; i
liter bctweeil Lots 10 anti 11, caforen)(.ni.-Cried, at the place of BEGINN1NO. '
13SING Lot Na. ! 1 in n crrtpir Plan of Lots known as Mt. Allen Hciehll (rornwrly killown as
Spring rt)n Ac:cs), witinh said Pl;cni5 1ecotcird in t1)c CQ.n}bvrlal)d CDun#v Rdcprdcr's Off oc it t
Plan Book 15, re)gc 14.
H.AA 1N0 T1 iBRRON EP.LC F0 a blit_k, stnrrc arc1 ali;t,t'inu n si<11ng dwel.1hig }Zoi)sc with Intecl-al 1
garuge I-W(r-vt, :wnc ntu,lbered as 107 KiM Acros Dilve, Mcch: ,1c!-,•)urg, PentagS lvart;x,
{
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Ccr{i fy this 1.0 I)c rece,
Jed
1,1 (;Uy;-tberjai-id County
PA
` tecordcr of Dec&
BEING THE SAME PREMISES WHICH, Roy M. Hawkins and Frances Hawkins, fka Frances
Petco, his wife, by their deed dated November 6, 1998 and recorded November 9, 1995 the
Office of the Recorder of Deeds in and for Cumberland County in Deed Book 188, Page.935,
granted and conveyed unto Steven G. Delp and Nicolle L. Delp, hiswife.
�C
*Exhibit has been redacted to remove allpersonally identifiable information or non-public.information
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL Tm
For Undeliverable Mail Only
9214 8901 0754 4636 1120 18
008259-1 of 5 NSPOHDLA-CA 71141672 0000000
STEVEN G DELP
107 KIM ACRES DR.
MECHANICSBURG PA 17055
Chase(OH4-7399) CHASE CFL
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
04/29/2014
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
STEVEN G DELP
107 KIM ACRES DR.
MECHANICSBURG,PA 17055
Act 91 Notice
Account: ******8988 (the "Loan")
Property Address: 107 KIM ACRES DR.
MECHANICSBURG,PA 17055 (the "Property")
Dear STEVEN G DELP:
On the following page,you will find a notice regarding your home as required by Pennsylvania law.
Cengied Article#:9214 8901 0754 4636 1120 18 008259-2 of 5 NSPOHDLA-CA J1141672 0000000
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official Notice that the mortgage on your home is in default and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSIST NCE PROGRAM
LHEMAPI may be able to help to save your home This Notice explains how the
program works. To see if HEMAP can help, you must MEET WITH A
CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (33)
DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you
meet with the Counseling Agency.
The name address and red
hone number of Consumer Cit Counseling Agencies
serving our County are listed at the end of this Notice If you have any questions
you may call the Pennsylvania Housing Finance Agency toll-free at 800-342-2397.
_ersons With impaired hearing can-ca- 717 780 1869 1
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help
explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA
TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR
EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): NICOLLE L DELP
STEVEN G DELP
PROPERTY ADDRESS: 107 KIM ACRES DR.
MECHANICSBURG, PA 17055
LOAN ACCOUNT NUMBER: _988
ORIGINAL LENDER: WILMINGTON FINANCE,INC.
CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A.
Certified Article#;9214 8901 0754 4636 1120 18
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE"ACT"),YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORE LOSURE--Under the Act,you are entitled to a temporary
foreclosure on your mortgage for thirty(30)days from the date of this Notice(plus three (3)da days s or of
mailing). During that time,you must arrange and attend a"face-to-face"meeting with one of the
consumer credit counseling agencies listed at the end of this Notice.THIS MEETING MUST OCCUR
WITHIN THIRTY-THREE(33)DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE
UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit
counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty
(30)days after the date of this meeting. The names addresses and telel2hone numbers of designated
consumer credit counseling agencies for the coun1y in which the 12rope i located are et f hat he
end of this Notice. It is only necessary to schedule one face-to-face meeting.Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default).
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so,you must fill out, sign,and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed at
the end of this Notice. Only consumer credit counseling agencies have applications for the program and
they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to
PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency.
YOUSHO ULD FILE HEMAP APPLICA TION A S SOON AS POSSIBLE.IF YOUHAVEA
MEETING WITHA CO UNSELING A GENCY WITHIN THIRTY-THREE(33)DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILEAN APPLICATION WITH THE PHFA WITHIN
THIRTY(30)DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECL OS URE A CTION A GAINST YOUR PROPERTY,AS
EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARYSTA Y OF FORECLOSURE."
YOUHAVE THE RIGHT TO FILEA flEMAPAPPLICATION EVEN BEFOND THESE T E
PERIODS.A LA TE APPLICA TION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECL OS URE A CTION,BUT IF YOUR APPLICA TION IS EVENTUALLYAPPROVED ATANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
Certified Article#:9214 8901 0754 4636 1120 18
008259-3 of 5 NSPOHDLA-CA J 1141672 0000000
AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty(60)days to make a decision after it receives your application. During
that time,no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision
on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Brin it up to
date .
NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located
at: 107 KIM ACRES DR. ,MECHANICSBURG,PA 17055 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
12/01/2013; $1,217.72
01/01/2014; $1,217.72
02/01/2014; $1,217.72
03/01/2014; $1,217.72
04/01/2014; $1,217.72
Other charges:
Late Charges: $164.52
Insufficient Funds (NSF)Fees: $0.00
Other Fees: $0.00
Advances: $50.00
Amount Held in Suspense: $297.80
TOTAL AMOUNT PAST DUE: $6,005.32
HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS
$6,005.32,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY(30)-DAY PERIOD.Payments must be made b cash cashier's check certified
check or money order made savable and sent to:
Overnight/Regular Mail: Chase
Mail Code: OH4-7133
3415 Vision Drive
Columbus, OH 43219-6009
Certified Article#:9214 8901 0754 4636 1120 18
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30)
DAYS of the date of this Notice,the lender intends to exer icP itc r;aht
debt.This means that the entire outstanding balance of this debt will be considered due immediately and
you may lose the chance to pay the mortgage in monthly installments.If full payment of the total amount
past due is not made within THIRTY(30)DAYS,the lender also intends to instruct its attorneys to start
legal action to foreclose upon lour mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the
delinquency before the lender begins legal proceedings against you,you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to$ 0.00.However;if legal proceedings are
started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00.Any attorney's fees will be added to the amount you owe the lender,which
may also include other reasonable costs. If you cure the default within the THIRTY(30)-DAY period
no
You will t be required to pal attorney's fees
9THER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the
default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,_you still have the
riht to cure the default and prevent the sal at an time u to one hour before the heriff s ale.You
may do sob a in the total amount then past dueplus anv late or other char es then due reasonable
attorne 's fees and costs connected with the foreclosure sale and anv other costs connected with the
Sheriff's Sale asspecified in writingby the lender and b performinganv other re uirements under the
mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6)
months from the date of this Notice.A notice of the actual date of the Sheriff s Sale will be sent to you
before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You
may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Chase
Address: Mail Code: OH4-7384
P.O.Box 41275
Jacksonville,FL 32203-1275
Telephone Number: 800-848-9380
Fax Number: 614-500-4605
Contact Person: Bruno Mejia
E-mail Address: state.programs.intake@jpmchase.com
EFFECT OF CHERIFF'S SALE --You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the
lender at any time.
