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10-1884
Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 -Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 233187 NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 Plaintiff V. STEVIE E. ROWE TRUDI M. ROWE 57 CONRAD ROAD CARLISLE, PA 17015-8857 Defendants FILED-01' rCE "OF TFE °FOTH,ONOTAPY 2010 MAR 17 AM I I : 08 culvpF ? viT1' !.: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY File #: 233187 tk 4 yz,r3Td 2??-3 9da9 i 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 233187 Plaintiff is NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 2. The name(s) and last known address(es) of the Defendant(s) are: STEVIE E. ROWE TRUDI M. ROWE 57 CONRAD ROAD CARLISLE, PA 17015-8857 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/03/2008 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR FLAGSTAR BANK, FSB which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200820086. The PLAINTIFF is now the legal owner ofthe mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 233187 dk 6. The following amounts are due on the mortgage: Principal Balance $79,432.85 Interest $5,488.00 05/01/2009 through 03/16/2010 (Per Diem $17.15) Attorney's Fees $650.00 Cumulative Late Charges $347.32 06/03/2008 to 03/16/2010 Appraisal/Brokers Price Opinion $126.45 Costs of Suit and Title Search $5-50L00 Subtotal $86,594.62 Suspense Credit $0.00 Escrow Credit $0.00 Deficit $211.87 Subtotal 21 1 _R7 TOTAL $86,806.49 7 8. Plaintiff is not seeking a judgment of personal liability (or an in nersr onam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 233187 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $86,806.49, together with interest from 03/16/2010 at the rate of $17.15 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP B. awrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 233187 LEGAL DESCRIPTION ALL THOSE TWO CERTAIN lots, parcels, pieces of ground with the buildings thereon erected situate in Middlesex Township, Cumberland County, Pennsylvania, being known and described as follows, to wit; ON THE West by Fifty (50) feet wide Conrad Road as shown on the hereinafter mentioned Plan of Lots; on the North by Lot No. 78; on the East by Lot Nos. 94 and 95; and on the South by Lot No. 75. CONTAINING One Hundred (100) feet in front along the eastern line of Fifty (50) feet wide Conrad Road and extending eastwardly along therefrom at an even width a distance of One Hundred Ninety-eight and Four tenths (198.4) feet, more or less. BEING all of Lot Nos. 76 and 77 as shown on the Dale Fetrow Revised Plan of Lots recorded in the hereinafter named Recorder's Office in Plan Book 3, page 103 and having thereon erected a dwelling house. BEING Parcel No. 21-22-0119-040 PROPERTY BEING; 57 CONRAD ROAD File #: 233187 40- The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsifications to authorities. orney for Plaintiff DATE: File #: 233187 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. STEVIE E. ROWE TRUDI M. ROWE Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 04/30/2010 to Date of Sale ($14.39 per diem) NO. 10-1884-CIVIL CUMBERLAND COUNTY $87,561.09 1 899.48 TOTAL ~ a y. av ~l'c~ ~- ~w. ga ~ C6~ ~ . tg7.3v - « s~ ~'a .OD W ~'. s~v ~ Note: Please attach description of property. PHS # 233187 CK~ Qs7~~l~ ~~ ~~3SY $90,811.07 ~~I~l~tn ~tt6rcf~y for Pla~ntt'ff"' V Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ F cis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 C7 ^.' a v ~, n f i 7 r ~ _ /_ r ~- W ~ l _. -' ., ^ ~~ ~ ' ( _} ~T". ~~ ~~ ~:-- .