HomeMy WebLinkAbout06-1300I*
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
com
JP Morgan Chase Bank, as
Trustee
1270 Northland Drive
Suite 200
Mendota Heights, MN 55120
Plaintiff
V.
Kevin Armstrong a/k/a Kevin D.
Armstrong
Amy Armstrong a/k/a Amy J.
Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. O to - 130b
(21UcL `?
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER 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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
.x
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 dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisioner de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: Mortgage Electronic Registration Systems, Inc.
Assignments of Record to: JP Morgan Chase Bank, as Trustee
Recording Date: LODGED FOR RECORDING
2. Defendant (s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 1722 Sherwood Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland
COUNTY: Cumberland
DATE EXECUTED: 6/30/04
DATE RECORDED: 8/6/04 BOOK: 1876 PAGE: 2584
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
2/22/06:
Principal of debt due $134,632.79
Unpaid Interest at 8.875°%
from 6/1/05
to 2/22/06
(the per diem interest accruing on
this debt is $33.19 and that sum
should be added each day after
2/22/06) 8,861.73
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Late Charges
hl
(mont
y late charge of $53.91
should e added in accordance
with the terms of the note
each month after 2/22/06) 161.73
Suspense Balance (101.58)
Attorneys Fees (anticipated and actual
to 50 of principal) 6,731.64
TOTAL $150,891.31
* This interest rate is subject to adjustment as more fully set
forth in the Note and Mortgage.
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and wil l be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $150,891.31 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
Mark J. Udren, ESQUIRE
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
Attorney I.D. No. 04302
ALL THAT CERTAIN tract or parcel of land situate in the Borough of New
Cumberland, County of Cumberland, Commonwealth o0eansylvania, more particularly bounded
and described accordingto a surveyofD.P. Raffcnsperga,RegisteredSurveyor, dated My2,5,1956,
as follows:
BEGINNING at a point on the western line of Sherwood Road, seven hundred thirty
and twenty-three one-hundredths (730.23) feet South ofthe Southwest comer of the intersection of
Sherwood Road and Brandt Avenue, also being at the dividing lino between Lot No. 20 and Lot No.
21, Block "A" ofthehereinaftermentionedPlanofLots; thence Southwardly along the Western line
of Sherwood Road, fifty-five (55) feet to apoint at the dividing line between Lot No. 19 and LotNo.
20, Block "A" on said Plan; thence Westwardly along same, said line running at right auglcs to
Sherwood Road, one hundred twenty (120) feet to a point on the Eastern right-of-way line ofYork-
Baltimore Expressway; thence Northwardly along same fifty-five (55) feet to a point at the dividing
line between Lot No. 21 and Lot No. 20, Block "A" on said Plan; thence Estwardly along same and
at tight angles to Sherwood Road, one hundred twenty (120) feerlo a point, the Place of
BEGINNING,
BEING Lot No. 20, Block "A" on Plan of Highland Park Extension, said Plan
recorded in Office ofthe Recorder o£Deeds in and forCumberland County inPlanBook 5, Page 59.
HAVING thereon erected a one story frame dwelling house, known and numbered
as 1722 Sherwood Road
UNDERAND SUBJECTtoanomememoftheCommonwedthofPemmylvaniafor
Highway slope purposes as shown on said Plan along the rear portion thereof.
UNDER AND SUBJECT to an easement in favor ofthe New Cumberland Borough
Authority for the maintenance of a sanitary sewer line as now existing upon the ground along the rear.
portion of said lot, created by a grant dated December 23, 1953, and intended to be recorded.
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ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
TFIIS NOTICE IS SENT" It, YOU M AN ATTEMPT TO C01.I.147 TI9E INDEH'FEDNLSS REFFRIRED TO
HEREIN AND ANY INFORMATION 013'IAINED FROM YOU WILL III: USED FOR "PHA I Pl llzl,OSP:.
This is an ndicial nonce that the mort v e on tour home is in deftuh. and the lender i v n<ts to loreelosc. S critic intomw rnt
alnrut the naturu ofthe derauh is txocided in the wmd od ma -,
7bc IfOMfOA'4[3IrRS MOIRT6A('7 ASSISTANCE PR(H;RAM (FfEMAI't mrv ho nble to hd?s sate vo r homr, 1'hs
Noyrc_cSplnrlr I?gw Ih?royrum work',:.
lT SM it 1I1LAP cat help you utst MRI37 W11,71 CONSVMVfR CIREDIT COi1NS1J 7N(3 AjjLb ' WITMN 3u UAA'S
O flf DATII?OT 1'?IS NOl ICP?[akc thi n liw «sIn vou,jto ep mcw;r with the Cnunscline Aeel ,
Tho mmm addreus and ubonc number of C ntswner Credit Counseling Aecnues wrvtne rout Cuuniv = limed at the mnd of
this Notice. If %ou have am ow.mrm, on may egll the Pcmwrtvanm llousine I inwwe Aum, loll ltee al I-SM-341-2397.
(Persons.., nnnirN hearing um.111717) 7R(1-1Y69L
This Notice oonwinn lmpormot Ioga) 6d'ormation, If you have anv gtwstioae, repmsontatitms at the Consumer Credit
ComtselinS Agaww, mnv be ahle m help explain it Yon may also wnut to contuet nn nltome4 in Wta area. Tito norm bar
A,,sot hon may 1> ublc to belt, sou find a lawvor.
LA NUFFFICACION EN ADAWrO ES DE SUMA IMPORTANCIA, PUSS AF17CIA SU DERECHO A CONfINUAR
VIVIENIX) EN S11 CASA. SI NO COMPRENDI. I.I. CONUMIX) DI: ESl)A NOTIfdCACION OB'1'FNGA. UNA
IRADUCCIONIMMEDIA'IAWN'IT. H AMANDA ISTA AG1,,NCIA (PI;NNSYLVANLt H(lUSW(] FiNANCEA(' ,WYi
SIN CARGOS Al. NUMLRO MENCIONAD) ARRIBA PUEbES ShR ELEGIBLE PARA UN PRf.srAMO POR )-T.
PROGROIMA I1.AMAIX) °AOMFOWNER'S 1,W)WENCY MOR'I GAGE ASSISTANCE VROGRAM' El. CUAL 11i7EDI:
SA VAIR SLI CASA Ill IA PPRDIDA DkLI)LRE:000 A RRDIMI R SU IIIPOTECA.
Dale. April 13-21x3
TO Am Almstrone
1722 tiLernv(xd Road
Ncnc Cumimland, PA 171,70
I'mmi.>cs' ! 7-'.-" gltertv(xd Road
New Cumhefland. PA 1707(1
Re- Lrwn NumhLr. (143SM539
I'ROM_ Fhxnusmions l' inanclul
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HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELPVOU MAKE FUTURE MORTGAGE PAYMENTc
IF YOU COMPLY WITH TI-II. PROVISIONS OF 'I'IE IIOMPOW'NPR s U'MINGYNCY N10R-foA(jE
ASSIIANCE ACI 01` 198> ('II11 ACT°)_ YOU MAY n( ['L[G1BLCi Fo j2 p?MEI2GLNCY Moffl'QAGE
ASSIS"[ANCI°.
I E YOOIZ Ok:FA[RT HAS 13H[;N C'AU.9F.I,) AY CIRCLIMSTANCF6
BEYOND YOUR (-C)N'PROL_
[F YOll IdA VE A12SASUNAn1.l3 PROSPECT OI' Hf?INCi Af31.E To
PAY YoIJR MORTGAGE PAYMENTS. AND
IF YOU MEFS oTHF.R ELIGInILII'Y lt[iQUIR1iMEN"rS
HSIABLISIU.D BY If 0: PENNSYLVANIA HOUSING FINANCE]
A03r:NCY.
TEMPORARY STAY OF FORECLOSURE -- Under nccAct, von are entitled to a tunporarv <tay oFLorecL:nure
on your mortgage lhr Ittirty (3rt1 days hour the date minis Noticc. During that time. vwt must anangc to d anard a
`fna.to-face'- minting with one of the consumev credit eotmsnling agencies listed at the end d this Notice. THIS
CONSUMER CREDIT COUNSELING AGENCIES - If wu meat widt nec of the wnsmucr arv dit aruuselinc
u@enuie' listed In tht end l this nottem. the I ender nwv NOT lake action agtnnst ytw for thirb' (30)lots alter the
dare of fin,; meeting. The names addressa•, end tclcroh-n= t o Fxr i' de ianatcvi m- n credit wt wling
igeoptW car fhe_u}nnn ?v ah_igtt t}I< pngxrh i,c 1rc,ttcvl lire sc`t. torrh u) lhr. end of this Notice [t is nnl_r ncas,an
m sdt?ult one fame-tu tote md7inµ Advise Your Icndcr immadtereh of vourimentions
-
APPLICATION FOR MORTGAGE ASSISTANCE - Your tnortgage is in de;f uh for the reawns" fcvth tarot
to this Notice (see full Nvvtg paper for spccific information alxau the nature of your default.) V you haw treed and
arm unawe to reulee this problem with the Ieudcx, you have the right to apply for imanctial as.,latmxce Iiom the
Homw,Iwr s F.mergemy Mortgage Assi:nanu Progrmn. In do so, }ou must fill out. sign and file it connpletz<i
Hcrneuusrer`s Timerg rom Aoaistanw Frogman Appiwanon with talent the designated 0alsumer credit counseling
agcncias listed at the end 0 this Notice. 0mv consumer crud t u>ansehm, agencies haven applications for the
progrun and they oitl assist mu in submitting a eompliae application to the PeMsvlvania Housing Pimmce
Agenc,% 'l our upplicatnm Ml1Sf tK filed or pminmrkal within thing c301 dma of your fnc:e-to-face mce91ng
LENDER CONTACT IN REGARDS TO PENNSYLVANIA HOUSING FINANCIAL ASSISTANCE
H allamn inu Itinunctal
9150 Wasic W,IV Snitc 100
San Dieeu. CA 92123
Arts Contact Center. Fred Mmtgmeth
Phone. t-8002()t21XJ t, or 858,in. 7553
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ALL CORRESPONDENCE REGARDING PHFA ASSISTANCE SHOULD BE FORWARDED TO THE
ABOVE REFERENCED ADDRESS.
