HomeMy WebLinkAbout08-7115
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 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
228 Walnut Street, Suite 220
Harrisburg, PA 17108,
Defendants.
Attorney for Plaintiff
File: 9.09683
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: U?` 7llS
/ -kv4w,
CIVIL ACTION
MORTGAGE FORECLOSURE
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
800-990-9108
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: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
INationstar Mortgage LLC f/k/a Centex COURT OF COMMON PLEAS
Home Equity Corporation CUMBERLAND COUNTY
350 Highland Drive
Lewisville, TX 75067,
Plaintiff,
Vs.
Richard L. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
No.:
CIVIL ACTION
MORTGAGE FORECLOSURE
and
Ann D. Barr
6996 Wertzville Road
Mechanicsburg, PA 17055,
and
The United States of America c/o U.S.
Attorney
228 Walnut Street, Suite 220
Harrisburg, PA 17108,
Defendants.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, Nationstar Mortgage LLC f/k/a Centex Home Equity Corporation (the
"Plaintiff'), is a Delaware 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, 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, Defendant, is located at 228 Walnut Street,
Suite 220, Harrisburg, PA 17108.
4. On April 14, 2000, in consideration of a loan in the principal amount of $97,000.00,
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. The current interest rate is
8.110 percent per annum.
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 August 1, 2008, 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 ................................$209,925.93
Accrued but Unpaid Interest from
7/1/08 to 12/3/08
@ 8.110% per annum
($46.64 per diem) ........................................$7,275.84
Accrued Late Charges .................................$1,004.01
Title Search Fees ............................................$350.00
Reasonable Attorney's Fees ........................$1,250.00
TOTAL as of 12/03/2008 ........................$219,805.78
Plus, the following amounts accrued after December 3, 2008:
Interest at the Rate of 8.110 per cent per annum ($46.64 per diem);
Late Charges of $67.12 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
Defendants at 6996 Wertzville Road, Mechanicsburg, PA 17050 as well as to address of
residences as listed in paragraph 3 of this document on October 8, 2008, 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 lenghth herein.
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, $219,805.78, plus the following amounts accruing after December 3, 2008, to the date of
judgment: (a) interest of $46.64 per day, (b) late charges of $67.12 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
_0 4--?
Mary L. Harbert-Bell, Esq
Attorney for Plaintiff
VERIFICATION
I, Mary L. Harbert-Bell, 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: Mary L. Harbert-Bell, Esquire
Title: Attorney
Date: 11/21/2008 Time: 6:50 PM To: 0 1-877-236-1259
Page: 013
11-21-'08 17:39 FfM-
EXHIBIT q
6kW* )N ftovc f16M"21
Mz R1CRAND L ale! So" SWRTZVU" mom
?,ar am 1oEMOMMCMMO, 9% 1:688
R:Z?TI' rA'
all chat 6extala Iot or V=aa a! laps sikmta is s11.ar spring
Tawashiy, Cm&ftlaad CoW kY, loa+PYL4aASar apse p%rt% gXv4Zy bwssded
and 4eaecihad as fax~ to v"s
BIWIS"m ar ta6 2aA?t..a?.i.a.:",''Um or Ulf Coster live OL Vvumftldatlla state
siGbway VD. 94ar 400MOMMY ds WA tWLUS Raved, Md tba ceatea lfne
of Leffis7atiwe *cube no' 21601, oaaemly knawn so t2m pinata Gap Road:
th,= sloes the water 12na Of acid Wactmilie Road south sight,-far
(441 dagteas wmit Ow Rmdted Wvxty-six (2261 feet is a spike: thews
aloes other Iaoda mm or foteerlr of i. 9. seat, eecth aka 11) dwsrm
tumty-fire (at) ditkAu Mat tea mundted 6wv mt)r fire 417st fast to a
spike: !bl=ue by the ease nofth alebt-fix 488S doareae teat tae
n,mdced Twenty-fire and ibir mmtba (118.4} &at to a spire is the
oat= Ltaa of thw mAlloca tap Rmaj thmm almq the owtar lice of
said Nillaxs Q!D load M"b sae (i) degrees TW6Utr-:Eivw (20 Vdnates
amt 6ae kamdced sarraty-two sad liVa Tmthw 1178.0) feet to the plaap
oc ae61-Log.
sartag'tbgz-w *-"*a a dwlLtpg boaso flown wad ymwbec sa csvo
)rraewwLlle shad. INC?.rwuts,rbvrs. Pmoarlawis.
r-w ( w. g Q=
61
=
!-.11 i..ifhlita Blcfhnow .." 0melovedi
r?ee??lna(sn Olagaid ?
CtcNoN,aIW._ @
"Olm?tw et-8
T-899 P612/075 F-153
rrr??
rr.rrrr?,w
71n9PLOt38 10:x9:53 AM CUMBERLAND COLNM tr4t# 200010125 - Page 7 of 7
EXHIBIT B
zava
department of the Treasury - Interne) Revenue Service
Form 668 (Y)(c)
Illev. February 2000 Nkvd+ce of Federal Talc Elea
Area: Serial Number Fay 0 ' rwl Use Rewrr>ing Otges
& I
19V R
ARE
A
#
1
Lion
ne:
Unit Phen
i@n ($00)
829
-
7654
407570807
?+f 111
rTI,
As Provided by section 6321, 6322, and 6323 of the internal
Code, we are xhft a trance that taxes (htrhadkg b l"ren am p,e0aidm) 1
(2 X-0
e
i 4 '
have beets assesnpd asst the foAowngvamed taxpayer. We have Made
a deet=d for paynsent of this fiabilEty. bttt it mn*K tmpaid. li re, R# o"?A17
tlt8re Ls a gent I" ffavar of slat 1laited States air all PropeM and d Ats to
PWW bek"W to this tarpaper for the awomt of dMe taxes, a" I
additional penaftIM ItHwest, and cons that IZW accrue. r
Name of Taxpayer .eMDI BARB
Raiddence 6996 WBRTSVILLE BD
MRCMM:ECSBURG, PA 17050-1540
I 8
?
MPORTAXT RELis.A I Iidi"OMA710W.* For each assessment Gated below, ?
-"
unless MIDI of the Gen is renj ad by the date given in oolmnn 1c)r ? rKKk0 shall
on the day following such date, operate as a Ce?tfflote of releass as defined
in IRC 6325(a).
ind of Tax
f TAX Pdm
Z
IdendMw Humber Due* of
Assam Last ftv for
RWift of
of Assn iK
e
o (b (c) d) (+e?
CIW 06/30/2004 XM-XX-7428 11/20/2006 22/20/2016 898
63
CIVP 09/30/2004 )=-XX-7428 11/20/2006 12/20/2026 .