~ b °' ~ ~ ~ ~ o0 v ~ 00 o 0 a~ ~ 3 dd W w a ~ a ~, w ~z~ o~ ~z~ ~o~ ~ r/~~nU E-'°U ~ ~ ~ ~ ~ H ~~ a V a U Oa w W~ H O ~ F'' O °: ~"O OU G ~ ~ wW~ 3 : ~~+ a~ ~~ ~ ~ Ey °a a° b w ~ O ~ V~ ... za w W~LI W o ~~ E~ O ~ rj ~ W ~U Z > ~H p.; o N ~ O~ O ~ ~ ~ M ~h N N N~ r o~~O ~ M rMi ~~ 0 O p O 0 ~p~° O~ OOMC ~ ~O~zNN 0 p„z o oz ozo~ornN~~o 0 0 ° c oz ,~ zzbzb o o °~ czz ~ZZb a~v,..,'b ^ '";,zzzoozb~j fn.tib ~~W ~W .. ^Q, ~ y o ~'~,W ,~ W W b o" o" ~, ~ti ~+" W W W v~ ; d W ~ ~ ~a ~ ~pq c~ ~ ~ ~ N~~.~ ~'~A ¢a^^^ ^^~^~~^^^^^~^ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1884 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE LLC, Plaintiff (s) From STEVIE E. ROWE AND TRUDI M. ROWE (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 $87,561.09 L.L. $.50 Interest FROM 4/30/2010 TO DATE OF SALE ($1.4.39 PER DIEM) -- $1,899.48 Atty's Comm % Due Prothy $2.00 Atty Paid $197.30 Other Costs Plaintiff Paid Date: JUNE 9, 2010 ~~ avid'l~Buell, Prothonotary (Seal) By: RF,QUESTiNG PARTY: Name MICHELE M. BF.ADFORD, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP Deputy 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 69849 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff v. STEVIE E. ROWE TRUDI M. ROWE Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.10-1884-CIVIL CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. 1nn~~ 1/1. ~~ a- ~ ~ ~ r~' ~.~( ~ .J _~ f'-~- - ~ :~ a =~ -~ : ; ; -. .Cl X1.1 Ll_ r..~ p _ ": . hl By: 1W'" ~ Atto ey fo Plainti Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Fr cis S. Hallinan, Esq., Id. No. 62695 ^ aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 NATIONSTAR MORTGAGE LLC Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v. STEVIE E. ROWE TRUDI M. ROWE Defendant(s) NO.10-1884-CIVIL CUMBERLAND COUNTY PHS # 233187 AFFIDAVIT PURSUANT TO RULE 3129.1 NATIONSTAR MORTGAGE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 57 CONRAD ROAD, CARLISLE, PA 17015-8857. Name and address of Owner(s) or reputed Owner(s): Name STEVIE E. ROWE TRUDI M. ROWE Address (if address cannot be reasonably " ~` N c ascertained, please so indicate) ~ ~ r r' - c_ -j ; "s ~~ r r ra ~ 1'a~ T i~ 57 CONRAD ROAD i ~_ t '~ CARLISLE, PA 17015-8857 ~ i~` ~o ~-? { ! 70 CONRAD RD ~` ~" ~ _ `~ ~'' CARLISLE, PA 17015-8854 C.v K 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CAPITAL ONE BANK (USA), N.A. C/O 2417 WELSH ROAD, SUITE 21 #520 APOTHAKER & ASSOCIATES, P.C. PHILADELPHIA, PA 19114 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. Name Address (if address cannot be reasonably ascertained, please indicate) None. ^ Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 57 CONRAD ROAD CARLISLE, PA 17015-8857 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 ATTENTION: JOHN MURPHY 6~ FL, STRAWBERRY SQ. DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 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.A. § 4904 relating to unsworn June 1, 2010 Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ F cis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. NO.10-1884-CIVIL CUMBERLAND C n Defendant(s) ~-. is. ~_j1r r. .e._ '_ OI~NTY © ...j ~~~ «u' f(l STEVIE E. ROWE TRUDI M. ROWE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY r,= ` w !