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HomeMy WebLinkAbout07-1092MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File 9.05784 Nationstar Mortgage, LLC 350 Highland Drive Lewisville, TX 75067, Plaintiff, Vs. Harold Lytle 865 Doggett Road Forest City, NC 28043-8150, and Robin G. Lytle 865 Doggett Road Forest City, NC 28043-8150, COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: Q7 - IM) Ct' v?? CIVIL ACTION MORTGAGE FORECLOSURE Defendants. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Notice to Defend 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 ?**?**,r*****sr***?,e**,???r,?xyr,?rx?,ir??r*****?r**nr?r?**?*?r?rr*x?t*?x*x?**?r*?r?ie?t?r?x?,?r?r****,?r,re??r,ir??r?r NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. MILSTEAD & ASSOCIATES, LLC BY:Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Nationstar Mortgage, LLC, 350 Highland Drive Lewisville, TX 75067 Plaintiff, Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: i'- 149 2 ?' ! T Vs. Harold Lytle 865 Doggett Road Forest City, NC 28043-8150, CIVIL ACTION MORTGAGE FORECLOSURE and Robin G. Lytle 865 Doggett Road Forest City, NC 28043-8150, Defendants. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, Nationstar Mortgage, LLC (the "Plaintiff'), is a Maryland corporation registered to conduct business in the Commonwealth of Pennsylvania and having an office and place of business at 350 Highland Drive, Lewisville, TX 75067. 2. Defendants, Harold Lytle and Robin G. Lytle, (collectively, the "Defendants"), are adult individuals and are the real owners of the premises hereinafter described. 3. Harold Lytle, Defendant, resides at 865 Doggett Road, Forest City, NC 28043-8150. Robin G. Lytle, Defendant, resides at 865 Doggett Road, Forest City, NC 28043-8150. 4. On September 30, 2005, in consideration of a loan in the principal amount of $131,250.00, the Defendants executed and delivered to Corestar Financial Group, LLC a note (the "Note") with interest thereon at 10.3 percent per annum, payable as to the principal and interest in equal monthly installments of $1181.01 commencing December 1, 2005. 5. To secure the obligations under the Note, the Defendants executed and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Corestar Financial Group, LLC a mortgage (the "Mortgage") dated September 30, 2005, recorded on October 10, 2005 in the Department of Records in and for the County of Cumberland under Mortgage Book 1926, Page 1262. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. Plaintiff is proper party plaintiff by way of an assignment to be recorded. 6. The Mortgage secures the following real property (the "Mortgaged Premises"): 1580 Holtz Road, Enola, PA 17025. A legal description of the Mortgaged Premises is attached hereto as Exhibit "A" and made a part hereof. 7. The Defendants are in default of their obligations pursuant to the Note and Mortgage because payments of principal and interest due September 1, 2006, and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late charges, escrow deficit (if any) and costs of collection including title search fees and reasonable attorney's fees. 8. The following amounts are due on the Mortgage and Note: Balance of Principal ................................$130,681.77 Accrued but Unpaid Interest from 8/1/06 to 2/27/07 @ 10.3% per annum ($36.88 per diem) ........................................$7,781.68 Accrued Late Charges ....................................$354.30 Corporate Advance .........................................$529.00 Title Search Fees ............................................$350.00 Deferred Late Charges ....................................$118.10 Reasonable Attorney's Fees ........................$1,250.00 TOTAL as of 02/27/2007 ........................ $141,064.85 Plus, the following amounts accrued after February 27, 2007: Interest at the Rate of 10.3 per cent per annum ($36.88 per diem); Late Charges of $59.05 per month. 9. Plaintiff has complied fully with Act No. 91 (35 P.S.' 1680.401(c) of the 1983 Session of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the Defendant, Harold Lytle at 1580 Holtz Road, Enola, PA 17025 as well as to address of residences as listed in paragraph 3 of this document on November 3, 2006 and to the Defendant, Robin G. Lytle on January 3, 2007 the notice pursuant to § 403-C of Act 91, and the applicable time periods therein have expired. True and correct copies of such notices are attached hereto as Exhibit "B" and made apart hereof. WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8, namely, $141,064.85, plus the following amounts accruing after February 27, 2007, to the date of judgment: (a) interest of $36.88 per day, (b) late charges of $59.05 per month, (c) plus interest at the legal rate allowed on judgments after the date of judgment, (d) additional attorney's fees (if any) hereafter incurred, (e) and costs of suit. MILSTEAD & ASSOCIATES, LLC Chrisovalante P. Fliakos, Esquire Attorney for Plaintiff VERIFICATION I, Chrisovalante