2611
15
CZVP 12/31/2004 X=-XX-7428 11/20/2006 22/20/2016 .
2364
29
CIVP
CTVP 03/31/2005
06/30/2005 X= -XX-7428
MM-XX-7428 11/20/2006
11/20/2005 12/20/2016
3-2J20/2016 .
2287.77
2873
94
CIVP
CIVP 09/30j2005
12/31/2005 XXK-XX-7428
XXX-XX-7428 11/20/2006
11/20/2006 12/20/2016
12/20/2016 .
3331.10
40
2
7
.
8
2
rlace ar Filing
Prothonotary
Cumberland County
Carlisle. PA 17013
TOW 1$
17207.60
This notice was prepared and signed at DETROIT, MI , on this,
the 05th day of December 2007
Signature .)c- fi. NMW
for DZBRA K. RMST
(HOM Ceroftraw of afrMf auftrizi
Rev. Rui. 71-466, 1971 - 2 C.B. 409)
EGt-3 6L0lZ£0d 668_1
ACS 11-00-0000
(800) 829-7650
by law tv take aaknow"ment is Mn a to the vaMw of Notice of Federal Tex Ken
-WOHI Z6 LL 80 ,-tZ-TL
CCO : GBvd
65ZT-96Z-LL8-T eO :01 Wd 09:9 :army SOOZ/TZ/TT .:9IgQ
EXHIBIT B
1.872
"
Farm 669 (Y)(t) Department of the Treasury - Internal Revenue Service
Morn. Fabnmy zoos, , - Notice of Federal 'rax UDD X. ? ;Ij -j_ F~'rL
Area:
W Serial Number For Optional ttae t)ffiea
ASPS & INV8STHWT AREA #I ?/
A
Lien Unit Phone. (goo) 829-769p 294183109 9 -
LAN
As pravided by simctbn d32#, 632.2, atad "23 of** Intend k*VMe CK- .S" 1
ode, " ar+e *&Ill a l that L azes (fig mom,",[ penal")
MW beea MOW amt the FoMaair?g?aamed . we have tirade
-
/ ';'F 04
a demand for paynK of thbr >EtWft, btrt it retnahts ate. Thom: M*
,
thus it a pmt h? favatr of the Unlteri; States as A pir+ppetty and rights to
pr"Oty bdauS tb dds CaoCvi"r for tine arts W* Of t taxes and ? o
addfNanal pMa hrteresc, and costs that may ape- j
Ue
Nerne of Taxpayer RI BARB
r
Residence 6995 WERTZVILLB RD ' - ' 5
MECHANICSBi3RO, PA 17050-1540
"ORTA T RELMS21t+)EFO MATION'. For each assessment listed wow C.'1
,
Was notice of the Nett is reified by the bate given in column (e), this notice shalt
,
an the day following such date, operate as a certifleste of release as defined
In iRC 6328(a).
1Cbtd of Tax Tax 1krlod
> ding
1d[?a MWnber pace of
Assesment Last D for
Mg uapdd BaIte
of Aximmum
a ( e
MW 09/30/2003 XXX-XX-0304 07/26/2004 08/2512024 5075.45
CIVP 12/31/2003 XXX-XK-0304 07/26/2004 08/25/2024 3661.41
Mace 07 Ft7trt9
Prothonotary
Cumberland Co=ty
Carlisle, PA 17013
Total 10 8736.86
This notice was praptuad and signed at DETROIT, MI
the 30th day of may , 2006
Signature: ?- A. ! yt?
for DEBRA K. R MM
(mom Carptleete of eft er auts+erked by taw to too
Rev. Red. 71-400,1971 -2 CA 4491
E91-3 910/Ked 668-1
, on this,
11-ao-noon
(800) 829-7650
Mt is not eaaW" to the vprx6ty of Notice of '
Fadsrei Tax Ben
-IOSd 19T7:LL $0,-TZ-11
960 : aBVd
65ZT-9GZ-LL9-T 8 :01 Rd 09:9 :autiy 800Z/TZ/TT :GlVa
?HhRrr Q
Feral "S (if)(c) Department of the Treasury - Internal Revenue Service
teov. Fabna+v 20041 Notice Of fe&'al Tax Lien
Area: Serial Number
WAGE 6 I33V$? 3 p.M #2
Lien Unit phone: (200) 029-7650
2a666$y+?s
As Pravlded by Section 6321, 6322, and 6333 of the Inbem:d Rover lxe
Cade, we are Shft a notice *4 wxet (Inclad leff bterest aad p+enait%r)
have been an wassed agalast the fOROWL49-na> aed UIVOrrr. We ]rave made
a demand fat paymem of this may, belt k MW M aQpaid, Therefam
there h a Leta hn favor of the United states on an progeny AW rights to
pirq*rty bdoggig to this twqpy+er for the apnowt of these taxes, and
additional P"IMUles, Interest„ and casts that way accrue.
Residence 6996 IgERTZVILLE RD
MECIiMICSBMG, PA. 17050-1540
IMPORTANT "1.MSrE INFORMATION: r-w each amessment listed below,
unless notice of the Hers is raffled by the date given in column (e), this nWce shall,
on the day foNawing such date, operate as a certificate of release as defined
in MC 6325(a).
Tax Period I Date of
faNd of Tax Rn+d'mg ldekIt ng Nams6er A es aeut
C ) ??a
2 IGt91
Sol
r,
C•3
Last Day for Ulapald Balance
ems of Assessment
CIVP 09/30/2001 166-46-7428 06/07/2004 07/07/2014 757
20
CIVP 12/31/2001 166-48-7428 06/07/2004 07/07/2014 .
6
94
CIVP 03/31/2002 166-48-7428 06/07/2004 07/07/2014 .
1911
23
CI VP 06/30/2002 166-48-7428 06/07/2004 07/07/2014 .
3349
13
CIVP 09/30/2003 166-48-7428 07/26/2004 08/25/2014 ,
508
5
28
CIVP 12/31/2003 166-48-7428 07/26/2004 08/25/2014 .
.