~ ~ TO: STEVIE E. ROWE TRUDI M. ROWE 57 CONRAD ROAD CARLISLE, PA 17015-8857 ` ; c"- ~::. "- ~ ~~ ci_. -• ~> =~ * *THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 57 CONRAD ROAD, CARLISLE, PA 17015-8857 is scheduled to be sold at the Sheriff's Sale on 09/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $87,561.09 obtained by NATIONSTAR MORTGAGE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THOSE TWO CERTAIN lots, parcels, pieces of ground with the buildings thereon erected situate in Middlesex Township, Cumberland County, Pennsylvania, being known and described as follows, to wit; ON THE West by Fifty (50) feet wide Conrad Road as shown on the hereinafter mentioned Plan of Lots; on the North by Lot No. 78; on the East by Lot Nos. 94 and 95; and on the South by Lot No. 75. CONTAINING One Hundred (100) feet in front along the eastern line of Fifty (50) feet wide Conrad Road and extending eastwardly along therefrom at an even width a distance of One Hundred Ninety-eight and Four tenths (198.4) feet, more or less. TITLE TO SAID PREMISES VESTED 1N STEVIE E. ROWE AND TRUDI M. ROWE, AS TENANTS BY THE ENTIRETIES, GIVEN BY SAMUEL A. CALAMAN AND JUANITA E. CALAMAN, HUSBAND AND WIFE, RECORDED APRIL 19, 2006IN BOOK 274 PAGE 364. PREMISES BEING: 57 CONRAD ROAD, CARLISLE, PA 17015-8857 PARCEL N0.21-22-0119-040 _ i .~ JUL 14 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff Civil Division v. CUMBERLAND County STEVIE E. ROWE . TRUDI M. ROWE No. 10-1884-CIVIL Defendants RULE AND NOW, this / `1~ ~ day of 2010, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. ~,`~`"`` Rule Returnable on +hP ~a ~ 1 ~.g} , BY TH OURT ~~ J. n y5~ ~°u„e E. roux ~~- V Tr ~, E ti: -~ O ~' t~_ ~. ,~~ 233187 ~_ --,, T r r-- -~ Y -~ ..~ ._~• 4ll~Vlm(-~ ~ . PN~~~r ZEl E ~ :~.1 ~ -:~ ~ '~ ~-_ ~ 03 AUC~ 3 Pnt K - 4` Phelan Hallinan &Schmieg, LLP I3y: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. f-Iallinan, Esq., Id. No. 62695 D~~nicl G, Schmieg, Esq., Id. No. 62205 Michele M. 13rad1ord, Esq., Id. No. 69849 ,ludith 1~. Romano, Esq., Id. No. 58745 SheetaC R. Shah-Jani, Esq., Id. No. 81760 ,(chine R. Davey, Esq., Id. No. 87077 Lauren R. 'I'abas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 ,I ay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 .(aime McUuinness, Esq., Id. No. 90134 Clu•isovalante P. Fliakos, Esq., Id. No. 94620 ,loshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Pcnn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff : Civil Division v. CUMBERLAND County STEVE E. ROWE : "hRUDI M. ROWE No. 10-1884-CIVIL Defendants CERTIFICATION OF SERVICE 233187 -~ . I hereby certify that a true and correct copy the July 14, 2010 Rule Returnable was sent to the following individual on the date indicated below. STLVIE E. ROWS STEVIE E. ROWE TRt1DI M. ROWE TRUDI M. ROWE 57 CONRAD ROAD 70 CONRAD RD CARLISLE, PA 17015-8857 CARLISLE, PA 17015-8854 S"CEVII? 1. ROWE 235 RIVERVIEW TER DAUPHIN, PA 17018-9598 Phelan Hallinan & Schmieg, LLP DA'L'E: ( By: ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinaiz, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ ,Taime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ATTORNEY FOR PLAINTIFF 233187 AFFIDAVIT OF SERVICE (FNMA) pl,~q~ CUMBERLAND COUNTY NATIONSTAR MORTGAGE LLC PITS i 233187 DEPENDANT ~g,VI(T TEAM! f~c STEVIE g ROWg COURT NOa 10.1884CIVIL TRUDI M. ROWS SERVE STEVIE E. ROWS AT: TYPE OF ACTION 57 CONRAD ROAD IIX Notlee d SLer>R's Sak CARLISLE, PA 17015-8857 SALE DAT& 09/0812010 ed and made known tD E fi. RdWB . De the ~~day of gu of . ?A 10,E at ~p~V ~_, oclock ~. M.. at x.23$ t ~P.E2yl6a-?F~Ae.E . in the manner desafbed below: ~[ Deferdant persoaa-ly served. Rgtt PaF tN, Pq ~ Adult family member with whom Defertdartt(s) tesid~(s). Relationship is _ Adult in charge of Defendant's residence who refused to givt name or relationship. _ Matraga'I~Cltrk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's oflioe ar usual place of busitxss. an officer of said Defendant's oompatry. ~. Other ~~ -~ _~, ~(~~ r-a C'~ ~.~ r.~ ~ ~,,~~ ~~, Q~. ~ '--' ~_._, ~_ ' U ~. 