HomeMy WebLinkAbout07-7598I 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
File: 9.07413
Nationstar Mortgage, LLC f/k/a Centex
Home Equity Corporation
350 Highland Drive
Lewisville, TX 75067,
Vs.
Plaintiff,
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
The United States of America c/o U.S.
Attorney General
228 Walnut Street
Harrisburg, PA 17108,
Defendants.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07 - ?S 98 &,; L7aj
CIVIL ACTION
MORTGAGE FORECLOSURE
t00211227)
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 Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
{002112271
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.
{00211227}
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 f/k/a Centex
Home Equity Corporation
350 Highland Drive
Lewisville, TX 75067,
Plaintiff,
Vs.
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
The United States of America c/o U.S.
Attorney General
228 Walnut Street
Harrisburg, PA 17108,
Defendants.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 0I- 7Y9g
CIVIL ACTION
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, Nationstar Mortgage, LLC f/k/a Centex Home Equity Corporation (the
"Plaintiff'), is a Nevada 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.
{00211227}
2. Defendants, Richard L. Barr and Ann D. Barr, (collectively, the "Defendants"), are
adult individuals and are the real owners of the premises hereinafter described.
3. Richard L. Barr, Defendant, resides at 6996 Wertzville Road, Mechanicsburg, PA
17055. Ann D. Barr, Defendant, resides at 6996 Wertzville Road, Mechanicsburg, PA 17055.
The United States of America c/o U.S. Attorney General, Defendant, is located at 228 Walnut
Street, Harrisburg, PA 17108.
4. On April 14, 2000, in consideration of a loan in the principal amount of $97,000.00,
Richard L. Barr and Ann D. Barr, the Defendants, executed and delivered to Centex Home
Equity Corporation a note (the "Note") with interest thereon at 11.500 percent per annum,
payable as to the principal and interest in equal monthly installments of $960.59 commencing
June 1, 2000.
5. To secure the obligations under the Note, the Defendants executed and delivered to
Centex Home Equity Corporation a mortgage (the "Mortgage") dated April 14, 2000, recorded
on April 24, 2000 in the Department of Records in and for the County of Cumberland under
Mortgage Book 1607, Page 802. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated
herein by reference.
6. The Mortgage secures the following real property (the "Mortgaged Premises"): 6996
Wertzville Road, Mechanicsburg, PA 17055. 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 July 1, 2007, and monthly thereafter are due and
have not been paid, whereby the whole balance of principal and all interest due thereon have
(002112271
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 ..................................$92,982.45
Accrued but Unpaid Interest from
6/1/07 to 12/18/07
@ 11.500% per annum
($29.30 per diem) ........................................$5,889.30
Accrued Late Charges ....................................$287.36
Corporate Advance ......................................$7,266.39
Title Search Fees ............................................$350.00
Deferred Late Charges ............................. ....$1,795.87
Insufficient Funds Charges ...................... .........$20.00
Reasonable Attorney's Fees .................... ....$1,250.00
TOTAL as of 12/18/2007 ........................ $109,841.37
Plus, the following amounts accrued after December 18, 2007:
Interest at the Rate of 11.500 per cent per annum ($29.30 per diem);
Late Charges of $48.03 per month.
9. Plaintiff has complied fully with Act No. 91 (35 P. SA 680.401 (c) of the 1983 Session
of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the
Defendants at 6996 Wertzville Road, Mechanicsburg, PA 17055 as well as to address of
residences as listed in paragraph 3 of this document on October 2, 2007, the notice pursuant to §
403-C of Act 91, and the applicable time periods therein have expired.
10. The United States of America is being sued pursuant to 28 U.S.C Section 2410
relating to federal tax liens. A copy of the tax lien information pertinent thereto is attached
hereto as "Exhibit B" and made a part hereof. The same is incorporated herein by reference as if
fully set forth at length herein.
{002112271
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, $109,841.37, plus the following amounts accruing after December 18, 2007, to the date
of judgment: (a) interest of $29.30 per day, (b) late charges of $48.03 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.
MILST,,BAD & ASSOCIATES, LLC
Chrisovalante P. Fliakos, Esquire
Attorney for Plaintiff
(00211227)
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 unsworn falsification to authorities.
