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HomeMy WebLinkAbout10-2447Phelan 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 I. 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 235450 NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 Plaintiff V. NATALIE A. BROSIUS 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 Defendant 20 i 0 h1 i 1 c ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Olt). NO. L CUMBERLAND COUNTY ?v eK--z-wj Q 416 WS" File #: 235450 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 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 235450 1. 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: NATALIE A. BROSIUS 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/17/2004 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CENTEX HOME EQUITY COMPANY, LLC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1870, Page 1729. The PLAINTIFF is now the legal owner of the 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 12/01/2009 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 #: 235450 6. The following amounts are due on the mortgage: Principal Balance $86,565.84 Interest $1,877.76 11/01/2009 through 04/12/2010 Attorney's Fees $650.00 Cumulative Late Charges $637.46 06/17/2004 to 04/12/2010 Appraisal/Brokers Price Opinion $27.78 Costs of Suit and Title Search $550-00 Subtotal $90,308.84 Suspense Credit .(,$397-99) TOTAL $89,980.86 7. 8 Plaintiff is not seeking a judgment of personal liability (or an in personam 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 #: 235450 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $89,980.86, together with interest from 04/12/2010 at the rate of $13.04 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 6 Cis By: = .{!!!l 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 I. Goldman, Esq., Id. No. 205047 2 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 235450 LEGAL DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the Declaration referenced to below as 'Walnut Villas Condominium' located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. Cons. Stat. Ann. et. seq. (Purdon Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, Page 147, which Declaration has been amended by a First Amendment to Declaration of Condominium, dated December 31, 1985 and recorded on December 31, 1985 in the aforesaid Office at Miscellaneous Book 313, page 133, and further amended by a Second Amendment to Declaration of Condominium dated March 23, 1987 and recorded on March 27, 1987 in the aforesaid Office at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Book 335, page 283, and further amended by a Fourth Amendment to Declaration of Condominium dated November 10, 1987 and recorded on November 30, 1987 in the aforesaid office at Miscellaneous Book 343, page 368, and further amended by a Fifth Amendment to Declaration of Condominium dated April 14, 1988, and recorded on April 18, 1988 in the aforesaid office at Miscellaneous Book 348, page 868 being and designated in such Declaration, as so amended, as Unit No. 801 as more fully described in such Declaration, as so amended together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as so amended and as further amended by any further amendments thereto hereafter recorded in the aforesaid office. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record, including (but not limited to) those contained in the instruments recorded in the aforesaid Office in Miscellaneous Book Vol. 304, page 227 and Miscellaneous Book Vol. 304, page 566. Being the same premises which Christopher D. Cremo and Susan M. Cremo, husband and wife, by deed dated June 14th, 2004 and which is intended to be recorded herewith in the Cumberland County Office of the Recorded of Deeds, granted and conveyed unto Natalie A. Brosius, Mortgagor herein. Premises being: 801 OLD SILVER SPRING ROAD PARCEL#: 18-22-0519-001 B-U-G801 File #: 235450 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 unsworn falsifications to authorities. ttomey for Plaintiff DATE: LA 117-10 File #: 235450 ~ > p rn ro o o ~'T"1 ~~ ~ °:o z ~ x o ..._ - a°r- _ es~ S z n ~,' a D c c - ~ -~ 0 4 Phelan Hallinan & Schmieg, LLP By: 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 I. 