3661.41
Place of Filing
Prothonotary
Cumberland County
Carlisle, PA :L?033
Total 10 14773.19
This notice was prepared and signet( at PHILADELPHIA, PA
,ors this,
the _ 02nd day of Mauch 2005
Signature i l
for p s E 7.2-00-0000
(800) 829-7650
(MOM C' rW!Oa-te of officer autborlaed by few To take aduw&; Vment is not sasentiat to the vaNdRy of Notice of F*dwof Tax Ren
Rev. Rul. 71-488. 1371 • 2 C.D. 408)
.691-9 5G0!IM 668-1 -61063 Z? LL 80,-2-IL
Z80 : 92'Rd
65ZT-9£Z-LL9-T 8 :01 Wd 05:9 :amts 800Z/TZ/TT :GIVU
EXHIBIT B
11052611192008 Cumberland County pronotary's
PYS510 Civil Case Pr Tlt office Page 1
2004-04732 U S TREASURY DEPARTMENT (v$) BARR RICHARD
Reference No. Filed.. 9/21{2004
Case Type._ FFsDkRhL TAX LIEN Time.......... $:15
Jydre Assigned 8983.50 Rxecution Date 0/00/0000
Dis osed Deac _ : L7ury Trial,
. .
Case Comments ---------- Dispposed Date. 0/00/0000
"'^ X: bier Crt 1.:
Hiyacr Crt 2.:
t*#dF*******w+rwYse4*ys*dt***wxw?r**w****t****w***ww+k***#*1EieF:frt*t,rikFwtr+kw+k+?ttT+Eia#itJtkatFirkFlr
General Index Attorney info
U S TREASURY DgpARTMEM PLAINTIFF
PITTSBURM OFFICE ROOM 80$
1000 TTSBURGH LIBERTY 9974
PI
B
69-96 AFR RICHARD DEFENDANT
MVCHANICSBURG PA 17050 1540
audgment index Amount Date Desc
BARB RICHARD 8,983.50 9/21/2004 TAX LIEN
www?*w?,??rtw**ww?r?rwwkw,??r???ar,?*,t*wsrw?rw,?vsx*???t*?**;r***tr**?xx;r??srrr?r?rx*a?**?***+?*??*:t
* Date Entries
w*w******www?rwx?****w****?txw?xri;rwwx+w***wt*-?,t*f*w*,r*?w?w?r?ewwwx***wt**?t*?*********t
ENTRY' _ - - _ _ _ _ - _ - -
3/21/2004 FEDERAL TA$ LIEN IN THE AMOUNT FIRST OF N8983.50
- - - - - - - - - - - - - LAST _ RY - - - - - - - - - - -
w*a4dr?t********wWrrwwyr**?F*#iFilrsF?ttYlrlrve?kArxYt#x4kiErf?t?t?t:tlr*dE-4?t*?Y?rx?Fir?t?trwk*xh#3ytie$tYfakak?lrst?*ka6k?F
* Escrow Info Lion
* Fees & Debits Beg Bal Pymt*sAd? Enid Bal
******xwauyvrki.*sF***dr**?r*xw,ewwwww *ir***#at **yF?I* ,eekwvrwxwww?t,bit*?******,S*k**,tatt.**w
FED TAX LIEN
AUTOMATION FEE 5.00 5.00 .00
-------- ------------
14.00 _00
14.00
4?t*ir*?F**?k?lrie*x?i?a6yedeaU?t?tdr*:ttE,t*7t#?t*?tr?trw?kwgtlr?w*ie*kie?F?t**ot?t7Fot?tib*'?'*?'*******Yi?txtt*ii,tie?lEwxw?w
* Rnd of Case Information
*wx?x?rw?:w***#*?x****x**wre?rw?ex*****was:tw**+w**ww***r?xrrwer*ww:a***?tww**w*??r*********?
£6T-9 5LOAM 668-1 -WOE TVZ1 801-TZ-TT
tZO :a2Ed
65ZT-98Z-LL9-T 8 :oy Rd 05:9 :amTL 800Z/TZ/TT :01'eu
7.J
14,?
.S
6...J
--D
1 -
r SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07115 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC
VS
BARR RICHARD L ET AL
KENNETH GOSSERT , 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 1658:00 HOURS, on the 11th day of December-, 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17055
by handing to
ANN BARR, WIFE
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
Service
Affidavit
Surcharge
'/oala9 CX
18.00
9.00
.00
10.00
.00
? 37.00
Sworn and Subscibed to
before me this
of
So Answers:
R. Thomas Kline
12/23/2008
MILSTEAD & A"""C"T"S
By:
day
A. D.
CASE NO: 2008-07115 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC
VS
BARR RICHARD L ET AL
KENNETH GOSSERT 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 1658:00;HOURS, on the 11th day of December-, 2008
at 6996 WERTZVILLE ROAD
MECHANICSBURG, PA 17055 by handing to
ANN BARR
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
Service
Affidavit
Surcharge
i1o"10a
6.00
.00
.OQ
10.0Q
.00
16.0
Sworn and Subscibed to
before me this
of
So Answers:
V.,? , "* ?.-
R. Thomas Kline 'd
12/23/2008
MILSTEAD & ASSOCIATES
?, BY
day
A. D.
D ut S?KerFf_f
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-07115 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSTAR MORTGAGE LLC
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 THE
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 December 23rd , 2008 , this office was in receipt of the
attached return from DAUPHI
Sheriff's Costs: So answers-
6.00
Docketing
Out of County 9.00
Surcharge 10.00 R. Thomas Klin
Dep Dauphin County 41.25 Sheriff of Cumberland County
Postage .76
67.01
? I/C f °9-
12/23/2008
MILSTEAD & AS',SOCIATES
Sworn and subscribe to before me
this day of ,
A. D.
In The Court of Common Pleas of Cumberland County, Pennsylvania
Nationstar Mortgw LLC, fka Centrex Home Equity Corporation
Richard L. Barr, et al
Serve: The United States of America No. 2008-7115Ciy-il
c/o U.S. Attorney
Now,
I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dau hin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff.
*ffidavit of Service
Now, , 20 , at o'clock
i
within
upon
at
by handing to
a copy of the original
and made known to
Thank you.
M. served the
the contents thereof.