ASSUMPTION OF MORT AGE--You X may or may not sell or transfer your home to a
buyer or transferee who will assume the mortgage debt,provided that all the outstanding
charges,and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
Certified Article#:9214 8901 0754 4636 1120 18
008259-4 of 5 NSPOHDLA-CA J 1141672 0000000
YOU MAY ALSO HAVE THE RIGHT:
0 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Certified Article#:9214 8901 0754 4636 1120 18
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY PHONE
ADDRESS CITY ZIP CODE
Advantage Credit Counseling 888-511-2227
Service/CCCS of Western PA 2000 Linglestown Road Harrisburg 17102
Community Action Commission of 717-232-9757
Ca ital Re ion 1514 Derry Street Harrisburg 17104
Housing Alliance of York/Y Housing 717-855-2752 290 West Market Street
Resources York
Maranatha 717-762-328517401
Pennsylvania Interfaith Community43 Philadel hia Avenue Wa nesboro 17268
Pro rams Inc. 717-3341518 40 E.High Street
Gettysburg 17325
PHFA 717-780-3940
211 North Front Street
800-342-2397 (Harrisburg 17110
Certified Article#:9214 8901 0754 4636 1120 18
008259-5 of 5 NSPOHDLA-CA J1141672 0000000
If you are represented by an attorney,please refer this letter to your attorney and provide us with
the attorney's name,address,and telephone number.
To the extent your original obligation was discharged,or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or
informational purposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation.However,a secured party retains rights under its security
instrument,including the right to foreclose its lien.
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service,you may be eligible for benefits and
Protections under the federal Servicemembers Civil Relief Act(SCRA).This includes protection from
foreclosure or eviction.You may also be eligible for benefits and protections under state law. SCRA and
state Military benefits and protections also may be available if you are the dependent of an eligible
Servicemember.
Eligible service may include:
• Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or
• Active service as a commissioned officer of the National Oceanic and Atmospheric
Administration,or
• Active service as a commissioned officer of the Public Health Service,or
• Service with the forces of a nation with which the United States is allied in a war or Military
action, or
• Service with the National Guard of a state militia under a state call of duty, or
• Any period when you are absent from duty because of sickness,wounds,leave,or other lawful
cause.
For more information,please call Chase Military Services at 877-469-0110.
AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS
As stated in the"Questions and Answers for Borrowers about the Homeowner Affordability and Stability
Plan"distributed by the Obama Administration, "Borrowers should beware of any organization that
attempts to charge a fee for housing counseling or modification of a delinquent loan,especially if they
require a fee in advance."Loan modification scams should be reported to PreventLoan Scam s.org,or by
calling 888-995-HOPE; 888-995-4673.We offer loan modification assistance free of charge (i.e.,no
modification fee required). Please call us immediately at 866-550-5705to discuss your options. The
longer you delay,the fewer options you may have.
BW860
i
Certified Article#:9214 8901 0754 4636 1120 18
P.O.Box 183205
Columbus,OH 43218 USPS CERTIFIED MAIL TM
For Undeliverable Mail Only
9214 8901 0754 4636 1120 01
008257-1 of 5 NSPOHDLA-CA J1141672 0000000
NICOLLE L DELP
107 KIM ACRES DR.
MECHANICSBURG PA 17055
Chase(OH4-7399) CHASE !i
P.O.Box 183205
Columbus,OH 43218
For Undeliverable Mail Only
04/29/2014
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
NICOLLE L DELP
107 KIM ACRES DR.
MECHANICSBURG,PA 17055
Act 91 Notice
Account: ******8988 (the "Loan")
Property Address: 107 KIM ACRES DR.
MECHANICSBURG,PA 17055 (the "Property")
Dear NICOLLE L DELP:
On the following page,you will find a notice regarding your home as required by Pennsylvania law.
Certified Article#:9214 8901 0754 4636 1120 01
008257-2 of 5 NSPOHDLA-CA J1141672 0000000
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official Notice that the mort a e on your home is in default and the
lender intends to foreclose. S ecific information about the nature of the default is
provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
H( EMAP) may be able to help to save your home This Notice explains how the
programworks. To see if HEMAP can help�you must MEET WITH A
CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (33)
DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you
meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice If you have any Guest=
you may call the Pennsylvania Housing Finance Agency toll-free at 00-342-2397.
(kersons w. hearing can all 717-780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help
explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA
TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR
EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): NICOLLE L DELP
STEVEN G DELP
PROPERTY ADDRESS: 107 KIM ACRES DR.
MECHANICSBURG,PA 17055
LOAN ACCOUNT NUMBER: M988
ORIGINAL LENDER: WILMINGTON FINANCE,INC.
CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A.
Certified Article#:9214 8901 0754 4636 1120 01
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
NCE
YOU MAY BE ELIGIBLE FOR FINANCIAL ASI TANCE
HI CH CAN SAVE YOUR HOME FROM FORE LO�TTRE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983(THE "ACT"),YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE_
-Under the foreclosure on your mortgage for thirty (3 0)days from the dateco�fth s Not ceyou arettemporary stay of
led(plus three (3)days for
mailing).During that time,you must arrange and attend a"face-to-face"meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETIN
UUST
WIT [IN THIRTY-THREE Q 1 DAYS OF THE DATE OF THIS NOTICE.IF YOU DO NOT OCCUR
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU
UP TO DATE. TIS PART OMUST BRING YOUR MORTGAGEF THIS NOTICE CALLED "HOW TOCURE YOUR MORTGAGE
O
DEFAULT" EXPLAINS HW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit
counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty
(30)days after the date of this meeting. The names addresses and telephone numbers of designated
consumer credit coun elfin agencies for the countyin hich the r e is located are et forth at the
end of this Notice. It is only necessary to schedule one face-to-face meeting.Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGA E ASSISTANCE--Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default).
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so,you must fill out, sign,and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed at
the end of this Notice. Only consumer credit counseling agencies have applications for the program and
they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to
PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency.
