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Home My WebLink About05-5768 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 JPMorgan Chase Bank (f/k/a The Chase Manhattan Bank), as Trustee for the IMC Home Equity Loan Trust 1998-1 c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff vs. Robert E. Starr and Lisa D. Starr 308 Middle Road Newville, PA 17241 Defendants #17653-TM Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 06- jr00 ~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demandado a usted en 1a corte. 8i usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo a1 partir de la fecha de la demanda y 1a notlficacion. Haee falta a sentar una compareneia eserita 0 en persona 0 con un abogado y entregar a la corte en forma eserita sus defensas 0 sus objeciones a Jas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte tOffia ra medidas y puede continuar 1a demanda en contra suya sin previa aviso 0 notificacion. Ademas. la corte puede decidir a favor del demandante y requiere que usted curnpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para listed. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIA TAMENTE. SI NO TIENE ABOGADO V A Y A EN PERSONA 0 TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRA TAR A UN ABOGADO. SI USTED NO T1ENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO 0 GRA TUlTO. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PAl 7013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. ~1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE V ALIDI'IY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY .PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR-EFFORTS_(THIWVGII L1TIGA]'ION OR . OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU.' YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA S. VON ROSSNSTISL, P.C. Martha S. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SSCANS, PA 19018 (610) 328-2887 Attorney 10 # 52634 Attorney for Plaintiff JPMorgan Chase Bank (f/k/a The Chase Manhattan Bank), as Trustee for the IMC Home Squity Loan Trust 1998-1 c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff COURT OF COMMON PLSAS Cumberland COUNTY Case No: vs. Robert S. Starr and Lisa D. Starr 308 Middle Road Newville, PA 17241 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is JPMorgan Chase Bank (f/k/a The Chase Manhattan Bank), as Trustee for the IMC Home Squity Loan Trust 1998-1, a bank organized and existing under state law, with offices for the conduct of business at c/o Select Portfolio Servicing, Inc. 3815 South West Temple, Salt Lake City, Utah 84165. 2. Defendants, Robert S. Starr and Lisa D. Starr are the mortgagors and real owners of premises 308 Middle Road, Newville, PA 17241, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Alternative Mortgage Source, Inc. on September 11, 1997, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1405 Page 135, secured on premises 308 Middle Road, Newville, PA 17241 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the Plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 2005 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 5/16/05 to 11/1/05 At $36.50 per diem Accrued late charges to 11/1/05 Accrued Escrow deficit to 11/1/05 Attorney's fee Title Information Certificate $114,959.84 $ 6,205.00 $ 1,293.13 $ 360.59 $ 5,747.99 $ 475.00 Photostats and Postage Notarizations $ $ 50.00 10.00 TOTAL $129,101.55 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $129,101.55, plus per diem interest at $36.50 from November 2, 2005 to the date of judgment plus costs thereon. 4 ~artha E. Von Rosenstiel / Attorney for Plaintiff I , / {' VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024(c) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel I I ! LEGAL DESCRIPTION ALL THA T CERTAIN tract of land with the improvements thereon situate in UppeI Mifflin Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike in the center of Township Road T-402; thence by the dividing line between Lot Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, South 48 degrees 48 minutes 18 seconds West 521.54 feet to an iron pin; thence by the dividing line between Lot No. 13 and Lot Nos. 12 and 16 on said Plan of Lots, South 41 degrees II minutes 42 seconds East 200 feet to an iron pin; thence by the dividing line between Lot No, 13 and Lot Nos, 14 and 15 on said Plan of Lots, North 48 degrees 48 minutes 18 seconds East 521.54 feet to a railroad spike in the center of Township Road T-402 aforesaid; thence along the center line of said Road, North 41 degrees 11 minutes 42 seconds West 200 feet to the place of beginning. CONTAINING 2.3946 acres, BEING Lot No. 13 on the Subdivision Plan of Aaron S. Stoltzfus, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 32, Page 18, Tax Parcel #44-06-0037-055 TITLE TO SAID PREMISES IS VESTED IN Robert E, Starr and Lisa D. Starr, his wife as tenants by the entireties by Deed from Daniel A, Brinton and Sharon L. Brinton, his wife, dated 3/19/1991 and recorded 3/27/1991 in Deed Book A35, Page 272. EXHIBIT .....,.