So answers,
Sheriff of
Sworn and subscribed before
me this day of , 20
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
County, PA
(Pilixf. of t4 IV
Mary Jane Snder
R al Estate Depu
William T. Tully
Solicitor
Dauphin County
1?Iarrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
NATIONSTAR MORTGAGE LLC
VS
THE UNITED STATES OF AMERICA
Sheriffs Return
No. 2008-T-2538
OTHER COUNTY NO. 20087115
And now: DECEMBER 12, 2008 j at 9:20:00 AM served the within COMPLAINT IN
MORTGAGE FORECLOSURE upojn THE UNITED STATES OF AMERICA by personally
handing to SUSAN MELENDEZ 1 true attested copy of the original COMPLAINT IN
MORTGAGE FORECLOSURE an4 making known to him/her the contents thereof at C/O US
ATTORNEY, 228 WALNUT STREET SUITE 220 HARRISBURG PA 17108
ADMIN. ASSISTANT
Sworn and subscribed to '
before me this 22ND day of December, 2008
NOTARIAL SEAL
MARY JANE SNYDER, Notary Publi
Highspixe, Dauphin County
M Commission $ ires Sept 1 2010
So Answers,
IeL?C-
Shbriff of Dauphin C P . 1
By
Deputy Sheriff
Deputy: R HOPKINS
Sheriffs Costs: $41.25 12/10/2008
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
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
228 Walnut Street, Suite 220
Harrisburg, PA 17108,
Defendants.
for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
i
No.: 08-7115 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 Plaintiffs damages as follows:
As set forth in Complaint $219,805.78
Interest 12/4/08 through 01/16/09 2,052.16
Late Charges 67.12
Additional Corporate Advance 413.75
TOTAL $222,338.81
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. copy attached.
ary L. Harbert-Bell, Esquire
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: JA<7,y . 20 ?1jQ
ROTH ARY
{00315744}
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
Attorney for Plaintiff
Our file number: 9.09683
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,
Defendants
COURT OF COMMON PLEAa
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
TO: Richard L. Barr Ann D. Barr
6996 Wertzville Road, 6996 Wertzville Road,
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
DATE OF NOTICE: January 6, 2009
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.
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
(00020971)
Page I of 2
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: Mary L. Harbert-Bell, Esquire
ID No. 80763
Attorney for Plaintiff
(00020971)
Page 2 of 2
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 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,
Defendants.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
VERIFICATION OF NON-MILITARY SERVICE
Mary L. Harbert-Bell, 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,
4. defendant, The United States of America c/o U.S. Attorney, is over 18 years of age
and resides at 228 Walnut Street, Suite 220, Harrisburg, PA 17108.
A
Mary L. Harbert-Bell, Esquire
(00315744)
_U
C- _'
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
Prothonotary
To: Richard L. Barr
Ann D. Barr
The United States of America c/o U.S. Attorney
Nationstar Mortgage LLC f/k/a Centex
Home Equity Corporation,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
Vs.
Richard L. Barr,
and
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney,
Defendants.
No.: 08-7115 Civil Term
NOTICE PURSUANT TO RULE 236
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in abov roc ing as indicate below.
'0p
Prothono
MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
MARY L. HARBERT-BELL, ESQ. #80763
MILSTEAD & ASSOCIATES, LLC
856-482-1400
Notice Pursuant To Fair Debt Collection Practices Act
This is an attempt to collect a debt and any information obtained will be used for that purpose.
{00315744}
t ..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Nationstar Mortgage LLC f/k/a Centex Home CIVIL ACTION
Equity Corporation,
Plaintiff,
Vs. ; NO.: 08-7115 Civil Term
Richard L. Barr
and
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Ann D. Barr,
and
The United States of America c/o U.S.
Attorney,
Defendants.
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
The United States of America c/o U.S. Attorney
Real Property involved: 6996 Wertzville Road
Mechanicsburg, PA 17055
Amount Due
Interest from 1/17/09 to 6/10/09
at $36.55 per diem (6%)
$222,338.81
TOTAL
(Costs to be added)
DATE: February 24, 2009
{00326380)
Respectively submitted,
Milstejtd & Associates, LLC
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
Ad
r.? - N
4 U° 000-()0 8 `n
TA
co
lqb
r ..,,,
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 WERTZVILI-E 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 SPIN IN THE CENTER LINE OF THE
MILLERS GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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 69% Wertzville Road, Mechanicsburg, PA 17055
Tax Parcel Number: 13-0985-0061-0000000-38
100326380)
JIL t4,
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
Attornev for Plaintiff
Nationstar Mortgage LLC f/k/a Centex Home COURT OF COMMON PLEAS
Equity Corporation, CUMBERLAND COUNTY
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr
No.: 08-7115 Civil Term
AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
and
The United States of America c/o U.S.
Attorney,
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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 Ann D. Barr
6996 Wertzville Road 6996 Wertzville Road
Mechanicsburg, PA 17055 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:
Internal Revenue Service
Federated Investors Tower
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
U.S. Dept. of Justice
U.S. Atty-Middle Dist. of PA
Attn: Mary Catherine Frye, Esq.
Asst. U.S. Atty
Federal Building
1003263801
JNO%A*
Commonwealth of PA
Bureau of Compliance
P.O. Box 280946
Harrisburg, PA 17128-0946
Monarch Products Company, Inc.
c/o Wayne F. Shade, Esq.
53 West Pomfret Street
Carlisle, PA 17013
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Selective Insurance Company of America
c/o Robert D. Kodak, Esq.
407 North Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
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 slatements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswo falsification to authorities.
ary L. Harbert-Bell, Esquire
Attorney for Plaintiff
Date: February 24, 2009
{003263801
ash
rQ
rte-'
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 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,
Defendants.
TAKE NOTICE:
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 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 10, 2009 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $222,338.81 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.
{00326380}
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
9.09683
{00326380}
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 WERTZVR LE 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
MUMS GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
100326380)
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7115 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONASTAR MORTGAGE LLC f/k/a CENTEX
HOME EQUITY CORPORATION, Plaintiff (s)
From RICHARD L. BARR and ANN D. BARR and THE UNITED STATES OF AMERICA c/o
U.S. ATTORNEY
(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 $222,338.81
L.L. $.50
Interest from 1/17/09 to 6/10/09 at $36.55 per diem (6%)
Atty's Comm % Due Prothy $2.00
Atty Paid $239.01 Other Costs to be Added
Plaintiff Paid
Date: 2/25/09
(Seal) By:
is R. Lon l, Prothonot
Deputy
REQUESTING PARTY:
Name: MARY L. HARBERT-BELL, 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. 80763
I
In the Court of Common Pleas
of Cumberland CdLmty, Pennsylvania
Writ No. 2008-7115 Civil
Nationstar Mortgage LLC, f/k/a Centex Home Equity Corporation
Vs
Richard L. Barr and Ann D. Barr
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
March 6, 2009 at 1705 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 L. Barr and Ann D. Barr, personally, at, 6996
Wertzville Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same
time handing to them personally the said true and correct copy of the same.
Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 4,
2009 at 0818 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 6996 Wertzville Road,
Mechanicsburg PA 17055. This letter was mailed under the date of April 2, 2009 and never returned
to the Sheriffs Office
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is
returned STAYED.
Sheriffs Costs
Docketing 30.00
Poundage 2.82
Posting Bills 15.00
Advertising 15.00
Law Library .50
Prothonotary 2.00
Mileage 18.00
Levy 15.00
Surcharge 30.00
Share of bills 15.43
?