YOUSHO ULD FILE HEMAPAPPLICATIONASSOONASPOSSIBLE. F YOUHAVEA
MEETING WITHA COUNSELINGAGENCY WITHIN THIRTRTHREE(I)DAYSOFT
H
E OFTHE
POSTMARKDATE OF THIS NOTICEAND FILEANApPLICATION WITH THE PHFA WITHIN
THIRTY(30)DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROMSTARTINGA FORECLOSUREACTIONAGAINST YOUR PROPERTY,AS
EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE."
YOU HAVE THERIGHT TO FILE HEMAPAPP ICATION E NBEYOND.T ESE T E
PE ODS.A LATEAppLICATION WILL NOT PREVENT THE LENDER FROMSTARTINGA
FORECLOSUREACTION,BUT IF YOURApPLICATIONIS EVENTUALLYApPROVED ATANY
TIME BEFORE A SHERIFFS SALE, THE FORECLOSURE WILL BE STOPPED.
Ceri ied Article#:9214 8901 0754 4636 1120 01
008257-3 of 5 NSPOHDLA-CA A 141672 0000000
AGENCY ACTION--Available funds for emergency mortgage assistance are very limited.They will
be disbursed by the Agency under the eligibility criteria established by the Act.The Pennsylvania
Housing Finance Agency has sixty(60)days to make a decision after it receives your application.During
that time,no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision
on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to
date).
NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located
at: 107 KIM ACRES DR. ,MECHANICSBURG,PA 17055 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
12/01/2013; $1,217.72
01/01/2014; $1,217.72
02/01/2014; $1,217.72
03/01/2014; $1,217.72
04/01/2014; $1,217.72
Other charges:
Late Charges: $164.52
Insufficient Funds(NSF)Fees: $0.00
Other Fees: $0.00
Advances: $50.00
Amount Held in Suspense: $297.80
TOTAL AMOUNT PAST DUE: $6,005.32
HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date
of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS
$6,005.32,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY(30)-DAY PERIOD.Payments must be made by cash cashier's check,certified
check or money order made payable and sent to:
Overnight/Regular Mail: Chase
Mail Code: OH4-7133
3415 Vision Drive
Columbus,OH 43219-6009
Certified Article C 9214 8901 0754 4636 1120 01
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30)
DAYS of the date of this Notice,the lender intends to exercise its rights to accelerate the mortgage
debt.This means that the entire outstanding balance of this debt will be considered due immediately and
you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount
past due is not made within THIRTY(30)DAYS,the lender also intends to instruct its attorneys to start
legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the
delinquency before the lender begins legal proceedings against you,you will still be required to pay the
reasonable attorney's fees that were actually incurred,up to $ 0.00.However,if legal proceedings are
started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which
may also include other reasonable costs. If you cure the default within the THIRTY (30)-DAY period,
you will not be required to gay attorney's fees.
OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the
default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.You
may do so by paying the total amount then past due plus any late or other charges then due,reasonable
attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the
Sheriff s Sale as specified in writing by the lender,and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately five to six (5 to 61
months from the date of this Notice.A notice of the actual date of the Sheriffs Sale will be sent to you
before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You
may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Chase
Address: Mail Code: OH4-7384
P.O.Box 41275
Jacksonville,FL 32203-1275
Telephone Number: 800-848-9380
Fax Number: 614-500-4605
Contact Person: Bruno Mejia
E-mail Address: state.programs.intake@jpmchase.com
EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff's Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the
lender at any time.
ASSUMPTION OF MORTGAGE--You X may or may not sell or transfer your home to a
buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments,
charges,and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the
mortgage are satisfied.
Certified Article#:9214 8901 0754 4636 1120 01 008257-4 of 5 NSPOHDLA-CA J 1141672 0000000
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Certified Article#:9214 8901 0754 4636 1120 01
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY PHONE ADDRESS CITY ZIP CODE
Advantage Credit Counseling 888-511-2227 2000 Linglestown Road Harrisburg 17102
Service/CCCS of Western PA
Community Action Commission of 717-232-9757 1514 Derry Street Harrisburg 17104
Capital Region
Housing Alliance of York/Y Housing 717-855-2752 290 West Market Street York
Resources 17401
Maranatha 1 717-762-3285 43 Philadelphia Avenue Waynesboro 1 17268
Pennsylvania Interfaith Community 717-334-1518 40 E.High Street Gettysburg 17325
Programs,Inc.
PHFA 717-780-3940 211 North Front Street Harrisburg 17110
800-342-2397
Certified Article#:9214 8901 0754 4636 1120 01 008257-5 of 5 NSPOHDLA-CA J1141672 0000000
If you are represented by an attorney,please refer this letter to your attorney and provide us with
the attorney's name,address,and telephone number.
To the extent your original obligation was discharged,or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code,this notice is for compliance and/or
informational purposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation.However,a secured party retains rights under its security
instrument,including the right to foreclose its lien.
IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS
If you are or recently were on active duty or active service,you may be eligible for benefits and
protections under the federal Servicemembers Civil Relief Act(SCRA).This includes protection from
foreclosure or eviction.You may also be eligible for benefits and protections under state law. SCRA and
state Military benefits and protections also may be available if you are the dependent of an eligible
Servicemember.
Eligible service may include:
• Active duty with the Army,Navy,Air Force,Marine Corps,or Coast Guard,or
• Active service as a commissioned officer of the National Oceanic and Atmospheric
Administration,or
• Active service as a commissioned officer of the Public Health Service,or
• Service with the forces of a nation with which the United States is allied in a war or Military
action,or
• Service with the National Guard of a state militia under a state call of duty,or
• Any period when you are absent from duty because of sickness,wounds,leave,or other lawful
cause.
For more information,please call Chase Military Services at 877469-0110.
AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS
As stated in the"Questions and Answers for Borrowers about the Homeowner Affordability and Stability
Plan"distributed by the Obama Administration, "Borrowers should beware of any organization that
attempts to charge a fee for housing counseling or modification of a delinquent loan,especially if they
require a fee in advance."Loan modification scams should be reported to 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.
BW860
Certified Article#:9214 8901 0754 4636 1120 01
Eyhibit
*Exhibit has been redacted to remove allpersonally identifiable information or non-public information
o
RSC
RDER f DEED
' 14
Record&Return TO:
Optimal Asset,LLC
500 Professional Centex'Dr.
Suite#525
Novato,CA 94947 DEPT.