P. Fliakos, hereby certify that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff's behalf. I verify that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C. S. ' 4904, relating to unswom falsification to authorities. Name: Chrisovalante P. Fliakos, Esquire Title: Attorney Dec-19-2006 12:42pm From- EXHIBIT A Exhibit A AU THAW CERTAIN tract of land situaw in East Pwrasbom Township, Cumberland County. Pamsylvaaia, consisting of two tracts, bounded and described a3 follows, to wit: 1RACf NO. 1: BEGIIQNINt3 at Stone; thence by lends of Emanuel Holtz, south sevawr4ix and three-fourth degrees west, eighty-three and Eve-tarths pard= to a stone; thence by land of John Heck, north nine dcp= east, sWeen (16) pmebes to a store; tbcdca north seventy-six and three-four degrees east fight 4brm artd five-troths (93.5) perches to a stone; thence south nine degrees west, sixteen (16) percW to the place of BEGUMNG. Containing sever (7) gores and Wnety-nine (99) pmbes, strict measum TRANo. 2: BEGINNING at a stone an the line of 1=6 lots of Jacob R Reuaicscr and the One of lauds of David Stoaffhr, it being the nordruast point; thence vw*westwxAy along the lice of lends of late Iamb R Reeninga' and lands of Foster S. and Pstttline A. MuW, formerly Freak QwM bve nwarea forty-abbe (349) Ar.L L. o atone; thence scutbenstwardly along lands of Frank QuiS founerly ,lacob R. Ronni err, four hundred fifty (450) feet to a point, thence east madly along lands of Gertrude E. Simmons five bundled eighty Eve (585) feet to a paint, tlxsce nottl"smadly alon8 lands late of David Stouffer five bundred one (501) feet to a point, then place of BEGGING. Said property being commonly !mown as 1580 Holtz Road. EnoK Penrwylvania 17025. Tax M# 09-I1-3010-007 I Certify this to be recorded Yn Cumberland C n,nty PA #47coTder 7'0 ! of Deeds T-452 P-027/027 F-257 IKI 926PG 1282 November 03, 2006 *0003513738* Harold Lytle 1580 Holtz Rd Enola, PA 17025 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling enc. The name address and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice If you have any ouestions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente Ilamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) : PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT SERVICER Harold Lytle 1580 Holtz Rd Enola, PA 17025 259918150 Centex Home Equity Company You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments if you comply with the provision of the Homeowners' 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, 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. Page two 259918150 TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of the 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 the designated consumer 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 attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this 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 Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed 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 you application. During that additional 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 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 (Bring it up to date) NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located at 1580 Holtz Rd Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 09/01/2006: $3,543.03 (b) Late charge(s): $236.20 (c) Other charge(s): NSF & Advances $.00 (d) Less: Credit Balance $.00 (e) Total amount required as of 11/02/2006: $3,779.23 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $3,779.23, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Centex Home Equity Company at 350 HIGHLAND DR., LEWISVILLE, TX 75067. Page three 259918150 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Centex Home Equity Company also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period, you will not be required to pa attorneys' fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' 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 sheriffs sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Centex Home Equity Company Lender: Address: 350 Highland Dr., Lewisville, TX 75067 Telephone 1-888-850-9398 Number: 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' 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 borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents. • To assert any other defense you believe you may have to such action by the lender. • To seek protection under the federal bankruptcy law. PAge four 259918150 Centex Home Equity Company is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Centex Home Equity Company Centex Home Equity Company, LLC 350 Highland Dr., Lewisville, TX 75067 1-888-850-9398 JANUARY 3, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage of your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provide in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP)my be able to Help save your home. This notice explains how the progam works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies servicing your County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance A¢encv toll free at 1-800-342-2397 (Persons with impaired hearing can call (717 780-1869. This Notice contains legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SI CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO " HOMEOWER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE DALVAR SU CASA DE LA PERDOD DEL DERECHO A REDMIR SU HIPOTECA. MORTGAGOR'S NAME: Robin Lytle MAILING ADDRESS: 1580 Holtz Road, Enola, PA 17025 LOAN ACCT NO.: 0259918150 ORIGINAL LENDER/SERVICER: Centex Home Equity Company, LLC CURRENT LENDER/SERVICER: Nationstar Motgage, LLC f/k/a Centex Home Equity Company, LLC YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME {00142657} FROM FORECLOSURE AND HELP YOUR MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS IF 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 the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU 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 telephone numbers of designated consumer 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. {00142657} 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 its receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the 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 IF THIS NOTICE IF FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN A ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:\ 1580 Holtz Road, Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months are now past due: Due for 9/06-12/06 Payments = $4,724.04 Late Charges = $354.30 TOTAL AMOUNT PAST DUE: $5,078.34 HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $5,078.34 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check or money order made payable and sent to: Nationstar Mort ¢e. LLC 1750 Viceroy Dallas, TX 75235 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. {00142657} IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgaged 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 THE SHERIFF'S SALE - If you have no cured the default within the THIRTY (30) DAY period and foreclose proceedings have begun, you will 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 charges then due, reasonable attorney's fees and costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing the default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately FIVE (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of the action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Nationstar Mortgage, LLC fka Centex Home Equity Company Address: 1750 Viceroy Dallas, TX 75235 Phone Number: 1-888-850-9398 Contact Person: Default Management EFFECT OF THE 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 sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to it at the sale and that the other requirements of the mortgage are satisfied. Please contact: YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO {00142657} BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDER YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDINGS OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS TO ASSERT ANY OTER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS INCLUDED. Michael J. Milstead, Esq. Milstead & Associates, LLC {00142657} This is an attempt by a debt collector to collect a debt. Any information obtained will be used for that purpose. Unless you notify this office within thirty (30) days after receiving this notice that you dispute the validity of the debt or any portion thereof, this office will assume that this debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice that the debt, or any portion thereof, is disputed, this office will obtain verification of the debt and mail you a copy of such verification. Collection agencies are regulated by federal law which grants you certain rights. One of these is right to have us cease communication with you about this debt. If you ask us in writing to cease, we will. This law is administered by the Federal Trade Commission, Division of Credit Practices, Washington, DC 20580. If you request this office in writing within thirty (30) days after receiving this notice, this office will provide you with a name and address of the original creditor, if different from the current creditor. 