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
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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}
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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 ***
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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
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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:
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PROTHONOTARY
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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
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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
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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
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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
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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
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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
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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
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Harold Lytle
865 Doggett Road
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Forest City ?"' nnn"
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? ATTEMPTED NOT KNOWN ? OTHER
C ? NO SUCH NUMBER/ STREET
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28043+6154--6S RODS
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COUNTY OF CUMBERLAND
Office of The Sheriff
1 Courthouse Square
Carlisle, Pennsylvania 17013
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7005 1820 0002 4619 2542
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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
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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
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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