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 NATIONSTAR MORTGAGE LLC vs. NATALIE A. BROSIUS Attorney for Plaintiff n r~~ ~ ..~ ~- ~ ~ N n ~ c: N ~t'~ ~ o CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2447-CIVIL TERM ~.~y,4~ rd~-~r c,~~9GQ176 2 a a-- ~yi~°z- PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against NATALIE A. BROSIUS. Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $89,980.86 Interest - 04/13/2010 to 06/09/2010 $756.32 TOTAL $90,737.18 I hereby certify that (1) the Defendant's last known address is 801 OLD SILVER SPRIN G ROAD, MECHANICSBURG, PA 17055-2883, and (2) that notice has been given in accordance with Rule 237.1, copy attached. - mom.. '® yz ~ °~ La c T. Phelan, E ui e ~"'~ z ° Q ~~ °G Fr cis Hallinan, quire Z ~ Daniel G. ,Esquire ~ ~ ~~ Michele M. Bradford, Esquire ~ ~ ~ °z >- `- ~ Judith T. Romano, Esquire ~ ~ ~ . o ~a Sheetal R. Shah-Jani, Esquire o Jenine R. Davey, Esquire ~~ Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire sovalante P. Fliakos, Esquire oshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: ~o ~~~-~/U PHS # 235450 PROTHONOTARY v C ~~ ~ A C Ttr-- --i A'__. 2 - L.. ~7 I =~ f- Z ~_ Q ~ n~ o n A C ? --t -~ 0 4 ~ -t ~~ cac- Phelan Hallinan & Schmieg, LLP By: 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 I. 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 NATIONSTAR MORTGAGE LLC vs. NATALIE A. BROSIUS Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2447-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant NATALIE A. BROSIUS is over 18 years of age and her last known residence is 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. U La,~OVre e T. Phelan sq., Id. No. 32227 ^ F ancis . Halli ,Esq., Id. No. 62695 ~ ^ Daniel G. ieg, Esq., Id. No. 62205 ~ ~ ©~ ^ Michele M. Bradford, Esq., Id. No. 69849 ~c~ ~-= ,s,Q. Q ^ Judith T. Romano, Esq., Id. No. 58745 ~~ ~o c.:v ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 _~ ,_,;o ^ Jenine R. Davey, Esq., Id. No. 87077 -_-_; z Q~ ^ Lauren R. Tabas, Esq., Id. No. 93337 ~'C ~ _° ~ ^ Vivek Srivastava, Esq., Id. No. 202331 ~'`~ N ~`°- ~ ^ Jay B. Jones, Esq., Id. No. 86657 r.~,. ^ 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 Attorney for Plaintiff (Rule of Civil Procedure No. 236) -Revised NATIONSTAR MORTGAGE LLC vs. NATALIE A. BROSIUS 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2447-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on ,,c. 11 all~Q ~~ By: If you have any questions concerning this matter please contact: ^ 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 I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRMISA DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE INBANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY. NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS CIVIL DTVISON Plaintiff v. NATALIE A. BROSIUS Defendant(s) TO: NATALIE A. BROSIUS 8Q1 OLD SILVER SPRING ROAD MECHEINICSBURG, PA 17055-2883 NO. 10-2447-CIVIL TERM CUMBERLAND C DATE OF NOTICE: May 21, 2010 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 WII,L 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. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIIvIS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 TQ YOUR LAWYER AT QNCE. IF YOU DO NOT HAVE A LAWYER, GO TO QR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE. YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 235450 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENiJE CARLISLE, PA 17013 (717) 249-3166 ~Chrisovalante P. Fliakos, Esq., Id. No. 94620 ~l Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 By: ~ Lawren Phelan, Esq. Id. No. 32227 Franci S. llinan, Es Id. No. 62695 Dani G. Sc mieg, ., Id. No. 62205 Michele M. Bra ord, 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 One Penn Center Plaza Philadelphia, PA 19103 PHS # 235450 PLAINTIFF NATIONSTAR MORTGAGE LLC v 0 N ~v~ ~~an ~~ f= c:.: aFOo w°z~~ ~ ~~ m~ a v DEFENDANT NATALIE A. BROSIUS SERVE NATALIE A. BROSIUS AT: 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PIiS # 235450 SERYICE TEAM/ kxc ?"? t~. ,,' COURT NO.: 10-2447-CIVIL TERM TYPE OF ACTION XX Notice of SheriEt's Sale , =~; SALE DATE: 12/08/2010 - SERVED ~ ~,, - Served and made known to NATALIE A. BROSIUS ,Defendant on the %6' day of ~_. 20 ~~. at oclock ~ M., at ~'~ / OL--^ SI ~ vr~ SFj21NG Qom, in the manner described below: /Defendantpersonallyserved. M~~[~ANt[Sgtlab~pl~~ _ Adult family membef with whom Defendant{s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ blanagerlCll;1•k of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: ' Description: Age ~~ Height ~ ~ Weight 1~ Race W Sex ~ Other 1_ ROiy~c.'D I~AO f-4 a competent adult, being duly sworn according to law, depose and state that 1 personally handed a true and COITeC[ copy of the Notice of Sheriffs Sale in the manner aS set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and sub_s;r}bed before me this 1~ day of ~k 20f6. •By- NOT SERVED On the da of _, at -o'clock -. M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at . Service Refused ~ = ~ • • ~ - _ ... Other: ~ ~ ~ . Sworn to and subscribed before me this day of ~-. By: Notary: yl ATTORNEY FOR PLAINTQ''F lawse~a T. P1dr, Fa4+K IN. 73227 Feeds S Winos. Fsy.. td. Na f2(NS Dnskl l:. SdrkG Fad„ Id.1N. f2216 MNde M. Bsadrmd, Feq., Id. tia. (9849 !emu T. taws, FN+ 1d. Nw 58745 Shalal R SYAJrI, Fi9+(L ti.817N Jade R Duey. Fi4, t6 Wa.6A77 I.aeso R Tarts; Fa9+li. tes.93JS7 Vhdt Sd.wrn, Fai+ 4. Na 382.U1 Jay & Jaees, Fi9+ld f1a.8ff57 PderJ. Mekail, Fiq., d.1w (1791 Aefms 4 Sphtl, Ey, Id. Nw 8ft99 Jaise McGeirsss, FN+tl.lie 981!1 Gh6aa-aase p. Ffskeq ~ K IVa 91620 Jes6r L CaiMre. Faq., li. Na DW17 ca.dm.y R Der, F+4. K t1a 26fT» Asdme C 8saesYldlI FaO., li. }la 2K375 Oee per CelQal ''~~ SYlise 1f17 Je4e F. Keesdy Bhd. Seik 1400 FMhde19W. PA 1910}!814 (215) 5f17060 ~, ® :-; ~_~._ ~ i5; - '+~ ., •IE t,,J - AFFIDAVIT OF SERVICE C't CUMBERLAND COUNTY c-` ___ PLAINTIFF _ ~ NATIONSTAR MORTGAGE LLC p}IS #235450 -r-• r_= ~,. 6~ DEFENDANT SERVICE TEAM/ lac == COURT NO.: 10-2447-CIVIL TERM : _ ~ NATALIE A. BROSIUS SERVE NATALIE A. BROSIUS AT: TYPE OF ACTION ' 801 OLD SILVER SPRING ROAD s Sak XX Notice of Sheritr SALE DATE: 12/08/2010 ~? MECHANICSBURG, PA 17055-2883 .. SERVED ~ ,~,, nt on the %6' day of k L , 20 ~~, at d D f -' Served and made known to NATAL a en e ~A. BROSIUS . in the manner described below: F~ Spj?r N6 Q D ~ o'clock ,~ M., at ~'D 1 4 L t/ Defendant personally served. , t [.v A M~~~AN-tSgd~6~ ~/~-~ _ Adult family member with whom Defendant(s) reside(s). v e°~ Unit' ~~a~ X ,~.~ ~ a o ~z°~~ ~~ Q yl Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: Desc^rip~tion: Age y~f~ Height r Weight ~~ Race w Sex ~ Ocher I, 1'~OiV `D .