YOU MM UST 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 AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds for euczgencv mortgage assistance are t,c y hinter Ibce will IV
disbursed by the Agvlwv tmdati the cligiblity ctneria established br the Act. the Pcnnsplvratia Housing Finmtec
Agenav has sfhty (60) days to make it decision atier it recvires roar application- During that time, no Foreclosure
Imxncdings will be pursued against you if wa have met the time rulmi-ements set forth above You Hill be
notated duvcdv tw the Peuncrlverla )dousing Finance Agow, 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 CONSTRUED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have riled bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date).
NATURE OF THE DEFAULT - the MORI CAGE debt held be the aloes lender on tour pn>Twrty boated at
1722 Shenvoal Road , Nets Cumberland. PA 17070
6 Y:RL01 TSLY IN DEFAUI, I' t,,-cauu'_
YOU IIAVI NOT MADE 100N'CHLY MOR"ICAGG PAYMENI:S frn' the n lhluing
months mid the foil Otmtg amounts we nOa past dun:
Months pa<incmi from 12/DI/01 to UU01 /Q5 totaling; $ 5.110t) S0
Late Chat des_ $ 2631.a±
Other fees andicr costs tincluding NSF cAtarges and prcmem°insl>Maionsi- S 3b.IXi
LLSS: Unapplied Fields IN/A
TOTAL, $ 5.61X, 05
HOW TO CURE THE DEFAULT - You map care the dannat within fHllffY i30) DAYS at the law ol'this
Notice BY PAYING THF, TOTAL AMOUNT DUE TO THE LENDER, Will(;H IS A 5.696.05. PIJ1S ANY
M)RI`GAGI, PAYMBN IS AND LA'1'P: CHARGIN WHICH Ill COMI: DUE DIAZIN0 'PHI. 1 HIRTY 0+411 DAY
PI- RIOD Prv na t tvl 1 + 1- tilt r lea Inch treater . cl ak certified check of monnv order made ai nude
and sent (o'?
Homecomings Financial, P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO:
1820 East Sky Harbor Circle South. Suite 100 Phoenix, AZ 85034-9700.
IF YOU DO NOT CURE THE DEFAULT - ll'vou do not cum the default 1sM1hnt 'I IURI Y 1301 DAYS of Nic
date of this Notice, the lender intends to exercise its retht to accelerate the tnortnave debt. This mums shut the
mitt o ls'lla ding balmlcc` Of this debt will be considered due immediately and von mac lose the chance to pav the
mortgage iu monthly instnllm?ts. If full payment of the loud amount past due is not made utthm l'[ORI'Y (10i
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Page 4 of 6
5/25/2005
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DAYS. the lender also intetds to instruct its auurnev to ,tart legal action to foreclose uptm evur mortgaged
property.
IF THE MORTGAGE IS FORECLOSED UPON - "f he mortgaged proper-[s will be sold by the She'ilf m flat
the mortgage debt. If the lurdet refers >ur cave to its attorney. but you cure the dclinquincw W, ale the lender
begins legal ploucetiugv against vorr lou will still X. required! to pav file reastntable atiorno , fees [flat w2rc
actually inu¢ruf up to $50,00. However, if legal pniccudings are started against roe. Sou will have to pat all
reaatnablo atroma3 s hills actuall, incurred by the fender, two ri they earned $50,00 Anv attorney-, I", will be
added to the amount you owe fire leader, which ntav also include other reasorlable owls it rim cure the default
within the THIRTY t30) DAY period, . will not be required to pav attorneys foes.
OTHER LENDER REMEDIES - "1'he lender map also sue volt person lly for the unpaid principnl balance and
all other suns, due utter the nrrntgage
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - U you have not curd tlec default Bride
die TIIIRi'Y (30) DAY pertool and fecch,eurc ptaxtdfngs have (vguu, you ptti! have the3 ht Ip un;e rho dYtpult
by - lirmfn • aztc other net uiremene: under themnn ale. Curing your default in the manner ,at forth fa this
Ntrthe will reslore your murigaw to the same petition as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE, DATE - It is estimated that Bee conic t date that such a Sheriffs
Sale of the mortgagml p operty could be held would f, APProumateh. six (6) months from the date of this
Notice. .A notice of Lila actual date of the Sheriff's Sate wdtl Ile sett to you before the sale. Of course. the amount
aceded w cone the default will increase the longer cut wait. You play find out ai tut, flow swat)) vvhai the
required paymut or action will he by contacting the lender.
HOW TO CONTACT THE LENDER:
Isom wminas Financed
2711 N. flitAcll_ Suite 1)(9)
Dallas, 1:R 1,5204
!fill: Linn Counseling Deparmtet
I'Itrnre: 1 149) 2ri'.2!x) 1
EFFECT OF THE SHERIFFS SALE - You should reahxc (fill (a Sheriff, gale will end 'our nwnmship of the
mortgaged prul-,ettv and vour tight to ux;upv It If you wahpuc In It IV in the proleriv "f0.',' the Sheriffs Sale_ a
lavysuit w srtwee you a ul %our furnishimts and other buf am inps owld fe stano d in' lire leader at mrv tune.
ASSUMPTION OF MORTGAGE - You map to nhle to soil or translary our hone to it diner or transterw who
will di'sume the mortgage dek provided that all the ouuunding pm?mcnts charges :md mtornw s fee, aril acts
are paid prior to or at the.,me and Oral the other wouv etneou of the mortgage are suti9lat.
YOU MAY ALSO HAVE THE RIGHT:
l'6 SL`LL "I IILS PROPWIY 10 4 0 '1AIN MONEY 10 FA 1' Of 1, 1178 MOR"IOAt,l: llid3'I
OR 1'0 BORROW MONEY FR(3M AN(11'I IL'R I NDINO INS] 1)'M ION TO I'AY Of J 11H.',
DJ:Bf
TO H.AVI; TIItS DEFAITJ CARED BY ANY TN1RO PARTY At TING ON YO1tR BII IAI.f
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TO I[A VE 'I'1I& N1010 FC AG :I2FSl'ORFD 'TO T'IIP CAME: POSITION AS IF NO DEFAULT
ILN7OCCI[RRED_SF YOUCITRETI{[ DEFAUL-1.(I IOWEVER YO[ DO NOT[LAVF. TATS
RIGHT TO CITE YOUR DFFAI TUI MORE 'I'IIAN l'IIRFF 'LIMES IN ANY CALENDAR
YEAR,)
10 ASSLRI LnE NONIXISTBNCH OF A DEF'AUM IN ANY FO721;CLOSURE
PROCEEDING OR ANY OILIER LAWSI.T"T (Ns,murED UNDLR 1'1W MOR'I(TAC
IN:?C'IrMI?:N"ES.
I'r) AtiSfiRi ANY' O'flJl R ll1TENSb YOU BkiLIE, V[i YOU MAY DAVIT TO SIICII A(lION
BY THE LENDER
11 t SU'K PROTECTION UNDER TTIF FEDERAL 13ANKRI 1}'TCY LAW.
Sinccrefv_
Loran Cowixliug Dcpttrtmcnt
Ium[osurei.sT
I, it of Conn ljng Agencies
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Homecomings Financial
A GAIAC Company
April 13. 2005
Certified Mail, Return Receipt Requested
043818)549
Kcvin Armstrong
1722 Shmcoud Road
Nett' Cumberland. PA 17070
Re- Prrgaa'n' Address: 1722 Sherwood. Road Loan Ntmdwr- 0438180-,49
New Cumtcrland_ PA 17070
A default mists under the above referenced Mortgage(Decd of Trust low, agreemcur, The action iequned to
cwc the default is the payment a all aunts due tmdcT the Mo,tgage/Deed o1' Trust loan ag1=110a. As of the
date of this letter the total amount duets S 5.696.05 _ That sum include, the following:
5 payments totaling S 5,3J).50
Latecherges' S 269-a6
Other tee, and/or cost. $ 3690
Unapplied I and, N/A
'I he total amount due shown alieve is subject to further mciea: for additional month1v ptonicnts. line
charges, atr(miev fees. andhr other fees and cost which mac beexi to due, after the date of this letter. to
obtain an update of the total amount due to cure this default, ctmlact us at 1.800.206.2901.
TO CUR], 'HhS DFI AITI.T, SEND YOUR CASIIIFR'S CIMCK, MONF,Y ORDER OR CERTIFIED
CHECK IN '09F AMOUNT OF S 51696-05 By Mav 13, 2005 10 'fl{L FOUXAN[N( k0t)RItSIS
Homcroomings Financial, P.O. Box 78426 Phoenix, AZ 85U62-8426 OR OVERNIGHT TO: 18211 East
Sky Harbor Circle South, Suite I00 Phoenix, AZ 85034-97181
If the default is not cared within thirty (30I dapa of the mailing of this letter. the lender, without further notice
or de na id, vall accelerate themannitr date of the Note and deelan; all stuns seemod be the MongagelDecd of
'I m>t to be inhmediateiv due and payable 77ne lender then intends to have the propene ;old at n public
fca'cclowre side. After twcekxatimt, a curing of the default and reinstatement of the loran will be permitted up
to the time of the sale Irv paving the past due mrn,thly payments and oilier sums (hen due under the
Morlgaga4h'<xl of"Crust loan agi cement and by comlih nrg iviN al [ team, of rcinstatenteut.