143.75
So Answers:
CID -
H
12
I
R R. Thomas Kline, Sheriff
BY
Real Estate Coordinator
_ -:
0
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
Attorney for Plaintiff
Nationstar Mortgage LLC f/k/a Centex Home ; COURT OF COMMON PLEAS
Equity Corporation, CUMBERLAND COUNTY
Plaintiff,
Vs.
Richard L. Barr
and
Ann D. Barr
and
The United States of America c/o U.S.
Attorney, '
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
No.: 08-7115 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 Ann D. Barr
6996 Wertzville Road 6996 Wertzville Road
Mechanicsburg, PA 17055 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:
Internal Revenue Service
Federated Investors Tower
13'' Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
U.S. Dept. of Justice
U.S. Atty-Middle Dist. of PA
Attn: Mary Catherine Frye, Esq.
Asst. U.S. Atty
Federal Building
{00326380}
Commonwealth of PA
Bureau of Compliance
P.O. Box 280946
Harrisburg, PA 17128-0946
Monarch Products Company, Inc.
c/o Wayne F. Shade, Esq.
53 West Pomfret Street
Carlisle, PA 17013
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Selective Insurance Company of America
c/o Robert D. Kodak, Esq.
407 North Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
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 tements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswo falsification to authorities.
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
Date: February 24, 2009
{00326380}
0
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,
Defendants.
TAKE NOTICE:
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 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 10, 2009 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $222,338.81 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.
{00326380}
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
9.09683
100326380)
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:
BEGM41NO 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 MII.LERS GAP ROAD;
THENCE ALONG THE CENTER LINE OF SAID WERTLVIIL.E ROAD SOUTH EIGHTY-FOUR
OTHER LANDS NOW OR FORMERLY TWENTY-SIX
OF ?? R. (E. 6 BESET, NTO A OR ?ONEME(1) EGREE
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 SPIN IN THE CENTER LINE OF THE
MILLERS GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
{00326380)
WRIT OF EXECUTION and/or ATTACHMENT
COMMO'dWEAVrH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7115 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONASTAR MORTGAGE LLC f/k/a CENTEX
HOME EQUITY CORPORATION, Plaintiff (s)
From RICHARD L. BARR and ANN D. BARR and THE UNITED STATES OF AMERICA c/o
U.S. ATTORNEY
(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 $222,338.81
L.L. $.50
Interest from 1/17/09 to 6/10/09 at $36.55 per diem (6%)
Atty's Comm % Due Prothy $2.00
Atty Paid $239.01
Plaintiff Paid
Date: 2/25/09
(Seal)
Other Costs to be Added
(IJA
Curtis R. Lorothono
By:
Deputy
REQUESTING PARTY:
Name: MARY L. HARBERT-BELL, 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. 80763
Real Estate Sale # 88
On March 5, 2009 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 5, 2009
B''' I-XQlL?-
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7115 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 AND THE UNITED STATES OF AMERICA
C/O U.S. ATTORNEY
(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: $222,338.81 L. L.:
Interest FROM 1/17/09 TO 9/7/11 AT $36.55 PER DIEM (6%)
Arty's Comm: % Due Prothy: $2.00
Arty Paid: $404.26 Other Costs: TO BE ADDED
Plaintiff Paid:
DatA: 6/611 ? lx'6L
v
David D. ell, Prot oip
(Sea)) By:
Deputy
REQUESTING PARTY:
Name: PATRICK J. WESNER, ESQUIRE
Address: 220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-482-1400
Supreme Court ID No. 203145
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,
and
The United States of America c/o U.S.
Attorney,
Defendants.
CIVIL ACTION
NO.: 08-7115 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: xrn ? -
.
Richard L. Barr ' -,r.
8
Ann D. Barr cn
C7a
.-
n
The United States of America c/o U.S. Attorney ' ?
:Gt ?
N ac~'
fii
Real Property involved: 6996 Wertzville Road -- ?
Mechanicsburg, PA 17055 3
Amount Due
Interest from 1/17/09 to 9/7/11
at $36.55 per diem (6%)
TOTAL
(Costs to be added)
DATE: June 3, 2 11 a
d 2 y D/) #q al'a` l-
437.66 L??IC
143 7 6-
7F• so
/ t/• d G ,f/
{00589861} av.OG
$222,338.81
Respectively submitted,
Milstead & Associ s LL
Patrick J. W er, Esquire
Attorney 220 Lake D East, Suite 301
Cherry Hill, NJ 08002
V. 6v 1".w e'2?.
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 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 GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
{00589861}
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
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
Our File No. 9.09683
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
Withdrawal and Entry of Appearance
The United States of America c/o U.S.
Attorney,
I -a
ON -
C:)
?
C C:7 •-r?
F
Defendant(s).
WITHDRAWAL/ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly withdraw the appearance of Mary L. Harbert-Bell, Esquire as counsel for the
Plaintiff, and enter my appearance on behalf of the Plaintiff, Nationstar Mortgage LLC f/k/a
Centex Home Equity Corporation, in the above captioned matter.
MILSTEAD & AS
BY: 1 "I r
MAR V. HARBERT-BELL, ESQ
Withdra ing Attorney
MILSTEAD & ASSOCIATES, LLC
BY
PA
Att
{00589843}
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
RCHARD L. BARR
ANN D. BARR
Chapter: 13
Debtor(s)
CHARLES J. DEHART, III, TRUSTEE
Movant(s)
vs.
RICHARD L. BARR
ANN D. BARR
Respondent(s)
Case Number: 09-02506
ORDER DISMISSING CASE
C=3
-ca3 ?
zM -mss
r
Upon consideration of the Trustee's Certificate of Default of Stipulation in
settlement of the Trustee's prior Motion to Dismiss case for material default and it
having been determined that this case should be dismissed, it is
ORDERED that the above-named case of the debtor(s) be and it hereby is
dismissed.
Dated: January 28, 2011
By the Court,
. ` -
Roben N. Opel, 11, Bankniptcy Judge
B4
MDPA-Dismiss Case.WPT- REV 03109
Case 1:09-bk-02506-RNO Doc 105 Filed 01/28/11 Entered 01/28/11 10:20:01 Desc
Main Document Page 1 of 1
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
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,
Defendants.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
AFFIDAVIT OF SERVICE
- -,
f
PURSUANT TO RULE 3129.1 C: _-'
00
m
?
M -rl
:Z:
Cn
-? ?' rn c3 c
-` - c7
N om,
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. Ban
6996 Wertzville Road
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the Judgment:
Same as above Internal Revenue Service
1000 Liberty Avenue, Room 112
Pittsburgh, PA 15222
{00589861}
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
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Commonwealth of PA
Bureau of Compliance
P.O. Box 280946
Harrisburg, PA 17128-0946
Selective Insurance Company of America
c/o Robert D. Kodak, Esq.