(800)645.0683
']Chis document pmpated by
1IANOVER CAPrrAL MTNM Ltd•
Trar.Idng# Traeldng#20
FA
A58XW14IENT OF MORTGAGE
Know that EIEC MORTGAGE COV"RAIJON, a Delaware corporation with a business address of
2790 ],.sire Vista Drive, L awisvft, TX 75067, "ANIVor", for value received and other' good And vshmblc
consideration paid by LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR
C)iilER'li lFlCATEHOLjD9U OF MAR STEARNS ASSET BACKED SiECURIMS X LLC ASSET BACKED
CERTWiCA,TES,SERM 21104.2,a makmai banking association,whose addrem is 2571 Buse]toad,tills Grove
Village, IL 6W07, -Ann see", the receipt and Rufickocy of which is hereby aclmowledged, the Assignor does
hereby gran#,bargain, sell,assign, transfier and convey unto the Assigam the following dcscn•bed MORTGAGE,
duly recorded in the office of reef property records in the County of CUMBERLAND, State of
PENNSYLVANIA,together with tbt h dobjednese or obligation described m said mstrumen t and the monies due
and to grow due dwoon with the interest,as follows:
SEE EXHIBIT"A"
To have and to hold the same unto the Assignee,and to the successors,legal representatives and assigns of
the Assignee forever.
This Amigntnent is trade without recourse to Assignor and without representation or warranty by Assurer,
express or implied
IN WITNESS*7MOF,the Assignor has hereunto set its hand this 25th day of January,2006,but
effective this 30th day of Septamber.2404.
Ing P a of EMC MORTGAGE CO RATION
B �•^�
Witness 1:Sam To Weeks
I Vice President
Witness 2:Sandy Trig-
'•�,'-�� :�t..P•.,•.G� �F lit
�'���JQfS9QV�V
- •-�- •• CUMBERLAND COUNTY Inst,#200721850-Page 1 of
A 1
The undersigned hereby cefifics that the precise Addmas of Assignee is:
LASALLE BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTMCATEHOL')E S OP'BEAR
S MARNS ASSET]BACKED SECURITIES I LLC ASSET BACKED CERTTFICATI`s,4,SEREESS 2004.2
a national baWft association
2571 Busse Road
Fik Grove VMago,IL 60007
Sy,
$mut Young
State of 'TEXAS )
Be
Caaaty of OEN'TON )
The undersigned, a notary public in and for above-said County and State, does hereby acknowledge that Jraan
Weeks, Vice Presidimt for EMC MORTGAGE CORPORAMT4 Pers NLUY appeared before me this day,and
being by me duty sworn, says that Ae, being informed of the contra s, vahmtar►7y executed the foregoing and
annexed instnment for and on behalf of such catity.
Wl WESS my hand and official seal,tbis 25th day of January,2006.
4
-,r Public:M (7t3ojrd
My Comrrumon,Expires: 11/27/08 an LOU A"
(awft"Oft�lP t.aftflaw
This docuiveut was prepared by Maureen D,Bradley,Hanover Capital Partuars Ltd.
Past Owe BOX 3980,Edison,N7 08818-3980 Phone:(732)393-3033 Flax:(732)572-3959
[Tracking#1:OM051697 Tracking 02:CW20/BS11 FA
GO73S.PG008 .1
-— f:UMBERLAND COUNTY InstA 200721850-Page 2 of
STs.PA AUNTY:CUIVIEIrItLAND
EXHBIT "A"
TraddnL#l_•8003051687 IrAdJU 02:CV40MI71
MORTGAGORM-UST-M STEVEN G.DELI'A"NICOLLE L.DELP,HIS WM
MORfGA E)=1BENEFICAItY: WILMINGTON FINANCE,INC.
DAOFMORTGtAt3EDYAD OF MM : 07/26M2 AMOUNT:S112,S00.00
RECOB.UED:
OATS yQL18 FAGFJFf)LIO Certify this to he rccordcd
09/13/02 1773 o2Qs In. Cumberland County PA
0
6
Recorder of keds
PRPP 'TY MI,i I 107 IGM ACRES DANE,MECHANICSBURG,PA 17055
Township of
AJ:I.THAT C7,si7AIN list 4f grognd sihtute In tha Towntbip of Urpec Allen,emnty VrL%u:lti,rrtond
had State of Ptnn.vivotau,b011WO rod damribed•a 1411011..to vritr
OC,,01NMNO sit a Point In thr svu:harn line vtk public toted!wnttrn of Xinh Aerea>ytiva(5d feet
vlde}.wlbeh point I:s In tl,a 3itIM11M Ung betwash LeW 10 and i t vtt the bvainolw"Nnu4ned
Plats of L+ot$;t3 ftm eJW11 dtt dlvietort line bnewaen Lege 10 eaten 11.Sculls I I dedtoes 30
grdtsute►Bast.a ditrUusce of I'S feet to a pWnt In the datfsdate tins between 240th 11 old 19 on
d tees 00 a nutty at+ f,a divIsIon an*dla".anae ergo feet Io a Pelnt In Ow 9divi�on line eraeen;,ots 1 j Mid
10:tholtee*1900 t-%s Own*,:tor!h t i depecs 30 MIftutes Neat;w disdance of 14S$bet to a Point
in the southern Pete of Kim Act"Peive,oArctndntl4nu4,.1lvcm&slog#gW southern 31ne of zm
Aeren Drive.Omit 70 0.1"Ums 30 tainuin Wrst,a diOunee of 90 Met to a p►�fpt in fife diytaioq
llne lfetnrtr+t Lots it)w,wd 11,a1o,e�pnt3anad,at the,tenet of 14COTNN010.
021SdO Lai No. t i m n etut do Pion o1 Lou known es Mt.Altus skjaWx(fotmerb kr A"es
S�9 Run AMB),blllith agtd Plan In reeordedl in th4 curgLcr9snd Gaurha.Aleeerda s Offk#In
Plan Book 18,t`ago 14.
RAL'S O TJIERRoN 8Ri[Ctgn u bdok,stewc ertl o umim&m!dung dwelikil domes with integmi
Range known and numbeyed ns 107 Xim luras DVM MeclhmdA sbutL Pufmisfvanis.
