The URL can be used to link to this page

Home My WebLink About10-6594 FILED-OF~`1CE: ~~Ji00~'T 29 P~ I: ~~ r~~J~Mf~~.~L~~tiD i C~lT,,~ o~ ~~~_~ t..tS~~..'f~a~alr`~~ 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 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 Plaintiff vs. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-6594 CIVIL TERM LEILANI MCBETH CUMBERLAND COUNTY RYAN FERREE , Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 250781 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorn for Plaintiff By: tit,Q ~~'~ ^ La ence 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 Date: 10-27-10 PHS #: 250781 VERIFICATION ~l `~ 2 ~e ,hereby states that he/she is '' bf, Nationstar Mortgage, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: V ~ ~ I ~ ill l Atty File #: 250781 Name: MCBETH Name: ~~ ~ f~ Title: ~ ~ , Servicer: Nationstar Mortgage „~~~„ ,,e.• ,•. ~~~~"•"~%% SHERRY SUMERAUER _ y ublic, State of Texas ~.= My Commission Expires ~'%N°;m~'~c AUQYif 26, 2014 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 3oshua 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 Plaintiff vs. LEILANI MCBETH RYAN FERREE Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-6594 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 PHS #: 250781 x LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 Phelan Hallinan & Schmieg, LLP Atto for Plaintiff , 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 Date: 10-27-10 PHS #: 250781 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Northstar Mortgage LLC Civil Action - Law 350 Highland Drive Lewisville, TX 75067 Vs. No. 10-6594 Civil Term leilani McBeth 773 Hamilton Ct . Carlisle PA 17013-1519 o: C-n ' And _ = - Ryan Ferree - ?' 95 Green House Rd Gardners, PA 17324-9055 ' PETITION TO PROCEED IN FORMA PAUPERIS and AFFIDAVIT I - I am the defendant in the above matter and because of my financial (emle whxh is applicable) condition am unable to pay the fees and costs of prosecuting or defending this action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. The information below relating to my ability to pay the fees and costs is true and correct: a) My name, address, and Social Security number are as follows: Name: ? a w ?- ,Y-Ye e- Address: 0S 61, ' r?h2 i?S 10A- Social Security Number: b) Present or last employment: rr ?tflyt,? C? ?ln WI/t ? G ? S S - Salary (net): tH DO./ - Type of work: c) Other income within the past 12 months (list amount and source): N (/X. f) Other contributions to household support: /A e) Property owned cash: N (((? bank accounts: CAA e- ?? CD's, stocks, bonds: Y?- real estate mcluding home): list cost, present value, amount still owed: car: make & year -cost $: - amount still owed $: other property (specify type and value): r f} My regular monthly living expenses are $ as follows: mortgage/rent food: moJj iu 'u. U (Ytl d (( ??v v water/sewer electricity: I OD , Vheating: transportation: .G. ? ? `' n o\? ? ,1-? __ ., s? ? ?'?j ? ???ti. a clothing: medical: V? CL other (specify): 0 ?Lb a)? 4 $O / 3 ?M a, g) Persons dependent upon me for support (name, age, relationship): &A5- d sow 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct and understand that the making of any false statements would subject me to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. WHEREFORE, I hereby request that the Court permit me to proceed in forma pauperis. Date: (Signature) VERIFICATION I verify that I am the defendant as designated in the present action and that the facts and statements contained in the above Petition to Proceed In Forma Pauperis and Affidavit are true and correct to the best of my knowledge. I understand that any false statements would subject me to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Signature: ,4 a _ 4 Date / - -- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Northstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 Vs. Leilani McBeth 773 Hamilton Ct. Carlisle PA 17013-1519 And Ryan Ferree 95 Green House Rd Gardners, PA 17324-9055 Civil Action - Law No. 10-6594 Civil Tenn PRELIMINARY OBJECTIONS .." N i. _ t?j s,. va ? s And now here comes Ryan Ferree, on his own behalf, and for his preliminary objections asserts the following: 1. The Complaint does not conform to the law and Rules of Court: a. The Complaint does not have the mortgage Agreement attached, as required by Rule 1019(1) of the Pennsylvania Rules of Civil Procedure. b. The Complaint claims attorneys fees in the amount of $650.00, and Plaintiffs are not allowed attorneys fees under the state's law. c. The Complaint asks for "interest per diem" "late charges" "costs of suit and title search" but does not have attached any writing itemizing these which would allow us to determine if the charges are correct and allowed by the mortgage agreement or what amounts and dates the charges are for or made on. d. The Complaint is verified by counsel for the Plaintiff, and there is no evidence that a mortgage company is "outside the jurisdiction" of the United States and that verification of no agent of the mortgage company can be obtained within the time allowed for filing the action to allow the attorney to verify the Complaint under 1024(c). e. The Complaint said the mortgage was assigned and there is no evidence attached of any assignment documents as required by the Rules. Public records in Texas or Delaware or whatever are not available to the Defendant, who has no idea where these can be obtained and viewed. 2. The parties have an agreement to resolve the foreclosure by alternative dispute resolution. We are negotiating with an agent of the company, Beau Guyton, to do a short sale and we are in the process of sending in all the papers. Therefore, the Defendant asks that the Complaint be dismissed, and the Plaintiff be required to refile a pleading which conforms to the law and the Rules, with the supporting documentation. Further, the Defendant requests the Court stay the proceedings in the matter pending a final determination by the mortgage company on eligibility for a short sale, and further stay the proceedings if the parties are determined eligible, in order for the sale to be accomplished. Ryan Ferree, Defendant, pro se I verify the statements contained herein are true and correct to the best of my knowledge, information and belief. 1 understand the statements herein is made subject to the penalties of 18 Pa C.S. § 4904 relating to unsworn falsification of authorities. ?(6s b-O tAA Date Ryan Ferree I verify the statements contained herein are true and correct to the best of my knowledge, information and belief. I understand the statements herein is made subject to the penalties of 18 Pa C.S. § 4904 relating to unsworn falsification of authorities. tf to Aio-,-L ?. r? LI/ Dated Ryan Ferree COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Northstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 Vs. Leilani McBeth 773 Hamilton Ct. Carlisle PA 17013-1519 And Ryan Ferree 95 Green House Rd Gardners, PA 17324-9055 Civil Action - Law No. 10-6594 Civil Term Certificate of Service I Ryan Ferree hereby certify I served a true and correct copy of the Preliminary Objections upon the following parties to the action on _ IT_SI ( V , 2010, in the following ways: Northstar Mortgage LLC By its attorney Joshua I Goldman, Esq. Phelan Haiilinan and Schmieg, LLP 16171FK Blvd. Suite 1400 One Penn Center Plaza Philadelphia PA 19103 via certified mail, return receipt requested to firm address Leilani McBeth via handing a copy at her residence SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson .? Sheriff . Jody S Smith r*t z =-n =rn Chief Deputy ?rn Richard W Stewart ao Solicitor c 1e: OF T ? e s?, R1F r ° ? 3 '= t M Nationstar Mortgage LLC r C N b vs. ase um er Ryan Ferree (et al.) 2010-6594 SHERIFF'S RETURN OF SERVICE 11/02/2010 08:02 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 2, 2010 at 2002 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ryan Ferree, by making known unto himself personally, at 95 Green House Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. LLIAM CLINE, DEPUTY 11/05/2010 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: Ryan Ferree, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Ryan Ferree. Request for service at 773 Hamilton Court, Carlisle, PA 17013 the defendant wa: not found. Ryan Ferree currently resides at 95 Green House Road, Gardners, PA 17324. 11/16/2010 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: Leilani McBeth, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Leilani McBeth. Request for service at 95 Green House Road, Gardners, PA 17324 the defendant was not found. Leilani McBeth currently resides at 773 Hamilton Court, Carlisle, PA 17013. 11/16/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 1420 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Leilani McBeth. After several attempts to 773 Hamilton Court, Carlisle, PA 17013 The Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $101.30 November 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF {c} GaunfySuite Shenff. Teleosoft Inc. R ' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Northstar Mortgage LLC 350 Highland Drive Lewisville, TX 75057 Vs. Leilani McBeth 773 Hamilton Ct. Carlisle PA 17013-1519 And Ryan Ferree ; 95 Green House Rd Gardners, PA 17324-9055 Civil Action - Law No. 10-6594 Civil Term !? R D A IL AND NOW, this day of _? , 20 , upon presentation and consideration of the attached, verified Petition to Proceed In Forma Pauperis, it is hereby ordered that _ Petititioner's request to proceed 1FP is granted. Petititioner's request to proceed IFP is denied. tl ?oS??uc s . ?ao?glrttak E.Sr ? Eya n rerrce THE COURT, Judge c 0 rn =-n x a? o r` -u rn MC:j o ?o Zn = = xii c 5c: o ar i o ? 6Pi e5 ma.)ed 11 /a 4l/lv Aiz- ('? fit ° ?r_ 1 Tt iy tlvl.ii; vt trhtiil`? Phelan Hallinan & Schmieg, LLP Joseph P. Schalk, Esquire, ID 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 Plaintiff V. LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 Defendants 250781 a l f !} 7\ t" A '01. 3 Psi r?,j ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM V594 NO. 10- CUMBERLAND COUNTY CIVIL ACTION - LAW AMENDED COMPLAINT IN MORTGAGE FORECLOSURE File #: 250781 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 #: 250781 1. Plaintiff is NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 2. The names and last known addresses of the Defendants are: LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 who are the mortgagors and/or real owners of the property hereinafter described. 3. On 08/27/2007 LEILANI MCBETH and RYAN FERREE made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR HOMECOMINGS FINANCIAL,LLC (F/K/A HOMECOMINGS FINANCIAL NETWORK, INC.) which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200735643. True and correct copies of the Mortgage and Note are attached hereto, incorporated herein by reference and marked as Exhibit "A" and Exhibit "B", respectively. 4. By virtue of an Assignment of Mortgage sent to the Cumberland County Office of Recorder of Deeds, on October 12, 2010, the PLAINTIFF is now the legal owner of the Mortgage and is in the process of formalizing an assignment of same. A true and correct copy of the Assignment of Mortgage that was sent to the Cumberland County Office of Recorder of Deeds is attached hereto, incorporated herein by reference and marked as Exhibit "C". File #: 250781 5. 6. 7 The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/20 10 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. The following amounts are due on the mortgage: Principal Balance $146,928.56 Interest $3,985.08 05/01/2010 through 09/09/2010 (Per Diem $30.19) Attorney's Fees $650.00 Late Charges through 09/09/2010 $160.47 Costs of Suit and Title Search $550.00 Escrow Deficit $1,184.54 TOTAL $153,458.65 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendants in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants 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. File #: 250781 9. Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and Notice of Default as required by the mortgage document have been sent to the Defendants on August 4, 2010, and the temporary stay as provided by said notice has terminated because Defendants have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or have been denied assistance by the Pennsylvania Housing Finance Agency. A true and correct copy of the Act Notice is attached hereto, incorporated herein by reference and marked as Exhibit "D". WHEREFORE, Plaintiff demands an in rem judgment against the Defendants in the sum of $153,458.65, together with interest from 09/09/2010 at the rate of $30.19 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. By: File #: 250781 PHELAN HALLINAN & SCHMIEG, LLP LEGAL DESCRIPTION ALL that certain tract of land with the improvements thereon erected situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, the center of the intersection of Township Roads Nos. 526 and 534; thence by the center of Township Road No. 534, South 54 degrees 45 minutes West 8.3 perches to a point; thence by the same, South 19 degrees 4.4 perches to a point; thence along a stone fence now, by land being retained by Carrie R. Gallaway, North 57 degrees 30 minutes West 15.4 perches to an iron pin; thence by land being retained by Carrie R. Gallaway, North 35 degrees 15 minutes East 14.25 perches to a point in the center of Township Road No. 526; thence by the center of said Township Road No. 526, South 49 degrees 45 minutes East 17.17 perches to the Place of BEGINNING. CONTAINING 1 acre 47 perches, more or less and being improved with a dwelling house. BEING the same premises which Bonnie L. Highlands, single woman, by deed dated September 29, 1995 and recorded October 2, 1995 in the Cumberland County Recorder of Deeds Office in Book 129, page 57, granted and conveyed unto Kevin E. Dillman and Mae F. Dillman, husband and wife. BEING the same premises which became vested in Leilani McBeth and Ryan Ferree by deed of Kevin E. Dillman and Mae F. Dillman, husband ad wife, dated 8/27/07 and recorded contemporaneously herewith in the Office of the Recorder of Deeds in and for Cumberland County. PROPERTY ADDRESS: 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055 PARCEL # 08-16-0210-060 File #: 250781 0 l'-f EXHIBIT A n Prepared By: Homecomings Financial 9 Sylvan Nay, Suite 310 Parsippany, NJ D1054 QLk-IAMA W, Sunset Seulcment Services, LL.C 341 Science Park Road suite 205 C i State College, PA 16803 3 nol-O t? L. Nunber: 047-499M-4 ParcolNumber. APN #1: 08-16-0210-060 APN #2: Premises: 95 aREENW OUSE ROAD GARDNERS, PA 17324 (Space Above n& Line Per Recording Des) PURCHASE MONEY MORTGAGE DEF) MONS MIN 200062604749968246 Words used in multiple sections of this document am defined below and other words are defined in Sections 3, 11. 13, 18, 20 and 21. Certain rules regarding the wage of words used in this document are also provided in Section 16. (A) "Security lndrameot" means this document, which is dated AUGUST 27TH, 2007 together with all Riders to this document. (R) "lbrroeer" is LEILANI NCSETH AND RYAN FERREE Borrower is the mortgagor under this Security Instrument. (I) "HERS" is Mortgage Electronic Registration Systems, Inc. MFRS is a separate corporation that is acting solely as a nominee for Leader std Lender's wccessors and assigns. MFRS is the ime tpgee under this Semdty Imtrument. HERS is organized and existing under the laws of Delaware. and has an address and telephone number of P.O. Box 2026, Film MI 4850I.2026, tel. (88M 679-MERS. PUMYLVANIA - Single Family • Fends MaelReddle Moe UNIFORM INSTRUNMT IANrN MFRS MFPA7770 (071=007) / D47-499MA Vialtors Kluwer Financls) Services VMPe4A(PA)s*mi,o2 303 1101 ! Pop / of 16 1 IN ntU15/9nin p-H.4-7n AM CUMBERLAND COUNTY Inst.if 200735643 - Page 1 of 18 (D)%mder"is HOMECOMINGS FINANCIAL, LLC (F/K/A HOMECOMINGS FINANCIAL NETWORK, INC.) Lender is a LIMITED LIABILITY COMPANY organized and existing under the laws of DELAWARE Lender's address is 9 SYLVAN WAY, SUM 1Q0 PARSIPPANY, NJ 07054 (E) "Note" mans the promissory tact signed by Borrower and dated AUGUST 27TH, 2007 The Note states that Borrower owes Lender ONE HUNDRED FIFTY THREE THOUSAND AND NO/ I oo Dollars (U.S. S 153, 000.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than SEPTEMBER 1ST, 2037 (F) "Property" mom the property that is described below under the heading 'Transfer of Rights in the property.. (G) "Loran" mans the debt evidenced by the Note. plus interest, any prepayment charges and hallo charges due under the Note, and all an= due under this Security Inatntment, plus interest. (H) "Riders" mecum all Riders to this Security Instrument that arc executed by Borrower. The following Riders are to be executed by Borrower (check box as appliablel: Adjustable Rate Rider Condominium Rider Second Home Rider Balloon Rider Planed Unit Development Rider 1-4 Family Rider VA Rider Biweekly Payment Rider Other(s) (specify) m "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as an applicable final. non-appealable judicial opinions. (J) "Commurdty Assodatlon Dues, Fees, and Assessments" means all dues, fees. assessments and other charges that arc imposed. on Borrower or the Property by a condominium association, homeowners association or similar organization. (IQ "Electronic Funds Transfer" means any transfer of furls. other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic teumtinat, teepbonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (I) "Escrow Items" means those items that an described in Section 3. ft "Mtsceilwteous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds pa td under the coveages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (N) "Mortgage Imumitce" mesas insurance protecting lender against the nonpayment of, or default on, the Loan. (O) "Periodic Payment" means the regalarly scheduled amount dine for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. ~ 19-6AWA) WOOM.o: MPPA7770 J07=01) / 047-499M4 Pp 7011a `-6 /L/1 e f Form 3039 1101 nomgi-min o•vz•7n ass rt IMRFRI AND COUNTY Inst.# 200735643 - Page 2 of 18 (P) "RFSPA" arenas the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its implementing rt elation, Regulation X (24 C.F.R. Pan 3500), as they might be ataended from time to time, or any additional or successor kgWation or regulation that govents the same subject natter. As used in this Security Instrument. "RESPA" refers to all require cents and restrictions that are briposed in regard to a "federally related mortgage loan' even if the loan does not qualify as a 'federally related mortgage loan" under RESPA. (Q) "Succeasta in bderet of Borrower" means any party that has taken title to the Property. whether or tat that party has assumed Borrower's obligations under the Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrurnent satires to Lender: (;) the repayment of the Lout, and all renewals, extensions and modifications of the Note: and (ii) the performance of Borrower's covenants and agreetnents under this Security Inttrume» t and the Note. For this purpose. Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in the COUNTY (Type of lawdiag rneNdietion) Of CUMBERLAND [Name of Recording tadtdicdos]: Legal description attached hereto and made a part hereof which currently has the address of 95 GREEN HOUSE ROAD €Sueal GARDNERS lCinl,Pennsylvania 17324: €zipCodel ("Property Address'): TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, a s, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agree that MBRS holds only legal title to the itnevests grazed by Borrower in this Security Instruatent, but, if nece cry to comply with law or custom, MFRS noirunce for Lender and Leader's successors and asift'PA) has theright: to exercise any or all of those interests, includr'ttg. but not limited to, the right to fo and sell the Property; and to take any action required of Lender including, but not litttited to, this Security Inst. rF hl". aA(PA) mw.oz pqp 3 311 B rnrm 3039 1101 VMP 6- MPPA7M(07/2007) 1 04749%624 ncvisnnin c1-,AA-,?n Ann CUMBERLAND COUNTY Inst.# 200735643 - Page 3 of 18 BORROWER COVENANTS shat Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered. except for encumbrances of record. Borrower warrants and will defend generally the tide to the Property against all claims std demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for rice kmW use and nom-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of PrhWpal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and We charges due under the Note. Borrower shall also pay funds for Escrow [term pursuant to Section 3. Payments due under the Note and this Security Instrument shall be trade in U.S. currency. However, if may check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash: (b) money order: (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits am insured by a federal agency, instrumentality. or entity; or (d) Electronic Funds Transfer. Payments are doomed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 13. Lender may return any payment or partial payment if the payment or partial payments am insufficient to bring the Lam correct. Lender may accept any payment or partial payment inwfftt ienu to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied hoods. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time. Lender shall either apply such foods or return them to Borrower. If not applied earlier, such hugs will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender stall relieve Borrower from making payments dote under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. ApplI atiou of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts stall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge doe, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding. LaWer may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to extent M e that, each payment Ww?. VMPS-0AIPAI1WA6 2 Pm 4.1 to Form 3038 1101 MFPA7770 (0712007) f 0474"682.4 nwisw7n1n o•31•70 Asa CUMBERLAND COUNTY inst.# 200735643 - Page 4 of 18 can be paid in !till. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments. such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to airy prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3, Funds for Escrow [tats. Borrower stall pay to Lender on the day Periodic Payments ate due under the Note, until the Note is paid in fug, a sum (the "Funds) to provide for payment of amounts due for: (a) taxes and assessment and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold psymams or ground rams on the Property, if any; (c) premiums for any and alt insurance requited by Lender under Section 5; and (d) Mortgage insurance premiums, if any, or any sums payable by Borrower to Leaider in lieu of the payment of Mortgage Insurance premium in accordance with the provisions of Section 10. Then items are called "Escrow Items.' At origination or at any time during the term of the Loam, Lender may require that C.otmuaoity Association Duet:, Fees, std Assessments, if any, be escrowed by Borrower, and such does, fees and assessments shall be an fiecrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lads the Funds for Escrow Item unless Lander waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Item at any time. Any such waiver tiny only be in writing. In the event of such waiver, Borrower shall pay directly. when and what payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lauder and, if Lender inquires, shall furnish to Lefler receipts evidencing such payment. within such time period as Leader may require. Borrower's obligation to retake such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenatm and agrsement• is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Harrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section, 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lauder any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Leader all Funds, and in such amounts, that are then required under this Section 3. Lamer may. at any time. collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESFA. Lender shall estimate this amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds small be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lander, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall apply the Furls to pay the Escrow Items no later than the time specified under RESPA. Lander shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Leaflet pays Borrower interest on the Funds and Applicable Law permits Lander to matte such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Feuds, Gender shall not be requited to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in tyriting, however, that interest ?.JOII). /?/\ F ?,414? V MP 6-6AIPAI moeLo2 Pp" d w 1 B Fo m 3039 1101 MFPA7770(07nW7) 1 047199682-4 nnncrrnen n-99-9n AAA e:I IMRFRI ANr) rOl INTY Ins!#200735643 - Page 5 of 1H shall be paid on the Furls. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds hold in escrow, as defined under RESPA. Lender shill account to Borrower for the excess funds in accordance with RFSPA. If them is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to render the amount necessary to nuke up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined tinder RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accords= with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower email pay all taxes, assessments, charges. funs, and impositions attributable to the Properly which can attain priority over this Security Irmruntmd, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessmenut, if any, To the extend than these items are Escrow Items, Borrower WWI pay them in the manner provided in Section 3. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lieu in a mamrer acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings arc pending. but only until such proceedings are concluded-, or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lxoder determines that any part of the Property is subject to a ties which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or mote of the actions ses forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification andlor reporting service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and hoods, for which Leader requires insurance. This insurance shall be maintained in the aumnix (including deductible levels) and for the periods that Lmuler requires. What Lender requires pursuant to the preceding sentences can change during-the term of the Loan, Tle insurance carrier providing the insurance shall be chosen by Borrower subject to Larder's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Leader may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification sad tracking services; or (b) a one-titre charge for flood zone determination and certification services and subsequent charges each time remappinga or similar changes occur which roaeonebly might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. 4 Mob: V MP s-aAIPA) rosoa1.w P.w $0 +s Form 3039 1101 MFPA7770 (ORIO 7) l 047499681.4 nn,+c, - -'3^^ ALA !`I IMAPPI ANTI r.011NTY Inst.# 200735843 -Pape 6 of 18 If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might riot protect Borrower, Borrower's equity in the Property, or the BonWM of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effoct. Borrower acknowledges that the cost of the insurance coverage so obtained might sigaiftauuly exceed the cost of insurance that Borrower could have obtained. Any mounts disbursed by Lender under this Section S shall become additional debt of Borrower secured by this Security Instrument. That amounts shall bear intact at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Leader's right to disapprove such policies, stall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Leander all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Leader, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall mote Leader as marlgagoe and/or as en additional loss payee. In the evert of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of foss if not made promptly by Borrower. Unless Lender and Borrower oilterwiae agree in writing, any insurance proceeds, whether or riot the underlying insurance was required by Leader, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and res oratlon period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such Inspection 9ta8 be undertaken promptly. Leader may disburse proceeds for the repain and restoration in a tingle payment or in a series of progress payments as the work is completed. Unless an agroanent is made in writing or Applicable Law requires interest to be paid on such inwranoe proceeds, Lender dolt not be required to pay Borrower any imcreat or earnings on such proceeds. Fees for public adjusters. or other third partlea, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Leader's security would be lessened, the insurance proceeds "I be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds sbail be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related natters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when the a vice is given. In either evert, or if Leader acquires the Property under Section 22 or otherwise. Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premium paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Itstntmeut, whether or not then due. , Mr F VMF 04A(PA) wamox FqW 7 W 16 Form 3039 trot MFPA7770 (o7aom) f 047499692.4 -14ceu4n n-oo.-)n Abe (`I IMRFRI ANr) (01 INTY Inst.# 200735643 - Page 7 of 18 6. Occupancy. Borrower shall occupy, establish. and use the Property as Borrower's principal residence within 60 days after the execution of this Security IMMMett and shall continue to oocapy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Leander otherwise agrees in writing, which consent shall not be unreasonably withbeld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste or the Property. Whether or not Borrower is raiding in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its Condition. Unless it is determined pursuau to Section 5 that repair or restoration is not economically feasible. Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection with damage to, or the taping of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the Conpletiew of such repair or runtoratiot. Lender or its agent rosy make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. 8. Borrower's Loan Application. Borrower shall be In default if, during the Loan application process, Borrower or any persons or entities acting at the direction of Bormwer or with Borrower's knowledge or consent gave materially fain, misleading, or inaccurate info nation or statements to Leader (or failed to provide Lender with material infomstion) in connection with die Wan. Material representations include, but are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Property and WSW Under this Seenily Instrument. If (a) Borrower fails to perform the covenants and agreemensa contained in this Seem* Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and/or rigbts under this Security Instrument (such as a proceeding in bankruptcy. probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce taws or regulations). or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect Leader's interest in the Property and right trader this Security Instrument, including protecting and/or assessing the value of the Property. and accuring amd/w repairing the Property. Leader's actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying masorsble attorneys' fees to protect is interest In the Property andlo' rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property Ind9des, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or dangerous condition, and have utilities turned on or off. Although Lender may take action under this Section 9. Lender does not have to do so and is riot under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking soy or all actions authorized under this Section 9. 4 A, N*ub: YMP s4A1PA1 aaoat.07 P#p a at re Form 3039 1101 MAPA777nt0712007) t 047,499682.4 4`10r14P7ntn Q`41•7n Ape M 1MRFRt AND COUNTY tnst# 200735643 - Page 8 of 18 Any amoums disbursed by Lander under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at die Note Tate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payrn-L If this Security Instrument is on a leasehold. Borrower shall comply with all the provisions of the lase. If Borrower acquires fee tide to the Property, the leasehold and the tee title shall not merge unless Lender agrees to tie merger in writing. 10. Mortgage Insurance. If Lender required Mortgage Insurance as it condition of snaking the Loan, Borrower shall pay the premiums requited to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to stake separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums requited to obtain coverage substantially equivalent to the Mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Inummoe coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loam reserve in lieu of Mortgage Insurance. Such loss reserve shall be on-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lzntler dull not be required to lay Borrower any interest or earnings on such loss reserve. Lender em no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Leader requires separately designated payments toward the premiums for Mortgage Insurance. It Lender regthtled Mortgage Insurance as a condition of making the Loan and Borrower was required to mains separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premium required to maintain Mortgage Insurance in effect, or to provide a non-refundable dos reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such tertriination or until termination is required by Applicable Law. Notting in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Linder (or any entity that purchases the Nate) for certain losses it may incur if Borrower does not repay the Loan as agreed. Harrower is not a patty to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such irmintrim in force from time to time, and tray enter into agreements with other parties that share or modify their risk, or reduce hose. That agrxments are on terms and conditions that arc satisfactory to the mortgage insurer mid the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insure may have available (which may include funds obtained from Mortgage Insurance Premiums). As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinstmer. any odor entity, or any affiliate of any of die foregoing, nay receive (directly or Indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing donna. If such agreement provides that an affiliate of Leader takes a share of the insurer's risk in exchange for a stare of the premiums paid to the insurer, the arrangement is often termed "captive reinsurance." Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terns of the Loan. Such agreements wM mat iacreane the amount Borrower will owe for Mortgage Insurance, and they will not entitle B,orr=wer to any retard. VMP*464IPA1 hosw.az No. a of ro Fam 3039 1101 WPA-MO(0712007) 1 0474996921 nmlcnnln a as ?n Ann CUMBERLAND COUNTY lnst.it 200735643 - Page 9 of 18 (b) Any such agreements will not affect the rights Borrower has - if any - with reap,-, to the Mortgage Insurance under the Homeowners Protection Ad of IM or any other law. Those rights may IneWe the right to receive chain disclosures, to request and obtain cancellation of the Mortgage insurance, to have the Mortgage insurance terminated atst,nutialy, and/or to receive a re8md of any Mortgage Insurance premiums that were unearned at the time of arch cancellation or termination. 11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds tie hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and L=der'a security is not lessened. During arch repair and restoration period. Leader shall have the right to hold such Miscellamotu Proceeds until Lender has had an opportunity to inspect such Property to ensure the work bs ban completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Leader may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds. Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically fusible or hander's security would be lessened, the Miscellaneous Proceeds shalt be applied to the wets secured by this Security Instrument. whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Misedlattoous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. In the event of a partial taking, destruction, or loss in valise of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums seared by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower sad Lender otherwise agree in writing, the sums seared by this Security Instrument shall be reduced by the amount of the M-aoellaneoas Proceeds multiplied by the following fraction: (a) the tool amount of the sums secured iawtediateiy before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial tatting. destruction. or Iola in value. Any balance ahail be paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or has in value is lea slum the amours of the sums secured immediately before the partial taking, destruction. or loos in value, unless Borrower and Leader otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the suns seared by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Parry (s defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given. Lender is suthorlaed to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums seared by this Security Instrument, whether or not then due. 'Opposing Party" mram the third party that owes Borrower Miscellaneous Proceeds or the patty against whom Borrower has a tight of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be 4 nn K F- fftu.,.: VMP ®-0A(PAI Psos)-w P.O. 10W is Form 3038 1101 MPPA7770 (0712007) / 04719%82.4 no/ z;min Q•R4•7n AM CUMBERLAND COUNTY Inst.# 200735643 - Page 10 of 18 dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property am hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that arc not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbears= By Lender Not a Walver. Extension of the time for payment or modification of amortization of the sutras secured by this Security Instrument granted by Lender to Borrower or any Successor in Interco of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender "I not be required to commence proceedioga agalost any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by mason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in a xemising any right or remedy including, without limitation, Lender's acceptance of paymeres from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assign Boaud. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who w-signs this Security instrument but does not execute the Note (a 'co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and convoy the co-signer's hirer st to the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the suns 70W10d by this Security Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or matte any accommodations with regard to the terms of this Security Instrument or the Noe without the co-signer's consent. Subject to the provisions of Section 18, any Successor in Interest of Borrower who assanta Borrower's obligations under this Security instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall cwt be released from Borrowers obligations and liability under this Security Instrument unless Fender agrees to sods release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors and assips of lender. 14, Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Leader's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security lasumment to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that arc expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to rodmx the charge to the permitted litnlt; and (b) any sums already collected from Borwwa which exceeded permitted limits will be refunded to Borrower. Lander may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as it partial prepayment without any prepayment chugs (wheedler or not a prepayment charge is provided for under the Note). Borrower's acceptance of any sudt refund trade by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Lender to connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be demeaned to M.:._n 9 F V1fiP°•8Att'A) aioei.o2 P.O. 11.1 16 Fpm 3039 1101 MFPA7770 (07/2007) t 0474996124 n(i/19.0n10 A`43•7n AM CUMBERLAND COUNTY Inst.# 200735643 . Page 11 of 18 have been given to Borrower when mailed by first class mail or when actually delivered to Bormwer's notice address if sent by other trims. Notice to any one Borrower shall constitute notice to all Botrowea unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute mice address by notice to Ltoder. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only out designated notice address under this Security In bums nt at any one time. Any notice to Leader shall be given by delivering it or by mailing it by first din tail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under security Insuvr0cot. 16. Governing LAw; Severability; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security Instrument arc subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. In the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable law. such conflict shalt not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. As used in this Security instrument: (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean roes include the plural and vice versa; and (c) the word 'may' gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security IOS[mmait. 13. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, 'Interest in the Property" awns any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for teed, installment Saks contract or escrow agreement, the huent of whirls is the transfer of title by Borrower at a fi cure date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial Interest in Borrower is sold or transferred) without Lender's prior written consent. Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if surlt exercise is prohibited by Applicable Law. If Lender exercises this option. Lender shall give Borrower notice of acceleration. The mortice stall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Bonower fails to pay time sums prior to the expiration of this period, Lender may Unroke any remedies permitted by this Security Instrument without further ranee or demand on Borrower. 14. Borrower's Right to Reinstate After Acceleration. If Borrower rants certain conditions, Borrower shall have the right to have enforcement of this Security Inanniment disconaimmd at arty time prior to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. These conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as; if no acceleration had occurred; (b) tuns any default of any other coverants or 4? M Imim: VMPB-6A(PA)WN1.M2 P.P+2.t is Form303e 1(01 MFPA7770 t(V772(f)7) 1 617499612+4 nWISOnin A•33.70 AM CUMBERLAND COUNTY Inst.# 200735643 - Page 12 of 18 agreements; (c) pays all expenses incurred in enforcing this Security instrument, including, but not limited to, reasonable attorneys' foes, property inspection and valuation fees, and other fees incurred for the purpose of protecting Liender's interest in the Property and rights under this Security Instrument; and (d) takes such action u Leader may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pry the sums secured by that Security Instrument, shall continue unchanged. Lender may require That Borrower pay such reinstatement am and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such duck is drawn upon an institution whose deposits arc insured by a federal agency, instrumentality or entity, or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security bhatrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section hg. 20. sate or Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in the entity (known as the "Loan Servicer') that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security htstntntent, std Applicable Law. Thum: also might be one or more changes of the Loan Servieer unrelated to a axle of the Note. If there is a change of the Loan Serviar, Borrower will be given written notice of the change which will state the time and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in cotmection with a notice of transfer of servicing. If the Note is sold and thertafter the Loan is serviced by a Lout Serviccr other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will rennin with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchases. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other patty's actions pursuant to this Security Instrument or that alleges that the other party has breaded any provision of, or any duty owed by munn of, this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Uw provides s time period which must elapse before certain action can be to=. that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) 'Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) 'Frhvirormhcntal Law" meats federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c) "Environmental Cleanup' includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition' means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. I.W.I. Q4 ?. r- VMP*•sA(PAI eafi".or P.q 13.1 rte Form 7038 1;01 MFPAIM e07rnrr7) 1 047499682-4 nQ/iri7nln Q%3.54,70 AM CUMBERLAND COUNTY Inst.# 200735643 - Page 13 of 18 Borrower shall not cause or permit the presence, use, disposal storsg or release of any Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do. nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Envirwrmen>si Cooffidon, or (c) which, die to the presence, use, or Toluene of a Hazardous Substance, creates a condition that adversely affects the value of the ply The preceding two sentences shall not apply to ftpresence, use. or storage on the at small quantities of Hazardous Substances that am `eta my recognized to be appropriate to? residential mks and to maintenance of the Propary (including, but not limited to, bazatdous subm. in consumer products). Borrower shall promptly give Lender written notice of (a) any claim. demand. lawsuit or other action by any governmental or regulatory agency or private parry lvlng the Praoertv arxl say Hazardous Substance or Environmental Law of which Borrower has actual l;nowt ge. (b) my Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or rate= of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other mmediation of any Hazardous Substance affecting the Property, is necessary, Borrower shall ptnarpdy take all necessary remedial actions in accordance with Envirordnentsl Law. Nothing herein shall ereata any obligation on Lender for at,, Environmental Cleanuupp NON-UNIFORM W VENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Renedies. Leader d" give notice to Borrower prior to acadaat[m fallowing Borrower's breach of any covenant or ogsoement in This Security lndrmmeW Ott not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the dehult; (b) the action required to ethic the dearth; (c) when the default must be cured; and (d) that hilure to core the dabult as specified may rgak In acceleration or the sums secured by this Sonority Instrument, ferocloo a by Judlicial pevoaadi and sak or the Property. Lander shall farther hifena Borrower of the right to relostoe afFa acceleration and the trfaht to assort in the foreclosure proceeding the non-existence of a dehult er any odber defense of Borrower to acceleration and foreclostme. If the defaok Is not cored as *Wfiad, Lender at its option niay require immediate payment In fail of ail stmt tenured by thb Security Instrument wiNrout further demand and may foreclose this Security Instmnmm by jndkbi Leader shall be entitled to collect all expanses incurred in yortufng the rates itl psovidal in this &Wooo 22, including, but not tlnked to, attorneys' few and costa of title evidence to the adent pamflted by Applicable Law, 23. Release. Upon payment of all sums secured by this Security Instrument. this Security Instrument and the estate conveyed shall tecminste and become void. After such occurrence, Leader shall discharge and satisfy this Security Instrument. Borrower stall pay a recordation own. Leader may charge Borrower a fee for releasing this Security Instrument. but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. Waivers. Borrower, to the extent permitted by Applicable lAw. waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any prmeot or future laws providing for stay of execution, extension of dirk, exemption from attschnx t, levy and sale, and homestead exemption. 25. Reinslatesnent Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or otter sale pursumt to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to aquire tide to the Property, this Security Instrument shah be a purchase money mortgage. 27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after aJudgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Noic. VMP--6A (PA),.sa,.o2 r.r, u ? , e form 3038 1101 MFPA7770 (071'(17) / 0474996824 namKnnin o•wa.?n AAA rtIMRFRI.AND COUNTY Inst.# 200735643 . Page 14 of 18 BY SIGN[NG BELOW, Borrower accepts and agrees to the temu and tenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witntemes: VMP6.9AMA1 osmor MPPA7770 (0712(1(17) i 047-499662-4 _ (Seat) -Borrower _ (Sal) -Borrower _ (Seal) (Sea) -Borrower -Borrower _ (Seal) -Borrower f .Borrower t.Birntu MCBETB /_1 - (seal) Bomwer RY FERREE r." 16.f to _ (Sal) -Borrower Firm W39 1101 09/15/2010 9:33:20 AM CUMBERLAND COUNTY lnst.# 200735643 - Page 15 o(18 COMMONWEALTH OF PENNSYLVANIA, Canty sa: On this, the 9- 7 day of 2007 , before toe, the undersigned officer, personally appeared Lart.ANT MCBETN AND RYAN FERRRE known to the (or satisfactorily proven) to ?,e person(?j whose name bscribed to the within iri mrtent and acknowledged t xtxaited same for the u rpa*s herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission lixpires: 42(4/07 COMMONWEALTH OF PEWISYLVANI A 4? nldalW Seel I Paul; oar. Nctxy r ubic l Low Paxton Twp.. Dauptyn Caalyr MM Camission Ex Aims Dec. 9. 2007 Member, Pennsylvania Association Or Neums Tide of 01Fk:er Certificate q?Res[dax? 1- I, do hereby certify that the correct address of the Within-named Mortgagee is P.O. Box 2026, Flint, M148501-2026. Witness my hand this A7 day of /4? 2007. VMP $-SA{PA) 05061.02 MPPA7770 [07/2(07) 1 047-4994924 Av Agent of Mortgagee vw.ISa le Imm. t ( Y r Form 3039 1101 09115!2010 9:33:20 AM CUMBERLAND COUNTY inst.# 200735643 - Page 16 of 18 ALL that certain tract of land with the improvements thereon erected situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, the center of the intersection of Township Roads Nos. 526 and 534; thence by the center of Township Road No. 534, South 54 degrees 45 minutes West 8.3 perches to a point; thence by the same, South 19 degrees 4.4 perches to a point; thence along a stone fence now, by land being retained by Carrie R. Gallaway, North 57 degrees 30 minutes West 15.4 perches to an iron pin; thence by land being retained by Carrie R. Gallaway, North 35 degrees 15 minutes East 14.25 perches to a point in the center of Township Road No. 526; thence by the center of said Township Road No. 526, South 49 degrees 45 minutes East 17.17 perches to the Place of BEGINNING. CONTAINING 1 acre 47 perches, more or less and being improved with a dwelling house. BEING the same premises which Bonnie L. Highlands, single woman, by deed dated September 29, 1995 and recorded October 2, 1995 in the Cumberland County Recorder of Deeds Office in Book 129, page 57, granted and conveyed unto Kevin E. Dillman and Mae F. Dillman, husband and wife. BEING the same premises which became vested in Leilani McBeth and Ryan Ferree by deed of Kevin E. Dillman and Mae F. Dillman, husband ad wife, dated 112110 and recorded contemporaneously herewith in the Office of the Recorder of Deeds in and for Cumberland County. Parcel #08-16-0210-060 ffi/li lf) W33:20 AM CUMBERLAND COUNTY Inst.# 200735643 - Page 17 of 18 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200735643 Recorded On 9/12/2007 At 1:14:19 PM * Total Pages - 18 * Instrument Type - MORTGAGE Invoice Number - 4366 User ID - AF * Mortgagor - MCBETH, LEILANI * Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. * Customer - SUNSET SETTLEMENT * FEES r--- STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES - RECORDER OF DEEDS Arl*P MLE HOUSING COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $10.00 $37.50 $11.50 $2.00 $3.00 $64.50 DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O Certification Page ' - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. NEW 11111111110 1 nA/1.Wn10 A23:70 AM CUMBERLAND COUNTY Inst.# 200735643 - Page 18 of 18 ?,?i? C?? EXHIBIT B Page 1 of 3 NOTE AUGUST 27TH, 2007 STATE COLLEGE PENNSYLVANIA Intel ICiryl I9wr1 95 GREEN HOUSE ROAD, GARDNERS, PA 17324 IPmpvty Add-l 1. BORROWER'S PROhI1SE TO PAY In return for a loan that I have received, I promise to pay U.S. S 153,000.00 (this amount is called "Principal'), plus interest, to the order of the lender. The Lender is HOMECOMINGS FINANCIAL, LLC (F/K/A HOMECOMINGS FINANCIAL NETWORK, INC.) I will nuke all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who b entitled to receive payments under this Note is called the "Note Ilolder." 2. INTEREST Intere t will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 7.5000 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMKNTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning on OCTOBER 1ST, 2007 . I will make these payments every month until I have paid all of the principal and iracrest and any other charges described Wow that I may owe under this Note. Fach monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on SEPTBMDER 1ST, 2 D37 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will matte my monthly payments at 9 SYLVAN WAY, SUITE 100, PARSIPPANY, NJ 07054 or at a different place if required by the Note Holder. (R) Amount of Monthly Payments My monthly payment will be in the amount of U.S. S 1,069.80 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment.' When I make a Prepayment. I will tell doe Note Holder in writing that 1 am doing so. I may tax designate a payment as a Prepayment if 1 have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe wider this Note. However. the Note [holder may apply try Prepayment to the accrual and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the arneunt of my monthly payment unless the Note I[older agrees in writing to those changes. MULTISTATE RXED RATE NOTE-Single Famay-Fannie MeeMroddle Mac UNIFORM INSTRUMENT Form 3200 1101 Wolter Kluwer Financial Services VMPO•6111 107071.01 Fp, % .13 Im' •- IaFCDa054 pa/ieeal 1047469502-4 Page 2 of 3 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to he collected in connection with this loan exceed the permitted limits, then: (a) any such Inan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sutra already collected from me which exceeded permitted limits will be refunded to me. The Note Ilolder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be tinted as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) late Charge for Overdue Payments If the Note Holder has cot received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Ilolder. The amount of the charge will be 5.00 S of my overdue payment of principal and interest. 1 will pay this late charge promptly but only once on each late payment. (B) Default IF] do not pay the full amount of each monthly payment on the date it is due, l will be in default. (C) Notice of Default If 1 am in default, the None Holder may send me a written notice telling me that if 1 do not pay the overdue amount by a certain date, the Note (folder may require me to pay immediately the full amount of principal which has not been paid and all the interest that 1 owe on that amount. That date must he at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note ]folder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Norte Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method. any notice that must be given to me under this Note will be given by delivering it or by trailing it by first class mail to me at the Property Address above or at a different address if 1 give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Ilolder at the address stated in Section 3(A) above or at a different address if 1 am given a notice of that different address. S. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises crude in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endotrser of this Note is also obligated to do these things. Any person who takes over these orbligadonts, including the obligations of a guarantor, surety on endorser of this Note, is also obligated to keep all of the promises trade in this Note. The Note Ilolder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may he required to pay all of the amounts owed under this Note. 9. WAIVERS 1 and any other person who has obligations under this Note waive the rights of Presemna:nt and Notice of Dishonor. "Presentment" means the tight to require the Nnte Ilolder to demand payment of amounts due. 'Notice of Dishonor" means the right to require the Note Holder to give notice to other persnns that amounts due have not been paid. /01 At VMP?