407 North Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
Monarch Products Company, Inc.
c/o Wayne F. Shade, Esq.
53 West Pomfret Street
Carlisle, PA 17013
Penn Waste, Inc.
P.O. Box 3066
York, PA 17402
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
{00589861}
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 unworn falsificatjbn to
authorities.
Patrick J. W,
Attorney for
Date: June 3, 2011
{00589861}
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
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,
Defendants.
TAKE NOTICE:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
NOTICE OF SHERIFF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
C
? `
z r-
cnr'
= C,
C?
Your house (real estate) at 6996 Wertzville Road, Mechanicsburg, PA 17055, is
scheduled to be sold at sheriff's sale on September 7, 2011 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $222,338.81 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 Sheriffs 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.
{00589861)
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
9.09683
{00589861}
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 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 GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
{00589861}
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 WERTZVII LE 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 GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
{00589861}
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145 _ w ::1T:!0 N 01r
220 Lake Drive East, Suite 301
Cherry Hill NJ 08002 ' 2 6 } r ; 10: '-J'S
(856) 482-1400
Attorney for Plaintiff {ARIBERt AUD COUNTY
p 1"'
Nationstar Mortgage LLC f/k/a Centex Home
Equity Corporation,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
Richard L. Barr
and
Ann D. Barr
and
The United States of America c/o U.S. Attorney,
Defendants.
1, Patrick J. Wesner, Esquire, say:
NO.: 08-7115 Civil Term
AFFIDAVIT PURSUANT TO
Pa.R.C.P. 3129.2
1. On June 20, 2011, a copy of the Notice of Sheriffs Sale of Real Property was served
upon the defendants, Richard L. Barr and Ann D. Barr, by a private process server. Copies of
the service returns are attached hereto and made a part hereof as Exhibit "A".
2. On June 29, 2011, a copy of the Notice of Sheriff's Sale of Real Property was served
upon the defendant, The United States of America c/o U.S. Attorney, by certified mail, return
receipt requested. Copies of the signed certified cards are attached hereto and made a part hereof
as Exhibit "B".
3. On April 1, 2011 and September 6, 2011, a notice of Sheriff s 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 "C".
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities.
Dated: September 20, 2011
Patrick esner, Esquire
Attorn No. 203145
Milstead and Associates, LLC
(00635077)
1. 003
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
NATIONSTAR MORTGAGE LLC F/K/A CENTEX HOME
EQUITY CORPORATION; et seq.
Plaintiff (Petitioner)
V.
RICHARD L. BARR; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 08-7115 CIVIL TERM
Sheriffs Sale Date: 9/7/2011
AFFIDAVIT OF SERVICE
Complaint Summons J Other: NOTICE OF SALE
I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party, and
that I attempted to serve ANN D. BARR the above process on the 20 day of June, 2011, at 6:20 o'clock, PM, at 6996 Wertzville Road Mechanicsburg,
PA 17055 , County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
J By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in
charge of the residence because no adult family member was found *
By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at
which he/she resides *
By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s') agent or to the person for the time being in
charge thereof *
* Name: MARSHA LYNN
Relationship/Title/Position: Co-Resident
Remarks:
Description: Approximate Age 46-50 Height 5'4 Weight 175 Race WHITE Sex FEMALE Hair BLONDE
Military Status: J No Yes Branch:
Commonwealth/State of /A )
SS:
County of
Before me, the undersigned otary public, this day, personally, appeared
being duly sworn accordin o law, deposes the following:
,&h M&cn
to me known, who
I hereby swear or affi4#4t the facts set forth in the foregoing Affidavit of Service are true and correct.
of Affiant)
File Number:9.09683
Subscribed sw rn to before me
this ZI day o , AL-t , 20 N .
coMMONWEAL O PPENN Notary Public
Eric M. Aflh rbech Notary Public
WomIngt ii WP., aerks County
res (Wv.18 2013
^
OrMnm
T-• •?
L
iJ :v?•
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
NATIONSTAR MORTGAGE LLC F/K/A CENTEX HOME
EQUITY CORPORATION; et seq.
Plaintiff (Petitioner)
V.
RICHARD L. BARR; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 08-7115 CIVIL TERM
Sheriffs Sale Date: 9/7/2011
AFFIDAVIT OF SERVICE
Complaint Summons J Other: NOTICE OF SALE
I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and
that I attempted to serve RICHARD L. BARR the above process on the 20 day of June, 2011, at 6:20 o'clock, PM, at 6996 Wertzville Road
Mechanicsburg, PA 17055, County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
J By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in
charge of the residence because no adult family member was found *
By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at
which he/she resides *
By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s) agent or to the person for the time being in
charge thereof *
* Name: MARSHA LYNN
Relationship/Title/Position: Co-Resident
Remarks:
Description: Approximate Age 46-50 Height 5'4 Weight 175 Race WHITE Sex FEMALE Hair BLONDE
Military Status: J No Yes Branch:
Commonwealth/State of M )
SS:
)
County of 8,C et-5
Before me, the undersigned/notary public, this day, personally, appeared R !j A,. M a.r 1, f to me known, who
being duly sworn accordin to law, deposes the following:
I hereby swear or aff" tat the facts set forth in the foregoing Affidavit of Service are true and correct.
of Affiant)
File Number:9
Subscribed an wo o before me
this 2 r day o 20_.
L Notarial Seal Notary Public
Eric M. Al wbach, Notary Public
Washington Twp., Barks County
My Cornni s_on.No_v_ 16 2013
2. Article Number
eax
L'1(411
C. SbMture
7160 3901 9649 1705 3780 X
D. Is delivery address different from Item 17
K YES, enter delivery address below:
3. Service Trype CERTIFIED MAIL
4. Restricted Delivery? (Extra Fse) Yes
1. Article Addressed to:
Inited States Dept. Of JUSOCe (.S. Atty-Middle
)istr;Ct ,) ?A -Attn: Mary Catnerine. Frye, 9.09683
?squ;rt - Assistant U.S. Attoroev
,odcral Building - 228 Walnut Street
'.O. Box 1.1754 G W
- a;Tisburg, PA 17108
'S Form 3811, January 2005
I?
No
2. Article Number
Domestic Return Receipt
L.] Addressee
? Yes
? No
PS Form 3811, January 2005 Domestic Return Receipt
fi'r'mal R.eser"':e;:rvice
1000 LJO-Criy Wjoni 1 12
I
Gw
E N C N
LL; N O N N N O
d
L c6 m t0
?
E C p U? c0 a 0- U
C 3 ? ?
_
V
L) ;?