OK0738PGO082
CUMBERLAND COUNTY lasts 200721850-Paga 3 of
Ey, hibit (17
*Exhibit has been redacted to remove all personally identifiable information or non public information
Y
I
4
LOAN MODIFICATION AGREEMENT
THIS LOAN IS PAYABLE IN PULL AT MATURITY. YOU MUST REPAY THE ENTIRE PRINCIPAL
BALANCE Or THE LOAN AND UNPAID INTEREST THEN DUE LENDER IS UNDER NO
OBLIGATIPAON TO REFINANCE THE LOAN AT THAT TIME YOU WILL,THERE,FORE BE
TO MAKE ENT OUT OF OTHER ASSETS THAT YOU MAY OWN, OR YOU WILL�AAVTO END
A LENDER, WHICH MAY BE THE LENDER YOU HAVE THIS LOAN WITH,WILLING TO LEND YOU
ALL THE'pMONEY. IF YOU REFINANCE' THIS LOAN AT MATURITY, YOU MAY HAVE TO PAY SOME OR
THE CLOSING COSTS NORMALLY ASSOCIATED WITH A NEW LOA
REFINANCING FROM THE SAME LENDER N EVEN II'YOU OBTAIN
Borrower ("I")1: STEVEN DELP
Lender ("Lender"): EMC Mortgage Corporation ("EMC'), as servicer for Bank of America National
Association as successor by merger to LaSalle Bank National Association as Trustee for certificateholders
of Bear Stearns Asset Backed Securities I LLC Asset Backed Certificates, Series 2004-2 Mortgagee
("Mortgagee")
Date of First Lien Security Instrument ("Mortgage') and Note ("Note"): July 26, 2002, in the amount of
$112,500.00
Loan Number: 3051687 ("Loan")
Property Address: 107 KIM ACRES DR, MECHANICSBURG, PENNSYLVANIA 17055 ("Property")
1 If there is more than one Borrower or Mortgagor executing this document, each Is referred to as "I". For purposes of this
LOAN MODIFICATION AGREEMENT
document words signifying the singular (such as'll shall include the plural (such as"weq and vice versa where appropriate.
WF101
E�II�Iilllll111lIIIIIIIIIIIIIIIIIflllllllllllll (Page 7 of s Pages)
IIIII IIlI1�lII Ilil II I Illi IIIII III I I LII IIIII IIIA
LN%0003051687+DW01786+EMWORKMD �IlIIIEIIlIllllllllllllllllllllflli�lllll
IIIIIIIIiII
e t
`Loan No:_ _
If my representations in Section 1 continue to be true in all material respects then the provisions of Section
ID:
860
2 of this Loan Modification Agreement ("Agreement")will, as set forth in Section 2,amend and supplement
(1) the Mortgage on the Property, dated Jul 26 2
Note secured by the Mortgage. The Mortgage and Note together, as may previously have been amend ni
Y 002 in the original amount of$112,500.00, and (2) the
are referred to as the "Loan Documents". Capitalized terms used tri this Agreement have the meaning
to them in the Loan Documents. ed,
given
I have provided confirmation of my financial hardship and documents to permit verification of all o
income to determine whether I qualify for the offer described in this Agreement. This Agreement twill
take effect unless and until the Lender signs it. f my
1 not
1 My Representations. I represent to Lender and agree:
A. I am experiencing a financial hardship, and as a result, am either in default under the Loan
Documents or a default is imminent;
B. The Property I live in is neither in a state of disrepair, nor condemned;
G There has been no change in the ownership of the Property since I signed the Loan Documents-
D. I am not a party to any litigation involving the Loan Documents, except to the extent I ma be'a
defendant in a foreclosure action;
E. I have provided documentation for all income that I earn; and Y
F. All documents and information I provide pursuant to this Agreement are true and correct.
2. The Modification. The Loan Documents are hereby modified as of May 11, 2010 (the "Modification
Effective Date") and all unpaid late charges are waived.
activities so long as I comply with the terms of the Loan Documents, as modified by this Agreement
The Loan Documents will a modified, and the first modified epaymentnwder grees to cease any foreclosure
in this Section 2: ill be due on the date set forth
A. The Maturity Date will be: August 1, 2034.
B. The modified principal balance of my Note will include all amounts and arrearages that will beast
due (excluding unpaid late charges), and may include amounts toward taxes insurance or other
assessments. The new principal balance of my Note is $131,629.18 (the "New Principal Balance").
C. The New Principal Balance will re-amortize over 480 months to a remaining scheduled balance on
the Maturity Date of $95,906.17 (the "Balloon Payment"), which is Dart of the New principal
Balance. The Balloon Payment will be repaid in accordance with Section D.
Interest will begin to accrue as of May 1, 2010. The first new monthly a
Principal Balance will be due on June 1, 2010, and monthly on the same day the eent afto the New
MY payment schedule for the modified loan is as follows:
LOAN MODIFtCAT[ON AGREEMENT
WF101
(Page 2 of 6 Pages)
Loan No: Data ID: 860
TEMPORARY INTEREST ONLY PERIOD I promise to pay monthly payments according to the
following schedule with respect to the New Principal Balance:
Years Interest Interest Monthly Monthly Payment Number of
Rate Rate Interest Principal Begins On Monthly
Change Only and Payments
Date Payment Interest
Amount Payment
Amount
1-10 7.500 05/01/10 $822.69 N/A 06/01/10 120
111-2517.500 05/01/20 NIA $920.37 06/01/20 171
ONCE THE INTEREST ONLY PERIOD EXPIRES, BORROWER WILL MAKE MONTHLY
PAYMENTS OF PRINCIPAL AND INTEREST AS INDICATED ABOVE FOR THE SPECIFIED
TIME PERIODS. BEGINNING June 1,2020,THE MONTHLY PAYMENT WILL BE A FULLY
AMORTIZED PRINCIPAL AND INTEREST PAYMENT. Whenever the monthly payment
amount changes, Lender will notify Borrower of the new payment amount prior to the date it first
becomes due.
The above terms in this Section 2.0 shall supersede any provisions to the contrary in the Loan
Documents, including but not limited to provisions for an adjustable or step interest rate.
D. I agree to pay in full any other amounts still owed under the Loan Documents, including the
Balloon Payment, as identified within this Agreement by the earliest of the date I sell or transfer
an interest in the Property, subject to Section 3.E below, the date I pay the entire New Principal
Balance, or the Matunty Date.
E I will be in default if I do not (i) pay the full amount of a monthly payment on the date it is due,
or (ii) comply with the terms opp the Loan Documents as modified by this Agreement. If a default
rate of interest is permitted under the current Loan bocuments, then in the event of default, the
interest that will be due on the New Principal Balance will be the rate set forth in Section 2.C.
LOAN MODIFICATION AGREEMENT WF101
(Page 3 of 6 Pages)
Loan No:
Data ID: 860
3. Additional Agreements. I agree to the following:
A. That this Agreement shall supersede the terms of any modification, forbearance or workout plan,
if any, that I previously entered into with Lender.
B. To comply, except to the extent that they are modified by this Agreement, with all covenants,
agreements, and requirements of Loan Documents including my agreement to make all payments
of taxes, insurance premiums, assessments, impounds, and all other payments, the amount of which
may change periodically over the term of my Loan. This Agreement does not waive future escrow
requirements. If the Loan includes collection for tax and insurance premiums, this collection will
continue for the life of the Loan.
C. That the Loan Documents are composed of valid, binding agreements, enforceable in accordance
with their terms are hereby reaffirmed.