Name: Chrisovalante P. Fliakos, Esquire
Title: Attorney
{00211227}
Order Number: 000222931 'ISED)
Re: RICHARD L BARR 6996 WERTZVILLE ROAD
ANN BARR MECHANICSBURG, PA 17055
CUMBERLAND County
EXHIBIT&A,
All that certain lot or parcel of land situate in Silver Spring
Township, Cumberland County, Pennsylvania, more particularly bounded
and described as follows to wit:
Beginning at the intersection of the center line of Pennsylvania State
Highway No. 944, commonly known as Wertzville Road, and the center line
of Legislative Route No. 21001, commonly known as the Millers Gap Road;
thence along the center line of said Wertzville Road south Eighty-four
(84) degrees west One Hundred Twenty-six (126) feet to a spike; thence
along other lands now or formerly of R. E. Best, north one (1) degree
twenty-five (25) minutes west one Hundred Seventy-five (175) feet to a
spike; thence by the same north Eight-five (85) degrees east One
Hundred Twenty-five and Four Tenths (125.4) feet to a spike in the
center line of the Millers Gap Road; thence along the center line of
said Millers Gap Road south one (1) degrees Twenty-five (25) minutes
east One Hundred Seventy-two and Five Tenths (175.5) feet to the place
of beginning.
Having thereon erected a dwelling house known and number as 6996
Wertzville Road, Mechanicsburg, Pennsylvania.
A TISIHX3
NOV-30-2007(FRI) 14:59 Patricia Black Abstracting (FAX)717 337 2248 P.023/066
12-29-'07 16:39 FROM-Premier Abstract E XHI-131T T-fi16 P023/0fi6 F-95@
1972 B
Department of the Treasury - intsm 11 Revenue Service
IForm 668 M(c) W^goa% of Cedes( I'ax I'eM
tRw. Februwy 7004
Area: Serial Number
W= 4 rNV38 T ApZA #2
Lion Unit Phone: (800) 029-7650 288897304
As provided by %ecdoar 6321, 6322, and 6323 of the lnternai Revwm
Code, we am + a nodce Burt Wm (Iadafte biurest and pooldes)
have beer: anused ap mt the f0UaWhW4 wd CaVayer.. We have made
a demand for pn%ftnt of Ok UWtlty, but it remabs uapakL Therefore,
there is a Ilea h11 favor Of the UnW Suites on aR property and rWW to
ProPerty belOiW* to this taxpayer for the amogim of diese taxes, and
addidonal pelolt(ea, hrtamt, and coats that my ai=ae.
Name of Taxpayer RICHARD BARR
Aesidonce 6996 WERTZVILL1r W)
r4ECKw1CSHORG, PA 170$0-3.540
n y- VV-1Z L-wa -7
For O/p?tional U= by pac&&V Office
.,& jrJ#f 6V
77
IMPORTANT RELEASE MFOR1"fJ4TWN: For each esaftasment listed balpw,
unless notice of the lean Is refiled by the data pivon in column (e). d6 notice shalt.
on the day following such date, operate as a certificate of relense as defined
In IRC 8325(11).
Tax Pentad
Kind of lax 9ndbg Date of L,,ISt Day for
Ident fAn Nmnber Anesswent Rerr
(a) (b) (c) (d) W
CIVP 09/30/2002 144-46-0304 05/24/2004 06/23/2014
CIVP 12/31/2001 144-46-0304 05/24/2004 06/2312014
CIVP 03/31/2002 144-46-0304 05/24/2004 06/23/2014
CIVP 06/30/2002 144-46-0304 05/24/2004 06/23/2014
Piave of Filing
Prothonotary
Culnberland County Total $
Carlisle, PA 17013
This notice was prepared and signed at PHILADELPHIA, PA
the 26th day of August 2004
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2965.94
1911.23
3349.13
8983.50
, on this.
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S?V t SL'" 'tep T+sti-? 12-00 0000
ft» P S LANE ? (800) 829-7650
(1'1O'iiFt Cwtiflpate of officer eathor>;ad by taw to take acknowledgment is not ossentlol w the vatldity of Notice of Fsdaat Tax lien
Rev. Rd. 71-466. 1971 - 2 C.B. 409)
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07598 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC ET AL
VS
BARR RICHARD L ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
BARR RICHARD L the
DEFENDANT at 1548:00 HOURS, on the 2nd day of January , 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17055 by handing to
ANN BARR ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.60
Affidavit .00
Surcharge 10.00
.00
37.6 0
Sworn and Subscibed to
before me this
of
day
So Answers:
R. Thomas Kline
01/04/2008
MILSTEAD & ASSOCIATES
By: ?.