~D ~-I-.r a competent adult, being duly Swom according to law, depose atttl state that I personally handed a tYue and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Swom to and subsc bed before me this ~ day of ~u 2010. N •By- NOT SERVED On the da of _> at _ o clock _ M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at . Service Refused Other: Swom to and subscribed before me this day of _ ~-. By: Notary: ATTORNEY FOR PLAlP1TIFF lrw~a~a T. Adrti Feq., k lM. 73227 Frrelc 3.1W1r. Pry., Id. Nw f3r97 Dodd 1:.5eisk6 dF, Id.lM. Q3~6 Mklde M. Bnlfwd, Pay., Id. Na NM9 Jdrl T. Rama, Fro. K Nw 56706 Slald R Slai]d, Faq, li Na 617f6 Jade R Davey, Fiy, li Na 11677 I.aw R Tale, Fiq., Id. Nw 97351 Vivdc Sdvrran, Ep., ld. Na. 301Ut ]q ! ]aara, Fay, li Na ttffel PderJ. Maial7. Fav, w N..lrnl Arleew V sdwel, Pay, w Na 8N79 Jdae McCdaaea, Pw, rd Na 9p31 CtiYNarare T. r6dwr, Gal. Id Na 9Af36 Jadar L CailaaR Fay, IA. Nw 365617 Caadsy A Dr•, Gq, Id Nw 3K719 Andrew G Bnal1A1,6a~,ltlla.316375 1i17]ala Raaed7re8oMfao~IM/ PYirdelplia, PA 29101614 1215)9C1~7W6 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.RC.P. 3180-3183 NATIONSTAR MORTGAGE LLC Plaintiff COURT OF COMMON PLEAS CIVII. DIVISION NATALIE A. BROSIUS Defendant(s) "fo the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 06/ 10/2010 to Date of Sale ($14.92 per diem) TOTAL s #d~.00 P A ATT'/ 37.00 Cef=' ga.oo N ~~,~ ~ a.50 #d.oo ~c~eL'o ' S0 ~-l. NO.10-2447-CIVIL TERM CUMBERLAND COUNTY 90 737.18 2 715.44 c'? ~2 C~ ~ o 's~ c, . ~_ e: ~^ .. _'. .._.._. .._ __ „~ ~._ `"~S w _a Attorney r P aintiff Phelan alli n & Schmi , LLP ^ La ence . Phel sq:, Id. No. 32227 ^ Francis S. ,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 ^ hrisovalante 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 Note: Please attach description of properly. PHS # 235450 ' ~~ gZ57a 1 (2* o'!Nlo33.3 ~~~ M b ~ y ~ ~1 y ~ O a ~, ~P4a ~ ~~~ ~, o ~ ~' > ¢d~ .. 3 ~A¢ ` ~ H~U . ¢ z°~ z O~ ~ ~ ~ ~ ~ ~ ~~M a ~ U ~UT~ N~N~~^'l~t~M ^'~.M-~ O~~ON a`f-a ~ a /~i M~~ Q~ DOME ~~TzNN O W ^ ° O OZ" ~MN~~p O b Oz ~~ C7 W ~ abvz'~~ZbZZZo~oZ'~z ~zb~ „ ~ ~, `., b b ~..~ o, d O ~ ~ u y H w ~ w ~ ~ ~ ~ ~ ~ y ~ ~ y W r~~ ~ ~° O ~ ~ ~ ~ w w b w y y y~ y w w~ W W N pV ~ p y ~ ~;, ~ o00 ~www ~w ~ ~w ~'~~pp H ~ ~ ~ O ~ ~ a ~ '~ ~ ~ ~ a~i ~ ~ W ~~'.~ ~ as .~ A c'a ~ b ~ pfl ~ i~ o OQ c ~ ~ ca ~ y ° ~ ~~ ~ o p~, GO Oa A U W O w ~ A ~ ti ~ x ~ 'v .~ ~ ;~ ~ .~ °' ~ OCR a~`i '~' ~ •~' ~ ~ `~' F ~ ~ ~ ~ ~ ~' q•~ N o Z > Z A, w ¢a^^^^^^^^^^^^^^U^^ ~V Phelan Hallinan & Sc6mieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff v. NATALIE A. BROSIUS Defendant(s) Attorneys for Plaintiff I P_i .,~ ~`E ~ ~, ,,r.~„ ,~ ~ is i• i =y G`v``v~;r.:. . ;; ; ~ ~ ,~ COURT OF COMMON PLEAS - - ., ~ ;;. ~ . CIVIL DIVISION CERTIFICATION NO.10-2447-CIVIL TERM 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. By: ~ Attorney for lainti Phelan Hal) nan Schmieg, U Lawrenybe T. Ph lan, Esq., . No. 32227 ^ Francis S. Hallin E d. 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 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS Plaintiff ~~~_.t_ ; ", _ . ',~ ?f',- ' ~~'`' CIVIL DIVISION v. . 2 ~ i D ~;'~ J -~ ~ ~ a ~ ° ~ ' t NO. 10-2447-CIVIL TERM NATALIE A. BROSIUS Defendant(s) C~,~,~~- - •''`'~~` CUMBERLAND COUNTY PHS # 235450 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 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) NATALIE A. BROSItUS Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 801 OLD SILVER SPRING ROAD MECHAhTICSBURG, PA 17055-2883 Address (if address cannot be reasonably ascertained, please so indicate) 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) BENEFICIAL CONSUMER DISCOUNT COMPANY 2700 SANDERS ROAD PROSPECT HEIGHTS, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY C/O CATHY ANN CHROMULAK, ESQ. 375 SOUTHPOINTE BOULEVARD, 4~ FLOOR CANONSBURG, PA 15317 BENEFICIAL CONSUMER DISCOUNT 375 SOUTHPOINTE BOULEVARD, 4~ FLOOR COMPANY C/O SCOTT E. CRAWFORD, ESQ. CANONSBURG, PA 15317 GREGORY A. MCCLAIN 6029 EDWARD DRIVE MECHANICSBURG, PA 17050 BENEFICIAL CONSUMER DISCOUNT 4910 CARLISLE PIKE, SUITE 104 COMPANY MECHANICSBURG, PA 17050 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) PNC BANK N.A. 8733 LIBERTY AVENUE PITTSBURGH, PA 15222 PNC BANK N.A. 2733 LIBERTY AVENUE PITTSBURGH, PA 15222 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) BOROUGH OF MECHANICSBURG C/O 37 WEST ALLEN STREET DAVID J. SPOTTS, ESQ. MECHANICSBURG, PA 17055 WALNUT VILLAS CONDOMINIUM ASSOC. 