-' l SJ>SISELECT Port olio SEi[VICING, inc 7182 6389 3060 0518 4607 December 03,2004 ROBERT E STARR LISA D STARR 308 MIDDLE RD NEWVILLE, P A 17241 ,,, ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morte8l!e on your home is in default and the lender intends to foreclose. Snecific information about the nature of the default is nTovided in the attached D3!!es. The HOMEOWNER S MORTGAGE ASSISTANCE PROGRAM IHEMAP1 mav be able to helD to save vour home. This Notice exolains how the orOl!rarn works. To see if HEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice wlth vou when vou meet wlth the Counselinl! A!!encv. The name. address and nhone number of Consumer Credit Coun!'elin!! Aeencies servin!! your Countv are listed at the end orims Notice. [(vou have any Questions. vou may call the Pennsvlvania Housine Finance AQencv toll-free at (800) 342-2397. Per,.ns with imllaired hearln2 can call (717) 78<1-] 869. This Notice contains important legal information. If )'ou 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 la\\yer. LA NOTIFICAClON EN ADJUSTO ES DE SUMA I111PORTA.,"lCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVlENDO EN SU CASA. SI NO COPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL 1\1JMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROBRA1I1A LLAMADO HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowner'sName: Property Address: ROBERTE STARR, LISA D STARR 308 MIDDLE RD NEWVILLE P A 17241 3008855664 Loan Acct No.: Original Lender Current Lender / Scrvicer: Select Portfolio Servicing, Inc. Ef031.:lINCP_ r-Yl.!lPIT 1f t.ll,ot.,. . HOMEOWNER S EMERGENCY MORTGAGE ASSISTA"ICE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVlSIONS OF THE HOMEOWNER S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (TIlE ACT), YOU MAY BE ELIGffiLE 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, A'ID . IF YOU MEET OTHER ELIGffiII~ITY REQUIREMENTS ESTABLISHED BY THE PEl'iNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a face-te- face meeting \"lith one of the conSlll11er credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRlNG YOUR MORTGAGE UP TO DATE. THE PART OF TIDS NOTICE CALLED HOW TO CURE YOUR MORTGAGE DEFAULT EXPLAJNS 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 telenhone numbers of desiQIlated consumer credit coum;elinQ 3eencies for the county in which the mODertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICA nON 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). If you have tried and are unable to resolve this problem with the lender, 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. Your application MUST be filed or postmarked within thirty (30) days of your face-te-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY A1\1> YOUR APPLICATION FOR ~10RTGAGE ASSISTANCE WILL BE DENIED. AGE~CY ACTION Available funda 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 INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT (If yoo have filed bankruptcy you can still apply for Emergancy Mortgage Assi stance) LR064 EBOOOS/NCP/&-6l HOW TO CURE YOUR MORTGAGE DEFAULT (Brin. it np to date) NATURE OF THE DEFAULT: The MORTGAGE debt held by the above lender on your property located at: 308 MIDDLE RD NEWVILLE PA 17241 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amOlmts are now past due: Payment of $1.202.58 per month due from 08/16/2004 through 11/16/2004 payment (a total of 4 months) : (Mortgage payment includes Escrow Payment of $0.00 per month): Accrued Late Charges Non-Sufficient Funds (NSF) / Return Check Fees Escrow Advances for Hazard Insurance, Real Estate Taxes and/or Municipal Liens: Other Advances (Property Preservation) : Funds on Account: ** Total Amount Due: $ 4,BI0.32 $ 1,293.13 $ 0.00 $ 2,622.27 $ 0.00 $ 0.84 $ 8,724.88 ** Funds on A ccount typically represent a paltial payment of principal and interest received that cannot be applied to the luan. B. YOU HA VE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use ifnot applicable) 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 $8,724.88, PLUS ANY MORTGAGE PAYMENTS A:'ID LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PER10D. Payments must be made either bv cash. cashier s check. certified check or money order made o3vabJe and sent to: Select Portfolio Servicing, Inc. Remittance Processing P.O Box 79157 Phoenix, AZ 85062 You can cure any other default by taking the follov.ing action within THIRTY (30) DAYS of the date of this letter: (do not use ifnot applicable) IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within TIJJRTY (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 \",,:ill be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made ",thin 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 "ill be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure tJle delinquency befoce the lender begins legal proceedings against you, you \ViII still be lequired to pay the reasonable