You have the right to bring a cowl atai(w to assert the nonexistence of a default or ally other defense that mac
Geist to prcva,t acuehaatitm and Sale W the prolvv- .
"fH1S Iv011(.G. IS 5}:N"17 70 YOU IN AN ATTLMi'T TO COLT LC'I I IIF INDI 13TF )WSS RITZ-MRIA)
TO IMRF,IN AND ANY INFORMATION OBTAINFI) FROM YOU WILL, lfl USED FOR 'rllA r
PURPOSI.-
Smo-reh.
Loan Counseling Dg,arunem II1,41
•IlwneounasMp counxlinp is availablaaayw hanwEh,ha"Ci aGrumding RCx,mmo Ccn4r (ITRC). an allianmuf ammmw amdit
scups.-i., . 'I'ha tCRC has hen mmhud a, l tom ingn Fimuciel la provide a&tle h, yu on uredir iuucx mdnding hmv to
,.6"'dola and mgnwve ekh nnmmanaycmrnl.'Isia" ti on mm' contact them w 1.977 806 0775 f ftsi?encc of no win to m, or you
.afar. ctmwcla IICl}appro.ndhourieu-tat.Inaaemo, b, a.11- 1800.169.42% 7 for fird-w noon.
Hcmecorcings Fin:vdcl
271, Nang Haskell Ave!we Seite 900Dollae.Jexas 75Rla
6W.M6,2 o Fb+Y?eCGb51fN?S.CGI11
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ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
PHIS NOPtu. IS SENT TO YOU IN AN AT-i imPT TO COL[ cT THE: INDFRIFDMSS RFFERRI3> TO
IWREIN AND ANY iNFORMA'ION 0131 AIN1D FROM YOU WILL 131' USUD I OR THAT PI IRPOSE.
elaulL and the leader intends In noted.. Specificinformation
this t, an o0"cal notice that the T"Onat a on mar time =10
about the nature oFdae dclault is P"Aided in the attached _
The IIOMFOtVN1iR'R O 'G C ASSISTANCE: PR(X'HLAM "11}'MAP mac he nhle to cl to svice vnar hone Ths
No4oresplams m thgPrgyrantwnk,
-- --- ----------
la see 7 HFMAP rnn 6cl?rrni mutt 'I AS TN A CONSl,PvIGR CRI.DII URI. S :I. QCrtNCY WO}jftL3_(LDAYS
qp Tai IJA I7.OT'IHIS NUIICI:. Take?hia nMfcc with cggylrcny9u meet wnh the Coutuel to Agcpe,..
'This Notice contains important legal inl'ornwtiort 11 }ou harm any questions, representatives at the C'oneouner Credit
Counseling Agcnev mat be able to help "plain it You nwp also want to contact an attorney in your arcs. The local bar
assoaatirnt may M ahle to hdp you lind a 1aw}mr.
IA NO'III ICACfON EN AIAUN'IO ES DE SUMA LMP(NOANCIA. PAIN AIECTA SU DIi.RFCF10 A CONI'WUAR
VIVIFNIX) IN SO CAS1 SI NO COMPRENDE I7. CONrF'NIDO DE ESTA NOITPICACION OPT1,NGA UNA
TRADUCCION IMMI971A fAMENIE LIAMANDA 1S IA MANCIA WFNNSYLVANIA IiOtISIN(, I I ANCE A(lENCY,
SIN CARGOS AL NUMLRO MI:NCIONADO ARRIBA F I i7)ES SPR I I EGBLi PARA UN PRI:S"IAMO POR FL
PROGRAMA LLIMNX) 91OMFOWNGR S EMERGENCY MORTGA( IASSISTANCE. PROGRAM" El, CURL PGE'DP:
SAI NAR SO CASA OF I -A PIMADA DI 1, I)ERLCRO A RDIMIR SU I IIYO'IGCA.
Date: Ala-11 13, 2()0;
'10t Kerin Armstrrntp
1722 Shmuxxl Road
New Cuntlvdand. PA 17070
11 remi1722 Shencoo ti Road
New Cuminarland. PA 17070
Re. Loan Numlxnr (14381 *649
F'ROM'. I lon,wmtinen Financial
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HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELPYOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY W1rif TILT PROVISIONS OF 1FIB HOMEOWNERS F;MERGFNCY MORTGAGE
ASSUUANCE AC-1 OF 1983 (1111; 'ACI'), YOU MAY 61 ILIOU31-E FOR FKAERGENCY MORTGAGI[
ASSIS"IANCG::
IF YO(JR DEFAULT HAS BF3EN CAUSED 13Y C IRC'IJMS'I'ANCFS
BFYOND YOUR CON] ROL-
IF YOII 11AVE A REASONABU PRO5PI'CI' OF 131:ING AB E TO
PAY YOUR MORTGAGF PAYMENTS- AND
IF YOU MEFi'U O"UI lllZ LLIGIBIL I FY REQIIIREMFN-l S
I'STABLISHIdD 13Y'INE PENNSYLVANIA IIOUSINC FINANCIi
AGENCY
TEMPORARY STAY OF FORECLOSURE - Under the Act, voti are entitled ton temporary star offoreclosme
On vow mortgage 1'or thirty (30) datsiiom the date of this Notice. During that time. cou nmst airmge and attend a
"face io-face" mceling with one of the consumer credit counseling agencies listed at (fie eaid of this Notice THIS
MEETING MUST OCCUR W rHIIN THE NEXT 31) DAYS 1F YOI I DO NOT APP; Y FO Z CMLIZCENCY
MOR"IGA(iF ASSISI ANCIS YotI Mi1S'f ffiZING YOUR MORTGAGF_ UP TO DATE. THE PART OF 11-1IS
NO] CI C'ALLhD' HOW FO CI IRF YOF!R MOR GAGE DFFAUI:I'-. FXPI AINS HOW It) BRING YOUR
MORTGAGE UP TO DAl'E.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit eounschng
agarcic? IisYed at the nil of tliis uaiee. die leader matt NO7 takr action against fMi for tlrinp (30) days attar the
date of this meeting- The names addresses and telethon e numhass of desumatod a"Isama' credit crnmwling
agenda for the algIn m which th_ptope n is kckned arc set FoYh at the aid of this Notice It is oilg nia c,,,avv
to schedule one tece-to-face meeting- Advise pour hander aunicdiawh ofvour intntions.
APPLICATION FOR MORTGAGE ASSISTANCE- )'ow' mortgage is in default for the reasons set forth Inter
in This Notice isce folbaking pages for Tu;ific information aNnit the mitre of cote defaujr) If Von how vial and
are unable to resolve this problem whh the larder. cou have the right to apply for financial assistance front the
I tomorsiner's Lmorpencv Mortgage Assistance Program. 'To do w, you must fill nut, >ign .md f Ic a annplcied
Homanmcr s Hmergncy Aavistance Program Applicntiar wilh one oC the dctitignaad anutancr nredil cowmtilurg
agnciee tinted at the end of this Notice. Chdv wry mner credit coumnYhng agencies have applications lot the
program and Lack- will assist you in suMnitimc a complete application to the Penn+plvtmia Housing Finance
Agency. Your application MILS I he filed nr pnatmarke3 onion mull, (40) da,, of tour faa:lo-tax mw[mg
LENDER CONTACT IN REGARDS TO PENNSVLVANIA HOUSING FINANCIAL ASSISTANCE
I hanc{;cnnmgs F intmcial
9350 Wasie Win Suite ER)
San Diego. C.A'T'1';
Ann" Contact Center. Fret Manparelli
Phone. I-8(x).2106 :9OI, or 858505 7558
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ALL CORRESPONDENCE REGARDING PHFA ASSISTANCE SHOULD BE FORWARDED TO THE
ABOVE REFERENCED ADDRESS
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 AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION -- Available funds tar ernergencr mwtptic as.siatance the vvey !united. Thee will he
disbursed be the Agent wider the eligibilitc criUnia cstabi Shod by the Act. '[lie P<auuvIi aina I lousing Finance
Agoiey has sixtY (6(i) day,, to make a derision after it ruxrv?N your application, During dmt tine. no fineclmure
proceedings Will lw pnrsuecl against wat it %ou have met the time requirCm2nly set firth above You will Ixs
notified ducellp by the Pennsylvania I lousung finance Agenw of its khei5lon im nmr application.
NOTE: IF YOU ARE CURRENTLY PROTECTED 81' THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSTRUED 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 (Brine it up to date).
NATURE OF THE DEFAULT -'Ihe MORTGAGE debt held by the nlx>vt leader ou your prop-TI} locates at
17'Shanyrnxi Road. New k einbvrland. PA 17070
IS SERIOUSLY IN DEP'AtILT Ixcau e
YOU HAVE NOT MADF MONTHLY MORTGAGE PAYMENTS fw the follo"Ing
months and the folluwing enutuvs arc wow past due-
Mutably pto.'menis fnmi 12!011041,)04A)1105 totaling' $ 5390-50
Lott Charges: $ 2f95'
Other fcei and/or costs (hwluding NSF charges and proptaty inslxstfcxu): $ 9611)
LESS: unapplied Funds: N/A
ToIAt S 5.696-05
HOW TO CURE THE DEFAULT - You may one the dtfau h sithin I14IR IY (30) DAYS ol'the date ol'this
Notice BY PAYING THE TOTAL AMOUNT DUE TO THE, LENDER. WHR'l l IF $ 5,696.01. 111,1N ANY
MOIYIGAGh Pt1Yh1f{N"fti ANll LAI h CHARhFS t5'i 11Cti HECOMP. UUT, l)U121NG'I ll[- THIKIY' 1101 DAY
PERIOD- Pasrnetits nwst tnr made tith.a by cash. aizhier ± clack. ccrtifi d chock or money orlo made navabk
and sent m.