100142657} \ IV v, v\ C.) O -n T r i N [3 t UJ l? ` t rl FQ ?: o 235 SOUTH 13TH STREET B&R Nationstar Mortgage, LLC -vs- Harold Lytle and Robin G. Lytle S National Association of Professional Process Servers r_X Philadelphia Association of Professional Process Servers COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 07-1092 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: B&R Control # CS037270 -1 Reference Number 9.057484 SERVICE INFORMATION )n 12 day of March, 2007 we received the Mortgage Foreclosure Complaint service upon Harold Lytle Doggett Road Forest City, NC 28043 FA Served Date ?"q W - Time ??, _ Accepted By: __ _ AMN In the manner described below. Personally served. - - - Adult family member. Relationship is Adult in charge of residence who refused to giv name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other -- - Description of Person Age Height 14 Weight Race Sex Other Q Not Served Date Time PHILADELPHIA, PA 19107 t PHONE: (215) 546-7400 FAX: (215) 985-0169 w Serice? for Profewloaals Iac. Not Served Information [] Moved Unknown No Answer ?Jl Vacant [ Other The Process Server, being duly sworn, w - deposes and says that the facts set forth HOYLE herein are true and correct to the best of their FAITH i.,,. knowledge, information and belief. NOTARY FUBUC C[ E,,T -: MID COUNTY, N.c. My C :m,T,, s cr Ev*es 410-2010 Process Server/Sheriff Law Firm Phone (856)482-1400 Fo Sworn to and subscribed before me this I t'y 1' ` day of roc MU a. flt Notary Public Chrisovalante P. Fliakos, Esquire ServeBy Date 4/4/2007 Michael Milstead, LLC Filed Date 2/28/2007 220 Lake Drive East #301, Woodland Falls Corp. Park Cherry Hill, NJ 08002 ORIGINAL 071VC *** Special Instructions *** r-I a-D .U i$ ? r? 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 WSW IR PHONE: (215) 546-7400 " FAX: (215) 985-0169 - ?' AM. or Profeuloaals Inc. National Association of Philadelphia Association Professional Process Servers of Professional Process Servers Nationstar Mortgage, LLC -vs- Harold Lytle and Robin G. Lytle COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 07-1092 AFFIDAVIT OF SERVICE B&R Control # CS037270 - 2 Reference Number 9.057484 SERVICE INFORMATION On 12 day of March, 2007 we received the Mortgage Foreclosure Complaint for service upon Robin G. Lytle j at 865 Doggett Road Forest City, NC 28045 *** Special Instructions *** Served Date ? ?A Time 3 ?? 1 1 Accepted By: -fift _ ?1?!?? ? ?!UI -t In the manner described below. Personally served. Adult family member. Relationship is Adult in charge of residence who refused to give) name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other qq-/?----- -- -- ---- Description of Person Age ,JV Height ij Weight Race Sex F Other 0 Not Served Date Time Not Served Information Moved Unknown FJ No Answer FFl Vacant j ] Other The Process Server, being duly sworn, FAI deposes and says that the facts set forth 0"o-, TH A. HOYLE herein are true and correct to the best of their NOTARY PUBLIC knowledge, information and CLEVELAND COUNTY, KC, Process Server/Sheriff? O''m-'res 41M0 Law Firm Phone (856)482-1400 Fo --- - ?' - - - _- - Sworn to and subscribed before me this I K day of LD Notary Public Chrisovalante P. Fliakos, Esquire ServeBy Date 4/4/2007 Michael Milstead, LLC Filed Date 2/28/2007 220 Lake Drive East #301, Woodland Falls Corp. Park Cherry Hill, NJ 08002 ORIGINAL 071VC f? ? -TI MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC COURT OF COMMON PLEAS 350 Highland Drive CUMBERLAND COUNTY Lewisville, TX 75067, Plaintiff, Vs. No.: 07-1092 Civil Harold Lytle 865 Doggett Road Forest City, NC 28043-8150, and Robin G. Lytle 865 Doggett Road Forest City, NC 28043-8150, Defendants. PRAECIPE FOR JUDGMENT, INREM, FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter Judgment, in rem, in favor of Plaintiff and against Harold Lytle and Robin G. Lytle, Defendants, for failure to file an Answer on 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 $141,064.85 Interest 2/28/07 through 05/17/07 2,913.52 Late Charges 177.15 Additional Corporate Advance 443.50 TOTAL $144,599.02 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above and (2) that notice has been given in accordance with Rule 237.1. copy attached. Chrisovalante P. Fli os, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: ?? ap0 7 `-- PROTHONOTARY ? r 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 claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office set forth below. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY NOTICE TO DEFEND 32 S. BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MILSTEAD & ASSOCIATES, LLC By: Chrisovalante P. Fliakos, Esquire ID No. 94620 Attorney for Plaintiff {00020971} Page 2 of 2 Si" ?? C> t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC, Plaintiff, Vs. Harold Lytle and Robin G. Lytle, Defendants. CIVIL ACTION NO.: 07-1092 Civil PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: 1. Directed to the Sheriff of CUMBERLAND County; 2. Against the Defendant(s) in the above-captioned matter; 3. and index this writ against the Defendant(s) as follows: Harold Lytle Robin G. Lytle Real Property involved: 1580 Holtz Road Enola, PA 17025 Amount Due Interest from 5/18/07 to 9/5/07 at $23.77 per diem (6%) TOTAL (Costs to be added) DATE: May 17, 2007 $144,599.02 Respectively submitted, Milstead & Associate LLC L Chrisovalante P. Fliakos, Esquire Attorney for Plaintiff 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, CONSISTING OF TWO TRACT, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. 