attorney s fees that were actually inclUTed, up to $50,00. HO\vever, iflegal proceedings are started against you, you will have to pay all reasonable attorneys fees actually inuUTed by the lender even if they exceed S50.00. Any attorney s fees \\,ill be added to the amount you owe the lender, LR064 which may also include other reasonable costs. If you cure the default ,",ithin the THIRTY (30) DA Y period, you ,""ill not be required to pay attorney s fees. OTHER LENDER REMEDIES The lender may also sue you personally for the unpaid principal balance and all other sums due lU1der the mortgage. RJGHT TO CURE THE DEF A UL T PRIOR TO SHERIFF S SALE If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney s fees and costs connected \\iith the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice ,",ill restore your mortgage to the same position as if you had never defaulted EARLIEST POSSffiLE 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 six (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: Address: Select Portfolio Servicing, Inc, P.O, Box 65250 Salt Lake City, UT 84165-0250 1-800-635-9698 (801) 293-2600 Diane Weinberger PHONE NUMBER: FAX NUMBER: Contact Person: EFFECT OF SHERIFF S SALE You should realize that a Sheliff s Sale "ill end your ownership of the mortgaged property and your right to occupy 1t, 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 Under the terms of your mortgage and note, it may, or may not, be possible to 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 saJe and that the other requirements of the mOJ1gage are satisfied, You may find out at any time if your loan is assumable by contacting your lender as provided herein. 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 INSTITUT10N TO PAY OFF THIS DEBT. . HAVE THIS DEFAUlT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . HAVE THE MORTGAGE RESTORED TO THE SAJ'vf:E POSITION AS IF NO DEFAUlT HAD OCCURRED, IF YOU CURE THE DEFAUlT. (HOWEVER, YOU DO NOT HAVE THIS RlGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . ASSERT THE NONEXISTENCE OF A DEFAUlT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTlTIITED UNDER THE MORTGAGE DOCUMENTS- . ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY LR064 E~OOOUINCP/ll-<)oO . Homeowners' Emergency Assistance Program CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A ] 7] 02 (717) 54]-1757 Financial Counseling Services of Franklin 3] West 3rd Street Waynesboro, PA ]7268 (7] 7) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, P A ] 71 0] (717) 234-5925 FAX (7] 7) 234.9459 YWCA of Carlisle 30] G Street Carlisle, PA 17013 (717) 243-38]8 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Derry StIeet Harrisburg, P A ] 7] 04 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A ] 7325 (717) 334-]5]8 FAX (717) 334-8326 -"OPO-O'/NCPI64' ~ 8~~ , tJ ""0. ~. ~ ~ -.. --.J o ~ 0. 0<;> 0 .....' ~".:..") C) ( c_? ""n ," c....... ~ :1", C' , rni-':"'; - _,_ ,-r~ \ >'~J r' , C) -{C, ..--- , -~'q :3':' . (, ~ ;;:- ~,"~ e:1 " ~,~ 0 ~D 0" .< '. . SHERIFF'S RETURN - REGULAR CASE NO: 2005-05768 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS STARR ROBERT E ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STARR ROBERT E the DEFENDANT , at 1327:00 HOURS, on the 9th day of November, 2005 at 308 MIDDLE ROAD NEWVILLE, PA 17241 by handing to LISA D STARR, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 13 .44 .00 10.00 .00 41.44 :r/;~j.~~<- ~.~~. R. Thomas Kline /:'~-,/.:;-: J<....(~.?'~- , . 11/14/2005 MARTHA VONROSENSTIEL Sworn and Subscribed to before , v+~ me this ,0 day of /vdLlt/l",b.r :)O~oc). . D. '/~_- - rothon y j1 By: ~p~ LA)~ Deputy Sheri :. SHERIFF'S RETURN - REGULAR CASE NO: 2005-05768 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS STARR ROBERT E ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STARR LISA D the DEFENDANT , at 1327:00 HOURS, on the 9th day of November, 2005 at 308 MIDDLE ROAD NEWVILLE, PA 17241 by handing to LISA D STARR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ?';?~.<:.?:, ., .,....,_.,;..~.- " ~~<? . -'"","'~."_.;f.~ R. Thomas Kline 11/14/2005 MARTHA VONROSENSTIEL Sworn and Subscribed to before me this / ",tl., _0 day of By: ~~ /J~ - Deputy She f 0.00-::; A.D. y~ Martha E. Von Rosenstiel, P.e. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 P.O. Box 307 Secane, PA 19018 610328-2887 Attorney I.D.# 52634 IPMorgan Chase Bank (f/k/a The Chase Manhattan Bank), as Trustee for the !MC Home Equity Loan Trust 1998-1 Plaintiff vs. Robert E. Starr and Lisa D. Starr Defendants #17653 -TM-GPG (SDE) Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY No: 05-5768 Civil PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly Settle, Discontinue and End the case on the above captio ed matter. Dated: September 21, 2006 artha E. Von Rosenstiel Attorney for Plaintiff o c ~ -Qq:: nil' ' t~. ~.c ~,l._ :P- E: -;7 ...-, ~ ~ c:;;::> <::f' (/) rn -0 N (J1 -v ::;1:. Q. ~-n rl1c -ai-r. -.fl'i) , )C' ';i~ ~\ ~ :..<. (-:2 o cr,