•5N 107071A1 Pp? 7 W 3 Fypiorm 41? MMD00N 0011008)104 7 4sa007J Page 3 of 3 10. UNIFORM SECURED NOTE This•Nole is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage. Deed of Trust, or Security Deed (the "Security Instrument'). dated the same date as this Now, protects the Note Holder from possible lasses which might result if 1 do nuu keep the promises which I make in this Note. That Security Instrument describes how and under what conditions 1 may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions arc described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written conmu, Lender may require immediate payment in full of all sunns secured by th)s Security Instrument. Howe vcr. this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Ixahx shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. _ (Seal) (Brad) LANI MCBETH -Borrower R FERREE -Bom %vr _ (Seal) -Dorrowcr -(Seal) -Bortmrer (Seal ) -Bummer WNIMA_FleA - . (Seal) Pay -Hammer m Mpy,tdltMY Aismod H n? rynartcial, LLC (Seal) -Hammer JSlga Original 0*1 VMP 00-6N 0707).81 P.C. 9 m a Form 8200 1101 M PGDN$4 IDIOM) 1 947.49MZi F KNOW ALL MEN BY THESE PRESENTS that "Mortgage Electronic Registration Systems, Inc." hereinafter "Assignor" the holder of the Mortgage baeinafter mentioned, for and in consideration of the sum of ONE DOLLAR ($1.00) lawful money unto it in hand paid by NATIONSTAR MORTGAGE LLC, "Assignee," the receipt whereof is acknowledged, has granted, bargained, sold, assigned, transferred and set over unto the said Assignee, its successors and assigns, ALL THAT CERTAIN Indenture of Mortgage given and executed by LEII ANI MCBETH and RYAN FERREE to MORTGAGE ELECTRONIC REGISTRATION SYSI`ItMB, INCORPORATED AS A NOMINEE FOR HOMECOMINGS FINANCIAL LLC (F/WA HOMECOMINGS FINANCIAL NETWORK, INC.), beating the date 08/2712007, in the amount of $153400.00, said Mortgage being recorded on 09/124007 in the County of CUMBERLAND, Commonwealth of Pennsylvania, in Mortgage Instrument No. 2007356#3, MIN: 100052604749968246. Being Known as Promises: 95 GREEN HOUSE ROAD, GARDNERRS, PA 17324-9055 Parcel No: 04-16-0210-060 The transfer of the mortgage and accompanying rights was effective at the time the loan was sold and consideration passed to the Assignor. This assignment is solely intended to describe the instrument sold in a manner sufficient to put third parties on public notice of what has been sold. Together with all Rights, Remedies and incidents thereunto belonging. And all its Right, Title, Interest, Property, Claim and Demand, in and to the same: TO HAVE, HOLD, RECEIVE AND TAKE, all and singular the hereditame nts and premises granted and assigned, or mentioned and intended so to be, with the appurtenances unto Assignee, its successors and assigns, to and for its only proper use, benefit and behoof forever; subject, nevertheless, to the equity of redemption of said Mortgagor in the said Indenture of Mortgage named, and his/her/their heirs and assigns therein. IN WITNESS WHEREOF, the saidUsi d gnnror" s cavoed its Corporate Seal ? erein affixed and these presents to be duly executed b its pmper officers this of 2t1 Sear and Delivered in the presence of us; Mortgage leetroule Registration Systems, Inc. By: is i de/ S= Vice President state/ of? m. tourdy of O s day of 201U before me, the subscribe, personally appeared who acim6vledged him/herself to be the Vice President of Mortgage Electronic Registration Systems, be,, and that he/she,, as such Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained. IN WITNESS WHEREOF, I haamto set my hand and official seal, TONIGUA L. GREEN Notary Public, State of Texas My Commission Expires januory 28, 2014 Stamp/Seal: The precise address of the within named After recording return to: Assignee is: r Phelan Hallinan & Schmieg, LLP 350 HIGHLAND DRWE 1617 JFK Boulevard, Suite 1400 September 23, 2010 LVV 75067 One Penn Center Plaza n By: Philadelphia, PA 19103 A ON 2' Natlo? tar- MORTGAGE August 4, 2010 7104 5400 2100 3222 4137 1110PRIPPRN Leilani Mcbeth 773 Hamilton Ct Carlisle, PA 17013 (Rev. 9/2008) August 4, 2010 A T 1N I E TA]r%.Icd A ? T) I YE UR N HOME FIR FO Thu is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Leilani Mcbeth PROPERTY ADDRESS: 95 Green House Road Gardners, PA 17324 LOAN ACCT. NO.: ORIGINAL LENDER: HOMECOMING FINANCIAL LLC CURRENT SERVICER: Nationstar Mortgage LLC CURRENT LENDER: Nationstar Mortgage LLC Page Three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 95 Green House Road, Gardners, PA 17324 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 06/01/2010: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 08/04/2010: $4,622.34 $106.98 $20.00 $0.00 $4,749.32 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,749.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 IF YOUDO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.if you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Page Four HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: Loss Mitigation Department: Website: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 1-888-725-2432 972-966-4755 Cody Nesbitt customer.service@nationstarmail.com 1-888-480-2432 www.nationstarmtg.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOUMAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. Nationstar Mortgage LLC is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Nationstar Mortgage LLC Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067, 1-888-725-2432 * Indicates Counties Serviced Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.792.2801 / 412.281.2102 www.aebonhousing.org 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blvd-8 Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.afnow.org -Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.afinow.org 'Chester, Delaware Alliance for Building Communities 830 Hamilton Map Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks. Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.ennstrongcap.com 'Armstrong Asociaci6n Puertorriqueflos an Mama, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphida.orgm 'Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.baseinc.org 'Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763/814.946.3651 'Blair Becks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.mm.odu/SociWService/b090.aspx 'Barks, Schuylkill, Montgomery Bucks County Housing Group 2324 Second St Pike; STE 17 Wrightstown, PA 18940 886.886.0280/215.598.3566 www.bchg.org 'Bucks Building United of Southwestern PA 801 N Homewood Ave; STE 201 Pittsburgh, PA 15206 412.281.4422 'Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association SW Campbell St Williamsport, PA 17701 570.322.5515 www.campbellsbfttcenter.org 'Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 `Delaware. Montgomery. Philadelphia Cambria Community Development Corporation 401 Candlelight Dr Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 600.9892227/215.563.5665 'Bucks CCCS of Delaware Valley - Centex City Philadelphia 1608 Walnut St: 10th FL Philadelphia, PA 19103 800.989.2227/215.563.5665 www.cccsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 Fast Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227 / 215.563.5665 www.cDcsdy.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavilion #401 Jenkintown, PA 19046 800.989.2227/215.563.5665 www.ccesdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227/215.563.5665 www.eccsdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227 / 215.563.5665 www.coesdv.org 'Philadelphia CCCS of Delaware Valley - Philadelphia 4400 North Reese St Philadelphia, PA 19140 800.989.2227/215.563.5665 www.cocsdv.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227/215.563.5665 www.cccsdv.org 'Chester, Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.consumercreditiv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.consumercreditiv.org 'Bucks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consumercredittv.org 'Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercrediflv.org 'Barks, Northampton CCCS of Northeastern PA - By Appt. Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.ccesnepa.org 'Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.602.2227 www.cocsnepa.org 'Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna CCCS of Northeastern PA - State College 202 W Hamilton Ave State College, PA 16801 800.922.9537/814.238.3688 www.cocsnepa.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537/570.602.2227 www.cocsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16802 886.511.2227/888.511.2227 www.cccspa.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr, STE 101 Butler, PA 16001 688.511.2227 / 888.511.2227 www.CCrspa.org 'Armstrorg. Beaver, Butler. Clarion. Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St Lower Level Erie, PA 16509 888.511.2227 1888.511.2227 www.cccspe.org 'Crawford, Elk, Erie, McKean, Mercer, Union, Venargo, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227/888.511.2227 www.cocspe.org 'Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 088.511.2227 1888.511.2227 www.cccwa.org 'Dauphin, Juniata, Lebanon, Mifflin. Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 808.511.22271888.511.2227 www.cocspa.org 'Atiegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 068.511.2227 / 888.511.2227 www.oompa.org 'Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thecenter-rwvpa.org 'Crawford, Mercer, Venargo Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.centarinthepark.org 'Philadelphia Chester Community Improvement Project 412 Ave of the States Chester, PA 19013 610.876.8663 Chester, Delaware, Montgomery, Philadelphia Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.cactricounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer * Indicates Counties Serviced Community Action Southwest Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.07881724.852.2893 www.cavwg.org 'Washington Community Action Southwest - Waynesburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788/724.225.9550 www.caswg.org 'Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity Wilkes-Barre 165 Amber Lane Wilkes-Barre, PA 18702 800.822.0359/570.826.0510 www.ceopeopbheipingpeople.org 'Carbon, Columbia, Luzems, Monroe Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pWsWrghfairhousing.org 'Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636/724.437.6050 www.focee.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 'Allegheny Genesis Housing Corporation 208 DeKalb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.gonesisWt*ng.org Bethlehem. PA 18015 'Bucks, Chester, Delaware, 610.691.5620 Montgomery, Philadelphia www.cadv.org 'Berks. Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.congreso.net 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 elconcilio.net 'Philadelphia Credit Counseling Center 832 2nd St Pike Richbom, PA 18954 877.900.4222/215.396.1880 www.cwo-cre k.com 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.ccc-credit.com 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.danetworkhousing.org 'Philadelphia Diversified Community Services Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 www.dcsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.gormantown.org 'Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18 W 9th St Erie, PA 16501 814.459.4581 www.gecac.org 'Ede, McKean, Vanango, Warren Harrisburg Fair Housing Council 2100IN 61hSt Harrisburg, PA 17110 717.238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (RACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 *PNladelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingeAliancoofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907/717.249.0789 www.cchra.com 'Cumberland Housing Development Corporation of Northeasters PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 'Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcinfb.org 'Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Dr Butler, PA 16001 800.433.6327/724.287.6797 www.housingauthodly, .coMHomeownership_Program.hlml 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpartnershipoc.com 'Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465.2657 www.iceep.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ftnc.org 'Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreancenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St; STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP ) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104/724.658.7258 www.hadv.org www.lccap•or9/h•php 'Delaware, Philadelphia 'Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lebanoncountyhousing.com 'Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.ibertyrosources.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship, Inc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 'Cumberland, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.niedWeRowsNphouse.org 'Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.monvalleyinitiative.oom 'Allegheny, Armstrong. Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland Mt. Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mteiryuss.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.mtnazarethcoMer.mWnazareth_housing.html 'AIIegFneny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.nhslackawanrepa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org 'Philadelphia Neighborhood Housing Services Greater Berke 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 www.nhsreading.org 'Barks * Indicates Counties Serviced Neighborworks Western PA Pittsburgh Community Reinvestment Group St. Martin Center, Inc. 710 Fifth Ave; STE 1000 (PCRG) 1701 Parade St Pittsburgh, PA 15219 1901 Centre Avenue; STE 200 Erie, PA 16503 412.281.9773 Pittsburgh, PA 15219 814.452.6113 www.nwwpa.org 412.391.6732 www.stmarfnc~.org *Allegheny, Armstrong, Beaver, Buller, Cambria, www.pcrg.org *Centre, Crawford, Erie, McKean, Fayette, Greene, Washington, Westmoreland *AXegbeny Mercer, Venango, Warren New Kensington Community Schuylkill Community Action Step, Inc. (a.k.a. Lyooming-Clinton Counties Development Corp.(NKCDC) 225 N Center St Commission for Community Action) 2515 Frankford Ave Pottsville, PA 17901 2138 Lincoln St Philadelphia, PA 19125 570.622.1995 Williamsport, PA 17701 215.427.0350 www.sdwylk#kwmrnun4ecfion.corn 800.346.3020 / 570.326.0587 www.nkcclc.org 'Becks, Carbon, Lebanon, Lehigh, Luzeme, www.stepcorp.og *Philadelphia Northumberland, Schuylkill 'Centre, Clinton, Lyooming, Union NID-Housing Counseling-Philadelphis Shenango Valley Urban League Tableland Services Inc./Community 3212 W. Cheltenham Ave 601 Indiana Ave Action Partnership for Somerset Cnty Philadelphia, PA 19150 Farrell, PA 19121 535 E Main St 267.385.7624 724.981.5310 Somerset, PA 15501 *Delaware, Montgomery. Philadelphia www.svul.org 800.452.0148 / 814.445.9628 *Butler, Crawford, Lawrence , Venango www.capfsc.org Northern Cambria Community Development Corp. *Bedford, Cambria, Fayette, (NORCAM Group) South of South Neighborhood Somerset Westmoreland 4200 Crawford Avenue Suite 200 Association, Inc. (SOSNA) Northern Cambria, PA 15714 1901 Christian St TABOR Community Services, Inc. 888.676.8781 / 814.948.4444 Philadelphia, PA 19146 308 E King St 'Bedford, Blair, Cambria, Cameron, Centre, 215.732.8446 Lancaster, PA 17608 Elk, Erie, Huntingdon, Jefferson, Somerset www.sou#wfsouth.org 800.788.5062 / 717.397.5182 *Philadelphia www.tabomet.org Northern Tier Community Action Corp. *Chester, Lancaster, Lebanon 135 West 4th Street South Philadelphia HOMES, Inc. (SPHINC) Emporium, PA 15834 1444 Pant Breeze Ave TREHAB Center, Inc. 814.486.1161 Philadelphia, PA 19146 703 S Elmer Ave; STE 104 *Cameron, Elk, McKean, Potter 800.349.59041215.334.4430 Sayre, PA 18840 www.sphkc.com 800.982.4045 / 570.888.0412 Northwest Counseling Service, Inc. 'Philadelphia www.trahab.org 5001 North Broad Street 'Bredford Southwest Community Development Philadelphia, PA 19141 Corporation TREHAB Center, Inc. 215.324.7500 6328 Paschall Ave 10 Public Ave *Bucks, Chester, Delaware, Philadelphia, PA 19142 Montrose, PA 18801 Montgomery, Philadelphia 215.729.0800 800.982.4045 !570.278.3338 The Partnership CDC www.southwestodc.org www.trehab.org 4020 Market St; STE 100 'Delaware, Philadelphia 'Susquehanna Philadelphia, PA 19104 Southwestern PA Legal Services - TREHAB Center, Inc. - Tioga County 215.662.1612 Fayette County. 52 Plaza Ln www.dwpartnershipcdc.org 'Philadelphia 48 E Main St Wellsboro, PA 16901 Uniontown, PA 15401 866.656.7768 / 570.724.5252 Pathstone Corporation Pennsylvania 888.855.3873 / 724.439.3591 www.trehab.org 1625 North Second St www.spin.org 'Tioga Harrisburg, PA 17102 'Fayette 717.234.6616 Southwestern PA Legal Services - United Communities Southeast Philadelphia www.ruralisc.org/pofhstoriej)a.Mm Greene sanity 2029 S 8th St *Adams, Barks, Cambria, Chester, Clearfield, 63 S Washington St Philadelphia, PA 19148 Cumberland, Dauphin, Franklin, Somerset Waynesburg, PA 15370 215.467.8700 Pennsylvania Interfaith Community Programs, Inc. 888.855.3873 / 724.627.3127 www.ucsep.org Adam's County Housing Authority (ACHA) www.spies.org 'Philadelphia 40 E High St *Greene United Neighborhood Centers of Gettysburg, PA 17325 Southwestern PA Legal Services - Northeastern PA 717.334.1518 Somerset County 410 Olive St www.ademscha.org 132 E. Catherine St Scranton, PA 18505 'Adams, Franklin, Somerset PA 15501 570.343.8835 Cumberland. Lackawanna, York 800,855.3873 / 814.443.4615 *Lackawanna Philadelphia Council for Community www.splas.org 'Somerset Universal Companies - Universal Advancement (PCCA) Community Homes 1617 JFK Blvd; STE 1550 Southwestern PA Legal Services - 800 S 15th St Philadelphia, PA 19103 Washington County Philadelphia, PA 19146 215.567.7803 10 W Cherry Ave 215.732.6518 www.pccahousing.org Washington, PA 15301 'Philadelphia *Bucks, Chester, Delaware, 888.855.3873 / 724.225.6170 Montgomery, Philadelphia www.splas.org Urban League of Philadelphia .Washington 121 S Broad St 9th FL Philadelphia, PA 19107 215.985.3220 www.urbonleaguephile.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.tApgh.org 'Allegherry Voices for Independence 1107 Payne Ave Erie, PA 16503 866.407.0064 / 814.874.0064 www.vowesfodnd"endence.org Clarion, Elk, Erie, McKean, Mercer, Venango Warren-Forest Counties Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797 / 814.726.2400 www.wkw.org *Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 *Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.818.0022/724.834.1260 www.weeVnorelaridco.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 www.woro-pa.com -Philadelphia Natio? n t r- MORTGAGE 4 3 Ryan Ferree 1! 773 Hamilton Ct Carlisle, PA 17013 (Rev. 9/2008) N D.te ? g ?,0 T E ?E RIOOM P N91 O?OySt?RUE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency tollfree at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Ryan Ferree PROPERTY ADDRESS: 95 Green House Road 24 LOAN ACCT. NO.: ORIGINAL LENDER: FINANCIAL LLC CURRENT SERVICER: Nationstar Mortgage LLC CURRENT LENDER: Nationstar Mortgage LLC Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MA Y BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARYSTAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - Ifyou meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORAR YSTA Y OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTL Y PR 0 TECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page Three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 95 Green House Road, Gardners, PA 17324 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 06/01/2010: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 08/04/2010: $4,622.34 $106.98 $20.00 $0.00 $4,74932 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,749.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 IF YOUDO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DA YS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheri 7s Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Page Four HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: Loss Mitigation Department: Website: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 1-888-725-2432 972-966-4755 Cody Nesbitt customer.service@nationstarmail.com 1-888-480-2432 www.nationstarmtg.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAYALSO HAVE THE RIGHT. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. Nationstar Mortgage LLC is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Nationstar Mortgage LLC Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067, 1-888-725-2432 * Indicates Counties Serviced Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.792.2801/412.2812102 www.aclbnhouskV.org •Altegheny. Beaver, Butler. Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blv" Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.afinow.org 'Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.afirww.org 'Chester. Delaware Alliance for Building Communities 830 Hamilton Mall Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armsb,ongmp.com 'Armstrong Asodaci6n Puedomqueflos on Mardis, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphila.orgm 'Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.basoinc.org 'Lancaster Sayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763/814.946.3651 'Blair Berks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.ram.odu/SocialService/b090.aspx 'Barks, Schuylkill, Montgomery Bucks County Housing Group 2324 Second St Pike; STE 17 Wrigtdstown, PA 18940 866.866.0280/215.598.3566 www.bchg.org 'Bucks Building United of Southwestern PA 801 N Homewood Ave; STE 201 Pittsburgh, PA 15208 412.281.4422 'Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport, PA 17701 570.322.5515 www.compballs"Mcenter.org •Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Devebpment Corporation 401 Candlelight Or Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 800.989.2227/215.563.5665 'Bucks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 800.989.2227/215.563.5665 www.cocsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227/215.563.5665 www.cccsdv.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavitlion #401 Jenkintown, PA 19046 800.969.22271215.563.5665 www.ccksdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227/215.563.5665 www.cocsdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227 / 215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Philadelphia 4400 North Reese St Philadelphia, PA 19140 800.989.2227/215.563.5865 www.cocsdv.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227 / 215.563.5665 www.cocsdv.org 'Chester, Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.consumercrechttv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.consumercredidv.org 'Bucks CCCS of Lehigh Valley- Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consumercreditiv.org 'Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercredigv.org 'Berks. Northampton CCCS of Northeastern PA - By Appt. Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.cocsnepa.org 'Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.6022227 www.cecsnepa.org -Bradford, Carton, Centre, Clearfield. Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna CCCS of Northeastern PA - State College 202 W Hamilton Ave State College, PA 16801 800.922.9537 / 814.238.3688 www.cocsnepa.org 'Blair CCCS of Northeastem PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537/570.602.2227 www.cccsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16602 888.511.2227 1888.511.2227 www.omspe.org 'Bedford, Blair, Cambria, Cenb% Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr, STE 101 Butler, PA 16001 888.511.2227 / 888.511.2227 www.cccspe.org 'Armstrong, Beaver, Butler, Clarion, Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227/888.511.2227 www.cccspa.org 'Crawford, Elk, Ede, McKean, Mercer, Union, Vanargo, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227/888.511.2227 www.hxcspa.org 'Ind'iana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227/888.511.2227 www.cocspe.org 'Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 886.511.2227 / 888.511.2227 www.oaxpe.org 'Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227/888.511.2227 www.cccspa.org 'Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Caller St Meadville, PA 16335 814.337.8450 www.ttmicenter-nwpa.org *Crawford, Mercer, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.conterinthepark.org 'Philadelphia Chester Community Improvement Project 412 Ave of the States Chester, PA 19013 610.876.8663 'Chester, Delaware, Montgomery, Philadelphia Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.ractncounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer * Indicates Counties Serviced Community Action Southwest - Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.8522893 www.casn.org 'Washington Community Action Southwest - Waynesburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788/724.225.9550 www.caswg.org 'Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity Wilkes-Barre 165 Amber Lan Wilkes-Barre, PA 18702 800.822.0359 / 570.826.0510 www.ceopeopkchelpingpeopb.org 'Carbon, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, inc. 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.Pifaburghfairhousing.org 'Allegheny Fayette Co. Community Action Agency, inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636 / 724.437.6050 www.fckao.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 'Allegheny Genesis Housing Corporation 206 DeMb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fitth St -.geneskshousnng.org Bethlehem, PA 18015 'Bucks, Chester, Delaware, 610.691.5620 Montgomery. Philadelphia www.hadv.org 'Barks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.oDngreso.net 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 alconcOlo.net -Philadelphia Credit Counseling Center 832 2nd St Pike Ricnboro, PA 18954 877.900.4222/215.396.1880 www.coc-crediLrom 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.ccc-cmdiLcom 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.danetworkhousing.org 'Philadelphia Diversified Community Services Q Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 www.dcsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.garmantDwn.org 'Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18 W 9th St Erie, PA 16501 814.459.4581 www.gw.ac.org 'Erie, McKean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717.238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (HACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingeliencoofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty, 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907/717.249.0789 www.cchra.tbm 'Cumberand Housing Development Corporation of Northeaster PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 *Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcinfb.org 'Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Dr Butler, PA 16001 800.433.6327 / 724287.6797 www.housingautodty .com/Homeownership_Pmgnam.html 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpannershpoc.com 'Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465 . 2657 www.iccap.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ifsino.org 'Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreancenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St: STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104/724.658.7258 www.hadv.org www.IccaP.org/h.phP 'Delaware, Philadelphia 'Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lobanonoDuntyhousing.com 'Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.fibegresouroes.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship, Inc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 'Cumberland, Dauphin, Perry Media Fellowship Hasse, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.medk"bwehiphouse.org 'Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.nonvalWnibaWo.com 'Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indian, Washington, Westmoreland ML Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mteiryuse.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.mtnazarethoenter.org/nazareth_housing.htmi `Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.nhslackawannapa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org `Philadelphia Neighborhood Housing Services Gre ater Barks 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 www.nhsroading.org 'Barks " Indicates Counties Serviced Neighborworks Western PA Pittsburgh Community Reinvestment Group SL Martin Center, Inc. 710 FM Ave; STE 1000 (PCRG) 1701 Parade St Pittsburgh, PA 15219 1901 Centre Avenue; STE 200 Erie, PA 16503 412.281.9773 Pittsburgh, PA 15219 814.452.6113 www.nwwpo.org 412.391.6732 www.stmarfincenter.org 'Allegheny, Armstrong, Beaver, Butler, Cambria, www.porg.org 'Centre. Crawford. Erie, McKean, Fayette, Greene, Washington, Westmoreland 'Allegheny Mercer, Venango, Warren New Kensington Community Schuylkill Community Action Step, Inc. (a.k.a. Lycoming-Clinton Counties Development Corp.(NKCDC) 225 N Center St Commission for Community Action) 2515 Frankford Ave Pottsville, PA 17901 2138 Lincoln St Philadelphia, PA 19125 570.622.1995 Williamsport, PA 17701 215.427.0350 www.sdiuyNdloommunityachon.com 800.346.3020 / 570.326.0587 www.nkcdc.org 'Berks. Carbon, Lebanon, Lehigh, Luzeme, www.stepoofp.org 'Philadelphia Northumberland, Schuylkill 'Centre, Clinton, Lycoming, Union NID-Housing Counseling-Philadelphia Shenango Valley Urban League Tableland Services IncJCommunity 3212 W. Cheltenham Ave 601 Indiana Ave Action Partnership for Somerset Cnty Philadelphia, PA 19150 Farrell, PA 19121 535 E Main St 267.385.7624 724.981.5310 Somerset, PA 15501 'Delaware, Montgomery, Philadelphia www.svul.org 800.452.0148 / 814.445.9628 'Butler, Crawford, Lawrence, Venango www.capfsc.org Northam Cambria Community Development Corp. 'Bedford, Cambria, Fayette, (NORCAM Group) South of South Neighborhood Somerset, Westmoreland 4200 Crawford Avenue Suite 200 Association, Inc. (SOSNA) Northam Cambria, PA 15714 1901 Christian St TABOR Community Services, Inc. 888.676.8781 / 814.948.4444 Philadelphia, PA 19146 308 E King St *Bedford, Blair, Cambria, Cameron, Centre, 215.732.8446 Lancaster, PA 17608 Elk, Erie, Huntingdon, Jefferson, Somerset www.soudxftouth.org 800.788.5062 / 717.397.5182 -Philadelphia www.tabomet.org Northern Tier Community Action Corp. Chester, Lancaster, Lebanon 135 West 4th Street Philadelphia HOMES, Inc. (SPHINC) South Emporium PA 15834 1444 Point Breeze Ave TREHAB Center, Inc. 814.486.1161 Philadelphia, PA 19146 703 S Elmer Ave; STE 104 'Cameron, Elk, McKean, Potter 800.349.5904 / 215.334.4430 Sayre, PA 18840 www.sphinc.oom 800.982.4045 / 570.888.0412 Northwest Counseling Service. Inc. -Philadelphia www.trehab.org 5001 North Broad Street 'Bradford Southwest Community Development Philadelphia, PA 19141 Corporation TREHAB Center, Inc. 215.324.7500 6328 Paschall Ave 10 Public Ave 'Bucks, Chester, Delaware, Philadelphia, PA 19142 Montrose, PA 18801 Montgomery, Philadelphia 215.729.0800 800.982.4045 / 570.278.3336 The Partnership CDC www.sougrmestcdc.org www.trehab.org 4020 Market St; STE 100 'Delaware, Philadelphia 'Susquehanna Philadelphia, PA 19104 Southwestern PA Legal Services - TREHAB Center, Inc. - Toga County 215.662.1612 Fayette County. 52 Plaza Ln www.ftpartnersNpodc.org 48 E Main St Wellsboro, PA 16901 'Philadelphia Uniontown, PA 15401 866.656.7788 / 570.724.5252 Pathstone Corporation Pennsylvania 888.855.3873 / 724.439.3591 www.Vehab.org 1625 North Second St www.splas.org •Tioga Harrisburg, PA 17102 'Fayette United Communities Southeast 717.234.6616 Southwestern PA Legal Services - Philadelphia www.rurelisc.orgtpathstone_pa.htm Greene County 2029 S 8th St 'Adams, Barks, Cambria, Chester, Clearfield, 63 S Washington St Philadelphia, PA 19148 Cumberland, Dauphin, Franklin, Somerset Waynesburg, PA 15370 215.467.8700 Pennsylvania Interfaith Community Programs inc. 888.855.3873 / 724.627.3127 www.ucsep.org , Adam's County Housing Authority (ACHA) www.sples.org 'Philadelphia 40 E High St 'Greene United Neighborhood Centers of Gettysburg, PA 17325 Southwestern PA Legal Services - Northeastern PA 717.334.1518 Somerset County 410 Olive St www.adamscha.org 132 E. Catherine St Scranton, PA 18505 'Adams, Franklin, Somerset, PA 15501 570.343.8835 Cumberland, Lackawanna, York 800,855,3873/814.443.4615 'Lackawanna Philadelphia Council for Community www.splas.org 'Somerset Universal Companies -Universal Advancement (PCCA) Community Homes 1617 JFK Blvd; STE 1550 Southwestern PA Legal Services - 800 S 15th St Philadelphia, PA 19103 Washington County Philadelphia, PA 19146 215.567.7803 10 W Cherry Ave 215.732.6518 www.pccahousing.org Washington, PA 15301 'Philadelphia 'Bucks, Chester, Delaware, 888.855.3873 / 724.225.6170 Montgomery, Philadelphia www.sples.org Urban League of Philadelphia 'Washington 121 S Broad St 9th FL Philadelphia, PA 19107 215.985.3220 www.urbonleaguephila.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'Allegheny Voices for Independence 1107 Payne Ave Erie, PA 16503 866.407.0064/814.874.0064 www.voiceaforindepender)ce.org • Clarion, Elk, Erie, McKean, Mercer, Venango Warren-Forest Counties I Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797/814.726.2400 www.wfcaa.org 'Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 'Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022 / 724.834.1260 www.wesbywWandco.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 www.worGpa.com 'Philadelphia Nation tar- MORTGAGE 11puppilk Leilani Mcbeth 95 Green House Road Gardners, PA 17324 (Rev. 9/2008) TAOMTMIN TICE 1,1,: N AVE ORECLOSURERAugust ' :ono KE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Leilani Mcbeth PROPERTY ADDRESS: 95 Green House Road LOAN ACCT. NO.: ORIGINAL LENDER: HOMECOMING ANCIAL LLC CURRENT SERVICER: Nationstar Mortgage LLC CURRENT LENDER: Nationstar Mortgage LLC Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VE YOUR HOME FROM FORECLOSURE AND HELP YOU MARE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - Ifyou meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE. " YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLYPR0TECTED BY THE FILING OFA PE TITIONINBANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page Three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 95 Green House Road, Gardners, PA 17324 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 06/01/2010: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 08/04/2010: $4,622.34 $106.98 $20.00 $0.00 $4,749.32 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,749.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.lf you cure the default within the THIRTY (30) DA Yperiod, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheri fs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Page Four HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: Loss Mitigation Department: Website: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 1-888-725-2432 972-966-4755 Cody Nesbitt customer.service@nationstarmail.com 1-888-480-2432 www.nationstanntg.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. Nationstar Mortgage LLC is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Nationstar Mortgage LLC Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067, 1-888-725-2432 * Indicates Counties Serviced AcBOn-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.7922801/412.281.2102 www.acbonhousirg.org 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Finenclel Independence - Philadelphia 1628 JFK BMW Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.ofrtow.org -Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.efinow.org *Chester, Delaware Alliance for Building Communities 830 Harmlton Mad Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armsbwgcop.com 'Armstrong Asoaad6n Puertomqueffos on Marche, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphila.ongm *Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.baseinc.org 'Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763/814.948.3651 *Blair Barks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.raoc.edu/SooisiServioe/b090.aspx *Barks, Schuylkill, Montgomery Bucks County Housing Group 2324 Second St Pike; STE 17 Wdghtstown, PA 18940 886.866.0280/215.598.3566 www.bchg.org 'Bkx*s Budding United of Southwestern PA 801 N Homewood Ave; STE 201 Pittsburgh, PA 15208 412.281.4422 *Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport. PA 17701 570.322.5515 www.campbelistrestoonter.org 'Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Development 401 Candlelight Dr Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE Fl Bristol, PA 19007 800.989.22271215.563.5665 •Budks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 900.989.2227/215.563.5665 www.cccsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.22271215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227/215.563.5665 www.cccsdv.org 'Chester. Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavilion #401 Jenkintown, PA 19046 800.989.2227/215.563.5665 www.cccsdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227 / 215.563.5665 www.cccsdv.org *Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227/215.563.5665 www.coesdv.org 'Philadelphia CCCS of Delaware Vary - Philadelphia 4400 North Reese St Philadelphia, PA 19140 800.989.2227/215.563.5665 www.c=sdv.org 'Bucks. Chester, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St STE 190 West Chester, PA 19382 800.9892227/215.563.5665 www.c;cesdv.org 'Chester, Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.corisumercreditlv.org *Chester. Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.corisumercreditiv.org *Bucks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consumercreditfv.org *Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercreditiv.org 'Berks. Northampton CCCS of Northeastern PA - By AppL Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.ecesnepa.org *Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.602.2227 www.cccsriepa.org *Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna CCCS of Northeastern PA - State College 202 W Hamilton Ave Stale College, PA 16801 800.922.9537/814.238.3688 www.cocsnepa.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537/570.602.2227 www.cccsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16602 888.511.2227 / 888.511.2227 W W W.cccspa.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr, STE 101 Butler, PA 16001 888.511.2227/888.5112227 WWW.kxxSpa.org 'Armstrong, Beaver, Butler. Clarion, Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St; Lower Level Erie, PA 16509 886.511.2727 / 888.5112227 WWW.Coow.org *Crawford, Elk, Erie, Md(ean, Mercer, Union, Venango, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227/888.511.2227 www.cccsda.org *Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Llnglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227/888.511.2227 www.cccspv.org *Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 888.511.2227/888.511.2227 WWW.ccospa.org *Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227/888.511.2227 www.cccspv.org *Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thecenter-nwpe.org *Crawford, Mercer, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.conterintheparlk.org *Philadelphia Chester Community Improvement Project 412 Ave of the States Chester, PA 19013 610.876.8663 'Chester, Delaware, Montgomery, Philadelphia Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.eactricounty.org *Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dods St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer * Indicates Counties Serviced Community Action Southwest Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.8622893 www.caswg.org 'Washingon Community Adorn Southwest - Waynesburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788/724.225.9550 www.caswg.org `Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity - Wilkes-Barre 165 Amber Lane Wilkes-Barre, PA 18702 800.822.0359/570.826.0510 www.ceopeoplehelpirgpeople.org *Carbon, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, Inc. 2840 liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pktsburghfairhousing.org `Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636 / 724.437.6050 www.fccaa.org `Fayette, Somerset. Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 .Allegheny Genesis Housing Corporation 208 DeKelb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.gon"shousing.org Bethlehem, PA 18015 `Bucks, Chester, Delaware, 610.691.5620 Montgomery, Philadelphia www.cadv.org 'Barks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.rongreso.nat 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 705.09 N Franklin St Philadelphia, PA 19123 215.627.3100 elconcillo.net `Philadelphia Credit Counseling Center 832 2nd St Pike Richboro, PA 18954 877.900.4222/215.396.1880 www.coocrWk.com *Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 `Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.danetworkhousing.org *Philadelphia Diversified Community Services Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 www.dcsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.garmantown.org `Delaware, Montgomery, Philadelphia Grace Neighbodood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18W9thSt Erie, PA 16501 814.459.4581 www.gecac.org 'Erie, McKean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717.238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (HACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingailiancoofyork.corn 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907/717.249.0789 www.cchre.com 'Cumberland Housing Development Corporation of Northeastern PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 *Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcinfb.org `Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Dr Butler, PA 16001 800.433.6327 / 724.287.6797 www.housingautority .coMHomeownership Pr grom.html `Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpadnomhow.com `Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465 . 2657 www.iceep.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ifsinc.org `Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreancenter.org `Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St; STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104/724.658.7258 www.hadv.org www.ocap.orgt h.php `Delaware, Philadelphia `Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.Mbwvxicoun4ftusing.com `Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155 / 215.634.2000 www.Ubertyresoumes.org 'Burks, Chester, Delaware, Montgomery, Philadelphia Loveship, Inc. 2320 N 5th St Harrisburg. PA 17110 717.232.2207 'Cumbedand, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.medWWtowsNphouse.org `Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.monvalleyinitiefve.com `Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland Mt. Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mteiryusa.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.mtnazarethconter.org/nazareto_housing.htmi `Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.nhslackawannape.org `Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org 'Philadelphia Neighborhood Housing Services Greater Beaks 213 N 5th St; STE 1030 Reading. PA 19601 610.372.8433 www.nhsreading.org 'Becks Neighborworks Western PA 710 Fifth Ave; STE 1000 Pittsburgh, PA 15219 412.281.9773 www.nwwpa.org 'Allegheny. Armstrong, Beaver, Butler. Cambria, Fayette, Greene, Washington, Westmoreland New Kensington Community Development Corp.(NKCDC) 2515 Frankford Ave Philadelphia, PA 19125 215.427.0350 www.nkcdc.org 'Philadelphia NID-Housing Counseling-Philedelphia 3212 W. Cheltenham Ave Philadelphia, PA 19150 267.385.7624 'Delaware, Montgomery, Philadelphia * Indicates Counties Serviced Pittsburgh Community Reinvestment Group SL Martin Center, Inc. (PCRG) 1701 Parade St 1901 Centre Avenue; STE 200 Erie, PA 16503 Pittsburgh, PA 15219 814.452.6113 412.391.6732 www.stmertincenter.org www.pcrg.org 'Centre. Crawford, Erie, McKean, 'Allegheny Mercer, Venango, Warren Schuylkill Community Action Step, Inc. (a.k.a. Lycomirg-Clirdon Counties 225 N Center St Commission for Community Action) Pottsville, PA 17901 2138 Lincoln St 570.622.1995 Williamsport, PA 17701 www.schuylkilkbmmunityacfion.com 800.346.3020 / 570.326.0587 'Berks. Carbon, Lebanon, Lehigh, Luzeme, www.stepcorp.org Northumberland, Schuylkill 'Centre, Clinton, Lycoming, Union Shenango Valley Urban League 601 Indiana Ave Farrell, PA 19121 724.981.5310 www.svul.org 'Butler, Crawford, Lawrence , Venango Northam Cambria Community Development Corp. (NORCAM Group) South of South Neighborhood 4200 Crawford Avenue Suite 200 Association, Inc. (SOSNA) Northam Cambria, PA 15714 1901 Christian St 886.676.8781 / 814.948.4444 Philadelphia, PA 19146 'Bedford, Blair, Cambria, Cameron, Centre, 215.732.8446 Elk, Erie, Huntingdon, Jefferson, Somerset WWW.sou&ofsouth.org 'Philadelphia Northam Tier Community Action Corp. 135 West 4th Street Emporium, PA 15834 814.486.1161 'Cameron, Elk, McKean, Potter Northwest Counseling Service, Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 Bucks, Chester, Delaware, Montgomery, Philadelphia The Partnership CDC 4020 Market St; STE 100 Philadelphia, PA 19104 215.662.1612 www.thapartnershipodc.org 'Philadelphia PaBu;tone Corporation Pennsylvania 1625 North Second St Harrisburg, PA 17102 717 234 6616 South Philadelphia HOMES, Inc. (SPHINC) 1444 Point Breeze Ave Philadelphia, PA 19146 800.349.5904 / 215.334.4430 www.spNnc.com 'Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 www.southwestedc.org 'Delaware, Philadelphia Southwestern PA Legal Services - Fayette County. 48 E Main St Uniontown, PA 15401 888.855.3873/724.439.3591 www.splas.org 'Fayette ' Southwestern PA Legal Services - www.ruralisc.org/pathstoneye.htm Greene County 'Adams, Barks, Cambria, Chester, Clearfield, 63 S Washington St Cumberland, Dauphin, Franklin, Somerset Waynesburg, PA 15370 Pennsylvania Interfaith Community Programs, Inc. 888.855.3873 / 724.627.3127 Adam's County Housing Authority (ACHA) www.splas.org 40 E High St 'Greene Gettysburg, PA 17325 Southwestern PA Legal Services - 717.334.1518 Somerset County www.adamscha.org 132 E. Catherine St 'Adams, Franklin, Somerset, PA 15501 Cumberland. Lackawanna, York 800.855.3873 / 814.443.4615 Philadelphia Council for Community www.splas.org 'Somerset Advancement (PCCA) 1617 JFK Blvd; STE 1550 Phiadelphi% PA 19103 215.567.7803 www.pccahoLWng.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Southwestern PA Legal Services - Washington County 10 W Cherry Ave Washington, PA 15301 888.855.3873 / 724.225.6170 www.splas.org 'Washington Tableland Services IncJCommunity Action Partnership for Somerset Cnty 535 E Main St Somerset, PA 15501 800.452.0148 / 814.445.9628 www.capfsc.org 'Bedford, Cambria, Fayette, Somerset. Westmoreland TABOR Community Services, Inc. 308 E King St Lancaster, PA 17608 800.788.5062/717.397.5182 www.tabomet.org 'Chester, Lancaster, Lebanon TREHAB Center, Inc. 703 S Elmer Ave; STE 104 Sayre, PA 18840 800.982.4045 / 570.888.0412 www.troMb.org 'Bradford TREHAB Center, Inc. 10 Public Ave Montrose, PA 18801 800.982.4045 / 570.278.3338 www.trehab.org 'Susquehanna TREHAB Center, Inc. - Tioga County 52 Plaza Ln Wellsboro, PA 16901 866.656.7788/570.724.5252 www.trehab.org •Tioga United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 www.ucsep.org 'Philadelphia United Neighborhood Centers of Northeastern PA 410 Olive St Scranton, PA 18505 570.343.8835 'Lackawanna Universal Companies - Universal Community Homes 800 S 15th St Philadelphia, PA 19146 215.732.6518 'Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia, PA 19107 215.985.3220 www.urbanleaguepN[a.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'Allegheny Voices for independence 1107 Payne Ave Ede, PA 16503 866.407.0064/814.874.0064 www.vdcesfodndependence.org Clarion, Elk. Erie, McKean, Mercer, Venango Warran-Forest Counties I Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797/814.726.2400 www.wfcoa.org 'Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 'Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022 1724.834.1260 www.wesVweiandes.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 WWW.worC-pa.COm 'Philadelphia Nation tar- MORTGAGE 11pplipli NMI 1 6 4 4 50 Ryan Ferree 95 Green House Road Gardners, PA 17324 (Rev. 9/2008) Date: August 4,2010 T- 9 1 1 E T A 1C - ru- j A I T E YOUR HOME IP.IR I% FOUCT-110SURE This is an oJfuial notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Ryan Ferree PROPERTY ADDRESS: 95 Green House Road LOAN ACCT. NO.: ORIGINAL LENDER: HOM CO FINANCIAL LLC CURRENT SERVICER: Nationstar Mortgage LLC CURRENT LENDER: Nationstar Mortgage LLC Page two HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORAR Y STA Y OF FORECLOSURE. " YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS E VENTUALL Y APPRO VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE. IF YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITIONINBANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page Three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 95 Green House Road, Gardners, PA 17324 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 06/01/2010: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 08/04/2010: $4,622.34 $106.98 $20.00 $0.00 $4,749.32 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,749.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Page Four HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: Loss Mitigation Department: Website: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 1-888-725-2432 972-966-4755 Cody Nesbitt customer.service@nationstarmail.com 1-888-480-2432 www.nationstarmtg.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAYALSO HAVE THE RIGHT. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES 5-7. Nationstar Mortgage LLC is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Nationstar Mortgage LLC Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067, 1-888-725-2432 * Indicates Counties Serviced Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.7922801 / 412.281.2102 www.aebonhousing.org *Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blvd-8 Penn Ctr; STE 2210 Philadelphia, PA 19103 215.218.4342 www.afinow.org 'Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.efirtow.org 'Chester, Delaware Alliance for Building Communities 830 Hamilton Mail Allentown, PA 18101 610.439.7007 `Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armstorgcap.com 'Armstrong Asocisci6n Puedoriqueffos on Marche, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.8070 www.apmphila.ongm *Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.lasainc.org 'Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 `Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.9763 / 814.946.3651 'Blair Barks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.ram.edu/SocialSoMce/b090.aspx 'Berks. Schuylkill, Montgomery Bucks County Housing Group 2324 Second St Pike; STE 17 Wrigldstown, PA 18940 866.866.0280/215.598.3566 www.bchg.org *Bucks Building United of Southwestern PA 801 N Homewood Ave; STE 201 Pittsburgh, PA 15208 412.281.4422 'Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport, PA 17701 570.322.5515 www.compbelistreetcemer.org •Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Development Corporation 401 Candlelight Dr Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 800.989.2227/215.563.5665 `Bucks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 800.98922271215.563.5665 W W W.kxxsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227 / 215.563.5885 www.cccsdv.org -Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.22271215.563.5665 www.cccsdv.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavillion #401 Jenkintown, PA 19046 800.989.2227/215.563.5665 www.cccsdv.org *Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227/215.563.5665 www.cccsdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227/215.563.5665 www.ocsdv.org 'Philadelphia CCCS of Delaware Valley - Philadelphia 4400 North Reece St Philadelphia, PA 19140 800.989.2227/215.563.5665 www.cocsdv.org `Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227/215.563.5865 www.cccsdv.org *Chester, Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.corisumercmditiv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.corisumercreditiv.org *Bucks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.corisumercreditlv.org *Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercreditty.org *Barks, Northampton CCCS of Northeastern PA - By Appt- Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.cccsnepa.org 'Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.602.2227 www.ocesnepa.org *Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna CCCS of Northeastern PA - State College 202 W Hamilton Ave State College, PA 16801 800.922.9537/814.238.3688 www.ecesnope.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA I WW 800.922.9537 / 570.602.2227 www.coesnepa.org *Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona, PA 16602 888.511.2227/888.5112227 www.ooma.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr, STE 101 Butler, PA 16001 888.511.2227/868.511.2227 www.caspa.org 'Armstrong, Beaver, Butler, Clarion, Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227 / 888.511.2227 www.coaspa.org 'Crawford, Elk, Erie, McKean, Mercer, Union, Venango, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227/888.511.2227 www.coospa.org `Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227/888.5112227 www.cocspa.org 'Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 888.511.2227 / 888.511.2227 www.cocspa.org 'Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227/888.511.2227 www.cccsdv.org `Adams, Cumberland, Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thwenter-nwpa.org 'Crawford, Mercer, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.conterinthepark.org 'Philadelphia Chester Community Improvement Project 412 Ave of the States Chester, PA 19013 610.876.8663 `Chester, Delaware, Montgomery, Philadelphia Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.cactricounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer * Indicates Counties Serviced Community Action Southwest Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.852.2893 www.caswg.org 'Washington Community Action Southwest - Wayrresburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788 / 724.225.9550 www.csswg.org 'Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity - Wilkes-Barre 165 Amber Lane Wickes-Barre, PA 18702 800.822.03591570.826.0510 www.osopeopbhelpirgpeople.org 'Carton, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, inc. 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pittsburghfairhmsing.org 'Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.4636 / 724.437.6050 www.fccaa.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 'Allegheny Genesis Housing Corporation 208 DeKalb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.genesWftuaing.org Bethlehem. PA 18015 'Bucks, Chester, Delaware, 610.691.5620 Montgomery, Philadelphia www.krecv.org 'Barks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.congreso.net 'Philadecphis Council of Spanish Speaking Organization (CONCILIO) 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 elconcilb.net 'Philadelphia Credit Counseling Center 832 2nd St Pike Richboro, PA 18954 877.900.4222/215.396.1880 www.coc-crodK.corn 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.ccccredk.com 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.danetworkhDusing.org 'Philadelphia Diversified Community Services Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 www.desphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.germantown.org 'Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18 W 9th St Erie, PA 16501 814.459.4581 www.gocac.org 'Erie, McKean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717.238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (HACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingaflianoeofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St STE 104 Carlisle, PA 17013 866.683.5907/717.249.0789 www.cchre.com 'Cumberland Housing Development Corporation of Northeastern PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 'Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobdnfo.org `Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Dr Butler, PA 18001 800.433.6327 / 724.287.6797 www.housingaut ority .coni/Homeownership_Progrem.html 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpaMershOw.com 'Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465.2657 www.iccap.net 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.ifeinc.org 'Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.6830 www.koreancenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) - Lawrence County Community Action Housing Association Information Program (HAIP) Partnership (LCCAP) 658 N Watts St 241 W Grant St Philadelphia, PA 19123 New Castle, PA 16101 215.978.0224 888.252.5104/724.658.7258 www.hadv.org www.kxop.ongfh.php 'Delaware, Philadelphia 'Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lebanor=untyhousing.com 'Lebanon Liberty Resources, Inc. (Serving Allentown and Philadelphia) 714 Market St STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.libertyresouroes.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship,lnc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 'Cumberland, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 vwvw.mediafellowshiphouse.org *Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.nionvalleyin'ifiative.com 'Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland ML Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mteiryusa.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.nitnazarethcenter.org/nauredi_housing.htrnl 'Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.nhslackawannapa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org 'Philadelphia Neighborhood Housing Services Greater Barks 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 www.nhsreading.org 'Barks Neighborworks Western PA 710 FM Ave; STE 1000 Pittsburgh, PA 15219 412.281.9773 www.nwwpa.org 'Allegheny, Armstrong. Beaver. Buller, Cambria, Fayette, Greene, Washington, Westmoreland New Kensington Community Devebpment Corp.