(D N N
O G 4) 3 U C N N
LL U L . C C C N C) cE N
N i
C3 V
U O 2
U C 0 V C 0 rn
'N O U cQ
O
u N N p` O C N
m
L N a)
n C Q
C
t6
E m>
'
y- O
U N
= N
U) LL p O
D
_ A U O. N L
d0 mtH C)
d
N
R .
C N.Ua
c
CLC O_?
lnN mm
O E:6
? y N
C E -5 N .a cn w
o
C r?o NLL c)
D'
?W
m
N
X O ai d ='a .
Q
C N
E
Q
LL y
p
? -
?
X N U f6
t
i? n
N D c
j (6
N
Q N
N
15 E Q.O n._ - N U
) D a b c L W 5 U N
• 0 N U ~ d V C E p t co
(D U7 w C! -0 N E X cO V
'2a Ea
O'O
1 mC UE c
.
m
a
m
2
m v
L
1 rt f n -0 a N C E
C L
7
N
3m ? w E° E O m
N=°_ CD 'ova
- C c0
m m N
c> mUO gO -
°1v°O21 E62
o
p p 7
p 0
0
N MO)
IT >? Q j Li' I
r I
I
CA p
C to I
1
a ? T
N L
U O
m = CL
CC E
?
r W
)
m N CL C
LL L
(, N
w
U
F-
N a N
'??Or
rn ?
Q
o
a) NO N
S UU
N ?
I
E
U O
o co O c0
>< . LL z
a
m
Cd ti
p a)
-?
WO
O N
d N
>
0
N
?
W
?+
.....
N a
y cr\
C
CS' Pr
0
ty
o
y U 0 q
p W 4) ^
r) W 4) 00 \
0 0 o ?" 4
9
o
a °' t-_
o - - o .5 - a _
a
coo 3r¢ gU ?o
Y
41
x o ¢
A
!F
oa° N y °' cNa° a od °c°'UNa oGx oQ Ari w ec, ??--
?
U
p v .?
p a) x
a) p t?l
o x.
P a
ai +
cNC iMt Q
L. w1 i
J Y
N O
z id
z ??+ O .O N r?Ti' .? O z ..O
ca Pa V cd m6
)cl?' '.? vi ? V .c p .D
Vs. 0 z 00 3 O py C
w N o& o N M tC O O
r- 00
El o cd (D o o
QM? Eye UAax AU ,U Ut?a;x v nU v?<C ??r aa;?
0
U a .' o
U)0
WOW2 o
?
Q!^ a)°
°aZ u
£? oa r
my c
? LL p=
- 7 a a m c
0
Y
w S
cCE
Z n
J f` L
7
~ a Z
0
m Z N y C
U a L
i
C)
N U J N M et tp c0 N 0
p QI N G
>
N
C
F- a. CO
n
F-
a
c
n
n
n
Q
Y
U -
:E
c
Q
LL
C
W
0.
W
Q
U_
z
0
LL
L?
f
a
ytf. 0.a. 41
r?
dltNO
O
W
O
-1 9
m o
LO
? T
E
Q1
LL b
W Y- O
S' 00
f? cn !6 N
N La p N
p
- N- N U? T j
o
16 0
r CS i
°•"• ma -v -avnv
N
•
N n
E c ... Y
d S n
Ljj
S
4?A1" Cl O
m -
N
N
C
N W y
- 7 U C W
C C C N OL OL t6
U N LY I ,? ;i? 6 d.ul U; U W O C 'O ? L U
.
N? S O. R.
N Z
U C O V C U
L w
?_ t•? ??•, O
C N
(D C>
CL 8 8
C-4
0
(d
u) LL
..... t7 J
? ,
-F, CD cm) W Ull 4)
' U
TC
N
.C p
s
.....
Q3
1fN?? N o<
° :t-' y t6
to N
69-
a
N L
A d
CL,:- N .
-? c? r> E
f
E p m
v tIj LL o. v c :t:f lL n N
C
N ;'.L Pk ?
C N
X O
E N
°C N r i _
E (a O N
y 7 N
C
Q O
LY LL
M •r O N
N`
7 E N .+ E l m
d
0
X N U N
UP
7
•?, Eanp «'
y 0
7
?
.a Z
° N X N .T• E w°.
W
y
L
•
O
°
C N
F
-
C E
o.c
y U
C O LL
U E '
r
C
C
U N
c '3 C Q E L c0 L
p
N .O
N N
O - N O O F- O lC
w o m
N E O
O O 'a 'U
L
C N N ?
x(
'p)
N L N
• . N
N
C ? I
-
Lo
F- T t3 CA E 64
o
°
a
N
o ?
w Ll
N N
N_ L t . 7
<
LY. ? ?
cm N
C
N
U (tl N
T
C C
=U O
n
d' aEi
c a rn
N c
5 N
N ? LL L h '(D
v
m °
Q1 L;
'
N
a p
-
O
Uc
U o Om
z
x0110 o a
Uy ?
Fi N
Y
c H O O
6 Y
CIO Y
Y
Y ? Y 00 N ?
6
(D PL,
a) 0 :j 0 00
4, 00 cd a)
a;? o a> ? ido?P.
o cd 0 b o41P. cd o?P.
0
a Y ? 9 ? -c
d o a a) C's U
!ac
_
y cd 0 a N'n L C'? O w
S:l
O G o x 0
°
IO
Z C,
4 El° 4. p P ?
O ° w a
O (?
y
W y N
' . O? U
O h 0 0 N o o
` O N O p Cad
ir O;
x
S
Qm C7?o UQ ?UWL
? UGC ?Urn UPgP.
o -
Up
o
.?
ca
O 0 (D
O
0
U) w CO
Q N N°
v
4).2
?
°
?
LL
LL E
a
7 ?
-0 y V
N
Z 2 7 J
Z N
~ U J
p
N
_ N O
(O U G
NU N U)
cD
n D
~ d (n
Q_
IL
U
IJ
J
Lll
UI
N
Z
O_
O
a
a
a
t
W
J
LL
O
W
r2
H
d
O
z
C7
W
CD
m
ti
r
o•?
o
O
LL cq
n
Cl)
a °
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff?,?r ati„ uy?ff f i .;;
Jody S Smith AN
Chief Deputy 24 lo: tf ,j
Richard W Stewart
Solicitor
Nationstar Mortgage LLC
Case Number
vs.
Richard L Barr (et al.) 2008-7115
SHERIFF'S RETURN OF SERVICE
06/20/2011 12:27 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 6996 Wertzville Road, Mechanicsburg, PA 17055, Cumberland County.
06/20/2011 12:27 PM - Deputy Stephen Bender, being duly sworn"according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Ann D
Barr at 6996 Wertzville Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County.