Deputy heriff
A. D.
r
46
CASE NO: 2007-07598 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC ET AL
VS
BARR RICHARD L ET AL
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
BARR ANN D the
DEFENDANT , at 1548:00 HOURS, on the 2nd day of January , 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17055
ANN BARR
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
00
1JIv/?? %'? 16'00
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
01/04/2008
MILSTEAD & ASSOCIATES
By:
Deputy eriff
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
4
CASE NO: 2007-07598 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC ET AL
VS
BARR RICHARD L ET AL
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
UNITED STATES OF AMERICA
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On January 4th , 2008 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answers---
Docketing 6.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep Dauphin County 29.25 Sheriff of Cumberland County
Postage 1.31
55.56 ? 11,1016P
01/04/2008
MILSTEAD & ASSOCIATES
Sworn and subscribe to before me
this day of ,
A. D.
ti
•
In The Court of Common Pleas of Cumberland County, Pennsylvania
Nationstar Mortgage LLC
vs.
Richard L. Barr et al
SERVE: The United States of America No. 07-7598 civil
Now, December 2.6, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this day of , 20
copy of the original
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
20 , at o'clock M. served the
County, PA
(Ptji't.t of the ' Iteri
Mary Jane yder
Real Estate DSnepu
Charles E. Sheaffer
Chief Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Michael W. Rinehart
Assistant Chief Deputy
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
NATIONSTAR MORTGAGE LLC
VS
THE UNITED STATES OF AMERICA
Sheriff s Return
No. 2007-T-1802
OTHER COUNTY NO. 07-7598
And now: DECEMBER 28, 2007 at 9:20:00 AM served the within COMPLAINT IN MORTGAGE
FORECLOSURE upon THE UNITED STATES OF AMERICA by personally handing to 1 true
attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to
him/her the contents thereof at US ATTORNEY GENERALS OFFICE 228 WALNUT STREET
HARRISBURG PA 17108
SERVED CINDY ZIMMERMAN RECEPTIONIST
Sworn and subscribed to So Answers,(( ?
before me this 31 ST day of December, 2007
Ili
NOTARIAL SEAL
ARY JANE SNYDER, Notary Publi
Highspire, Dauphin County
Lmy Commission Expires Sept 1 2010
Sheriff of Dauphin County, Pa.
`?•y,.,....
By
Deputy Sheriff
Deputy: T WONG
Sheriffs Costs: $29.25 12/27/2007
MILSTEAD & ASSO(?.ATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationstar Mortgage, LLC f/k/a Centex
Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
Entry of Appearance
and
The United States of America c/o U.S.
Attorney General,
Defendant(s).
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Plaintiff, Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation, in the above captioned matter.
MILSTEAD & ASSOCIATES, LLC
A""
Heidi R. Spivak, Esquire
Attorney ID No. 74770
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MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationstar Mortgage, LLC Vk/a
Centex Home Equity Corporation
350 Highland Drive
Lewisville, TX 75067,
Plaintiff,
Vs.
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
The United States of America c/o
U.S. Attorney General
228 Walnut Street
Harrisburg, PA 17108,
Defendants.
for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
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 Richard L. Barr, and Ann D. Barr,
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 $109,841.37
Interest 12/18/07 through 02/14/08 1,699.40
Late Charges 144.09
Additional Corporate Advance 283.75
TOTAL $111,968.61
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.
""j,
Hei R. Spivak, Esquire
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: a2[Q OS
P O HON
f
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr
and
The United States of America c/o
U.S. Attorney General,
Defendants.