Homecomings Financial, P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO:
1820 East Sky Harbor Circle. South, Suite 100 Phoenix, AZ 85034-971f0.
IF YOU DO NOT CURE THE DEFAULT _. 11 viii do not cure the default tWluu TI LIl'ZfF (30) DAYS ot'the
date of this Notice, the lender intends to exercise Its richt to accelerate the murteaee debt Tlais meatus that (lie
entire otawandurg twlance of this debt will be amsldeied due immediately and von may lose the chance to pay the
mungage in monthly invallme?us. If hill pmiwu of (lie tend amount past due is not made within TIlIR'I'Y (30)
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DAYS, the lender also intends to instruct ib attorn,n to start legal achon to fexeclow upon tour mortgaged
prolvi-tc.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will he sold M? the Shoat] to pup
oft the mortgage data, If the londcr refers your case to its attorney, but you care the dclinquenc-y before the lender
begins legal procecdinis against con, you will still be requactl to pac the reitsmable anorne's fees that were
actualiv incurred. up hi, $50.(X7. However, illegal proceedings are started against yon, you will have to pay all
reasonable attorney a lei actually incurred by the lends, even if they woad $5200. An, altonnat s fees will be
added to the amount cou one the lender, which muv also indutlc other reasonable costs. If vast cure the default
within the THIRTY (30) DAY period, vast will wit he required to Pas attorney's fees.
OTHER LENDER REMEDIES - the lender may also sue cog personally for the unpaid pronalml Imlance and
all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If con hate not cued the default within
the T1{I bf1'Y ('.)) DAY period and foralontre prcrecdiues bare began, you_ti11 hate the right to one the default
,aid prevent the sale at air, time stn to one hour before the Sheriffs Safe- You mac do vu h. paving the total
amount then past due plus any late or other chances then due reasonable aroma's fees and costs connected veldt
the forcelowrt sale and any other costa eonuoetoyl with th, Sheri13 s Rule ns s1xx.Uied in wriun ? be the lender and
be erRorrnin mic other re uiremsxtla undo th° <rt ?•. Curing your default in the manner set forth in this
Notice will rextarepour 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 Sherul's
Sal, of the mortgaged property could be hold would be approximately six (6) months from the date of this
Notice. A notice of the actual date of the Slic iff`s Sale will fee sent to cou before the safe. Of course, the amount
needed to cure the default will increase the longer you wait- You may find out at any time caactly what the
requ rod pavment or action will be by contacting the tender.
HOW TO CONTACT THE LENDER:
Heaneconungs Financial
2711 N. HasW], Swle y(X)
Dalhe, [:N 75204
Ann: Loan C:ounseliug DL[ a ftroau
Phone' Ipe(N)?IHi2901
EFFECT OF THE. SHERIFF'S SALE - You should realise that a Sheriffs Sale will end v-err ownership of the
meMgagod property and yon' right to moulw it. If tou continue to lh'e in Rte protx'rtc after the Shuiff- Sale. a
law.sult to remove ,,in and your funnA ings and other belongings could be-started be the lender at any ham.
ASSUMPTION OF MORTGAGE - You now he able to sell or transfer vo ur home to a haver or transfers who
will assume tire mortgage debt, provided that all the outstanding pavmenta, Charges and auormc's fee, slid co-as
are paid prior to of at the sale and that the other requirvmrents of the mortgage are satisfied_
YOU MAY ALSO HAVE THE RIGHT:
10 "HA, 'I 111. PROPIiR"I ) "10 013 FAIN MONEY TO PA) OH 'I [IF MORIGACL DL13T
OR T'O BORROW MONEY FROM ANI)I HER 11ND1NG IN$Il"I'(tIION ltd PAY t Fl'IIIIS
DFIl f.
t 1 I1AA1- THIS DF.F'A171:1 Ct1RED BY ANY THII2o PARTY ACTING ON YOUR RF,HALF.
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TO I I.A VU "LHE MORT'GA(E RES'10RI D I'O TIIF SAME PosmON AS H- NO DFdFAUL I
IIAD OCCURRED, IF YOU CURT TFIE DFFAULF. (HCIWF.VF_R, YOU D0 NO"F I{AVE MIS
RIGHT TO CURE YOUR DEFAULT MORE TI LAN THRI Y1 TIMES IN ANY CM I{NDAR
YEAR')
IO ASSI:Rl HIE NONIaISIENCU OF A DITAULI IN ANY PORECLOSITRI3
PROCEEDING OR ANY OMER I.AWSUfT INSII7UI'FD UNDFR HH; MORIGA01
DOCUMENIS.
10 ASSERT ANY OTHER DiT FW: YOU BFt,lFVU YOU MAY] AVE FO SUCH AC'F[ON
nY TIE: I.F_NT)ER,
TO SfTK PROTECTION UNDF,R THF; FEDERAL HANKRI PICY LAW
Smcemh_
I.mn Counuling Dywrlmmi
Lndn,'ure(s)
List of Counseling Agnciuti
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V E R I F I C A T I O N
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
J r v
Mark J. Udren, ESQUIRE
UDREN LAW OFFICES, P.C.
V-1 C
QV)
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01300 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JP MORGAN CHASE BANK
VS
ARMSTRONG KEVIN ET AL
WILLIAM CLINE Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ARMSTRONG KEVIN AKA KEVIN D ARMSTRONG the
DEFENDANT , at 1120:00 HOURS, on the 16th day of March , 2006
at 1722 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070 by handing to
ARMSTRONG
ADULT IN CHARGE
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 18.00
Service 14.96
Affidavit .00
Surcharge 10.00
.00
42.96
Sworn and Subscribed to before
me this al.k- day of
A. D.
rotho ry
So Answers:
R. Thomas Kline
03/17/2006
UDREN LAW OFFICE
By : yl,
"Deputy Sheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01300 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JP MORGAN CHASE BANK
VS
ARMSTRONG KEVIN ET AL
WILLIAM CLINE Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ARMSTRONG AMY AKA AMY J ARMSTRONG the
DEFENDANT , at 1120:00 HOURS, on the 16th day of March , 2006
at 1722 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070 by handing to
AMY ARMSTRONG
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this o2(0? day of
D.
26
otho
So Answers:
1
R. Thomas Kline
03/17/2006
UDREN LAW OFFICE
By: - 77?/?
eputy Sheriff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE-200
CHERRY HILL, NJ 08003-3620
856-669-5400
JP Morgan Chase Bank, as
Trustee
1270 Northland Drive
Suite 200
Mendota Heights, MN 55120
Plaintiff
V.
Kevin Armstrong a/k/a Kevin D.
Armstrong
Amy Armstrong a/k/a Amy J.
Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 06-1300 Civil Term
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendants, Kevin
Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a/k/a Amy J.
Armstrong have filed Chapter 13 Bankruptcy in the Middle District
of Pennsylvania on April 7,2006, Bankruptcy Case No. 06-00619.
Mark J. Udren, Esquire
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
?-j r--a Q
?' C:3
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
9275 Sky Park Court, 3rd Floor :CIVIL DIVISION
San Diego, CA 92123 :Cumberland County
Plaintiff
V. :MORTGAGE FORECLOSURE
Kevin Armstrong €NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Defendant (s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant (s) Kevin Armstrong, a/k/a Kevin D. Armstrong and Amy Armstrong,
a/k/a Amy J. Armstrong for failure to file an Answer to Plaintiff's
Complaint within 20 days from service thereof and for foreclosure and sale
of the mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
Interest Per Complaint
From 2/23/06 to 3/20/07
Late charges per Complaint
From 2/23/06 to 3/20/07
TOTAL
I hereby certify that (1) the addresses of the
are as shown above, and (2) that notice has been
Rule 237.1, a copy of which is attached hereto.
$150,891.31
12,977.29
700.83
$164,569.43
Plaintiff and Defendant
given in accordance with
LAW OFFICES, P.
'Mark J. Udren, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE : a 9
PRO PROTKY
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Require
.ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
ATTORNEY FOR PLAINTIFF
JP Morgan Chase Bank, as Trustee
Plaintiff
V.
Kevin Armstrong a/k/a Kevin D. Armstrong
Amy Armstrong a/k/a Amy J. Armstrong
Defendant(s)
TO: Amy Armstrong a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
DATE of Notice: March 9, 2007
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 06-1300 Civil Term
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 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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,. PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN
TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI
USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA
EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLECTOR AND-JOIS IS AN ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL
THAT
Wo dcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. N0..04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY BILL; NJ 08003
856-669-5400
pleadinas@udren.com
JP Morgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff ECIVIL DIVISION
;Cumberland County
V.
Kevin Armstrong a/k/a Kevin D. Armstrong
Amy Armstrong a/k/a Amy J. Armstrong NO. 06-1300 Civil Term
Defendant (s)
TO: Kevin Armstrong a/k/a Kevin D. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
DATE of Notice: March 9, 2007
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 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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. .AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN
TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS,
IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI
USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA
EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICE ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLE T.OR AND THIS IS AN ATTEMPT O COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL ?Fi USED FOR.A;4AT PURPOSE.