(NKCDC) 2515 Frankfad Ave Philadelphia, PA 19125 215.427.0350 www.nkcclc.org -Philadelphia NID-Housing Counseling-Philadelphia 3212 W. Cheltenham Ave Philadelphia, PA 19150 267.385.7624 *Delaware, Montgomery, Philadelphia * Indicates Counties Serviced Pittsburgh Community Reinvestment Group St. Martin Canter, Inc. (PCRG) 1701 Parade St 1901 Centre Avenue; STE 200 Erie, PA 16503 Pittsburgh, PA 15219 814.452.6113 412.391.6732 www.stmarbricentar.org www.pcrg.org *Centre, Crawford, Erie, McKean, 'Allegheny Mercer, Venango, Warren Schuylkill Community Action Step, Inc. (a.k.a. Lycoming-Clinton Counties 225 N Center St Commission for Community Action) Pottsville, PA 17901 2138 Lincoln St 570.622.1995 Williamsport, PA 17701 www.schuyb ilkbmmunityac ion.com 800.346.3020 / 570.326.0587 *Barks, Carton, Lebanon, Lehigh, Luzeme, www.stepcorp.org Northumberland, Schuylkill *Centre, Clinton, Lycoming, Union Shenengo Valley Urban League 601 Indiana Ave Farrell, PA 19121 724.981.5310 www.sviA.org 'Buller, Crawford, Lawrence, Venango Northern Cambria Community Development Corp. (NORCAM Group) South of South Neighborhood 4200 Crawford Avenue Suite 200 Association, Inc. (SOSNA) Northers Cambria, PA 15714 1901 Christian St 888.676.8781 / 814.948.4444 Philadelphia, PA 19146 'Bedford, Blair, Cambria, Cameron. Centre, 215.732.8446 Elk, Erie, Huntingdon, Jefferson, Somerset www.sou#mfsouth.org 'Philadelphia Northern Tier Community Action Corp. 135 West 4th Street Emporium, PA 15834 814.486.1161 *Cameron, Elk McKean, Potter Northwest Counseling Service, Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia The Partnership CDC 4020 Market St STE 100 Philadelphia, PA 19104 215.662.1612 www.#Wartnershipodc.org `Philadelphia Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg, PA 17102 717 234 6616 South Philadelphia HOMES, Inc. (SPHINC) 1444 Point Breeze Ave Philadelphia, PA 19146 800.349.5904 / 215.334.4430 www.spNnc.com 'Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 www.southwestodc.org 'Delaware, Philadelphia Southwestern PA Legal Services - Fayette County. 48 E Main St Uniontown, PA 15401 888.855.3873/724.439.3591 www.splas.org 'Fayette ' Southwestern PA Legal Services - www.rurelisc.org1pa8rs1oneya.hbm Greene County *Adams, Barks, Cambria, Chester, Clearfield, 63 S Washington St Cumberland, Dauphin, Franklin, Somerset Waynesburg, PA 15370 Pennsylvania Interfaith Community Programs, Inc. 888.855.3873 / 724.627.3127 Adam's County Housing AuOo* (ACHA) www.splas.org 40 E High St 'Greene Gettysburg, PA 17325 Southwesters PA Legal Services - 717.334.1518 Somerset County www.ademscha.org 132 E. Catherine St *Adams, Franklin, Somerset, PA 15501 Cumberland. Lackawanna , York 800,855.3873 / 814.443.4615 Philadelphia Council for Community www.splas.org 'Somerset Advancement(PCCA) 1617 JFK Blvd; STE 1550 Philadelphia, PA 19103 215.567.7803 www.pcoahousing.org *Bucks, Chester, Delaware, Montgomery, Philadelphia Southwestern PA Legal Services - Washington County 10 W Cherry Ave Washington, PA 15301 888.855.3873 1724.225.6170 www.spies.org *Washington Tableland Services IncJCommunity Action Partnership for Somerset Cnty 535 E Main St Somerset PA 15501 800.452.0148/814.445.9628 www.cepfsc.org *Bedford, Cambria, Fayette, Somerset Westmoreland TABOR Community Services, Inc. 308 E King St Lancaster, PA 17608 800.788.5062/717.397.5182 www.tabomet.org 'Chester, Lancaster, Lebanon TREHAB Center, Inc. 703 S Elmer Ave; STE 104 Sayre, PA 18840 800.982.4045 1570.888.0412 www.trehab.org 'Bradford TREHAB Center, Inc. 10 Public Ave Montrose, PA 18801 800.982.4045/570.278.3338 www.trehab.org 'Susquehanna TREHAB Center, Inc. - Toga County 52 Plaza Ln Wellsboro, PA 16901 866.656.7788/570.724.5252 www.trehab.org 'Tooga United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 www.ucsep.org 'Philadelphia United Neighborhood Centers of Northeastern PA 410 Olive St Scranton, PA 18505 570.343.8835 'Lackawanna Universal Companies - Univerml Community Homes 800 S 15th St Philadelphia, PA 19146 215.732.6518 *Philadelphia Urban League of Philadelphia 121 S Broad St; firth FL Philadelphia, PA 19107 215.985.3220 www.urbanleagusphha.org 'Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'allegheny Voices for Independence 1107 Payne Ave Erie, PA 16503 866.407.0064/814.874.0064 www.voices dndepenclence.org * Clarion, Elk, Ede, McKean, Mercer, Venango Warren-Forest Counties I Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797 1814.726.2400 www.wfcaa.org *Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 *Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022/724.834.1260 www.westmorelandco.org 'yyestmorelerd Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.564.5500 www.worc-pa.com 'Philadelphia VERIFICATION 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. DATE: OF THEPRO Ty®NO O TAR `r' 1010 DEC 13 PH 12: 4 CUMBERLAND COUN.Fy PENNSYLVANIA PHELAN HALLINAN & SCHMIEG, LLP By: JOSEPH P. SCHALK, ESQUIRE Identification No. 91656 126 Locust Street Harrisburg, PA 17101 (215) 563-7000 Nationstar Mortgage LLC Plaintiff V. Leilani McBeth Ryan Ferree Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO.. 1049.7T ) b-6v CERTIFICATION OF SERVICE I hereby certify a true and correct copy of Plaintiff s Amended Civil Action Complaint was served by regular and certified mail on the following on the date listed below: Leilani McBeth 773 Hamilton Court Carlisle, PA 17013 DATE: 12,1bolX10 Ryan Ferree 95 Green House Road Garners, PA 17324 n for Plaintiff 4 FILED-OFFICE 0t= THE PROTHONOTAR' 2010 DEC -3 PM 1:09 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP Joseph P. Schak Esquire, ID 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 NATIONSTAR MORTGAGE LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 Plaintiff v. LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 Defendants TERM NO. 10-48TH CUMBERLAND COUNTY C_ I Jr. Ac- _ L A! W AMENDED COMPLAINT IN MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF 250781 F9,? COURT OF COMMON PLEAS CIVIL DIVISION File #: 250781 VERIFICATION 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. DATE: Of - 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 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff vs. LEILANI MCBETH RYAN FERREE Defendants FILED-OFFICE OF THE PROTHONOTARY 2011 J;.` 03 R0r i-;_ c±r'TY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : No. 10-6594 CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE O rT b a? a) 10, IZ* a5 3q'7 I I ._ TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLIW fi SCHMIEG, LLP By: ? Lawrence T. , 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 ZSheetal 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 ? Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff Date: Januar 10, 2011 /jnc, Svc Dept. File# 250781 PHELAN HALLINAN & SCHMIEG ti ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 m r '-'' (215) 563-7000 ATTORNEY FOR PLAINTIFF dry t NATIONSTARMORTGAGE LLC CUMBERLAND COUNT - rc d (=)rn vs. COURT OF COMMON < PLEAS LEILANI MCBETH . RYAN FERREE CIVIL DIVISION No. 10-6594 CIVIL TERM PRAECIPE TO VACATE JUDGMENT WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly vacate the Judgment, which was entered against LEILANI MCBETH, Defendant, in the amount of $158,651.33, Defendant, relative to the instant matter, without prejudice. Date ? Lawrence T. Phel , Esq. . No. 32227 ? Francis S. Hallinan, sq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? ith 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 ? William E. Miller, Esq., Id. No. 308951 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 250781 can, t g) a? tL# Ibk 731q 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 1. 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff CD C-1 ., l Mm F v} rte" - ? n D c c? C Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6594 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: id tc-e Kindly enter judgment in favor of the Plaintiff and against LEILANI MCBETH, and AfiffiE, 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: 'tA 31U. to ?d aN 250781 As set forth in Complaint $153,458.65 Interest - 09/10/2010 to 02/28/2011 $5,192.68 TOTAL $158,651.33 I hereby certify that (1) the Defendants' last known address is 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. , , ^ . Lj Lace . Phelan, q., Id. No. 32227 ? Fr cis S. allinan, E ., Id. No. 62695 ? Daniel G. ><e sq., 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 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 3 - 1 - PHS # 250781 PROTHONOTARY 250781 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6594 CIVIL TERM AFFIDAVIT 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 LEILANI MCBETH is over 18 years of age and last known address is 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. 250781 (c) that defendant RYAN FERREE is over 18 years of age and resides at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. _ February 28, 2011 No. 32227 No. 62695 ? DanVl G. S ie sq., 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 FIChrisovalante 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 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 250781 NATIONSTAR MORTGAGE LLC V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-6594 CIVIL TERM LEILANI MCBETH RYAN FERREE Defendant(s) TO: LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 DATE OF NOTICE: February 15, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DF P IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS' HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE I ) ; PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN ? THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTk(+ ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OII PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER ; APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WIT? z YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST Y01 ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA) AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERT IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y(. HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BF A7;1 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL: TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 250781 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAI':_ ASSOCIATION CUMBERLAND COUNTY COURTH01. 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,Aawrence T. Phelan, Esq., rd. No. 3-2-221 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69841, Judith T. Romano, Esq., Id. No. 58745 She 1 R. Shah-Jani, Esq., Id. No. 81760 taturen me R. Davey, Esq., Id. No. 8707 7 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. 844) 9 Chrisovalante P. Fliakos, Esq., Id. No. 94624, Joshua I. Goldman, Esq., Id. No. 205,04 Courtenay R. Dunn, Esq., Id. No. 2007",, Andrew C. Bramblett, Esq., Id. No. 2OR x Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS 4 250781 NATIONSTAR MORTGAGE LLC V. Plaintiff COURT OF COMMON PLFA' CIVIL DIVISON NO. 10-6594 CIVIL TERM LEILANI MCBETH RYAN FERREE Defendant(s) TO: LEILANI MCBETH 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 DATE OF NOTICE: February 15, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DLi IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE I 1 PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONS]! ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF 9 PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER .` APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WI TI y YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YGL;. . ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA--y AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERI IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y(,' HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY 131- PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL ?1 TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 250781 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: awrence T. Phelan, Esq., Id. No 27 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judi h T. Romano, Esq., Id. No. 58745 Sh tal R. Shah-Jani, Esq., Id. No. 81760 J ine R. Davey, Esq., Id. No. 87077 auren 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 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 250781 NATIONSTAR MORTGAGE LLC V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-6594 CIVIL TERM LEILANI MCBETH RYAN FERREE Defendant(s) TO: RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 DATE OF NOTICE: February 15, 2011 CUMBERLAND COUNTY" THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DIt3 IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNE:a , HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE L PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE I°t ± THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRU 4 ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT Of, I PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WFFI YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOI ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MN AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPER'I IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y' HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 1 CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY B?. .: PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LFGAI, >r f TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 250781 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COUR 1 t Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 1 (717) 249-3166 ,Vat4ence T. Phelan, Esq., Id. N27 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69840.- Judith T. Romano, Esq., Id. No. 58745 Sh tal R. Shah-Jani, Esq., Id. No. 81 7 6,' J nine R. Davey, Esq., Id. No. 87077 auren 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. 9 °?>•' Joshua 1. Goldman, Esq., Id. No. 2051 i" Courtenay R. Dunn, Esq., Id. NO.?OE? ; Andrew C. Bramblett, Esq., Id. No. 208? Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 250781 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE Attorney for Plaintiff rTi : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6594 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES 1q. co ea a"? C1r-i?I OUi, 1316 ,I ?Dfi G'e 250781 TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against LEILANI MCBETH. and RYAN FERREE, Defendant(s) for failure to file an Answer to Plaintiff's Amended 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 $153,458.65 Interest - 09/10/2010 to 03/03/2011 $5,283.25 TOTAL $158,741.90 I hereby certify that (1) the Defendant's last known addresses are 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055, and (2) that notice has been given in accordance with Rule 237.1, copy attached. - ZI-) Lj Lawrence T. Phel , Es ., Id. No. 32227 ? Francis S. Hallinan, sq., 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 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: -?' PHS # 250781 PROTHONOTA Y 250781 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6594 CIVIL TERM AFFIDAVIT 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 LEILANI MCBETH is over 18 years of age and last known addresses are 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and the mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. 250781 (c) that defendant RYAN FERREE is over 18 years of age and resides at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. rte ;-2e?x-- 11 ? Lawrence T. Phelalk.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 ? J ith 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 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 250781 (Rule of Civil Procedure No. 236) - Revised NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6594 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on J " " I ( -. By: If you have any questions concerning this matter please L_j 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 ? Jmdith 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 ? William E. Miller, Esq., Id. No. 308951 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 250781 NATIONSTAR MORTGAGE LLC V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-6594 CIVIL TERM LEILANI MCBETH RYAN FERREE Defendant(s) TO: LEILANI MCBETH 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 DATE OF NOTICE: February 15, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, i : i : '. IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS RI:I `' :1;. HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USI?a1 t ??<. PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN Il,'1^.(!: TINS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUI;I ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF L11i PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A Wk i i' f l :i> APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTI'l f '1 0 i; YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 11''J! + ;i ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY If l ± f : i AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY 0!". l : ±? IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOt I i.)O HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, 'PHIS OFFICE MAY 131-i AMA, 1'(; PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SH61 i0'.' TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, PHS # 250781 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6i95 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTI 1()(),S I 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judi T. Romano, Esq., Id. No. 58745 Sh tai R. Shah-Jani, Esq., Id. No. 81760 J ine R. Davey,-Esq., Id. No. 87077 vi,auren 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 William E. Miller, Esq., Id. No. 308951 Phelan HaIlinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS ti 250781 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS CIVIL DIVISON Plaintiff V. NO. 10-6594 CIVIL TERM LEILANI MCBETH CUMBERLAND COUNTY RYAN FERREE Defendant(s) TO: RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 DATE OF NOTICE: February 15, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DF',111 IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS •<. HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE U '10' 4 PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN THIS CORRESPONDENCE IS NOT AND SHOUI D NOT BE CONSTRUI'I; . ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF i .1l•.i PROPERTY. IMPORTANT NOTICE, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER t'. t APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH '1 o: YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU i , ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY i ? < < < . AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY ?< + IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. )F YOt - 1::C; ..;, HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 'I1; CAN PROVIDE YOU WITH INFORMA'T'ION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY Bl t M t; !I,; PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGA L k \' 1' i TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 250781 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURT140 i ; `; 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 _jG *tini ce T. Phelan, Esq., Id. No 27 Francis S. Hallinan, Esq., Id. o. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judi T. Romano, Esq., Id'. No. 58,745 Sh tal,R. Shah-Jani, Esq., Id. No. 81760 J ` ine R. Davey,Esq., Id. No. 87077 wren 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. 2050=17 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 20837-5 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PI-IS # 250781 NATIONSTAR MORTGAGE LLC COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-6594 CIVIL TERM LEILANI MCBETH CUMBERLAND COUNTY RYAN FERREE Defendant(s) TO: LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 DATE OF NOTICE: February 15, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS i?Ls1 HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE US1 O `ic : i PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN t31\" ' i THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUI.,;Ii ATTEMPT TO COLLECT A DEB'T', BUT ONLY AS ENFORCEMENT OI, 1.it'r PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER i APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITI I '11 YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, (, ACT WITIIIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY f,l AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY f)!