TO: Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
Our file number: 9.07413
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
DATE OF NOTICE: January 28, 2008
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS
NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS
REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL
BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
{00020971}
Page I of 2
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 BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
MILSTEAD & ASSOCIATES, LLC
By: A'L'
R. Spivak, Esquire
ID No. 74770
Attorney for Plaintiff
(00020971)
Page 2 of 2
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney General,
Defendants.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
VERIFICATION OF NON-MILITARY SERVICE
Heidi R. Spivak, Esquire, hereby verifies that she is attorney for the Plaintiff in the
above-captioned matter, and that on information and belief, she has knowledge of the following
facts, to wit:
1. that the defendants are not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldier' and Sailors' Civil Relief Act of
Congress of 1940, as amended,
2. defendant, Richard L. Barr, is over 18 years of age and resides at 6996 Wertzville
Road, Mechanicsburg, PA 17055,
3. defendant, Ann D. Barr, is over 18 years of age and resides at 6996 Wertzville Road,
Mechanicsburg, PA 17055,
kal?l
Hei R. Spivak, Esquire
((? 6' C.0 j iii
10
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr,
x see b°'ek'
Defendants.
CIVIL ACTION
NO.: 07-7598 Civil Term
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:
Richard L. Barr
Ann D. Barr
Real Property involved: 6996 Wertzville Road
Mechanicsburg, PA 17055
Amount Due
Interest from 2/15/08 to 6/11/08
at $18.41 per diem (6%)
TOTAL
(Costs to be added)
DATE: February 13, 2008
sjr see bark
$111,968.61
Respectively submitted,
Milstead & Associates, LLC
4 Hei R. Spivak, Esquire
Attorney for Plaintiff
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
D° -
con
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P" CO
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ON? (Q?? 6Q
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40
ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN SILVER SPRING
TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT THE INTERSECTION OF THE CENTER LINE OF
PENNSYLVANIA STATE HIGHWAY NO. 944, COMMONLY KNOWN AS
WERTZVILLE ROAD, AND THE CENTER LINE OF LEGISLATIVE ROUTE NO.
21001, COMMONLY KNOWN AS THE MILLERS CAP ROAD; THENCE ALONG
THE CENTER LINE OF SAID WERTZVILLE ROAD SOUTH EIGHTY-FOUR (84)
DEGREES WEST ONE HUNDRED TWENTY-SIX (126) FEET TO A SPIKE;
THENCE ALONG OTHER LANDS NOW OR FORMERLY OF R. E. BEST, NORTH
ONE (1) DEGREE TWENTY-FIVE (25) MINUTES WEST ONE HUNDRED
SEVENTY-FIVE (175) FEET TO A SPIKE; THENCE BY THE SAME NORTH
EIGHTY-FIVE (85) DEGREES EAST ONE HUNDRED TWENTY-FIVE AND FOUR
TENTHS (125.4) FEET TO A SPIKE IN THE CENTER LINE OF THE MILLERS CAP
ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS CAP ROAD
SOUTH ONE (1) DEGREE TWENTY-FIVE (25) MINUTES EAST ONE HUNDRED
SEVENTY-TWO AND FIVE TENTHS (172.5) FEET TO THE PLACE OF
BEGINNING.
Being known as 6996 Wertzville Road, Mechanicsburg, PA 17055
Tax Parcel Number: 38-13-0985-061
.+
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
Nationstar Mortgage, LLC f/k/a Centex Home Equity Corporation, 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 6996 Wertzville Road,
Mechanicsburg, PA 17055:
1. Name and address of Owners(s) or Reputed Owner(s):
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the Judgment:
Same as above
N
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
United States Dept. of Justice
U.S. Atty-Middle District of PA
Attn: Mary Catherine Frye, Esquire
Assistant U.S. Attorney
Federal Building
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Internal Revenue Service
Federated Investors Tower
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
4. Name and Address of the last recorded holder of every mortgage of record:
Nationstar Mortgage, LLC f/k/a Centex Home
Equity Corporation
(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
6996 Wertzville Road
Mechanicsburg, PA 17055
Commonwealth of Pennsylvania
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
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.
k?xl
Heidi . Spivak, Esquire
Attorney for Plaintiff
Date: February 13, 2008
17,
°:a C
it
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
NOTICE OF SHERRIF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
Defendants.
TAKE NOTICE:
Your house (real estate) at 6996 Wertzville Road, Mechanicsburg, PA 17055, is
scheduled to be sold at sheriff's sale on June 11, 2008 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $111,968.61 obtained by Nationstar Mortgage, LLC f/k/a Centex Home Equity
Corporation.