W do t Corporate Center
111 Woodcrest Road, Suite 200
.rry.Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
ATTORNEY FOR PLAINTIFF
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
V. :Cumberland County
Kevin Armstrong
a/k/a Kevin D. Armstrong :MORTGAGE FORECLOSURE
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s) :NO. 06-1300 CIVIL TERM
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF CAMDEN
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its Allies
as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117
Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known
residence and employment of each Defendant are as follows:
Defendant:
Age.
Residence:
Employment:
Defendant:
Age:
Residence:
Employment:
Kevin Armstrong
a/k/a Kevin D. Armstrong
Over 18
As captioned above
Unknown
Amy Armstrong
a/k/a Amy J. Armstrong
Over 18
As captioned above
Unknown /
Name :
Title:
Sworn to and subscribed Company:
before me this 20th day
of March, 2007.
No ? y P:,. is
MARK J. UDREN, ESQ.
ATTORNEY FOR PLAINTIFF
UDREN LAW OFFICES, P.C.
IN THE UNITED STATES BANKRUPTCY
COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE: CHAPTER 13
Kevin D. Armstrong
Amy J. Armstrong CASE NO. 1-06-bk-00619 MDF
JP Morgan Chase Bank as Trustee
Movant
VS.
Kevin D. Armstrong
Amy J. Armstrong
Debtor(s)
and
Charles J. DeHart, III, Esquire
Trustee
RESPONDENTS
ORDER MODIFYING AUTOMATIC STAY
Upon consideration of the Motion of JP Morgan Chase Bank as Trustee for Relief from
Automatic Stay, as well as the Certification of Default filed by same, it is hereby
ORDERED AND DECREED THAT: The 11 U.S.C. §362 Automatic Stay of all
proceedings is hereby modified with respect to premises located at:
1722 Sherwood Road
New Cumberland, PA 17070
so as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises
at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to
possession of said premises; and it is further
ORDERED THAT: The relief granted by this order shall survive the conversion of this
bankruptcy case to a case under any other Chapter of the Bankruptcy Code; and it is further
BY the Court,
Dated: February 27, 2007 U14MP14 Judge 0?-
This document is electronically signed and filed on the same date.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01300 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JP MORGAN CHASE BANK
VS
ARMSTRONG KEVIN ET AL
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ARMSTRONG KEVIN AKA KEVIN D ARMSTRONG the
DEFENDANT , at 1120:00 HOURS, on the 16th day of March 2006
at 1722 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070
AMY ARMSTRONG
by handing to
ADULT IN CHARGE
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 18.00
Service 14.96
Affidavit .00
Surcharge 10.00
.00
42.96
Sworn and Subscribed to before
me this day of
A. D.
Prothonotary
So Answers:
R. Thomas Kline
03/17/2006
UDREN LAW OFFICE
By: ,
Deputy Sheriff
qho
SHERIFF'S RETURN - XhUULAX
"CASE NO: 2006-01300 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JP MORGAN CHASE BANK
VS
ARMSTRONG KEVIN ET AL
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ARMSTRONG AMY AKA AMY J ARMSTRONG the
DEFENDANT
at 1120:00 HOURS, on the 16th day of March , 2006
at 1722 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070 by handing to
AMY ARMSTRONG
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this day of
A. D.
So Answers:
R. Thomas Kline
03/17/2006
UDREN LAW OFFICE
BY -
eputy Sheriff
Prothonotary
V
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee =COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
:Cumberland County
V.
:MORTGAGE FORECLOSURE
Kevin Armstrong
a/k/a Kevin D. Armstrong :NO. 06-1300 CIVIL TERM
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
To: Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania you are
' in the
hereby notified that a Judgment has been enterP*4-ry
above proceeding as indicated below.
X Judgment by Default
Money Judgment
Judgment in Replevin
3/-1q1o ?
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esquire
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
:Cumberland County
V.
'MORTGAGE FORECLOSURE
Kevin Armstrong :NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
To: Kevin Armstrong
a/k/a Kevin D. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
NOTICE
Pursuant to Rule 236 of the Supreme Court of Penn ylvania, ou are
hereby notified that a Judgment has been entered ga' in the
above proceeding as indicated below.
othon
x Judgment by Default
Money Judgment
Judgment in Replevin -?/.2 516
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren Esquire
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
:Cumberland County
V.
:MORTGAGE FORECLOSURE
Kevin Armstrong :NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
Amount due
$164,569.43
Interest From 3/21/07 5,609.11
to Date of Sale 9/5/07
Ongoing Per Diem of 33.19
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
UDREN LAW OFFICES, P.C.
v.,.ai.ia, uv}lvsnu
EY FOR PLAINTIFF
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee ':COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
Cumberland County
V.
:MORTGAGE FORECLOSURE
Kevin Armstrong :NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
C E R T I F I C A T E
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff in the above-captioned matter and that the
premises are not subject to the provisions of Act 91 because it
is.
( ) An FHA insured mortgage
( ) Non-owner occupied
( ) Vacant
( x ) Act 91 procedures have been fulfilled.
( ) Over 24 months delinquent.
This certification is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
UDREN LAW OFFICES, P.C.
Oren, ESQUIRE
FOR PLAINTIFF
C"? ? C7
f-
D
W
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee ::COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
:Cumberland County
v.
MORTGAGE FORECLOSURE
Kevin Armstrong :NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, as Trustee, Plaintiff in the above action, by
its attorney, Mark J. Udren, ESQ., sets forth as of the date the
Praecipe for the Writ of Execution was filed the following
information concerning the real property located at: 1722 Sherwood
Road, New Cumberland, PA 17070
1. Name and address of Owner(s) or reputed owner(s):
Name Address
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
1722 Sherwood Road
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address
Joanna Ward Neidig
4. Name and address of
of record:
Name
JPMorgan Chase Bank
as Trustee
506 Lamp Post Ln.
Camp Hill, PA 17011
the last recorded holder of every mortgage
Address
9275 Sky Park Court, 3rd Floor
San Diego, CA 92123
5. Name and address of every other person who has any record lien
on the property:
Name Address
none
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address
Tax Claim Bureau
55 East Court Street
Doylestown, PA 18901
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
30 East Court Street
Doylestown, PA 18901
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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:
Name Address
Tenants/Occupants
1722 Sherwood Road
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
DATED: March 20, 2007
UDREN LAW OFFICES, P.C.
i r\ rk J. Udren, ESQ.
Attorney for Plaintiff
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee
Plaintiff
V.
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 06-1300 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Kevin Armstrong
a/k/a Kevin D. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Your house (real estate) at 1722 Sherwood Road, New Cumberland, PA
17070 is scheduled to be sold at the Sheriff's Sale on September
5, 2007, at 10:00 am in the James Lorah Auditorium, Broad & Main
Streets, Doylestown, PA, to enforce the court judgment of
$164,569.43, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how much
you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You
may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two 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 TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to
the highest bidder. You may find out the price bid by calling 856-669-5400.
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
856-669-5400.
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 the 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 30 days after the 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 Schedule of
Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
='? 9--
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1300 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE,
Plaintiff (s)
From KEVIN ARMSTRONG A/K/A KEVIN D. ARMSTRONG AND AMY ARMSTRONG
A/K/A AMY J. ARMSTRONG
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $164,569.43
L.L. $.50
Interest FROM 3/21/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $33.19 TO
ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $5,609.11
Atty's Comm %
Atty Paid $154.96
Plaintiff Paid
Date: MARCH 29, 2007
(Seal)
Due Prothy $2.00
Other Costs
Curtis R. ong, Protho
By:
Deputy
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 04302
l
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as
Trustee
9275 Sky Park Court, 3rd Floor
San Diego, CA 92123
Plaintiff
V.
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Defendant (s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 06-1300 CIVIL TERM
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of
which is attached hereto as Exhibit "A", was sent to every recorded
lienholder and every other interested party known as of the date of the
filing of the Praecipe for the Writ of Execution, on the date(s) appearing
on the attached Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent,to Defendant(s) by regular mail
and certified mail on the date appearing on the attached Return Receipt,
which was signed for by Defendant(s) on the date specified on the said
Return Receipt. Copies of the said Notice and Return Receipt are attached
hereto as Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by
personal service on the date specified on the attached Return of Service,
attached hereto as Exhibit "B".
4. If service was by order of Court, then proof of compliance with said
order is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P.
3129.
n 4904
This Affidavit is made subject to pe ies o 1 Pa VPC ectio
relating to unsworn falsification to au orities.
Dated: August 30, 2007 UDREN A OF CESBY:
Mark J. Udren, Esquire
Attorney for Plaintiff
i
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY BILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee
Plaintiff
V.
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 06-1300 CIVIL TERM
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, as Trustee, Plaintiff in the above action, by
its attorney, Mark J. Udren, ESQ., sets forth as of the date the
Praecipe for the Writ of Execution was filed the following
information concerning the real property located at: 1722 Sherwood
Road, New Cumberland, PA 17070
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
1722 Sherwood Road
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address
Joanna Ward Neidig
506 Lamp Post Ln.
Camp Hill, PA 17011
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
JPMorgan Chase Bank.
as Trustee
5. Name and address of
on the property:
Name
none
Address
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address
Real Estate Tax Department
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Square
Carlisle, PA 17013
13 North Hanover Street
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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:
Name Address
Tenants/Occupants
1722 Sherwood Road
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities. ?---?
UDREN LAW OMCES1 P.C.
DATED: August 30, 2007
9275 Sky Park Court, 3rd Floor
San Diego, CA 92123
every other person who has any record lien
Mark J, Udreh squire
Attorney for 4intiff
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee
Plaintiff
V.