D. That all terms and provisions of the Loan Documents, except as expressly modified by this
,Agreement, remain in full force and effect; nothing in this Agreement shall be understood or
construed to be a satisfaction or release in whole or in part of the obligations contained in the Loan
Documents; and that except as otherwise specifically provided in, and as expressly modified by, this
Agreement,the Lender and I will be bound by,and will comply with,all of the terms and provisions
of the Loan Documents.
E. That, as of the Modification Effective Date, notwithstanding any other provision of the Loan
Documents, I agree as follows: If all or any part of the Property or any interest in it is sold or
transferred without Lender's prior written consent, Lender may, at its option, require immediate
payment in full of all sums secured by the Mortgage. However, the Lender shall not exercise this
option if federal law prohibits the exercise of such option as of the date of such sale or transfer.
If Lender exercises this option,Lender shall give me notice of acceleration. The notice shall provide
a period of not less than thirty (30) days from the date the notice is delivered or mailed within
which I must pay all sums secured by the Mortgage. If I fail to pay these sums prior to the
expiration of this period, Lender may invoke any remedies permitted by the Mortgage without
further notice or demand on me.
F. That, as of the Modification Effective Date; a buyer or transferee of the Property will not be
permitted, under any circumstance, to assume the Loan. In any event, this Agreement may not be
assigned to, or assumed by, a buyer of the Property.
LOAN MODIFICATION AGREEMENT WF101
(Page 4 of 6 Pages)
i 1
• r
1 ,
Loan No:
Data ID: 860
G. If any document is lost,misplaced,misstated,'or inaccurately reflects the true and correct terms and
conditions of the Loan Documents as amended by this Agreement, within ten (10) days after my
receipt of the Lender's request, I will execute, acknowledge, initial, and deliver to the Lender any
documentation the Lender deems necessary to replace or correct the lost, misplaced, misstated or
inaccurate document(s). If I fail to do so,I will be Iiable for any and all loss or damage which the
Lender reasonably sustains as a result of my failure.
H. All payment amounts specified in this Agreement assume that payments will be made as scheduled.
I. If the Borrower(s) received a discharge in a Chapter 7 bankruptcy subsequent to the execution of
the Loan Documents, the Lender agrees that such Borrower(s) will not have personal liability on
the debt pursuant to this Agreement.
Lender has relied upon the truth and accuracy of all of the representatioJ. That in agreeing to the changes to the original Loan Documents as reflected in this Ans made by the Borrowers},
greement,the
both in this Agreement and in any documentation provided by or on behalf of the Borrower(s) in
connection with this Agreement. If the Lender subsequently determines that such representations
or documentation were not truthful or accurate, the Lender may, s its option, rescind this
occurred.
Agreement and reinstate the original terms of the Loan Documents as if this Agreement never
THIS WRITTEN LOAN AGREEMENT REPRESENTS THE FINAL AGREEMENT BETWEEN THE
PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR
SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL
AGREEMENTS BETWEEN THE PARTIES.
LOAN MODIFICATION AGREEMENT
WF101
(Page 5 of 6 Pages)
Loan No:
Data ID: 860
In Witness Whereof, the Lender and I have executed this Agreement.
Date:
STEVEN DELP—Borrower
I '
Lender:EMC MORTGAGE CORPORATION, as servicer for Bank
of America National Association as successor by merger to
LaSalle Bank National sociation as Trustee for
certificateholders of Bea ams set Backed Securities I LLC
Asset Backed Certi tes, Se ' 2004..
Its: VICI~PRESIDENT
(Title)
LOAN MODIFICATION AGREEMENT
WFi 01
(Page 6 of 6 Pages)
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF1U TF St,ZRIFF
�
HjPROTHO,4O r{ ti
2014 OCT 21 PM 3: 11
CUMBERLAND
U.S. Bank National Association
vs.
Steven G Delp (et al.)
Case Number
2014-6001
SHERIFF'S RETURN OF SERVICE
10/20/2014 04:15 PM - Deputy Shawn Gutshall, 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 Brody Delp, Son 19Yrs Old, who accepted as
"Adult Person in Charge".for Steven G Delp at 107 Kim Acres Drive, Upper Allen, Mechanicsburg, PA
17055.
GUTSHALL, DEPUTY
10/20/2014 04:15 PM - Deputy Shawn Gutshall, 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 Brody Delp, Son 19Yrs Old, who accepted as
"Adult Person in Charge" for Nicolle L Delp at 107 Kim Acres Drive, Upper Allen, Mechanicsburg, PA
17055.
GUTSHALL, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
I
October 22, 2014 RONNR ANDERSON, SHERIFF
ici CountySuito Sheriff: "ieleosoft, i1c.
tit
In the Court of Common Pleas of Cumberland County
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN
INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES 1 LLC ASSET BACKED
CERTIFICATES, SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
STEVEN G. DELP
NICOLLE L. DELP
(Mortgagor(s) and Record Owner(s))
107 Kim Acres Drive
Mechanicsburg, PA 17055
Plaintiff
Defendant(s)
C) ry
No. 14-6001 to CZ:,
rr1r' C—
m w, r'
.)L
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT. -
Enter the Judgment in favor of Plaintiff and against STEVEN G. DELP and NICOLLE L. DELP by default for
want of an Answer.
Assess damages as follows:
$144,729.40
Debt
Interest from 8/1/2014 to
Date of Sale per diem at $27.05
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mail
is to be entered and to his attorney of record, if any, after the default oc
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
By:
delivered to the party against whom judgment
d at least ten days prior to the date of the
KML W r• ROUP, P.C.
_Mich. -1 Mc Weever Pa. ID 56129
_Jay E. Pa. ID 26769
=Lisa Lee 'a. ID 78020
_Kristina Murtha Pa. ID 61858
_David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua L Goldman Pa. 205047
_Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
_Salvatore Filippello Pa. ID 313897
_Alyk L. Oflazian Pa. ID 312912
_Jennifer Lynn Frechie Pa ID 316160
Attorneys for Plaintiff
$11D.50 l'-113 ATTr
C
risco 055
{? 3t5g3q
\dice nailed
pL vitt-G'ist. Vv C1NQA7
ectSb 617 —/
AND NOW 15+4 CONiah , 215 , Judgment is entered in favor of U.S.
BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OFAR STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES, SERIES 2004-2 and against STEVEN G.QELP and NICOLLE L. DELP by
default for want of an Answer and damages assessed in the sum of $144,729.40 as perhe ab •''Y erti
131409FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
STEVEN G. DELP
DELP, STEVEN G.
107 Kim Acres Drive
Mechanicsburg, PA 17055
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN
INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED
CERTIFICATES, SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219 Plaintiff
vs.