1: BEGINNING AT STONE; THENCE BY LANDS OF EMANUEL HOLTZ, SOUTH SEVENTY-SIX AND THREE-FOURTH DEGREES WEST, EIGHTY-THREE AND FIVE-TENTHS PERCHES TO A STONE; THENCE BY LAND OF JOHN HECK, NORTH NINE DEGREES EAST, SIXTEEN (16) PERCHES TO A STONE; THENCE NORTH SEVENTY-SIX AND THREE-FOUR DEGREES EAST EIGHTY-THREE AND FIVE-TENTHS (83.5) PERCHES TO A STONE; THENCE SOUTH NINE DEGREES WEST, SIXTEEN (16) PERCHES TO THE PLACE OF BEGINNING. CONTAINING SEVEN (7) ACRES AND NINETY-NINE (99) PERCHES, STRICT MEASURE. TRACT NO. 2: BEGINNING AT A STONE ON THE LINE OF LANDS LATE OF JACOB R. RENNINGER AND THE LINE OF LANDS OF DAVID STOUFFER, IT BEING THE NORTHWEST POINT; THENCE SOUTHWESTWARDLY ALONG THE LINE OF LANDS OF LATE JACOB R. RENNINGER AND LANDS OF FOSTER S. AND PAULINE A. SINGER, FORMERLY FRANK QUIGG, FIVE HUNDRED FORTY-NINE (549) FEET TO A STONE; THENCE SOUTHEASTWARDLY ALONG LANDS OF FRANK QUIGG, FORMERLY JACOB R. RENNINGER, FOUR HUNDRED FIFTY (450) FEET TO A POINT; THENCE EASTWARDLY ALONG LANDS OF GERTRUDE B. SIMMONS FIVE HUNDRED EIGHTY FIVE (585) FEET TO A POINT; THENCE NORTHEASTWARDLY ALONG LANDS LATE OF DAVID STOUFFER FIVE HUNDRED ONE (501) FEET TO A POINT, THEN PLACE OF BEGINNING. Being known as 1580 Holtz Road, Enola, PA 17025 Tag Parcel Number: 09-11-3010-007 p,[ ' J i ' C T` d c? 44 IZ, C-Zk •o .. w w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1092 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC., Plaintiff (s) From HAROLD LYTLE AND ROBIN G. LYTLE (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 $144,599.02 L.L. $30 Interest FROM 5/18/07 TO 9/5/07 AT $23.77 PER DIEM (6%) Atty's Comm % Due Prothy $2.00 Atty Paid $150.72 Other Costs Plaintiff Paid Date: MAY 23, 2007 s R. ong, Prothonotary (Seal) Deputy REQUESTING PARTY: Name CHRISOVALANTE P. FLIAKOS, ESQUIRE Address: MILSTEAD & ASSOCIATES, LLC 220 LAKE DRIVE EAST, SUITE 301 CHERRY HILL, NJ 08002 Attorney for: PLAINTIFF Telephone: 856482-1400 Supreme Court ID No. 94620 of w MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, No.: 07-1092 Civil Vs. ' Harold Lytle AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 and Robin G. Lytle, Defendants. STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Nationstar Mortgage, LLC, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 1580 Holtz Road, Enola, PA 17025: 1. Name and address of Owners(s) or Reputed Owner(s): Harold Lytle 865 Doggett Road Forest City, NC 28043-8150 Robin G. Lytle 865 Doggett Road Forest City, NC 28043-8150 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known f .w 4. Name and Address of the last recorded holder of every mortgage of record: Nationstar Mortgage, LLC (Plaintiff herein) 350 Highland Drive Lewisville, TX 75067 5. Name and address of every other person who has any record lien on the property: None Known 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: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 1580 Holtz Road Enola, PA 17025 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 Department of Domestic Relations Cumberland County Courthouse 13 N. Hanover Street Carlisle, PA 17013 I verify that the statements made in the 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. Section 4904 relating to unworn falsification to authorities. Chrisovalante P. iakos, Esquire Attorney for Plaintiff Date: May 17, 2007 - w MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-1092 Civil Harold Lytle, NOTICE OF SHERRIF'S SALE OF and REAL PROPERTY PURSUANT TO PA.RC.P.3129 Robin G. Lytle, Defendants. ' TAKE NOTICE: Your house (real estate) at 1580 Holtz Road, Enola, PA 17025, is scheduled to be sold at sheriff's sale on September 5, 2007 at 10:00 am in the Commissioner's Hearing Room, - Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of - - $144,599.02 obtained by Nationstar Mortgage, LLC. 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 Milstead & Associates LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 856-482-1400. 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 following page 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 TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead & Associates at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty 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. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Notice to Defend 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 9.05784 1 ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, CONSISTING OF TWO TRACT, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. 1: BEGINNING AT STONE; THENCE BY LANDS OF EMANUEL HOLTZ, SOUTH SEVENTY-SIX AND THREE-FOURTH DEGREES WEST, EIGHTY-THREE AND FIVE-TENTHS PERCHES TO A STONE; THENCE BY LAND OF JOHN HECK, NORTH NINE DEGREES EAST, SIXTEEN (16) PERCHES TO A STONE; THENCE NORTH SEVENTY-SIX AND THREE-FOUR DEGREES EAST EIGHTY-THREE AND FIVE-TENTHS (83.5) PERCHES TO A STONE; THENCE SOUTH NINE DEGREES WEST, SIXTEEN (16) PERCHES TO THE PLACE OF BEGINNING. CONTAINING SEVEN (7) ACRES AND NINETY-NINE (99) PERCHES, STRICT MEASURE. TRACT NO. 2: BEGINNING AT A STONE ON THE LINE OF LANDS LATE OF JACOB R. RENNINGER AND THE LINE OF LANDS OF DAVID STOUFFER, IT BEING THE NORTHWEST POINT; THENCE SOUTHWESTWARDLY ALONG THE LINE OF LANDS OF LATE JACOB R. RENNINGER AND LANDS OF FOSTER S. AND PAULINE A. SINGER, FORMERLY FRANK QUIGG, FIVE HUNDRED FORTY-NINE (549) FEET TO A STONE; THENCE SOUTHEASTWARDLY ALONG LANDS OF FRANK QUIGG, FORMERLY JACOB R RENNINGER, FOUR -- - HUNDRED FIFTY (450}FEET TO A POINT; THENCE EASTWARDLY ALONG - LANDS OF GERTRUDE B. SIMMONS FIVE HUNDRED EIGHTY FIVE (585) FEET TO A POINT; THENCE NORTHEASTWARDLY ALONG LANDS LATE OF DAVID STOUFFER FIVE HUNDRED ONE (501) FEET TO A POINT, THEN PLACE OF BEGINNING. Being known as 1580 Holtz Road, Enola, PA 17025 Tax Parcel Number: 09-11-3010-007 r..? ??? _? - i ' ?