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 06-1300 CIVIL TERM
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
PROPERTY: 1722 Sherwood Road
New Cumberland, PA 17070
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the CumbedoW County
Sheriffs Sale on September 5. 2007, at 10:00 am, at the COMMISSIONERS
HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate
that you may hold a mortgage or judgment on the property which will be extinguished by
the sale. You may wish to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff
not later that 30 days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within 10 days after the filing of the
schedule.
EXHIBIT A
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JP Morgan Chase Bank, as Trustee In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
Kevin Armstrong a/k/a Kevin D. Armstrong Writ No. 2006-1300 Civil Term
and Amy Armstrong a/k/a Amy J.
Armstrong
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on May 25, 2007 at 1138 hours, he served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendants,
to wit: Kevin Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a.k.a Amy J.
Armstrong, by making known unto Amy Armstrong a/k/a Amy J. Armstrong personally,
and wife of Kevin Armstrong a/k/a Kevin D.Armstrong, at 1722 Sherwood Road, New
Cumberland, Cumberland County, Pennsylvania its contents and at the same time
handing to her personally the said true and correct copy of the same.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that
on July 11, 2007 at 1320 hours, he posted a true copy of the within Real Estate Writ,
Notice, Poster and Description, in the above entitled action, upon the property of Kevin
Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a/k/a Amy J. Armstrong
located at 1722 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Kevin Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a/k/a
Amy J. Armstrong, by regular mail to their last known address of 1722 Sherwood Road,
New Cumberland, PA 17070. These letters were mailed under the date of July 2, 2007
and never returned to the Sheriffs Office.
So Answers:
R. Thomas Kline, Sheriff
BY J6
Real Estate Sergeant
EXHIBIT B
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LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: SCOTT A. STEIN, ESQUIRE
PA Supreme Court ID: 81738
3800 Market Street
Camp Hill, PA 17011
PH: (717) 591-1755
F: (717) 591-1756
sstein@pjrlaw.com
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
KEVIN ARMSTRONG
a/k/a KEVIN D. ARMSTRONG and
AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG
Defendants
MORTGAGE FORECLOSURE
NO. 2006 - 1300 CIVIL TERM
PETITION TO SET ASIDE SHERIFF'S SALE
OF REAL PROPERTY
AND NOW COMES the above-named Defendants by and through their attorney Scott
A. Stein, Esquire and files the within petition upon the grounds hereinafter more fully set forth:
1. Defendants Kevin Armstrong and Amy Armstrong are the title owners of
premises identified as 1722 Sherwood Road, New Cumberland, Pennsylvania.
2. Notice of Sheriffs Sale of Real Property was sent to the defendants at the
property address of 1722 Sherwood Road, New Cumberland, Pennsylvania by Counsel for
Plaintiff, Udren Law Offices, P.C. prior to the sale.
3. The notice sent by Plaintiff advised defendants that the sheriff s sale of the
property was scheduled for September 5, 2007 at 10:00 am in the James Lorah Auditorium,
1? .
Broad and Main Streets, Doylestown, Pennsylvania. (A true and correct copy of the Notice is
attached hereto as Exhibit A).
4. The defendants traveled to Doylestown on the date of the Sheriffs Sale and were
informed by the Sheriff s Office that their property was not being sold by the Sheriff in
Doylestown and that the property should be sold by the Sheriff of Cumberland County.
5. Defendants missed the sale of their property as a direct result of the improper
notice received from counsel for plaintiff.
6. To permit the present sale to go through, especially in view of the inadequacy of
the notice provided to defendants would constitute, in the opinion of counsel for the defendants,
a gross miscarriage of equitable justice.
WHEREFORE, petitioners request that this Court set aside the sheriff's sale of the
property or in the alternative, enter a rule on the plaintiff, JP Morgan Chase Bank, the Sheriff of
Cumberland County, and the prospective purchaser, to show cause why the Sheriff s Sale. of the
defendants' property should not be set aside.
The Law Offices of Peter I Russo, P.C.
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Scott-A Stein, Esquire
Attorney I.D. No. 81738
3800 Market Street
Camp Hill, PA 17011
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
Attorney for Plaintiff
Date:
YFRHgCA110N
1, Awvln i.), Amisimns and Amy .i. Armstrong, verily tiwt the statements etude in this
Pelidon we true and mot. I undwdnd that false its made hatin are subject to the
penaities or I's Ya.i:,a. § 4W4 relating to unworn taisiucation to aumontics.
Doft: NO
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LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: SCOTT A. STEIN, ESQUIRE
PA Supreme Court ID: 81738
3800 Market Street
Camp Hill, PA 17011
PH: (717) 591-1755
F: (717) 591-1756
sstein@pjrlaw.com
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : MORTGAGE FORECLOSURE
KEVIN ARMSTRONG NO. 2006 - 1300 CIVIL TERM
a/k/a KEVIN D. ARMSTRONG and
AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG
Defendants
CERTIFICATE OF SERVICE
I, Scott A. Stein, Esquire, hereby certify that I am on this day serving a copy of the
foregoing Petition to Set Aside Sheriff's Sale upon the person and in the manner indicated
below:
First Class Mail addressed as follows:
Mark J. Udren, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
ott A. Stein, Esquire
Date: l e r - C-7
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LAW OFFICES OF PETER J. RUSSO, P.C.
BY: PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
3800 Market Street
Camp Hill, PA 17011
PH: (717) 591-1755
F:(717)591-1756
prusso@pjrlaw.com
Attorneys for Defendants
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
KEVIN ARMSTRONG
a/k/a KEVIN D. ARMSTRONG and
AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG
Defendants
: MORTGAGE FORECLOSURE
: NO. 2006 - 1300 CIVIL TERM
ADDENDUM TO PETITION TO SET ASIDE SHERIFF'S SALE
OF REAL PROPERTY
AND NOW COMES the above-named Defendants by and through their attorney Peter J.
Russo, Esquire and in compliance with local rules files the attached Addendum to their Petition
to Set Aside Sheriff s Sale of Real Property:
Pursuant to Cumberland County Local Rule 208.3(a)(2), it is the assertion of
undersigned counsel that no Judge has ruled upon any other issue in this or any related matter.
2. Pursuant to Cumberland County Local Rule 208.3(a)(9), after speaking with
Attorney Stuart Winneg and requesting his concurrence or non-concurrence with Defendants'
filing of this petition, it is the assertion of undersigned counsel that Plaintiff, by and through their
counsel, Stuart Winneg, Esquire did not concur with the filing of this Petition to Set Aside
Sheriffs Sale of Real Property.
Thel.aw-Offiee-ofIWer ,Ru-sso, P.C.
Peter J. Russo, Esqu
Attorney I.D. No. 72897
3800 Market Street
Camp Hill, PA 17011
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
Attorney for Defendants
Date: October 11, 2007
LAW OFFICES OF PETER J. RUSSO, P.C.
BY: PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
3800 Market Street
Camp Hill, PA 17011
PH: (717) 591-1755
F:(717)591-1756
prusso@pjrlaw.com
Attorneys for Defendants
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
KEVIN ARMSTRONG
a/k/a KEVIN D. ARMSTRONG and
AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG
Defendants
: MORTGAGE FORECLOSURE
NO. 2006 - 1300 CIVIL TERM
CERTIFICATE OF SERVICE
I, Peter J. Russo, Esquire, hereby certify that I am on this day serving a copy of the
foregoing Addendum to Petition to Set Aside Sheriff's Sale upon the person and in the manner
indicated below:
First Class Mail addressed as follows:
Mark J. Udren, Esquire
Stuart Winneg, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
I I 1 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Peter J. Russo, Esqu
Date: October 11, 2007
N
OCT 0520074
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : MORTGAGE FORECLOSURE
KEVIN ARMSTRONG NO. 2006 - 1300 CIVIL TERM
a/k/a KEVIN D. ARMSTRONG and
AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG
Defendants
ORDER OF COURT
AND NOW, this day of 6j T , 2007 upon consideration of
the within Petition to Set Aside the Sheriff's Sale of Real Property, a Rule is hereby entered on the
Sheriff of Cumberland County, and JP Morgan Chase Bank, to show cause why the sheriff s sale
covering the premises identified as 1722 Sherwood Road, New Cumberland, Pennsylvania,
exposed for sheriffs sale on Sep+t?ember 5, 2007, should not be set aside. Z&91
Rule returnable on the a t? day of If> , 2007 at . ?d o'clock:
FM. in Courtroom number 3 , of the Cumberland County Courthouse, One Courthouse
Square, Carlisle, Pennsylvania. All proceedings to stay meanwhile, including further proceedings in
connection with the Sheriffs Sale.
BY THE COURT,
J.
Distribution:
Scott A. Stein, Esquire0 Market Street, Camp Hill, PA 17011
dark J. Udren, Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Cumberland County Sheriff '
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SO :8 V 9 1 130 LCOZ
AUVIC, :'Hi JO
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Bank on New York Co Tr is the grantee the same having been sold to said
grantee on the 5th day of Sept A.D., 2007, under and by virtue of a writ Execution issued on the 29th
day of March, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2006
Number 1300, at the suit of JPMorgan Chase Bank Tr against Kevin Armstrong aka Kevin D AM
Armstrong aka AmyJ is duly recorded as Instrument Number 200727252.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this )'(0 day of
A.D. 4-0
Recorde of Deeds
• '
ky em51m E*h' #* ft INo PA
Mey d,?n JWL.IIOtO
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JP Morgan Chase Bank, as Trustee In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
Kevin Armstrong a/k/a Kevin D. Armstrong Writ No. 2006-1300 Civil Term
and Amy Armstrong a/k/a Amy J.