'W. -{J Descri n: Ago ~~i o Height~Q r Weighs a~Oo Race w sex M other I, "~'~ ~ ~-. a cot~errc adult, being duly sworn aooordirtg to law, depose and atsoe that I personally handed a true and cornorK Dopy of the Notice o~.Sheriff's Sak in the tnanna as set forth her+eirt, issued in the captioned case on the dace and at the address indicatod abo~. ~7 Swartr to ana s bed ~ cJ• /~• (5 Tf~vA~T sec-atQ t f~ _ ~ NV ES ~ ~~, ~nl D r SG,di fry beef this 1Sn day -t-F~'~'f' DMtu'i' R~5 ~4rF~ @ a35 ~tA/~2v~ i%(~uT,~ ~ ~~~, zoo (/,~I ,, ~ /1 DA,,c pr~iN, ~ ~ . NOT SERVED e y of 20~, at ~ o'clock _ M., Defendant NOT POUND because: _ nt _ sd Address. ~ Moved _ Does Not Reside (Not Vacant) _ No Answer on at ,_ tu... ,.._ Service Refrised. ~ _ . Other: Swan to and subscribed obfrfore me this ~=day s Y Notary: KIMBERLY CURTY NOTARY PUBLIC STATE OF NEW 3ERSEY MY COMMiSSit7N EXPIRES MARCH 1, 2013 r..~..T rrr..nw.rii+..mn rn.a~ a a.sr.~ srs, sa rr. srs+s a.ra c. si.rr, sti, rc w ~t r~aa~ w< u.+a~ ~. rt x.. tears ~.ir r. a.~w bs. ++. etn eats s ~ .. r a s.++ w, a,. x r .. u, N Joel An1by i~,tiltaf'M! la. R 71iy sMy, li. M. fals- Ylri 8d~ee+- ~ li n~. ~14#ll Jq s. te.oa tbs, iL xa seesr riser ~ et.r+r, tbs.>z r. ~ e.ra- e. s~.a. W.>i x. tew~ aru Mucr.e.~ ~4. w a. rnsr awn.r.r.t! sa+.. stis,tr.rt..sew t.r. ~ s.>i•.~ aes.>i ee. ~eaeer l7w~esiY R D~-Oy, Y e4..7UeY/! ]~~ 1ri411tirAtlmttsre RIS)lt3~eN AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CilMBERI.N NATIONSTAR MORTGAGE LLC PISS • ?3187 DEFENDANT STEVIE & ROWS COURT NO.:10-1884-CI`7L TRUDI M. ROWS ~ ~ , r4'. co r 3 SERVE TRUDI M. ROWE AT: TYPE OF ACTION 70 CONRAD RD XX Nollee ~ Sha1fC's 3ak ---; ;~'' C', _~ _ CARLLSLE, PA 17015-8854 SALE DATE: 0~/08I2010 ~ ~F-~ _ - ~ ~- .. Served and made krawn to Detertdant on the y of Ll N~ 2D ~ at ~-: .. ~ V_ 0 , o'clock ,g. M., at ~ ~ i1n U S i.E.1~1, in the mantra described below: Defendant persowdly served. 1~ `: ~ Aduh family member with whom Defendant(s) rrsidc(s). .f.... Relationship is ~_. ' - .~,) '- _ Adult in ~ of Defendant's residence who refused to 8i"'e name or relationship. Msnage~rl'Clerlt of place of lodging in which Defendant(s) reside(s)• Agent or person in charge of Defetdartt's office a usual place of business. an officer of said Defendant'a company. -- Otlkr - ~,; :Age 9. Height ra'g" weight ~ Race Sex ~ Ot6a' M i. tU6 w s imp ,duk, being duly sworn according so law, depose and state that I peasonally handed a true and cornea copy of the Ivy of Sheriffs Sak in the mettrter as s~ forth herein, iasuod in the captioned case on the date and ~ the address indicased above. Sworn to and subscribed KIMBERLY CURTY before me this ~M day of „~, 20~t1: NOTARY PUBLIC C~~ STATE OF NEW JERSEY y' COMMiss[ON EXPIRES MARCH 7,1013 NOT SERVED ~ y , Zl)_, at _ ocloclc _ M., Defendant NOT ruse: ~ _ Bad tLddress _ Mo_ red .. `.Does Not Reside (Not V§cant) _ No Answer on at at .. - . . - .. _ Service Refused Other. Sworn to and subscribed obfefore ttu this ~ day B . r Notary: I~wsr T. lYi- 4+1i rl~ >ut7 lsd~5. ali~tidr.IL lV~ NfllS D~~C.ar.~a~.ttNw~ Mf3ie ~!. asiw~.16+, Y. fla ~~raU r~iMT.~tia~„lirbrR~S as.w a. etrd~. a.~, ~ ty mw J~Ir t Daq, di. tL ti iM'rJ I.w~e R 7YrM di. ti• TN. f Ci7Jr va~a aawwni, ate. ra x.. amsr ~ a. Jew, rEK, t~. N~ atiT/ lYUr 1 Mrsb.lw.li Na U7f1 Aiw L l~hi, 6~{, t<!Iw M~1! Jit Md~Ur~1 a~,1a Na ln3r Ctilrwl~b R laiii~ aw, tt t4. f~ Aim L6ditr-a,, li rl~laal0 C~7RD~gaw.w.r+.arrA ~~i'"~:' ~~. TYriyi/~ M>lws.aq+ pL~SQ70~ 1'~ M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC Plaintiff, V 5TEVIE E. ROWE TRUDI M. ROWE Defendant(s) CUMBERLAND COUNTY c? COURT OF COMMON PICAS ° _ `; --, , ,.