STEVEN G. DELP
NICOLLE L DELP
(Mortgagor(s) and Record Owner(s))
107 Kirn Acres Drive
Mechanicsburg, PA 17055
Defendant(s)
TO: STEVEN G. DELP
107 Kim Acres Drive
Mechanicsburg, PA 17055
DATE OF THIS NOTICE: December 29, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14-6001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACI' WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
\ ft-Ike/6)41)i
By:
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. IID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
. Jennifer Lynn Freebie Pa ID 316160
V Cristina Lynn Connor Pa. ID 318389
Victoria Chen Pa. ID 317741
215-627-1322
Attorneys for Plaintiff
131409 FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
NICOLLE L. DELP
DELP, NICOLLE L.
107 Kim Acres Drive
Mechanicsburg, PA 17055
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN
INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED
CERTIFICATES, SERIES 2004-2 -
c/o 3415 Vision Drive
Columbus, OH 43219 Plainaf
vs.
STEVEN G. DELP
NICOLLE L. DELP
(Mortgagor(s) and Record Owner(s))
107 Kim Acres Drive
Mechanicsburg, PA 17055
Defendants)
TO: NICOLLE L. DELP
107 Kim Acres Drive
Mechanicsburg, PA 17055
DATE OF THIS NOTICE: December 29, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14-6001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
/Jennifer Lynn Freebie Pa ID 316160
Cristina Lynn Connor Pa. ID 318389
Victoria Chen Pa. ID 317741
215-627-1322
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN
INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED
CERTIFICATES, SERIES 2004-2
Plaintiff
vs.
STEVEN G. DELP
NICOLLE L. DELP
Defendant(s)
NO. 14-6001.
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
- RELIEF ACT AS AMENDED
1: The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do)
for the following individual(s): STEVEN G. DELP, has a last known residence of 107 Kim Acres Drive,
Mechanicsburg, PA 17055. The following information was used to search the DMDC (check all that
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the sta : - - n s ' _ ,ein are made subject to penalties of 18 Pa.
C.S.A. 4904 relating to unsworn falsification t
Date 1 i By:
KML OUP, P.C.
cKeever Pa. ID 56129
Lisa - - Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Jill. P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Vristina Lynn Connor Pa. ID 318389
ictoria W. Chen Pa. ID 317741
Attorneys for Plaintiff
Department of Defense Manpower Data Center
Status deport
Pursuant to Servicernernbers Civil. Relief Act
Last Name: DELP
First Name: STEVEN
Middle Name: G.
Active Duty Status As Of: Jan -13-2015
Results as of : Jan -13-2015 12:40:03 PM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA -
No'
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Das of Active Duty Status Date
Da
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA - -
No ."
NA
This response
reflects where the individual left active duty status within 367 days precedirio 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, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
rh.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
'The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: S1I8D17EQ1C1UCO
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN
INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED
CERTIFICATES, SERIES 2004-2
Plaintiff
vs.
STEVEN G. DELP
NICOLLE L. DELP
Defendant(s)
NO. 14-6001
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center (`"MDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do)
for the following individual(s): NICOLLE L. DELP, has a last known residence of 107 Kim Acres Drive,
Mechanicsburg, PA 17055. The following information was used to search the DMDC (check all that
apply) : -
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statemen - e -n are made subject to penalties of 18 Pa.
C.S.A. 4904 relating to unsworn falsification to aut
Date
By:
oriti
KML LAW e',' OUP, P.C.
Micha: cKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
,Cristina Lynn Connor Pa. ID 318389
/Victoria W. Chen Pa. ID 317741
Attorneys for Plaintiff
' Department of Defense Manpower Data Center
Status Report
Pursuant to Servicenernbers Civil Relief Act
Last Name: DELP
First Name: NICOLLE
Middle Name: L
Active Duty Status As Of: Jan -13-2015
Results as of : Jan -13-2015 08:10:16 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA ,
No .
NA
• This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date -
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects where the individual 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 G 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, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (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: U1A2SEADK100XDO
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL
ASSOCIATION AS TRUSTEE, SUCCESSOR BY MERGER TO
LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR -
CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED
SECURITIES I LLC ASSET BACKED CERTIFICATES, SERIES
2004-2
c/o 3415 Vision Drive
Columbus, OH 43219 -
vs.
STEVEN G. DELP
NICOLLE L. DELP
(Mortgagor(s) and Record owner(s))
107 Kim Acres Drive
Mechanicsburg, PA 17055
Plaintiff
Defendant(s)
ORDER FOR JUDGMENT
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-6001
Please enter Judgment in favor of U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF
AMERICA, NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY MERGER 5 - LE BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKE ► SECURIT S I LLC ASSET BACKED CERTIFICATES, SERIES
2004-2, and against STEVEN G. DELP and NICOLLE L. DELP for failure to file . Answer i` a ab e action within (20) days from the date of service
of the Complaint, in the sum of $144,729.40.
By:
UP, P.C.
cKeever Pa. ID 56129
vitz Pa. ID 26769
L..
Pa. ID 78020
_Kris na Murtha Pa. ID 61858
_David Fein Pa. ID 82628
_Thomas Puleo Pa. 11) 27615
_Joshua I. Goldman Pa. 205047
_Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
_Salvatore Filippello Pa. ID 313897
_Alyk L. Oflazian Pa. ID 312912
_Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
Vic a- V\l,CANsiry
I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is U.S. BANK NATIONAL
ASSOCIATION, AS TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR
BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET
BACKED SECURITIES I LLC ASSET BACKED CERTIFICATES, SERIES 2004-2 t c s Drive Columbus, OH 43219 and that the name(s) and
last known address(es) of the Defendant(s) is/are STEVEN G. DELP, 107 Kim Acres rive Mec . ics • urg, PA 17055 and NICOLLE L. DELP, 107 Kim
Acres Drive Mechanicsburg, PA 17055;
By:
KML L r" ROUP, P.C.
Mi • ael cKeever Pa. ID 56129
7. E. itz Pa. ID 26769
Ia
Pa. ID78020
_Kristina Murtha Pa. ID 61858
_David Fein Pa. ID 82628
_Thomas Puleo Pa. ID 27615
_Joshua L Goldman Pa. 205047
_Jill P. Jenkins Pa. ID 306588
_Andrew F. Gomall Pa. ID 92382
_Salvatore Filippello Pa. ID 313897
_Alyk L. Oflazian Pa. ID 312912
_Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
\k 1 JiQ W •C nan
(23 ( . 3 V1'T 1/41.1
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 11/01/2013 through
07/31/2014
Reasonable Attorney's Fee
Late Charges
Escrow Advance
Suspense Balance
Bv:
$131,628.85
$7,404.1.2
$1,650.00
$164.52
$4,179.71
($297.80)
KM . A GROUP, P.C.