• ? +- ?? - ' ?' } -^-? -- f'+., - r, C.+..° ?- - " i '• _ ? , [' ^ . ' SHERIFF'S RETURN - U.S. CERTIFIED MAID CASE NO: 2007-01092 P COMMONWEALTH OF PENNSYLVANIA CTOUNTY OF CUMBERLAND NATIONSTAR MORTGAGE LLC VS. LYTLE HAROLD ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT LYTLE HAROLD , by United States Certified Mail postage prepaid, on the 1st day of March ,2007 at 1000:00 HOURS, at 865 DOGGETT ROAD FOREST CITY, NC 28043-8150 and attested copy of the attached COMPLAINT - MORT FORE with a true Together The returned receipt card was signed by RETURNED AS "UNCLAIMED" on 00/00/0000 . Additional Comments: Sheriff's Costs: So ansW?s . Docketing 18.00 Service 5.36 R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 33 .36 ? Y1?a?o„ Paid by MILSTEAD & ASSOCIATES on 04/11/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2007-01092 P COMMONWEALTH OF PENNSYLVANIA t "LbUNTY OF CUMBERLAND NATIONSTAR MORTGAGE LLC VS. LYTLE HAROLD ET AL R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT LYTLE ROBIN G , by United States Certified Mail postage prepaid, on the 1st day of March ,2007 at 1000:00 HOURS, at 865 DOGGETT ROAD FOREST CITY, NC 28043-8150 and attested copy of the attached COMPLAINT - MORT FORE with a true Together The returned receipt card was signed by RETURNED AS "UNCLAIMED" on 00/00/0000 . Additional Comments: Sheriff's Costs: So answer. ?:-- Docketing 6.00%`. Service 5.36 'R. Thomas Kline Affidavit .00 Sheriff of Cumberland County Surcharge 10.00 .00 21.36E k1?l?Io'? Paid by MILSTEAD & ASSOCIATES on 04/11/2007 Sworn and Subscribed to before me this day of A.D. JNTY OF CUP..iERLAND fice of TI-m Sheriff 1 Courthc.,se Square isle, Pe nsylvania 17013 7005 1820 0002 4619 0135 aC/ U '¦i 10r-Ji_ED F ?I ?-l Harold Lytle 865 Doggett Road n"r_n Forest City ?"' nnn" OA ? INSUFFICIENT ADDRESS ? ATTEMPTED NOT KNOWN ? OTHER C ? NO SUCH NUMBER/ STREET S ? NOT DELIVERABLE AS ADDRESSED - UNABLE TO FORWARD ' 28043+6154--6S RODS ,;. N COUNTY OF CUMBERLAND Office of The Sheriff 1 Courthouse Square Carlisle, Pennsylvania 17013 I 7005 1820 0002 4619 2542 CIO P? . Pses PosT'o ' F ') P17NE V 02 1A 0% 0004631598 MAR( MAILED FROM ZIP GOD A5? , rj V31 - V, Robin G. Lytle t " 7 865 Doggeltli;W Forest City. nl? `'Q^"' 0-111 A ? INSUFFICIENT ADDRESS 0 ATTEMPTED NOT KOWN NO SUCH NUMBERNSTREET OTHER C ? QS ? NOT DELIVERABLE AS ADDRESSED . - UNABLE TO FORWARD MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC, Plaintiff, Vs. Harold Lytle and Robin G. Lytle, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 07-1092 Civil AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.2 Defendants. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Chrisovalante P. Fliakos, Esquire, being duly sworn according to law upon my oath, depose and say, 1. On June 1, 2007, a copy of the Notice of Sheriff's Sale of Real Property was served upon the defendants, Harold Lytle and Robin G. Lytle, by a private process server. Copies of the Service returns are attached hereto and made a part hereof as Exhibit "A". 2. On May 22, 2007, a notice of Sheriffs Sale was served upon lien holders of record and interested parties by ordinary mail. A copy of the certificate of mailing is attached hereto and made a part hereof as Exhibit "B". -AA-'av hrisovalante P. F akos, Esquire Attorney ID No. 94620 Milstead and Associates, LLC Dated: August 3, 2007 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 B&R FAX: (215) 985-0169 for Profe?sionab Inc. Nationstar Mortgage, LLC -VS- Harold Lytle and Robin G. Lytle S National Association of Philadelphia Association Professional Process Servers of Professional Process Servers COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 07-1092 Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: B&R Control # CS039505 -1 COUNTY OF PHILADELPHIA: Reference Number 9.05784 - SERVICE INFORMATION On 22 day of May, 2007 we received the Notice of Sheriff Sale for service upon Harold Lytle at 865 Doggett Road Forest City, NC 28043 *** Special Instructions ® Served Date Time 9p Accepted By: t? I -_vCaro - ()-d an'1- In the manner described below. Personally served. Adult family member. Relationship is -5on- j -r> --L--caw-- -- - Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging - Agent or person in charge of office or usual place of business Other Description of Person Age ajD/.15 Height 5 10 Weight Race Sex Other Not Served Date Time Not Served Information Moved Unknown f- No Answer Vacant Other The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and lief. Process Server/Sheriff ?