~ . CIVIL DIVISION .. ; ~ ~' ~ ~ No. 10-1884-CIVIL -~~ .a . .. ~ AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 ~ ~ .. ca .... COMMONWEALTH OF PENNSYLVANIA ) d' PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 381'n and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto F,~zhi~t ~~A". U Lawrence T. Phel~Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ dith T. Romano, Esq., Id. No. 58745 [.~Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 n Attorney for Plaintiff Date: '(j IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 233187 E r ~p 00 V 01 VI ~+ w ~ r ~ • n IP * 4 ~F ~F * 1F IF y. fF ! i (0 O' `' ~. ~ ,~~ y ~ :'d' ~C7 ~o~r~e ~~ ~ ~ i~ ~ a> beA ~~ c ~ ~'' ~~ ~q ~I~C ~~~~ ~~~~ ~ wcw'~,a C ~o~~ d S~~a e~ b~~ p g~ a ~ AWnti M C a ~"~x~ ~ ay ~ ~ ~ x ,~ s ~~. ~ y W~~'~ Q~~yApp 'b 00~i ~ ~ 00~, ~ ~i ~ 0 W~ ~ ~ ~OQM CO 5 0~y Q ~~xn~ ~ °~by~ .~-.. ISJ~O~~!~ • ~ ~~~ ~! VJD ~ ; C_! ~~ ~ p R MN 01 w 1'DN „C,~ Ei'~. '~~~Ts ~.r0 p C ~~~ 1 ~, ~ }Z it ~ ~ o ~1C ~~ ~ ~' ~ ~~ ~ ~ -O0~1 >~~ 1 ~,y ~ ; Dy~C'/ -- ~e ~ ~ ~ F+ ~ ~ '¢'- ~~,d~~O,~ $ os ~ ~ ~ C O -+ N~ yrR ~ S ~A ~ a~~ ~ ~ ~..,I e ~~ p O ~ w~ d a ~~e • ~ ', ~~~ orbs ~ V ~ 1t. !] v r ti g Q ~ by „„ ~ s , ~ ~ ~ a N '~ 'i ~ ~ M ~ U ~'7 be ~ R ~ yy ~t~=' , x }~y C.~JOy ! he L ~ y ~M d A Q Oi OD ~ C : i :~ ~ ~ o g .. ~ R o ~, A w ~ '~ ~6 ~ o ~ ~' ~ ~ ~ W ~. . s ~Np hC Y w. • ~,, ~. ~ ~ "~~ G ~~ 8 ~ ~ ~~~ ~ a '~. ~'~ _ N .~ g ~ 2 o ~ t s ~ ~~. ~ .. ~ ,~ %•. ,4 j,•~i ,: i .. ~ ~~~ ~ .~r~ wll~rx °°'~ o ~ .. .. , 02 1M 6 ~ V~ypg 20'10 0042T7 g103 g fROM~CO~ 1 0 ~~ ~ ~ $ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson• Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~3.~"~LLt o~ ~~rtrabrpr,~~o ~~ t U ~~ 1 ~ 4 f~~ I~~ ~ '~4 ~'? ~ RLAP~O CQUN~'` Nationstar Mortgage LLC vs. Stevie E. Rowe (et al.) Case Number 2010-1884 SHERIFF'S RETURN OF SERVICE 06/24/2010 10:10 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 6-24-201C at 1005 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 Steve E. &Trudi M. Rowe, located at, 57 Conrad Road, Carlisle, Cumberland County, Pennsylvania according to law. 07/13/2010 08:27 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on 7/13/10 at 2027 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Trudi M. Rowe, by making known unto, Trudi M. Rowe, personally, at, 70 Conrad Road ,Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 07/13/2010 08:27 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stevie E. Rowe, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Stevie E. Rowe, no longer resides at address provided, still receives mail there, no forwarding at post office. 09/09/2010 Ronny R. Anderson, Sheriff, who 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 Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg on behalf of Fannie Mae, P.O. Box 650043, Dallas, TX 75265, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 792.38 SHERIFF COST: $792.38 October 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~ .DD Pa!• Co_ ..sro ~ ~. ~~ 7~~~~ ~ a ~~s~s (c) GountySuite Snenft. TeleosoR. Inc. i' ~ • NATIONSTAR MORTGAGE LLC Plaintiff ' COURT OF COMMON PLEAS v. ,r ' STEVIE E. ROWS TRUDI M. ROWE Defendant(s) CIVIL DIVISION NO.10-1884-CIVIL CUMBERLAND COUNTY PHS # 233187 AFFIDAVIT PURSUANT TO RULE 3129.1 NATIONSTAR MORTGAGE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 57 CONRAD ROAD, CARLISLE, PA 17015-8857. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) STEVIE E. ROWS TRUDI M. ROWE 57 CONRAD ROAD CARLISLE, PA 17015-8857 70 CONRAD RD CARLISLE, PA 17015-8854 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CAPITAL ONE BANK (USA), N.A. C/O 2417 WELSH ROAD, SUITE 21 #520 APOTHAKER & ASSOCIATES, P.C. PHILADELPHIA, PA 19114 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. Name Address (if address cannot be reasonably ascertained, please indicate) None. r' 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by tl~e sale: Name _ Address (if address cannot be _ ~ reasonably ascertained, please indicate) . TENANTJOCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 57 CONRAD ROAD CARLISLE, PA 17015-8857 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 ATTENTION: JOHN MURPHY 6~ FL, STRAWBERRY SQ. DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 I verify that the statements made in this affidavit aze true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn June 1, 2010 Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ F cis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ~ ~ , NATIONSTAR MORTGAGE LLC ~~ vs. STEVIE E. ROWS TRUDI M. ROWE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION NO.10-1884-CIVIL CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEVIE E. ROWE TRUDI M. ROWE 57 CONRAD ROAD CARLISLE, PA 17015-8857 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 57 CONRAD ROAD, CARLISLE, PA 17015-8857 is scheduled to be sold at the Sheriff s Sale on 09!08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $87,561.09 obtained by NATIONSTAR MORTGAGE LLC (the mortgagee) against you. Iu tl~e eveiil QrC sale is wnlitiued, an annuuncemenl will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 Sheriffls Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. .~ . ~, 2. You may be able`to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 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 the 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 shaze of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THOSE TWO CERTAIN lots, parcels, pieces of ground with the buildings thereon erected situate in Middlesex Township, Cumberland County, Pennsylvania, being known and described as follows, to wit; ON THE West by Fifty (50) feet wide Conrad Road as shown on the hereinafter mentioned Plan of Lots; on the North by Lot No. 78; on the East by Lot Nos. 94 and 95; and on the South by Lot No. 75. CONTAINING One Hundred (100) feet in front along the eastern line of Fifty (50) feet wide Conrad Road and extending eastwardly along therefrom at an even width a distance of One Hundred Ninety-eight and Four tenths (198.4) feet, more or less. TITLE TO SAID PREMISES VESTED IN STEVIE E. ROWS AND TRUDI M. ROWS, AS TENANTS BY THE ENTIRETIES, GIVEN BY SAMUEL A. CALAMAN AND JUANITA E. CALAMAN, HUSBAND AND WIFE, RECORDED APRIL 19, 2006IN BOOK 274 PAGE 364. PREMISES BEING: 57 CONRAD ROAD, CARLISLE, PA 17015-8857 PARCEL N0.21-22-0119-040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-1884 Civil COUNTY OF C)rJMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE LLC, Plaintiff (s) From STEVIE E. ROWE AND TRUDI M. ROWE (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 $87,561.09 L.L. $.50 Interest FROM 4/30/2010 TO DATE OF SALE ($14.39 PER DIEM) -- $1,899.48 Atty's Comm % Due Prothy $2.00 Atty Paid $197.30 Other Costs Plaintiff Paid Date: JiJNE 9, 2010 (Seal) Deputy REQUESTING PARTY: Name MICHELE M. BRADFORD, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 69849 4 • A On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 57 Conrad Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: Rea state Coordinator :~ ~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a legal periodical published in the Borough of Cazlisle in the County and.State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Co ,Editor SWORN TO AND SUBSCRIBED before me this 0 da of Jul 2010 Notary ~._..