212 NORTH THIRD STREET HARRISBURG, PA 17108 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 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 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 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. Boz 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 falsification to autho>~i~ ~ /~ July 13, 2010 hrisovalante 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 By: Attorney r aintiff Phelan alli an & Sch , LLP ^ Lawrence . Phel sq., Id. No. 32227 ^ Francis S. ,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 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. NO. 10-2447-CIVIL TERM NATALIE A. BROSIUS CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NATALIE A. BROSIUS 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 * *THIS FIRM 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 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $90,737.18 obtained by NATIONSTAR MORTGAGE LLC (the mortgagee) against you. In the event the sale is co~nu an _, announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. ..~, ~. ;, ; ; -„ NOTICE OF OWNER'S RIGHTS F C.r. YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE "~' ,~. ~_ __ To prevent this Sheriff's Sale, you must take immediate action: .~ r~ e .`w. 1. The sale will be canceled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 21230. 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 compazed 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 shaze of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepazed 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) aze 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 THAT CERTAIN unit in the property known, named and identified in the Declazation referenced to below as'Walnut Villas Condominium' located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. Cons. Stat. Ann. et. seq. (Pardon Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declazation of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, Page 147, which Declazation has been amended by a First Amendment to Declazation of Condominium, dated December 31, 1985 and recorded on December 31, 1985 in the aforesaid Office at Miscellaneous Book 313, page 133, and further amended by a Second Amendment to Declazation of Condominium dated Mazch 23, 1987 and recorded on Mazch 27, 1987 in the aforesaid Office at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Book 335, page 283, and further amended by a Fourth Amendment to Declazation of Condominium dated November 10, 1987 and recorded on November 30, 1987 in the aforesaid office at Miscellaneous Book 343, page 368, and further amended by a Fifth Amendment to Declazation of Condominium dated April 14, 1988, and recorded on April 18, 1988 in the aforesaid office at Miscellaneous Book 348, page 868 being and designated in such Declazation, as so amended, as Unit No. 801 as more fully described in such Declazation, as so amended together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declazation as so amended and as further amended by any further amendments thereto hereafter recorded in the aforesaid office. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of--way, easements and agreements of record, including (but not limited to) those contained in the instruments recorded in the aforesaid Office in Miscellaneous Book Vol. 304, page 227 and Miscellaneous Book Vol. 304, page 566. TITLE TO SAID PREMISES VESTED IN Natalie A. Brosius, given by Christopher D. Cremo and Susan M. Cremo, husband and wife, recorded June 21, 2004 in Book 263 Page 3219. PREMISES BEING: 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883 PARCEL NO. 18-22-0519-OO1B-U-G801 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2447 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONASTAR MORTGAGE LLC, Plaintiff (s) From NATALIE A. BROSIUS (1) You are directed to lery 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 $90,737.18 L.L.