{ . Law Firm Phone (856)48 1400 Fo Pina S. Wertzberger, Esquire Michael Milstead, LLC 220 Lake Drive East #301, Woodland Falls Corp. Park Cherry Hill, NJ 08002 Sworn to and subscribed before me this day of Notary ublic C O C' /2.5?/ ServeBy Date 6/11/2007 Filed Date Sale Date 9/5/2007 ORIGINAL 142VC Ju1.18. 2091 1:39PM 9 & R SERVICES 235 SOUTH 19TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 548.7400 FAX: (215) 985.0189 4 8aloa l?r tioteaiossls tao. Nationster Mortgage, LLC -vs- Harold Lytle and Robin G. Lytle 215-986-9169 No. 3521 3 ` Ntfi0ry71 A?ynpn Ot pAilid?wl IS700?iQon a?oross?w,a1 P,oau Swrws d t+,vkaFbr?ei Praor?r sw»,. 1oswgLi COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 07-1092 Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: R&R Control0 C6039505-2 Reference Number 9.06784 SERVICE INFORMATION Special Instructions On 22 day of May, 2007 we received the Notice of Sheriff Sale for service upon Robin G. Lytle at 885 Dogget Road Forest City, NC 28043 Served Date (0 !'. V 1 Time as p Accepted By: A_d OL ?? b In the manner described below. Personally served. Adult family member. Relationship is - t Ir) _ Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other - Description of Person Age aad Height _ Weight Race L,?--) Sex M Other _ 71 Not Served Date Time Not Sstved Information Moved Unknown - No Answer _ Vacant - Other The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Server/Sheriff Sworn to and subscribed before me this ?L day of - Notary IFILb-110 Law Firm Phone (856)482A400 For ServeBy Date 6111/2007 Pine S. WerizbergeT, Esquire Michael Milatead, LLC Filed Date 220 Lake Drive East Sale Date 91512007 P301, Woodland Falls Corp. Park Cherry Hill, NJ 08002 ORIGINAL CIA r O Cl Co U»-I (D (p' O () N O to co -+l 01 Cn A W N -? r 3 (D nN*K - p o r O O m to Crt I Z uri 3 z = N a W a? 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N O 0 . 02 I P T ,, ?_ y 0002388662 MAY 22 2007 ? c 0 MAILED FROM ZIP GOD£ 080 02 0 0 O m m z m v z n m n z 0 a v v m 9) CD z v 0 m m 0 m n 2 m n X n v O D m C> e--> a ?s? c? .....? :? ? -s-? ?, ,??;,- _ -c- ,,.. cv `? ? c', _:f, :? ? Nationstar Mortgage, LLC VS Harold Lytle and Robin G. Lytle In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-1092 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriffs Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant, to wit: Harold Lytle, at his last known address of 865 Doggett Road, Forest City, NC 28043-8150 on June 15, 2007. The unopened letter was returned to the Cumberland County Sheriffs Office on July 11, 2007 marked "UNCLAIMED." R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriffs Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant, to wit: Robin G. Lytle, at her last known address of 865 Doggett Road, Forest City, NC 28043-8150 on June 15, 2007. The return receipt card was signed by Jen Harbin on June 18, 2007 and returned to the Cumberland County Sheriffs Office. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2007 at 15 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 Harold Lytle and Robin G. Lytle, located at 1580 Holtz Road, Enola, 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: Robin G. Lytle, by regular mail to her last known address of 865 Doggett Road, Forest City, NC 28043-8150. This letter was mailed under the date of July 3, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Chrisovalante Fliakos. Sheriffs Costs: Docketing 30.00 Poundage 18.69 Posting Bills 30.00 Advertising 30.00 Law Library .50 Prothonotary 2.00 Mileage 13.44 Certified Mail 10.42 Levy 30.00 Surcharge 40.00 Law Journal 355.00 Patriot News 377.33 Share of Bills 15.69 Postpone Sale 20.00 $ 973.07 J46610 CN` (.1310 f Gee.• :1 b i G 7? S S: -.? R. Thomas Kline, Sheriff BWJ. 6 ` Real Estate ergeant MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, No.: 07-1092 Civil Vs. Harold Lytle AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 and Robin G. Lytle, Defendants. STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Nationstar Mortgage, LLC, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 1580 Holtz Road, Enola, PA 17025: 1. Name and address of Owners(s) or Reputed Owner(s): Harold Lytle 865 Doggett Road Forest City, NC 28043-8150 Robin G. Lytle 865 Doggett Road Forest City, NC 28043-8150 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known 1 4. Name and Address of the last recorded holder of every mortgage of record: Nationstar Mortgage, LLC (Plaintiff herein) 350 Highland Drive Lewisville, TX 75067 5. Name and address of every other person who has any record lien on the property: None Known 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: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 1580 Holtz Road Enola, PA 17025 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 Department of Domestic Relations Cumberland County Courthouse 13 N. Hanover Street Carlisle, PA 17013 I verify that