Armstrong
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on May 25, 2007 at 1138 hours, he served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendants,
to wit: Kevin Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a.k.a Amy J.
Armstrong, by making known unto Amy Armstrong a/k/a Amy J. Armstrong personally,
and wife of Kevin Armstrong a/k/a Kevin D.Armstrong, at 1722 Sherwood Road, New
Cumberland, Cumberland County, Pennsylvania its contents and at the same time
handing to her personally the said true and correct copy of the same.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that
on July 11, 2007 at 1320 hours, he posted a true copy of the within Real Estate Writ,
Notice, Poster and Description, in the above entitled action, upon the property of Kevin
Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a/k/a Amy J. Armstrong
located at 1722 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Kevin Armstrong a/k/a Kevin D. Armstrong and Amy Armstrong a/k/a
Amy J. Armstrong, by regular mail to their last known address of 1722 Sherwood Road,
New Cumberland, PA 17070. These letters were mailed under the date of July 2, 2007
and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
that after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on September 5, 2007 at 10:00 o'clock A.M. He sold the same for
the sum of $1.00 to Attorney Mark Udren on behalf of The Bank of New York Trust
Company as Successor to JP Morgan Chase Bank as Trustee. It being the highest bid and
best price received for the same, The Bank of New York Trust Company as Successor to
JP Morgan Chase Bank as Trustee of One Meridian Crossings, Suite 100, Minneapolis
MN 55423, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of
$1,278.28.
Sheriff s Costs:
Docketing $30.00
Poundage 25.06
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Mileage 32.64
Levy 15.00
Surcharge 30.00
Law Journal 491.00
Patriot News 482.39
Share of Bills 15.69
Distribution of Proceeds 25.00
Sheriff s Deed 41.00
$1,278.28
So Answers:
00
R. Thomas Kline, Sheriff
BY !IC
Real Estate rgeant
K 9' /6/7/0 1
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UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTY I.D. NO.-04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
ATTORNEY FOR PLAINTIFF
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
€ Cumberland County
V. _
Kevin Armstrong
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant (s)
:MORTGAGE FORECLOSURE
:NO. 06-1300 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, as Trustee, Plaintiff in the above action, by
its attorney, Mark J. Udren, ESQ., sets forth as of the date the
Praecipe for the Writ of Execution was filed the following
information concerning the real property located at: 1722 Sherwood
Road, New Cumberland, PA 17070
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Kevin Armstrong
a/k/a Kevin D. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address
Joanna Ward Neidig
506 Lamp Post Ln.
Camp Hill, PA 17011
4. Name and address of the last recorded holder of every mortgage
of record:
Name Address
JPMorgan Chase Bank
as Trustee
9275 Sky Park Court, 3rd Floor
San Diego, CA 92123
1W
5. Name and address of every other person who has any record lien
on the property:
Name Address
none
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address
Tax Claim Bureau
55 East Court Street
Doylestown, PA 18901
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
30 East Court Street
Doylestown, PA 18901
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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:
Name Address
Tenants/Occupants
1722 Sherwood Road
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. sec. 4904 relating to
unsworn falsification to authorities.
UDREN LAW OFFICES, P.C.
DATED: March 20, 2007
rUrk J. Udren, ESQ.
Attorney for Plaintiff
•* r
UDREN LAW OFFICES, P.C.
BY: Mark J. Udren, Esquire
ATTORNEY FOR PLAINTIFF
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee :COURT OF COMMON PLEAS
Plaintiff :CIVIL DIVISION
Cumberland County
V.
;MORTGAGE FORECLOSURE
Kevin Armstrong NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J Armstrong
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Kevin Armstrong
a/k/a Kevin D. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Your house (real estate) at 1722 Sherwood Road, New Cumberland, PA
17070 is scheduled to be sold at the Sheriff's Sale on September
5, 2007, at 10:00 am in the James Lorah Auditorium, Broad & Main
Streets, Doylestown, PA, to enforce the court judgment of
$164,569.43, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how much
you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You
may also ask,the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
y
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to
the highest bidder. You may find out the price bid by calling 856-669-5400.
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
856-669-5400.
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 the 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 30 days after the 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 Schedule of
Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
j .
ALL THAT CERTAIN tract or parcel of land situate in the Borough of Now
Cumberland, County of Cumberland, Commonwealth ofPennsyivania, more particularly bounded
and described according to a murve:yofD.P. Raffensperger, Rgistorod Surveyor, dated July 25,1956,
as follows:
BEGINNING at apoint on the western line of9herwood Road, sevenbtmdred thirty
and twenty-three one-himdredtba (730.23) feet South ofthe Southwest comer of the intersection of
Sherwood Road and Brandt Avenue, also being at the dividing line betweenLot No. 20 and Lot No.
21, Block "A" of the-hereinaftermentioned Plsn of Lots; thence Soudmm-dly along the Western line
of Sherwood Road, fly-five (55) fact to a point at the div ftg line between Lot No. 19 and LotNo.
20, Block "A." on said Plan, thence Wcstwaradly along same, said lieu running at right angles to
Sherwood Road, one hundred twenty (120) feet t6 a, point on the Bastern right-of-way line of'York
Baltimore Bxpressway; thence Northwattily along some stty--five (55) feet to a point at the dividing
line between Lot No. 21 and Lot No. 20, B1cak "A" on said Plan; thane Eastwa dly along same and
at right angles to Sherwood Road, one hundred twenty (120) fWlto a point, the Place of
3313OD NINA,
BM G Lot No. 20, Block "A" on Pfau of Highland Park Rdmdon, said Plan
recorded in 0f6w ofthe-Recorder oMecds in and for Cumberland County in P1=Baok 5, Page 59.
.HAVING thereon crated a one story, iisme dwelling house, known and munberod
as 1722 Shenvood Road.
UNDMAND SUBJECi'to an ari=a= ofthc Commonwealth of Peumsyhmdafor
Highway slope ptuposes as shown on said Plan along the rear portion thereof
UNDER AND SUBJECT to an casement in favorofthe Now CumberlandBamugh
Authority for thematute naneeofasauttarysewerlinea's now esdad"gupon the groumdalong therm .
portion of said lot, created by a grant dated December 23. 1953, sad intended to be recorded.
BEING KNOWN AS: 1722 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070
PROPERTY ID NO.: 26-23-0543-191
TITLE TO SAID PREMISES IS VESTED IN KEVIN D. ARMSTRONG AND AMY J.
ARMSTRONG, HUSBAND AND WIFE BY DEED FROM JEFFREY R. BESHORE AND
MARLA R. BESHORE, HUSBAND AND WIFE DATED 06/30/04 RECORDED 08/06/04
IN DEED BOOK 264 PAGE 2935.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
f ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
JPMorgan Chase Bank, as Trustee 'COURT OF COMMON PLEAS
Plaintiff ;CIVIL DIVISION
:Cumberland County
V.
:MORTGAGE FORECLOSURE
Kevin Armstrong NO. 06-1300 CIVIL TERM
a/k/a Kevin D. Armstrong
Amy Armstrong
a/k/a Amy J. Armstrong
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Amy Armstrong
a/k/a Amy J. Armstrong
1722 Sherwood Road
New Cumberland, PA 17070
Your house (real estate) at 1722 Sherwood Road, New Cumberland, PA
17070 is scheduled to be sold at the Sheriff's Sale on September
5, 2007, at 10:00 am in the James Lorah Auditorium, Broad & Main
Streets, Doylestown, PA, to enforce the court judgment of
$164,569.43, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how much
you must pay, you may call: (856)-669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to
strike or open the judgment, if the judgment was improperly entered. You
may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RfGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
J
1. If the Sheriff's Sale is not stopped, your property will be sold to
the highest bidder. You may find out the price bid by calling 856-669-5400.
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
856-669-5400.
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 the 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 30 days after the 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 Schedule of
Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE 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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
a a
ALL THAT CERTAIN tract or parcel of land situate in the Borough of New
Cumberland, Cot mty of Cumberland, Commonwealth of Pennsylvania, more particularly bounded
and described accordingto a surveyofD.P. Raffensperger, Rogistmvd Surveyor, dated July 25, 1956,
as follows:
BEGINNING at apoint on tht westernlint of 5`hmvood Road, seven hundred thirty
and twenty-three one-hun&edths (730.23) facet South ofthe Southwest corner of the intersection of
Sherwood Road and Brandt Avenue, also being at the dividing Em between Lot No. 20 and lAt No.
21, Block "A" oftba-herakeftermondonedPlanofLots; thence Souttmwdlyalong the Westezu line
of Sherwood Road, fifty-five (55) fact to a point at the dividing lase between Lot No. 19 and LotNo.
20, Block W = said Plan; thence Wcstwardly along samr, said line running at right angles to
Sherwood Road, one hundred twenty (120) feet to a point on the But= right-of-way line of York
Baltimore Bxpressway; thence Northwardly along same fl#ty--five (55) feet to a point at the dividing
line between Lot No. 21 sad Lot No. 20, Block "A" on said Plan; thence Bastwardly along same and
at right angles to Sherwood Road, one hundred twenty (120) faWlto a point, the Place of
BECIIlVNTNQ,
BM G Lot No. 20, Block "A" on Phu of Highlnnd Park P.atatsion, said Plan
recorded in Office ofthe-Recorder of Deeds in and for Cumberland County in Pl=Book 5, Page 59.
HAVING thereon eected a one story, frame dwelling house, known and munberad
as 1722 Sherwood Road.