~ NOTARIAL SEAL DEBORAH A COLUNS N~aty Puhlfc CARLISLE BOROUGH, CUMBERLAND COUNTY My Commiaalon Erna Apt 28, 2011 w:tt >~o. a01O-1~4 Cidl Nationstar Mortgagc LLC vs. Stevie E. Rowe Trudi M. Rowe Atty.: Daniel Schmieg ALL THOSE TWO CERTAIN lots, parcels, pieces of ground with the buildings thereon erected situate in Middlesex Township, Cumberland County, Pennsylvania, being known and described as follows, to wit; ON THE West by Fifty (50) feet wide Conrad Road as shown on the hereinafter mentioned Plan of Lots; on the North by Lot No. 78; on the East by Lot Nos. 94 and 95; and on the South by Lot No. 75. CONTAINING One Hundred (100) feet in front along the eastern line of Fifty (50) feet wide Conrad Road and extending eastwardly along there- from at an even width a distance of One Hundred Ninety-eight and Four tenths (198.4) feet, more or less. TITLE TO SAID PREMISES VEST- ED IN Stevie E. Rowe and Trudi M. Rowe, as tenants by the entireties, given by Samuel A. Calaman and Juanita E. Calaman, husband and wife, recorded April 19, 2006in Book 274 Page 364. ..r;~;~,,r; ~; }~SG4~ '.~~,r L> xwtn,. •,.sWymiltl.~~.'w..•,. ~, 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 ~e ~latriot•News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 812 to 818 Arlarket Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-Ne~NS and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and SeptE~mber 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither 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 ernpowered 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. " writ No. 2010-1884 civil Term This ad ran on 1:he date(s) shown below: Nationstar Mortgage LLC 07!09/10 Vs Stevie E. Rowe 07!16/10 Trudi M. Rowe 07/23!10 Atty: Daniel Schmteg ALL THOSE TWO CERTAIN lots, pazcels. pieces of ground with the buildings thereon erected situate in Middlesex Township. Cumberland County, Pennsylvania, being known and described as follows, to wit; Sworn to d su scribed before me this ~ d y of August, 2010 A.D. ON THE West by Fifty (50) feet wide Conrad ~ ~, ~ ~/ Road as shown on the hereinafter mentioned 1 } i ~ j / `~ l .~ /_ ;. Plan of hots; on the Nonh by Lot No. 78; on the ~ _ r' ~ r East by Lot Nos. 94 and 95; and on the South ~ ~~ ~~ r' ~ ' ~ ~ '~ G ~"- byLotNo.75. Notary PUbIIC -~._`~"' CONTAINING One Hundred (100) feet io front along the eastern line of Fifty (50) feet wide Conrad Road and extending eastwardly along therefrom at an even width a distance of One Hundred Nine ei ht and Four tenths (198.4) COMW101VWEALTH OF ~~ ty g NNSYLVAN feet, more or less. 4; Notarfai Seai IA TITLE TO SAID PREMISES VESTED IN herne L• Kfsner, Nota p STEVIE E. ROWE AND TRUDI M. ROWE. tower Paxton ~~ Pry ublic MY Comm+~on p'' Dau hln County AS TENANTS BY THE ENTIItETIES, GIVEN Memt.er, pnhr,.xylvar" ;~iSmQ at on ~f Notaries BY SAMUEL A. CALAMAN AND JUANITA E. CALAMAN, HUSBAND AND WIFE. RECORDED APRIL 19, 2006IN BOOK 274 PAGE 364. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } 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 Fannie Mae is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 9th day of June, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Tenn, 2010 Number 1884, at the suit of Nationstar Mortgage LLC against Stevie E & Trudi M Rowe is duly recorded as Instrument Number 201029356. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,/ !~ day of ~~, . of Deeds Reoorderddeed~-C1~hnaQeuRx~~M,M '': Nhr Cortr-~ion ExpY~ih~R~itMo~lydJw~N