$.50 Interest from 6/10/10 to Date of Sale ($14.92 per diem) -- $2,715.44 Atty's Comm Due Prothy $2.00 Atty Paid $169.50 Other Costs Plaintiff Paid Date: 8/5/10 avid D. B (Seal) By. REQUESTING PARTY: Name: JOSHUA I. GOLDMAN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 205047 uell, Prothonotary Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION NATALIE A. BROSIUS Defendant(s) No.: 10-2447-CIVU, TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) 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 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached ereto E 't "?1". ? Lawrence "t. Phel ., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 I ? J dith T. Romano, Esq., Id. No. 58745 ?heetal 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 C..) e=, 6< ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 3= U- U- 04Z ? Courtenay R. Dunn, Esq., Id. No. 206779 CD ? Andrew C. Bramblett, Esq., Id. No. 208375 N ? Allison F. Wells, Esq., Id. No. 309519 _j cr CCCIL --?uj ?N Attorney for Plaintiff E ?Pat I1V1`P'ORXANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the alaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 235450 `a U C a N F C O. ?o av ? M ? c U d =aUU•- CL. t Rl y •b y ? q E a in z<0 w £0 L6 L 3000diZ W08:10311VW OLE)nV OSLLLZI'OOO OL OZ wl ZO 0 9P.90 s Y ? o a 8 . 8 N N .S g i vii M a e wa ? 1 A, ? ?? o ' e ? A 'C ? W C W E A+ fig a, ti o 16 p a 'wE+ wQ O .r V E+??Fl! O Z ! ?! < p4, .7! ,. Ix l z p? c °i Y e a; 8pq ? oa i o ?v? g p oo as W z ?O z O?O QQ3 ?d1 d Z Z Z F C?.M-? Vo. DF? Dw l l eaW eoCi. f»e?•? ?PO l??o V'3 Aa?e?+? POU?M AFpriP: C t8• ` t U_ # # # # # # # # # # 5 a r• N M a ir, ?o ? ao o, ? ? ? ? ?j t? £046L3cloOaz WOHA O31ItlW t w 0407 , OL O 9gZttW`°i0 09Z? _ ? ? I? Al W O F 0 ? v a ((?ZZj1' o en z G7 vo z i > U as cq 1 oaa.,?.axU G7 ??a•d °yfs'?U alarm z 0. eq ? • f f N f f f v c H .? Q ?°ya ? ? ? ? .r N t7 zQO a ? a M 14 Sb z A m t i f f o ? d h?O t?000?C1.4 IQ' dd WTP\. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor CFF!C i -F rHIE S'IERIFF FILED-OFFICE I T I? ?1THONOT??RY 2011 APR I I AM 10: 13 CUMBERLAND COUNTY FENNSYLVAHIA Nationstar Mortgage LLC vs. Natalie A. Brosius Case Number 2010-2447 SHERIFF'S RETURN OF SERVICE 10/13/2010 03:20 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on 10-13-10 at 1515 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 Natalie A. Broosius, located at, 801 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. 10/22/2010 03:35 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10/28/10 at 1034 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: Natalie A. Brosius, by making known unto, Chris Brosius, adult son at, 801 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/28/2010 10:42 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Sheriffs Levy, Sale and Posting of Schedule of Distribution and Plaintiffs Notice of Sheriffs Sale and Debtor's Rights by "personally" handing a true copy to a person representing themselves to be CHRIS BROSIUS - SON, who accepted as "Adult Person in Charge" for Natalie A. Brosius at 801 Old Silver Spring Road, Mechanicsburg Borough, Mechanicsburg, PA 17055. Copy of the Plaintiffs Notice attached to and made part of the within record. 