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HomeMy WebLinkAbout06-4972#19300-TM MARTHA E. VON ROSENSTIEL, P.C Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 C FC Attorney for Plaintiff JP Morgan Chase Bank, as : COURT OF COMMON PLEAS trustee, in trust for the : Cumberland COUNTY Holders of Truman Mortage Loan . Trust 2002-2 Asset-Backed Certificates, Series 2002-2 47? ??ULC 1 c/o Select Portfolio Servicing, Case No: ?? - Inc. 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff VS. Steven P. Conrad and Shelly R. Conrad 314 Wertzville Road Enola, PA 17025 Defendants CIVIL ACTION - MORTGAGE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment maybe 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dies de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con on abogado y entregar a la corte en forma escrita sus defenses o sus objeciones a las demandas en contra de so persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra soya 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 o otros de rechos importantes Para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166-- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 JP Morgan Chase Bank, as COURT OF COMMON PLEAS trustee, in trust for the Cumberland COUNTY Holders of Truman Mortage Loan Trust 2002-2 Asset-Backed Certificates, Series 2002-2 c/o Select Portfolio Servicing, Case No: CJto l 1. ""' l Inc. 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff VS. Steven P. Conrad and Shelly R. Conrad 314 Wertzville Road Enola, PA 17025 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is JP Morgan Chase Bank, as trustee, in trust for the Holders of Truman Mortage Loan Trust 2002-2 Asset-Backed Certificates, Series 2002-2, a bank organized and existing under state law, with offices for the conduct of business at c/o Select Portfolio Servicing, Inc., 3815 South West Temple, Salt Lake City, Utah 84165. 2. Defendants, Steven P. Conrad and Shelly R. Conrad are the mortgagors and real owners of premises 314 Wertzville Road, Enola, PA 17025, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Alliance Funding on January 18, 2001, which mortgage was recorded on January 12, 2001 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1663, Page 755, secured on premises 314 Wertzville Road, Enola, PA 17025 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from October 12, 2005 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 09/12/05 to 08/24/06 At $21.53 per diem Accrued late charges to 08/24/06 Accrued Escrow deficit to 08/24/06 Corporate Advances NSF Fees Attorney's fee (5$ of unpaid Principal Balance) Title Information Certificate Photostats and Postage Notarizations Suspense Balance TOTAL $62,859.22 $ 7,449.38 $ 1,677.15 $ 1,356.42 $ 1,292.86 $ 30.00 $ 3,142.96 $ 515.00 $ 50.00 $ 10.00 ($ 207.01) $78,175.98 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $78,175.98, plus per diem interest at $21.53 from August 25, 2006 to the date 9f judgment plus costs thereon. Martha E. Von Rosenstiei Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. By: Title: Vice President LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on a State Road, which iron pin is at the dividing line between Lots No. 4 and 5 on the hereinafter mentioned Plan of Lots; thence along same, South 14 degrees 45 minutes West 153 feet to a stake; thence South 78 degrees 22 minutes West 32.5 feet to a stake at the dividing line between Lots No. 3 and 4 on said Plan of Lots; thence along same, North 05 degrees 36 minutes East 176 feet to a point on the Southerly line of said State Road; thence along same, South 68 degrees 47 minutes East 57.65 feet to an iron pin, the place of beginning. BEING Lot No. 4 on the Plan of West Enola, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 1, Page 29. HAVING thereon erected a one and one-half story frame dwelling house known and numbered as 314 Wertzville Road, Enola, PA 17025. Tax Parcel #09-14-0834-260 ?y EXHIBIT Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, UT 84165-0250 DATE: 7/12/06 19300-TM TO: Steven P. Conrad and Shelly R. Conrad 314 Wertzville Road Enola, PA 17025 FOR PROPERTY ADDRESS: 314 Wertzville Road Enola, PA 17025 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. Counsellne Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed /VV-1VVJ/. EXHIBIT This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNl'O ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION EVEWEDITAMENTE LLAMANDO ESTA AGENCEA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A RED111HR SU HH'OTECA. HOMEOWNER'S NAME(S) Steven P. Conrad and Shelly R. Conrad PROPERTY ADDRESS: 314 Wertzville Road. Enola. PA 17025 LOAN ACCOUNT NO: #: 0002196343 CURRENT LENDER/SERVICER: Select Portfolio Servicing, Inc. SERVICER FOR: JP Morgan Chase Bank, as trustee, in trust for the HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HOME FROM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. -IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, -IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND -IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of thenonsumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and teleohone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Brine it uo to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 314 Wertzvllle Road. Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments 10/12/05 to 07/12/06 @ $ 857.29 per month $8,572.90 Late Charges $1,677.15 NSF Charges $ 30.00 Corporate advances $ 108.55 Suspense ($ 207.01) TOTAL AMOUNT PAST DUE $10,181.59 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ PL US ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYPERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: Select Portfolio Servicine Inc. 3815 South West Temple, Salt Lake City, Utah 84165 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaeed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 8 months from the date set forth in this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Select Portfolio Servicing, Inc. Address: 3815 South West Temple, Salt Lake City. Utah 84165 Phone Number: 1-800-635-9698 Contact Person: LOAN RESOLUTION DEPARTMENT EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney" fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: -TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTEHR LENDING INSTITUTION TO PAY OFF THIS DEBT. -TO HAVE THIS MORTGAGE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF -TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). -TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. -TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. -TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511-2227 CUMBERLAND COUNTY Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717)232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717)762.3285 PHFA 2101 North Front Street Harrisburg, PA 17140..... 800.342-2397 Urban League of Metropolitan Hbg 2107 N. 6th Street Harrisburg, PA 17101 (717)234.5925 Effective 1012312003 at 7:00:11 AM 4 l _ l 2'`? w s1 ? (,a R F ? 4 , SHERIFF'S RETURN - REGULAR iI ` % CASE NO: 2006-04972 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS CONRAD STEVEN P ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE CONRAD STEVEN P was served upon the DEFENDANT , at 0018:40 HOURS, on the 12th day of September, 2006 at 314 WERTZVILLE ROAD ENOLA, PA 17025 STEVEN CONRAD a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.20 Affidavit .00 - Surcharge 10.00 R. Thomas Kline .00 41.20.,-- 09/13/2006 MARTHA VON ROSENSTEIL Sworn and Subscibed to By: before me this day eputy erif of A.D. by handing to CASE NO: 2006-04972 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS CONRAD STEVEN P ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon CONRAD SHELLY R the DEFENDANT , at 0018:40 HOURS, on the 12th day of September, 2006 at 314 WERTZVILLE ROAD ENOLA, PA 17025 STEVEN CONRAD (HUSBAND a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 "E"?•?., Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 ? 09/13/2006 R/a2lo& MARTHA VON ROSENSTEIL Sworn and Subscibed( to By: before me this day D puty Sheriff 11 of A.D. by handing to 19300- CPG -RD Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 JP MORGAN CHASE BANK, AS TRUSTEE,: IN TRUST FOR THE HOLDERS OF TRUMAN MORTAGE LOAN TRUST 2002-: 2 ASSET-BACKED CERTIFICATES, SERIES 2002-2 C/O SELECT PORTFOLIO SERVICING, INC. Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY No: 06-4972 Civil Term Plaintiff vs. STEVEN P. CONRAD AND SHELLY R. CONRAD Defendants PRAECIPE TO MARK CASE DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark this action discontinued and ended without prejudice. Martha E. Von 1Z'oser Attorney for Plaintiff Dated: February 25, 2008 ?a r?' n"-r i .;., Y :; ? _ ??w __ .;, ?.:' --a? ?::. - ? ..