06/24/2011 05:53 PM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be SERVED ANN
BARR- WIFE, who accepted as "Adult Person in Charge" for Richard L Barr at 6996 Wertzville Road,
Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County.
09/02/2011 As directed by Patrick J. Wesner, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/5/2011
10/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, PA on October 5,
2011 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Patrick Wesner on behalf of
Nationstar Mortgage LLC f/k/a Centex Home Equity Corporation at 350 Highland Dr. Lewisville TX. 75067.
Nationstar Mortgage LLC f/k/a Centex Home Equity Corporation, being the buyer in this execution, paid to
the Sheriff the sum of $1,056.10
01/24/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED.
SHERIFF COST: $1,056.10
January 24, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
q-3 (X) l d . G -
?? C wu ySaite 1,nentt. Teie.osot7. Inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson -
Sheriff r =_ -
Jody S Smith f) ; 7 a
.,t'
Chief Deputy •,, t, : 21'
h
Richard W Stewart
Solicitor ?C'EM;y?i?
LV,1 F, JEa
Nationstar Mortgage LLC
vs. Case Number
.
Richard L Barr (et al.) 2008-7115
SHERIFF'S RETURN OF SERVICE
06/20/2011 12:27 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 6996 Wertzville Road, Mechanicsburg, PA 17055, Cumberland County.
06/20/2011 12:27 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Ann D
Barr at 6996 Wertzville Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County.
06/24/2011 05:53 PM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be SERVED ANN
BARR- WIFE, who accepted as "Adult Person in Charge" for Richard L Barr at 6996 Wertzville Road,
Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County.
09/02/2011 As directed by Patrick J. Wesner, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/5/2011
10/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, PA on October 5,
2011 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Patrick Wesner on behalf of
Nationstar Mortgage LLC f/k/a Centex Home Equity Corporation at 350 Highland Dr. Lewisville TX. 75067.
Nationstar Mortgage LLC f/k/a Centex Home Equity Corporation, being the buyer in this execution, paid to
the Sheriff the sum of $1,056.10
01/24/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED.
SHERIFF COST: $1,056.10 SO ANSWERS,
(y-Z,
January 24, 2012 RON R ANDERSON, SHERIFF
11
v? 7e /?
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
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. i
i
Richard L. Barr
and i
Ann D. Barr
and i
The United States of America c/o U.S.
Attorney
Defendants.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 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 Internal Revenue Service
1000 Liberty Avenue, Room 112
Pittsburgh, PA 15222
{00589861}
r
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
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Commonwealth of PA
Bureau of Compliance
P.O. Box 280946
Harrisburg, PA 17128-0946
Monarch Products Company, Inc.
c/o Wayne F. Shade, Esq.
53 West Pomfret Street
Carlisle, PA 17013
Selective Insurance Company of America
c/o Robert D. Kodak, Esq.
407 North Front Street, P.O. Box 1] 848
Harrisburg, PA 17108-1848
Penn Waste, Inc.
P.O. Box 3066
York, PA 17402
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
{00589861}
r
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
1 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. l
Patrick J. We" er, Esquire
Attorney for?jaintif
Date: June 3, 2011
{00589861}
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
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,
Defendants.
TAKE NOTICE:
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-7115 Civil Term
NOTICE OF SHERIFF'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 September 7, 2011 at 10:00 am in the Commissioner's
Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court
Judgment of $222,338.81 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.
{00589861}
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
9.09683
(00589861)
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 SPIN; 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 GAP ROAD; THENCE ALONG THE CENTER LINE OF SAID MILLERS GAP 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: 13-0985-0061-0000000-38
(00589861)
WRIT OF EXEC>LTICN anc/or A"'" -AC7'VT7N7
COMMONWEALTH OF PENNSY LVANLA)
COUNTY OF CUMBERLAND)
NC) 08-7115 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NAT IONSTAR MORTGAGE LLC F/K/A CENTEX
HOME EQUITY CORPORATION Plaintiff (s)
From RICHARD L BARR AND ANN D. BARR AND THE UNITED STATES OF AMERICA
C/O U.S. ATTORNEY
(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 lie/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $222,338.81 L. L.:
Interest FROM 1/17/09 TO 9/7/11 AT $36.55 PER DIEM (6%)
Atty's Comm: °i0 Due Prothy: $2.00
Atty Paid: $404.26 Other Costs: TO BE ADDED
Plaintiff Paid:
Date: 6/6/11
David D. Buell, Prothonot
(Seal) B
Deputy
REQUESTING PARTY:
Name: PATRICK J. WESNER, ESQUIRE
Address: 220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-482-1400
Supreme Court ID No. 203145
TRUE COPY FROM RECORD
In Testimony whereof, I her unto set roy haul
and the se--I of said Court at Carlisle, Fa.
This ixr day of. -k1Nli ,2G 11
Prothonotary
4a 64??
On June 9, 2011 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: June 9, 2011
By:
ealCEstate Coordinator
2008-7115 Civil Term
Nationstar Mortgage LLC
Vs
Richard L Barr
Ann D Barr
Atty: Patrick J. Wesner
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
'16 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 Gap Road; Thence Along
The Center Line Of Said Millers Gap Road
South One (1) Degree "Twenty-Five (25)
Minutes East One Hundred Seventy-Twu
And Five Tenths (172.5; Feet To The Place
Of Beginning.
Being Known As 6996 Wertzville Road.
Mechanicsburg. Pa 17055
Tax Parcel Number: 13-0985-(061-
000(t000-38
The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
i4e Patti* ot-Nevus
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
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she 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:
07/15/11
07/22/11
C 1 07/29/11
Sworn to and s ascribed be 0e met is-1 cjay of August, 2011 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal ?I
Sherrie L. Kisner, Notary Public
Lower Paxton Twp., Dauphin County
f
My Commission Expires Nov. 26, 2011
Member. Pennsvivanla Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Nationstar Mortgage LLC f/kla Centex Equity Corporation is the grantee the
same having been sold to said grantee on the 5 day of October A.D., 2011, under and by virtue of a writ
Execution issued on the 6 day of June, A.D., 2011, out of the Court of Common Pleas of said County as
of Civil Term, 2008 Number 7115, at the suit of Nationstar Mortgage LLC flk/a Centex Home Equity
Corporation against Richard L. Barr and Ann D. Barr is duly recorded as Instrument Number
201202274.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and sAl of said office this L? day of
A.D.
f -- Recorder of Deeds
1 4?
Recorder d Cu+ iWwd Cour ty, Carlisle, PA ' 96A
My Cort W"? Expires the Fist Monday of Jan. 2014