the statements made in the 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. Section 4904 relating to unsworn falsification to authorities. Chrisovalante P. iakos, Esquire Attorney for Plaintiff Date: May 17, 2007 I MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Nationstar Mortgage, LLC, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-1092 Civil Harold Lytle, NOTICE OF SHERRIF'S SALE OF and REAL PROPERTY PURSUANT TO PA.R.C.P.3129 Robin G. Lytle, Defendants. TAKE NOTICE: Your house (real estate) at 1580 Holtz Road, Enola, PA 17025, is scheduled to be sold at sheriff's sale on September 5, 2007 at 10:00 am in the Commissioner's Hearing Room, - Cumberland-County Courthouse, Carlisle, -PA 1-7013 to enforce the Court Judgment of - - - $144,599.02 obtained by Nationstar Mortgage, LLC. 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 Milstead & Associates LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 856-482-1400. 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 following page 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 TAKE PLACE. s ' 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead & Associates at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty 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. 7. You may.. also-have other rights and defenses, or ways of getting your house back, if . you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Notice to Defend 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 9.05784 ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, CONSISTING OF TWO TRACT, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. 1: BEGINNING AT STONE; THENCE BY LANDS OF EMANUEL HOLTZ, SOUTH SEVENTY-SIX AND THREE-FOURTH DEGREES WEST, EIGHTY-THREE AND FIVE-TENTHS PERCHES TO A STONE; THENCE BY LAND OF JOHN HECK, NORTH NINE DEGREES EAST, SIXTEEN (16) PERCHES TO A STONE; THENCE NORTH SEVENTY-SIX AND THREE-FOUR DEGREES EAST EIGHTY-THREE AND FIVE-TENTHS (83.5) PERCHES TO A STONE; THENCE SOUTH NINE DEGREES WEST, SIXTEEN (16) PERCHES TO THE PLACE OF BEGINNING. CONTAINING SEVEN (7) ACRES AND NINETY-NINE (99) PERCHES, STRICT MEASURE. TRACT NO. 2: BEGINNING AT A STONE ON THE LINE OF LANDS LATE OF JACOB R. RENNINGER AND THE LINE OF LANDS OF DAVID STOUFFER, IT BEING THE NORTHWEST POINT; THENCE SOUTHWESTWARDLY ALONG THE LINE OF LANDS OF LATE JACOB R. RENNINGER AND LANDS OF FOSTER S. AND PAULINE A. SINGER, FORMERLY FRANK QUIGG, FIVE HUNDRED FORTY-NINE (549) FEET TO A STONE; THENCE SOUTHEASTWARDLY ALONG LANDS OF FRANK QUIGG, FORMERLY JACOB R RENNINGER, FOUR HUNDRED FIFTY (45%FEET-TO A POINT; THENCE EASTWARI>LY -ALONG LANDS OF GERTRUDE B. SIMMONS FIVE HUNDRED EIGHTY FIVE (585) FEET TO A POINT; THENCE NORTHEASTWARDLY ALONG LANDS LATE OF DAVID STOUFFER FIVE HUNDRED ONE (501) FEET TO A POINT, THEN PLACE OF BEGINNING. Being known as 1580 Holtz Road, Enola, PA 17025 Tax Parcel Number: 09-11-3010-007 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1092 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC., Plaintiff (s) From HAROLD LYTLE AND ROBIN G. LYTLE (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 $144,599.02 L.L. $.50 Interest FROM 5/18/07 TO 9/5/07 AT $23.77 PER DIEM (6%) Atty's Comm % Due Prothy $2.00 Atty Paid $150.72 Other Costs Plaintiff Paid Date: MAY 23, 2007 (Seal) REQUESTING PARTY: Name CHRISOVALANTE P. FLIAKOS, ESQUIRE Address: MILSTEAD & ASSOCIATES, LLC 220 LAKE DRIVE EAST, SUITE 301 CHERRY HILL, NJ 08002 Attorney for: PLAINTIFF Telephone: 856482-1400 Supreme Court ID No. 94620 Deputy CC?i Real Estate Sale # 57 On June 13, 2007 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 15 80 Holtz Road, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 13, 2007 By: Real Estat ergeant L W1 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 #57 9 i. Sworn to and subscribed NOW~ L DK0d" NwbnEWkWJWW462W ns**Me MsootadW albs CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 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. REAL ESTATE SALE NO. 57 Writ No. 2007-1092 Civil Nationstar Mortgage, LLC vs. Harold Lytle and Robin G. Lytle Atty.: Chrisovalante P. Fliakos DESCRIPTION ALL THAT CERTAIN tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, consisting of two tract, bounded and described as follows, to wit: TRACT NO. 1: BEGINNING at stone; thence by lands of Emanuel Holtz, South seventy-six and three- fourth degrees West, eighty-three and five-tenths perches to a stone; thence by land of John Heck, North nine degrees East, sixteen (16) perches to a stone; thence North seventy-six and three-four degrees East eighty- three and five-tenths (83.5) perches to a stone; thence South nine de- grees West, sixteen (16) perches to the place of beginning. Containing seven (7) acres and ninety-nine (99) perches, strict measure. TRACT NO. 2: BEGINNING at a stone on the line of lands late of SWORN TO AND SUBSCRIBED before me this 3 day of August, 2007 Notary NOTARIAL SEAL DEBORAH A COLLMIS Notary Pub4C CARLISLE BORO, CUMBERLAND COt My My CorrKnWm Expb« Apr 24. 2010