Mi ael cKeever Pa. ID 56129
Ja E. itz Pa. ID 26769
Lisa e Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Salvatore Filippello Pa. ID 313897
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
AND NOW, this /514 day of Jan. , 20115 damages are assessed as above.
14-6001/131409FC
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR
BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE
HOLDERS OF BEAR STEARNS ASSET BACKED
SECURITIES I LLC ASSET BACKED CER IIFICATES,
SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219
STEVEN G. DELP
NICOLLE L. DELP
Mortgagor(s) and Record Owner(s)
107 Kim Acres Drive •
Mechanicsburg, PA 17055
vs.
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-6001
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
4a8.5o Po Aici
3a 3o c$r
1 I x.'75 1,4
110.50
Saco.05 - PA A'rr1
$a.a5 tCm
'SO LL.
18(oQ5
04 315 73L/
RE-orit-4suLact
Amount Due
Interest from 8/1/2014
to Date of Sale per diem
at $27.05
(Costs to be added)
By:
$144,729.40
KM r W GROUP, P.C.
Mi ' ae McKeever Pa. ID 56129
J. E 'vitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Salvatore Filippello Pa. ID 313897
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
\f i deo_ W • CA�ar\
ci>0.. kD 1-1 `f l
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
'SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL ASSOCIATION,
AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET
BACKED CERTIFICATES, SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219
STEVEN G. DELP
NICOLLE L. DELP
(Mortgagor(s) and Record Owner(s))
107 Kim Acres Drive
Mechanicsburg, PA 17055
vs.
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129
No. 14-6001
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF
AMERICA, NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK
NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED
SECURITIES I LLC ASSET BACKED CERTIFICATES, SERIES 2004-2, Plaintiff in the above action, by counsel, KML
Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information
concerning the real property located at:
107 Kim Acres Drive
Mechanicsburg, PA 17055
1.Name and address of Owner(s) or Reputed Owner(s):
STEVEN G. DELP
1.07 Kim Acres Drive
Mechanicsburg, PA 17055
NICOLLE L. DELP
107 Kim Acres Drive r-- -7�• ;_--
Mechanicsburg,
_Mechanicsburg, PA 17055 r ?> crl L
CD
,
2. Name and address of Defendant(s) in the judgment: r rx�
CI -r..
STEVEN G. DELP �� ' r
107 Kim Acres Drive --a = '
Mechanicsburg, PA 17055
NICOLLE L. DELP
107 Kim Acres Drive
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
107 Kim Acres Drive
Mechanicsburg, PA 17055
I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: '1 [ 3 (-
By:
GROUP, P.C.
McKeever Pa. ID 56129
JaKivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Salvatore Filippello Pa. ID 313897
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
1J, crerttc . W .CJJen
Qa i l7 ri-14 1
•r
KML Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
14-6001
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL ASSOCIATION,
AS TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET
BACKED CERTIFICATES, SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
STEVEN G. DELP
NICOLLE L. DELP
Mortgagor(s) and Record Owner(s)
107 Kim Acres Drive
Mechanicsburg, PA 17055
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Docket No. 14-6001
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: DELP, STEVEN G.
STEVEN G. DELP
107 Kim Acres Drive
Mechanicsburg, PA 17055
Your house at 107 Kim Acres Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs
Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $144,729.40 obtained by U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES, SERIES 2004-2 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:
14-6001
1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE, SUCCESSOR IN IN I'EREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES, SERIES 2004-2, the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-
866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of Cumberland County at 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
- 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
14-6001
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
131409FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
14-6001
KML Law Group, P.C. .
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
SUCCESSOR IN INTEREST TO BANK OF AMERICA,
NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL ASSOCIATION,
AS TRUSTEE FOR CERI'1FICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I LLC ASSET
BACKED CERTIFICATES, SERIES 2004-2
do 3415 Vision Drive
Columbus, OH 43219
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Docket No. 14-6001
STEVEN G. DELP c=3
NICOLLE L. DELP
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Mortgagor(s) and Record Owner(s) rrt
107 Kim Acres Drive to i'• ;` r
Mechanicsburg, PA 17055
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Defendant(s) a> C' `
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THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO < <=)
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: DELP, NICOLLE L.
NICOLLE L. DELP
107 Kim Acres Drive
Mechanicsburg, PA 17055
Your house at 107 Kim Acres Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs
Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $144,729.40 obtained by U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES, SERIES 2004-2 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:
14-6001
1. The sale will be cancelled if you pay to U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION AS
TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CERTIFICATE HOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES 1
LLC ASSET BACKED CERTIFICATES, SERIES 2004-2, the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-
866-413-2311. -
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of Cumberland County at 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
14-6001
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
-FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
131409FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
KML Law Group, P.C.
Suite 5000 – BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE,
SUCCESSOR IN INTEREST TO BANK OF AMERICA,
- NATIONAL ASSOCIATION AS TRUSTEE, SUCCESSOR
BY MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR CERTIFICATE
HOLDERS OF BEAR STEARNS ASSET BACKED _
SECURITIES I LLC ASSET BACKED CERTIFICATES,
SERIES 2004-2
c/o 3415 Vision Drive
Columbus, OH 43219
vs.
STEVEN G. DELP
NICOLLE L. DELP
Mortgagor(s) and Record Owner(s)
107 Kim Acres Drive
Mechanicsburg, PA 17055
Plaintiff
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff, by counsel, hereby certifies that it has complied
property in question is not subject to the Act.
By:
NO. 14-6a01rri
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ovisions of Act 91 of 1983 and/or the real
GROUP, P.C.
M chael cKeever Pa. ID 56129
Jay vitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Salvatore Filippello Pa. ID 313897
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
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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
U.S. BANK NATIONAL ASSOCIATION,
as Trustee, Successor in interest to BANK OF AMERICA,
NATIONAL ASSOCIATION, as Trustee, Successor by
merger to LASALLE BANK NATIONAL ASSOCIATION,
as Trustee for Certificate Holders of BEAR STEARNS
ASSET-BACKED SECURITIES 1 LLC
ASSET-BACKED CERTIFICATES, SERIES 2004-2
Vs. NO 2014-06001 Civil Term
CIVIL ACTION — LAW
STEVEN G. DELP
NICOLLE L. DELP
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: $144,729.40 L.L.: $ .50
Interest from 8/1/14 to Date of Sale per diem @ $27.05
Atty's Comm:
Atty Paid: $200.05
Plaintiff Paid:
Date: 1/15/15
(Seal)
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary
REQUESTING PARTY:
Name: VICTORIA W. CHEN, ESQUIRE
Address: KML LAW GROUP, PC
SUITE 5000 - BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322