. UNDERAND SUBJECTto an easement ofthe Commonwealth ofPeamsylvamafor
Highway slope purposes as shoatn on said Plan along the raw portion thereof
MER AND SUWECI' to an easement in favor ofthe Now Camberlaad Borough
Authority for the maintenance of a sanitary sewer litre as now exdsdng upon the groundalong the rear .
porttoa of said lot, created by a grant dated December 23. 1953, and intended to be reearded.
BEING KNOWN AS: 1722 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070
PROPERTY ID NO.: 26-23-0543-191
TITLE TO SAID PREMISES IS VESTED IN KEVIN D. ARMSTRONG AND AMY J.
ARMSTRONG, HUSBAND AND WIFE BY DEED FROM JEFFREY R. BESHORE AND
MARLA R. BESHORE, HUSBAND AND WIFE DATED 06/30/04 RECORDED 08/06/04
IN DEED BOOK 264 PAGE 2935.
WRIT OF EXECUTION and/or ATTACHMENT
t
COMMONWEALTH OF PENNSYLVANIA) NO 06-1300 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, AS TRUSTEE,
Plaintiff (s)
From KEVIN ARMSTRONG A/K/A KEVIN D. ARMSTRONG AND AMY ARMSTRONG
A/K/A AMY J. ARMSTRONG
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $164,569.43
L.L. $.50
Interest FROM 3/21/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $33.19 TO
ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $5,609.11
Atty's Comm %
Atty Paid $154.96
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: MARCH 29, 2007
(Seal)
REQUESTING PARTY:
Name MARK J. UDREN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
d1,11h - I -I::-
&I - d-.,
Curs R. Long, P nota
By:
Deputy
Supreme Court ID No. 04302
I..LJ
Real Estate Sale # 07
On April 13, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
New Cumberland Borough, Cumberland County, PA
Known and numbered as 1722 Sherwood Road,
New Cumberland, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: April 13, 2007 By:
Real Estat Sergeant
1 E '8 ,V S - 8d'V H-01
J? r_. , .
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Shannon D. Billhime, being duly sworn according to law, deposes and says:
That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st
day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY _
SALE #7
. ..... . . ..................
Sworn to and subscribed betl,iQIfa?r-p?g}Q??i1-D•
Sad
"erry pucirc
?;ity of itu; r?urg; u?wphin Colirty
f V^
amm? i011 Expire;JL)!-, ; 20,b'
M@ oki?r 4?a c .,anta AScArir,t` nr 1?f?1A7?
NOTAOY P LIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
+14. 11" W-
ve
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AnrAM MW
Aft-
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ALL nW CEMN tta¢t of puml of land
sitotdc m. aw talp* of *w b mheriaad,
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MAIaf.A R i1B4?N ? ANiD
IN
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 20, July 27, and August 3, 2007
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
a Marie Coyne ditor
SWORN TO AND SUBSCRIBED before me this
__2 __day of August, 2007
Notary
NOTARIAL SEAL
DEBORAH A COWNS
Notary Pubac
CARLISLE BORO. CUMBERLAND COINViy
My COmmluion EXI*6$ Apr 28, 2010
REAL ESTATE SALE NO. 7
Writ No. 2006-1300 Civil
JP Morgan Chase Bank, as Trustee
vs.
Kevin Armstrong a/k/a Kevin D.
Armstrong and Amy Armstrong
a/k/a Amy J. Armstrong
Atty.: Mark Udren
DESCRIPTION
ALL THAT CERTAIN tract or parcel
of land situate in the Borough of New
Cumberland, County of Cumberland,
Commonwealth of Pennsylvania,
more particularly bounded and de-
scribed according to a survey of D.P.
Raffensperger, Registered Surveyor,
dated July 25, 1956, as follows:
BEGINNING at a point on the
western line of Sherwood Road,
seven hundred thirty and twenty-
three one-hundredths (730.23) feet
South of the Southwest corner of
the intersection of Sherwood Road
and Brandt Avenue, also being at the
dividing line between Lot No. 20 and
Lot No. 21, Block "A" of the herein-
after mentioned Plan of Lots; thence
Southwardly along the Western line
of Sherwood Road, fifty-five (55) feet
to a point at the dividing line between
Lot No. 19 and Lot. No. 20, Block "A"
on said Plan; thence Westwardly
along same, said line running at
right angles to Sherwood Road, one
hundred twenty (120) feet to a point
on the Eastern right-of-way line of
York-Baltimore Expressway; thence
Northwardly along same fifty-five
(55) feet to a point at the dividing
line between Lot No. 21 and Lot No.
20, Block "A" on said Plan; thence
Eastwardly along same and at right
angles to Sherwood Road, one hun-
dred twenty (120) feet to a point, the
Place of BEGINNING.
BEING Lot No. 20, Block "A" on
Plan of Highland Park Extension,
said Plan recorded in Office of the
Recorder of Deeds in and for Cum-
berland County in Plan Book 5,
Page 59.
HAVING thereon erected a one
story frjM_? d welling house, known
and numbered as 1722 Sherwood
Road.
UNDER AND SUBJECT to an
easement of the Commonwealth of
Pennsylvania for Highway slope pur-
poses as shown on said Plan along
the rear portion thereof.
UNDER AND SUBJECT to an
easement in favor of the New Cum-
berland Borough Authority for the
maintenance of a sanitary sewer line
as now existing upon the ground
along the rear portion of said lot, cre-
ated by a grant dated December 23,
1953, and intended to be recorded.
BEING KNOWN AS: 1722 SHER-
WOOD ROAD, NEW CUMBERLAND,
PA 17070.
PROPERTY ID NO.: 26-23-0543-
191.
TITLE TO SAID PREMISES IS
VESTED IN Kevin D. Armstrong and
Amy J. Armstrong, husband and wife
by deed from Jeffrey R. Beshore and
Marla R. Beshore, husband and wife
dated 06/30/04 recorded 08/06/04
in Deed Book 264 Page 2935.
JP MORGAN CHASE BANK, as TRUSTEE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS MORTGAGE FORECLOSURE
KEVIN ARMSTRONG a/k/a KEVIN D. NO. 2006-1300 CIVIL TERM
ARMSTRONG and AMY ARMSTRONG
a/k/a AMY J. ARMSTRONG,
Defendant
ORDER OF COURT
AND NOW, this 29th day of October, 2007, this matter
having been resolved by agreement of the parties as placed upon the
record in open court, the parties' agreement is adopted as an order
of this Court.
/Urden Law Offices, P.C.
Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
V/Law Offices of Peter J. Russo, P.C.
Peter J. Russo, Esquire
3800 Market Street
Camp Hill, PA 17011
?p ex mu c
P
?07
:mlc
c
r y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA, CIVIL DIVISION
JPMorgan Chase Bank, as Trustee € NO. 06-1300
Plaintiff
V.
Kevin Armstrong a/k/a Kevin D. Armstrong _
and Amy Armstrong a/k/a Amy J. Armstrong
Defendants
CONSENT ORDER
dam`
AND NOW, to wit, this /1D day of Dw? 92007,
upon consideration of Defendants' Petition to Set Aside Sheriff's Sale and the Plaintiff's
response, by consent of the parties, the terms of which were placed on the record on October 29,
2007, it is hereby ORDERED AND DECREED as follows:
The Petition to Set Aside Sheriffs Sale is hereby dismissed with prejudice;
2. Plaintiff shall pay to Defendants the sum of $2,500.00 within 10 days of the date
of this Order;
3. Plaintiff is hereby granted Judgment for Possession of the premises located at
1722 Sherwood Road, New Cumberland, PA 17070 ("Premises"), except that Defendants shall
remain in the premises as conditioned below;
4. Defendants shall vacate the subject premises on or before December 28, 2007;
5. Defendants shall leave the premises in broom clean condition;
6. In the event that the Defendants vacate the premises on or before December 28,
2007, Plaintiff shall file appropriate discontinuance documents with the Prothonotary regarding
these proceedings and Plaintiff shall thereafter waive any deficiency rights against the
Defendants pertaining to this matter;
7. In the event that the Defendants vacate the premises as set forth hereinabove,
Plaintiff shall diligently provide written correspondence to the Defendants setting forth that the
foreclosure proceedings would be dismissed forthwith; and
In the event that the Defendants fail to vacate the premises on or before December
28, 2007, Plaintiff is entitled to immediate possession of the premises and may utilize a certified
copy of this Order with a proposed Writ of Possession pursuant to this docket number and these
proceedings for submission to the Prothonotary for immediate issuance of a Writ of Possession
without additional proceedings so that the Sheriff can evict/eject the Defendants from the
premises as early as December 29, 2007.
9. The Defendants hereby agree to release and forever discharge the Plaintiff, and
each of the officers, directors, shareholders, partners, attorneys, predecessors, successors,
representatives, insurers, assignees, agents, employees, executors, administrators, heirs, and all
persons acting by, through, or in any way on behalf of the parties, of and from any and all claims,
debts, defenses, liabilities, costs, attorneys' fees, actions, suits at law or equity, demands,
contracts, expenses, damages, whether general, specific, punitive, exemplary or contractual, and
causes of action of any kind or nature in connection with the subject matter of this litigation.
10. In the event that the Defendants fully comply with the terms and conditions of this
Agreement, Plaintiff shall waive its rights to in accordance with the Deficiency Judgment Act, 42
P.S. 8103.
AND AGREED:
?ICES. P.C.
By:?
Alan N
Attorney
Attorney
Entered
2007
Edward E. Guido,
Xhl vm
Ls?
6ep, ?usso J
.ato, Esq.
Plaintiff
PETER J. RUSSO, P.C.
i
Peter J. Russo, Esq.
Attorney for Defendants
of
J.
0C :6 14V 1 i 0-i0 LODZ
"-trq f n-;