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 Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
9.07413
ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN SILVER SPRING
TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT THE INTERSECTION OF THE CENTER LINE OF
PENNSYLVANIA STATE HIGHWAY NO. 944, COMMONLY KNOWN AS
WERTZVILLE ROAD, AND THE CENTER LINE OF LEGISLATIVE ROUTE NO.
21001, COMMONLY KNOWN AS THE MILLERS CAP ROAD; THENCE ALONG
THE CENTER LINE OF SAID WERTZVILLE ROAD SOUTH EIGHTY-FOUR (84)
DEGREES WEST ONE HUNDRED TWENTY-SIX (126) FEET TO A SPIKE;
THENCE ALONG OTHER LANDS NOW OR FORMERLY OF R. E. BEST, NORTH
ONE (1) DEGREE TWENTY-FIVE (25) MINUTES WEST ONE HUNDRED
SEVENTY-FIVE (175) FEET TO A SPIKE; THENCE BY THE SAME NORTH
EIGHTY-FIVE (85) DEGREES EAST ONE HUNDRED TWENTY-FIVE AND FOUR
TENTHS (125.4) FEET TO A SPIKE IN THE CENTER LINE OF THE MILLERS CAP
ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS CAP ROAD
SOUTH ONE (1) DEGREE TWENTY-FIVE (25) MINUTES EAST ONE HUNDRED
SEVENTY-TWO AND FIVE TENTHS (172.5) FEET TO THE PLACE OF
BEGINNING.
Being known as 6996 Wertzville Road, Mechanicsburg, PA 17055
Tax Parcel Number: 38-13-0985-061
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7598 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC, f/k/a CENTEX
HOME EQUITY CORPORATION, Plaintiff (s)
From RICHARD L. BARR and ANN D. BARR
(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 $111,968.61
L.L.$ 0.50
Interest from 2/15/08 to 6/11/08 at $18.41 per diem (6%)
Arty's Comm % Due Prothy $2.00
Atty Paid $228.16 Other Costs to be added
Plaintiff Paid
Date: 2/19/08
P thonota
(Seal)
By:
REQUESTING PARTY:
Name HEIDI R. SPIVAK, ESQUIRE
Address: MILSTEAD & ASSOCIATES, LLC
220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-482-1400
Deputy
Supreme Court ID No. 74770
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationst r Mortgage, LLC Vk/a Centex
Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney General,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
Entry of Appearance
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Plaintiff, Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation, in the above captioned matter.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney ID No. 80763
100251681)
? -
.
? ?. + ?
? e "
?? ? ??'
??
.?..
.?'.
'?
Nationstar Mortgage, LLC, f/k/a Centex In the Court of Common Pleas of
Home Equity Corporation Cumberland County, Pennsylvania
Vs Writ No. 2007-7598 Civil Term
Richard L. Barr and Ann D. Barr
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
March 27, 2008 at 1600 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendants, to wit: Richard L. Barr
and Ann D. Barr by making known unto Richard Barr personally, and adult in charge for Ann D.
Barr, at 6996 Wertzville Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and
at the same time handing to him personally the said true and correct copy of the same.
Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 02,
2008 at 1037 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 Richard L. Barr and Ann D. Barr
located at 6996 Wertzville Road, Mechanicsburg, 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 defendants, to wit: Richard L.
Barr and Ann D. Barr by regular mail to their last known address of 6996 Wertzville Road,
Mechanicsburg, PA 17055. This letter was mailed under the date of March 31, 2008 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 Heidi Spivak. Defendants reinstated their
loan; plaintiff collected $6,961.51.
Sheriff's Costs:
Docketing 30.00
Poundage 139.23
Posting Bills 15.00
Advertising 15.00
Law Library .50
Prothonotary 2.00
Mileage 19.60
Levy 15.00
Surcharge 30.00
Law Journal 355.00
Patriot News 372.17
Share of bills 14.73
$1008
23 ? ??<O?
.
So Answers:
R. Thomas Kline, Sheriff
BY
Real Estate Se eant-
k (, yd 93
A-,, "7106111-
I
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr
and
The United States of America c/o
U.S. Attorney General,
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
Nationstar Mortgage, LLC f/k/a Centex Home Equity Corporation, 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 6996 Wertzville Road,
Mechanicsburg, PA 17055:
1. Name and address of Owners(s) or Reputed Owner(s):
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055
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:
United States Dept. of Justice
U.S. Atty-Middle District of PA
Attn: Mary Catherine Frye, Esquire
Assistant U.S. Attorney
Federal Building
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Internal Revenue Service
Federated Investors Tower
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
4. Name and Address of the last recorded holder of every mortgage of record:
Nationstar Mortgage, LLC f/k/a Centex Home
Equity Corporation
(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
6996 Wertzville Road
Mechanicsburg, PA 17055
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
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.