12/01/2010 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 02/25/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 4/4/11. SHERIFF COST: $723.99 April 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ?.?. so i?L co 813ryy (c) CountgSuite Shenff. Teieosoft. Inc. NATIONSTAR MORtG,?GE LLC Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION V. NATALIE A. BROSIUS Defendant(s) NO. 10-2447-CIVIL TERM CUMBERLAND COUNTY PHS # 235450 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 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) NATALIE A. BROSIUS Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 Address (if address cannot be reasonably ascertained, please so indicate) 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) BENEFICIAL CONSUMER DISCOUNT COMPANY 2700 SANDERS ROAD PROSPECT HEIGHTS, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY C/O CATHY ANN CHROMULAK, ESQ. 375 SOUTHPOINTE BOULEVARD, 4' FLOOR CANONSBURG, PA 15317 BENEFICIAL CONSUMER DISCOUNT 375 SOUTHPOINTE BOULEVARD, 4' FLOOR COMPANY C/O SCOTT E. CRAWFORD, ESQ. CANONSBURG, PA 15317 GREGORY A. MCCLAIN 6029 EDWARD DRIVE MECHANICSBURG, PA 17050 BENEFICIAL CONSUMER DISCOUNT COMPANY 4910 CARLISLE PIKE, SUITE 104 MECHANICSBURG, PA 17050 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) PNC BANK N.A. 8733 LIBERTY AVENUE PITTSBURGH, PA 15222 PNC BANK N.A. 2733 LIBERTY AVENUE PITTSBURGH, PA 15222 5. Name and address ofo vwy Ether person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF MECHANICSBURG C/O 37 WEST ALLEN STREET DAVID J. SPOTTS, ESQ. MECHANICSBURG, PA 17055 WALNUT VILLAS CONDOMINIUM ASSOC. 212 NORTH THIRD STREET HARRISBURG, PA 17108 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 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 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 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 r I verify that the swetnents 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 falsification to authc#i,pf.) 1A July 13, 2010 By: _ Attorney aintiff Phelan alli an & Sch LLP ? Lawrence . Phel sq., Id. No. 32227 ? Francis S. , 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 hrisovalante 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 t NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. : NO. 10-2447-CIVIL TERM NATALIE A. BROSIUS : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NATALIE A. BROSIUS 801 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055-2883 "THIS FIRM 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 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $90,737.18 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. 4 I 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 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 THAT CERTAIN unit in the property known, named and identified in the Declaration referenced to below as 'Walnut Villas Condominium' located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. Cons. Stat. Ann. et. seq. (Purdon Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, Page 147, which Declaration has been amended by a First Amendment to Declaration of Condominium, dated December 31, 1985 and recorded on December 31, 1985 in the aforesaid Office at Miscellaneous Book 313, page 133, and further amended by a Second Amendment to Declaration of Condominium dated March 23, 1987 and recorded on March 27, 1987 in the aforesaid Office at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Book 335, page 283, and further amended by a Fourth Amendment to Declaration of Condominium dated November 10, 1987 and recorded on November 30, 1987 in the aforesaid office at Miscellaneous Book 343, page 368, and further amended by a Fifth Amendment to Declaration of Condominium dated April 14, 1988, and recorded on April 18, 1988 in the aforesaid office at Miscellaneous Book 348, page 868 being and designated in such Declaration, as so amended, as Unit No. 801 as more fully described in such Declaration, as so amended together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as so amended and as further amended by any further amendments thereto hereafter recorded in the aforesaid office. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record, including (but not limited to) those contained in the instruments recorded in the aforesaid Office in Miscellaneous Book Vol. 304, page 227 and Miscellaneous Book Vol. 304, page 566. TITLE TO SAID PREMISES VESTED IN Natalie A. Brosius, given by Christopher D. Cremo and Susan M. Cremo, husband and wife, recorded June 21, 2004 in Book 263 Page 3219. PREMISES BEING: 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883 PARCEL NO. 18-22-0519-001B-U-G801 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2447 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONASTAR MORTGAGE LLC, Plaintiff (s) From NATALIE A. BROSIUS (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 $90,737.18 L.L.$.50 Interest from 6/10/10 to Date of Sale ($14.92 per diem) -- $2,715.44 Atty's Comm % Atty Paid $169.50 Plaintiff Paid Date: 8/5/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs tsy: Deputy Name: JOSHUA I. GOLDMAN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 205047 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 801 Old Silver Spring Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: Real Estate 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 Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 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. L' a Marie Coyn?, Editor SWORN TO AND SUBSCRIBED before me this 5 da of November. 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28.2014 CUMBERLAND LAW JOURNAL Writ No. 2010-2447 Civil Nationstar Mortgage LLC VS. Natalie A. Brosius Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 10-2447-CIVIL TERM, NATION- STAR MORTGAGE LLC vs. NATALIE A. BROSIUS, owner of property situ- ate in the BOROUGH OF MECHANIC- SBURG, Cumberland County, Penn- sylvania, being 801 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2883. Parcel No. 18-22-0519-OO1B-U- G801. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $90,737- .18. 15 The Patriot-News Co. 2020 Technology Pkwy Suite 300, Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE The Patr1*otAotXtws Now you know CARLISLE PA 17013 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 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither 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: 2010-2447 Civil Term Nationstar Mortgage LLC 10/15110 Vs Natalie A. Broslous 10/22/10 Atty: Daniel G Schmleg 10/29/10 By virtue of a Writ of Execution NO. 10-2447-CIVIL TERM NATI ` ) ? ' ? ? ?? ? ONSTAR MORTGAGE LLC _> • ?. . ?: .L ........ . vs. ?_... NATALIE A. BROSIOUS ? owner(s) of property situate in the BOROUGH Of' Sworn to and?r ZI-be ore me this 1 day gf,No4ember, 2010 A.D. MECHANICSBURG, Cumberland County, Pennsylvania, being (Municipality) , 801 OLD SILVER SPRING ROAD. MECHANICSBURG, PA 17055-2883 Notary Public Parcel No.18-22-0519-0018-U-G801 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $90,737.18 COPIMONW EALTH OF PENNSYLVANIA Seal - Sh" L Kisner ' NOtary Public -o I wer Paxton My COMM Wm t'p., Dauphin county Memh r fires NOV- 26, 20ennsvtvanla Assodation of -? N otaHes Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff NATIONSTAR MORTGAGE LLC Court of Common Pleas ' Plaintiff rn Civil Division rn vs r CUMBERLAND County -" NATALIE A. BROSIUS ? Defendant No. 10-2447-CIVIL TERM Z CD 1 i ° TO THE PROTHONOTARY: PRAECIPE Please vacate the judgment(s) entered and mark the action discontinued and ended without prejudice. Date: PHELAN HALLINAN & SCHMIEG, LLP By: 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 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 Allison F. Wells, Esq., Id. No. 309519 PHS# 235450 Attorneys for Plaintiff G s8.00V4 ate IC)7 87 80 () 24;25?935