Heidi 1R. Spivak, Esquire
Attorney for Plaintiff
Date: February 13, 2008
MILSTEAD & ASSOCIATES, LLC
BY: Heidi R. Spivak, Esquire
ID No. 74770
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Nationstar Mortgage, LLC f/k/a
Centex Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney General,
Defendants.
TAKE NOTICE:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
NOTICE OF SHERRIF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
Your house (real estate) at 6996 Wertzville Road, Mechanicsburg, PA 17055, is
scheduled to be sold at sheriff's sale on June 11, 2008 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $111,968.61 obtained by Nationstar Mortgage, LLC f/k/a Centex Home Equity
Corporation.
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 Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
9.07413
ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN SILVER SPRING
TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT THE INTERSECTION OF THE CENTER LINE OF
PENNSYLVANIA STATE HIGHWAY NO. 944, COMMONLY KNOWN AS
WERTZVILLE ROAD, AND THE CENTER LINE OF LEGISLATIVE ROUTE NO.
21001, COMMONLY KNOWN AS THE MILLERS CAP ROAD; THENCE ALONG
THE CENTER LINE OF SAID WERTZVILLE ROAD SOUTH EIGHTY-FOUR (84)
DEGREES WEST ONE HUNDRED TWENTY-SIX (126) FEET TO A SPIKE;
THENCE ALONG OTHER LANDS NOW OR FORMERLY OF R. E. BEST, NORTH
ONE (1) DEGREE TWENTY-FIVE (25) MINUTES WEST ONE HUNDRED
SEVENTY-FIVE (175) FEET TO A SPIKE; THENCE BY THE SAME NORTH
EIGHTY-FIVE (85) DEGREES EAST ONE HUNDRED TWENTY-FIVE AND FOUR
TENTHS (125.4) FEET TO A SPIKE IN THE CENTER LINE OF THE MILLERS CAP
ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS CAP ROAD
SOUTH ONE (1) DEGREE TWENTY-FIVE (25) MINUTES EAST ONE HUNDRED
SEVENTY-TWO AND FIVE TENTHS (172.5) FEET TO THE PLACE OF
BEGINNING.
Being known as 6996 Wertzville Road, Mechanicsburg, PA 17055
Tax Parcel Number: 38-13-0985-061
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7598 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC, f/k/a CENTEX
HOME EQUITY CORPORATION, Plaintiff (s)
From RICHARD L. BARR and ANN D. BARR
(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 $111,968.61
L.L.$ 0.50
Interest from 2/15/08 to 6/11/08 at $18.41 per diem (6%)
Atty's Comm % Due Prothy $2.00
Atty Paid $228.16 Other Costs to be added
Plaintiff Paid
Date: 2/19/08
Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name HEIDI R. SPIVAK, ESQUIRE
Address: MILSTEAD & ASSOCIATES, LLC
220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-482-1400
Supreme Court ID No. 74770
Real Estate Sale # 48
On March 4, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA
Known and numbered as 6996 Wertzville Road, Mechanicsburg,
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: March 4, 2008
By:
Jt-
Real Es Sergeant
9 h :E d 0 Z 933 8001 S E:E d 9 Z 933 8001
IMMM%
Cara
AA183HS 3HI Ji0 3013 j0I31d3N ,
The-Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
t4ePahiot News
Now you know
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
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of 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 on the date(s) indicated below. 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
This ad ran on the date(s) shown below:
04/23/08
Sworn to
of May, 2008 A. D.
COMMONWEALTH OF PENNSYLVANIA
-Notarial Seal
Chy i ae L. Shappw u, Notary Public
City Of Harrisburg, Dauphin County
My Commission Expires May 29, 2010
Member, Pennsylvania Association of Notaries
04/30/08
05/07/08
Meal Estate Sale #48
Writ No. 2007-7598 Civil Term
Nationstar Mortgage, LLC, f/k/a
Centex Home Equity
Corporation
VS
Richard L. Barr and
Ann D. Barr and The United
States of America
Attorney: Heidi Spivak
DESCRIPTION
'3u. CHAT CERTAIN LOT OR PARCEL 01?
LAND SITUATE IN SILVER SPRING
FOWNSHIP_ CUMBERLAND COUNTY.
PENNSYLVANIA. MORE PARTICULARIA
BOUNDED AND DESCRIBED AS FOLLOWS
r0WII
BEGINNING AT THE INTERSECTION OF
THE CENTER LINE OF PENNSYLVANIA
)TXIE HIGHWAY' NO. 944, COMMONLY
KNOWN AS WERTZVILLE ROAD. AND
TIII'. CE:NITR LINE OF LEGISLATIVE.
ROUTE NO. 21001. COMMONLY KNOWN
AS THE MILLERS CAP ROAD: THENCE
VLONG THE CENTER LINT; OF SAID
WERII.A'1LLE ROAD SOUTH EIGHTY-
FOCR 184 DEGREES WEST ONE
HUNDRED'IWENTY -SIX (126) FEET TO rA
SPIKE: THENCE ALONG OTHER LANDS
NOW OR FORMERLY OF R. E. BEST-
NORTH ONE (11 DEGREE TWENTY-FIVE:
MIND "TES WEST ONE HUNDRED
SEVENTY-FIVE (17i) FEET TO A SPIKE:
TIIENC; BY THE SAME NORTH EIGH'1 Y-
FIVE (8i) DEGREES EAST ONE HUNDRED
118EN1Y-FIVE AND FOUR TENTHS (125.4
PEE"T TO A SPIKE IN THE CENTER LINE,
01- "THE'. MILLERS CAP ROAD: THENCE.
-ALONG THE CENTER LINE OF SAID
MILLERS CAP ROAD SOUTH ONE ; I
DEGREF TWENTY-FIVE (25) MINUTES
EAST ONE HUNDRED SEVENTY-TWO
AND FIVE TENTHS (17'.5) FEET TO 'FIJI:
PLACE OF BEGINNING.
Bang known a, 6996 Werwille R,?ad.
Mechanicsburg, PA 17055
o Pu,el Number i8-11-0985-061
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
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:
May 2, May 9, and May 16, 2008
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.
6 L" Marie Coyne, Ttor
SWORN TO AND SUBSCRIBED before me this
16 day of May, 2008
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
RZAL XDTATZ BALL NO. 46
Writ No. 2007-7598 Civil
Nationstar Mortgage, LLC, f/k/a
Centex Home Equity Corporation
vs.
Richard L. Barr and Ann D. Barr
and The United States of America
Atty.: Heidi Spivak
ALL THAT CERTAIN lot or parcel
of land situate in Silver Spring Town-
ship, Cumberland County, Pennsyl-
vania, more particularly bounded
and described as follows to wit:
BEGINNING at the intersection
of the center line of Pennsylvania
State Highway No. 944, commonly
known as Wertzville Road, and the
center line of Legislative Route No.
21001, commonly known as the
Millers Cap Road; thence along the
center line of said Wertzville Road
South eighty-four (84) degrees West
one hundred twenty-six (126) feet
to a spike; thence along other lands
now or formerly of R. E. Hest, North
one (1) degree twenty-five (25) min-
utes West one hundred seventy-five
(175) feet to a spike; thence by the
same North eighty-five (85) degrees
East one hundred twenty-five and
four tenths (125.4) feet to a spike
in the center line of the Millers Cap
Road; thence along the center line
of said Millers Cap Road South one
(1) degree twenty-five (25) minutes
East one hundred seventy-two and
five tenths (172.5) feet to the place
of beginning.
Being known as 6996 Wertzville
Road, Mechanicsburg, PA 17055.
Tax Parcel Number: 38-13-0985-
061.
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Nationstar Mortgage, LLC f/k/a Centex
Home Equity Corporation,
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 07-7598 Civil Term
Praeciue to Vacate Judgment and
Discontinue and End Action
Attorney General,
Defendant(s).
TO THE PROTHONOTARY:
Kindly vacate the Default Judgment filed on February 19, 2008 in the amount of
$111;968.61 and Discontinue and End the above captioned Mortgage Foreclosure action without
Prejudice.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney ID No. 80763
{00251683}
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