/. z)] IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU J )G k HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. "l CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, T141S OFFICE MAY BE, AW 1 1 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL')'F,1?V1.c:! TO ELIGIBLE.., PERSONS AT A REDUCED FEE OR NO FEE. PHS # 250781 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOIJ ;1 2 LIBERTY AVENUE CARLISLE, PA 17013 f (717) 249-3166 Xawrance T. Phelan, Esq., Id. No / 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 Sh l R. Shah-Joni, Esq., Id. No. 81760 , e R. Davey, Esq., Id. No. 87077 AAuren 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. 20837:1 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 250781 ,i 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, Esqq , 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. Fllakos, 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 William E. Miller Esq., Id. No. 308951 Melissa J. Scheiner, Esq. Id. No. 308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC Plaintiff, V. LEILANI MCBETH RYAN FERREE Defendants FILED-OFFICE OF THEE PROTHONOTARY 2011 J!JN 14 IN 15 CUMBERLAND COUNTY s-`ENNSYLVAN1A CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-6594 AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to LEILANI MCBETH & RYAN FERREE on 5/18/2011 in accordance with the Order of Court dated 5/11/2011. The property was posted on 5/19/2011. Publication was advertised IN THE CUMBERLAND LAW JOURNAL on 5/27/2011 & in THE SENTINEL on 5/25/2011. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsificatim to authorities. 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 1. 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 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF Dated: t.. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE Civil Division No. 10-6594-CIVIL TERM ORDER AND NOW, this t day of 2011, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendants, LEILANI MCBETH and RYAN FER.REE, by: 1. Posting of the premises: 95 GREEN HOUSE ROAD, GARDNERS, PA 17324- 9055. 2. First class mail to LEILANI MCBETH and RYAN FERREE at the last known address, 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and the mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055; and 3. Certified mail to LEILANI MCBETH and RYAN FERREE at the last known address, 773 HAMILTON COURT, CARLISLE, PA 17013-1519 and the mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055; and 4. Publication in accordance with PA. R.C.P. 430. BY THE COURT', y J. 250781 Cc: LEILANI MCBETH and RYAN FERREE 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055 773 HAMILTON COURT, CARLISLE, PA 17013-1519 2 I { PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz May 27, 2011 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. /v f ?T Marie Coyne, Vditor SWORN TO AND SUBSCRIBED before me this 27 day of May, 2011 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County, Pennsylvania NO. 10-6594 NATIONSTAR MORTGAGE LLC vs. LEILANI McBETH & RYAN FERREE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: LEILANI McBETH & RYAN FERREE Being Premises: 95 GREEN HOUSE ROAD, GARDNERS, PA 17324. Being in DICKINSON Township, County of CUMBERLAND, Common- wealth of Pennsylvania. TAX PARCEL# 08-16-0210-060. Improvements consist of residen- tial property. Sold as the property of LEILANI McBETH & RYAN FERREE. Your house (real estate) at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324 is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 7, 2011 at 10:00 A.M., at the CUMBER- LAND County Courthouse to enforce the Court Judgment of $158,741.90 obtained by, NATIONSTAR MORT- GAGE LLC (the mortgagee), against the above premises. PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff May 27 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Sale Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL, has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): May 25, 2011 COPY OF NOTICE OF PUBLICATION 'r4,T'e?1/?sa r- Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 Sworn to and subscribed before me this AFFIDAVIT OF SERVICE (FNMA) VLAINTIFF CUMBERLAND COUNTY NATIONSTAR MORTGAGE LLC PHS # 250781 DEFENDANT SERVICE TEAM/ lxh LEILANI MCBETH COURT NO.: 10-6594 CIVIL TERM RYAN FERREE SERVE RYAN FERREE AT: TYPE OF ACTION 95 GREEN HOUSE ROAD XX Notice of Sheriffs Sale GARDNERS, PA 17324-9055 SALE DATE: 09/07/2011 **PLEASE POST PROPERTY PER COURT ORDER** SERVED SGerved. and made known to RYAN FERREE , Defendant on the ITP-day of V/ IT7 20 ?1 , at a : 10, o'clock A. M., at 95 (Seefow46yjig Rn,6*04" in the manner describedbelow: Defendant personally served. Adult family member with whom Defendant(s) reside(s). 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: _ 1-y Descri 'on: Age Height Weight Race Sex Other I, A-c,D ?w a competent adult, hereby verify that 1 personally h?rue 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. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: Q (? NAME: j:?ez _ PRINTED NAME: RoJA-1-0 Md u- TITLE: r g,)cSS Jt;-4 NOT SERVED On the day of , 20_, at _ o'clock _. M., Defendant NOT FOUND because: - Vacant - Does Not Exist - Moved - Does Not Reside (Not Vacant) _ No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF 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 Jenne 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 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY NATIONSTAR MORTGAGE LLC PHS # 250781 DEFENDANT SERVICE TEAM/ lxh LEILANI MCBETH COURT NO.: 10-6594 CIVIL TERM RYAN FERREE SERVE LEILANI MCBETH AT: TYPE OF ACTION 95 GREEN HOUSE ROAD XX Notice of Sheriff's Sale GARDNERS, PA 17324-9055 SALE DATE: 09/07/2011 "PLEASE POST PROPERTY PER COURT ORDER" SERVED Served and made known to LEILANI MCBETH , Defendant on the lq_?ay of M 14 1 20 l 1 , at 10, o'clock&. M., at 9S APft SE QA, C--?DNAA11in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). 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: D5TPP 1>P_6?AA-q Description: Age Height Weight Race Sex Other I, i2b-A1+(.n hbfe, a competent adult, hereby verify that I personally handed a true 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. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. i DATE: _ Q (1 NAME: 1140 PRINTED NAM/E?:' TZONl?-L D / o l L TITLE: r f-W CjS5 EA S NOT SERVED On the __ day of , 20_, at o'clock _. M., Defendant NOT FOUND because: - Vacant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) - No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF 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 William E. Miller, Esq_, Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 a? Z * * * * * * * * * * * * a?? a??c ? aw-C awrM z z ? y b?z rxz rxr ?zZrZr -20 ?z C•" t? a r ° a O c "4 r O O 0-? y y ? -4 ne i 00 o 0 ? ?O a d ?O a d f!i , .] ? ? a ° O my o ? a CD N z CD ° CD P VA, PQst C ? wiaEr ao+nn?> 68° $ 01 . -0 2 IM 11 1 8 20 0004277256 MAY ti MAILED FROM ZIP CODE , 9 7 0 3 0 = r y 'S = C. I I ? O '? o Z bar a? z Wiz C g 0 a K ? A O O 7178 2417 6099 0081 2981 3/SPL RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-0000 --fold here (regular) -- fold here (60) --fold here (regular) 7178 2417 6099 0081 2998 3 / SPL RYAN FERREE 773 HAMILTON COURT CARLISLE, PA 17013-0000 --fold here (regular) -- fold here (60) --fold here (regular) 7178 2417 6099 0081 2967 3 / SPL LEILANI MCBETH 95 GREEN HOUSE ROAD GARDNERS, PA 17324-0000 --fold here (regular) -- fold here (6x9) --fold here (regular) 7178 2417 6099 0081 2974 3 / SPL LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-0000 --fold here (regular) -- fold here (60) --fold here (regular) USPS - Track & Confirm image I o' UNITEDST11TES POSTAL SERVICE;, Home I Help I sign lr, Track & Confirm FAQs Track & Confirm Seareh Results Label/Receipt Number: 7178 2417 6099 0081 2998 - -- - - Class: First-Class Mail® Track & Confirm Service(s): Return Receipt Electronic Enter Label/Receipt Number. Status: Delivered Your item was delivered at 11:16 am on May 26, 2011 in PHILADELPHIA,, PA 19103. Detailed Results: • Delivered, May 26, 2011, 11:16 am, PHILADELPHIA, PA 19103 • Notice Left (No Authorized Recipient Available), May 26, 2011, 8:15 am, PHILADELPHIA, PA 19103 • Arrival at Unit, May 25, 2011, 7:11 am, PHILADELPHIA, PA 19104 • Processed through Sort Facility, May 24, 2011, 11:43 pm, PHILADELPHIA, PA 19176 • Undeliverable as Addressed, May 20, 2011, 9:52 am, CARLISLE, PA 17013 • Processed through Sort Facility, May 19, 2011, 9:55 pm, HARRISBURG, PA 17107 • Electronic Shipping Info Received, May 18, 2011 C .,ti r.Gttt Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Grp > Return Receipt (Electronic) Verify who signed for your item by email. Go> Site Map C sto_.er Se:v ce Fo is Gov't Services: ("aree, P )va y Poky Terms gf Use B s mess Custornw-Gattway Copyright(O 2010 USPS_ All Rights REServed. No FEAR Fact EFO Data FO) A http://trkcnfrm 1. smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do?strOrigTrackNum=71... 6/9/2011 USPS - Track & Confirm Page 1 of 11, i' NffED STATES POST4L. SERV?,:E,; Home I H" I Sign In Track & Confirm FAQs Truck & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0081 2981 Class: First-Class Mailo Service(s): Return Receipt Electronic Status: Unclaimed Your item was returned to the sender on June 09, 2011 because it was not claimed by the addressee. Track & Confirm Enter Label/Receipt Number. Gas > ` Detailed Results: • Unclaimed, June 09, 2011,11:12 am, MOUNT HOLLY SPRINGS, PA • Notice Left, May 23,2011,10-55 am, MOUNT HOLLY SPRINGS, PA 17065 • Notice Left, May 21, 2011, 4:04 pm, MOUNT HOLLY SPRINGS, PA 17065 • Arrival at Unit, May 21, 2011, 7:00 am, CARLISLE, PA 17013 • Processed through Sort Facility, May 20, 2011,11:03 pm, HARRISBURG, PA 17107 • Electronic Shipping Info Received, May 18, 2011 Notification Options Track & Confirm by email .............. Get current event information or updates for your item sent to you or others by email. Go> Site Map Custome'l St,•vica Forfn?, Gov't servi5xt5 Criieers CopynghtO? 2010 LISPS. All Rights Reserved. Pdc FEAR i EEO Data ();A Privacy Policy terms of tJse E# Jsinc?ss CUSWITIet_G_?atevray http://trkcnfrml -smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do?strOrigTrackNum=71... 6/9/2011 USPS - Track & Confirm Page ' of' 0 UNITEDSTATES POSTAL SFRVKE- Home I Help i sign In Track& Confirm FAgs Track Confirm Search Results Label/Receipt Number: 7178 2417 6099 0081 2974 - Class: First-Class Mail" Track & Confirm Service(s): Return Receipt Electronic Enter Label/Receipt Number. Status: Unclaimed Your item was returned to the sender on June 07, 2011 because it was Go > not claimed by the addressee. Detailed Results: • Unclaimed, June 07, 2011,10:26 am, ENOLA, PA • Notice Left, May 21, 2011,10:43 am, ENOLA, PA 17025 • Processed through Sort Facility, May 21, 2011, 3:29 am, HARRISBURG, PA 17107 • Electronic Shipping Info Received, May 18, 2011 Nctific ft on Options Track & Confirm by email ................... Get current event information or updates for your item sent to you or others by email. Gos Site klcap C_ ustomer_S_cxv.-<_e Forms Gott services Careers (?rivary Palicy Terrns of Use Business Customer Gateway Copyrightii`, 2010 LISPS. All Rights Reserved. Na FEAR Act EEO Data FOIA http://trkcnfrm 1. smi.usps.comIPTSIntemet Web/InterLabelInquiry. do?strOrigTrackNum=71... 6/9/2011 LISPS - Track & Confirm Page o` UNI TED 5 rd*r S 1 POSTAL SERVXF-+ Home I Help I Sign In Track & Confirm FAQ, Track & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0081 2967 Class: First-Class Mail® Trick & Confirm Service(s): Return Receipt Electronic Enter Label/Receipt Number. Status: Delivered Your item was delivered at 10:07 am on May 25, 2011 in PHILADELPHIA, Gil } PA 19103. Detailed Results: • Delivered, May 25, 2011, 10:07 am, PHILADELPHIA, PA 19103 • Notice Left (No Authorized Recipient Available), May 24,2011,10:20 am, PHILADELPHIA, PA 19103 • Arrival at Unit, May 21, 2011,12:28 pm, PHILADELPHIA, PA 19104 • Processed through Sort Facility, May 20, 2011, 12:25 am, PHILADELPHIA, PA 19176 • Electronic Shipping Info Received, May 18, 2011 ?a!:_;titis ;r (-:; bons Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go Return Receipt (Electronic) Verify who signed for your item by email. +> Site Map Customer Service Forryis S_ov't Services Gareer_s Gopyright3 Y090 LISPS, All Rights Reserved. No FEAR Act EEO Data FOBA Privacy I'oVi Terns of Use E3usiness C;usto ner_Gateway m http://trkcnfrm 1. smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do?strOrigTrackNum=71... 6/9/2011 4 THE PROTHONOTArk +,. 2011 JUN 29 AM 10: 08 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County LEILANI MCBETH RYAN FERREE No.: 10-6594 CIVIL TERM Defendants PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorneys, Phelan Hallinan & Schmieg, LLP, moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on October 18, 2010. 2. Judgment was entered on March 4, 2011 in the amount of $158,741.90. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit "A". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item 250781 which can be calculated from the complaint, i.e. bringing the interest current. However, new items cannot be added at the time of entry of the judgment. 4. The Property is listed for Sheriffs Sale on September 7, 2011. Additional sums have been incurred or expended on Defendants' behalf since the Complaint was filed and Defendants have been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $146,928.56 Interest Through September 7, 2011 $14,873.94 Per Diem $30.19 Late Charges $695.37 Legal fees $1,300.00 Cost of Suit and Title $1,621.00 Property Inspections/ Property Preservation $174.90 Appraisal/Brokers Price Opinion $125.00 Non Sufficient Funds Charge $20.00 Escrow Deficit $4,590.47 TOTAL $170,329.24 6. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendants. 8. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiff's attached brief. 9. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on June 22, 2011 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit "B". 250781 10. No judge has previously entered a ruling in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan & Schmieg, LLP r? W D ATE: B? Lawrence T. P e an, 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 ? W' ? E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division V. CUMBERLAND County LEILANI MCBETH RYAN FERREE No.: 10-6594 CIVIL TERM Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES 1. BACKGROUND OF CASE LEILANI MCBETH and RYAN FERREE executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. The Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. 250781 In the instant case, Defendants defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendants credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM WDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage Corporation of the Southwest v Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriff s sale. Nationsbanc Mortgage Corp v Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co of N.Y. v Mow]., 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa. Nat. Bank 445 Pa. 117, 282 A.2d 335 (1971), that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect 250781 its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendants as it imputes no personal liability. In B.C.Y. v. Bukovich, the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case, the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendants' failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagors to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagors are also requited to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums, fire insurance premiums, taxes and other assessments relating to the Property. The mortgagor s have breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. 250781 III. THE FORECLOSURE IUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action, the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village- Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer Discount Company v Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff. IV. INTEREST The Mortgage clearly requires that the Defendants shall promptly pay when due the principal and interest due on the outstanding debt. In addition, the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriff s sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the 250781 outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly, the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. VI. ATTORNEY'S FEES The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan Association v. Street Road Shopl?in Center, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner, the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). Recently, the Superior Court cited Fetner in confirming that an attorney's fee of ten percent included in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton Re t , 662 A.2d 1120 (Pa. Super. 1995). Importantly, Plaintiff recognizes this Honorable Court's equitable authority to set attorney's fees and costs as it deems reasonable. VII. COST OF SUIT AND TITLE Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortgage default. 250781 The title report is necessary to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners to be named as Defendants in the foreclosure action. It is also necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens on the property, whether the Defendants are divorced (which could affect service of the complaint), and numerous other legal issues. The title bringdown is necessary to identify any new liens on the property or new owners between the time of filing and complaint and the writ date. The Freedom of Information Act inquiries and the investigation into Defendants' whereabouts are necessary to effectively attempt personal service of the complaint and notice of sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriff's sale date, as their interests will be divested by the Sheriff's sale. Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred. The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, which will not cause harm to the Defendants. VIII. PROPERTY INSPECTIONS AND PRESERVATION The terms of the mortgage provide for property inspections and property preservation charges. The lender or its agent may make reasonable inspections of the property pursuant to the 250781 terms of the mortgage. When a borrower defaults under the terms of the mortgage, the lender may do, or pay for, whatever is reasonable to protect its interest in the collateral, including property maintenance. Any amounts disbursed by the lender for property inspections and preservation become additional debt of the borrower secured by the mortgage. The lender may charge the borrower for services performed in connection with the default, for the purpose of protecting the lender's interest in the property, including property inspections and valuation costs. When a loan is in default, the lender's risk increases. Mortgage companies typically have a vendor visit the premises to determine if any windows need to be boarded up, if the property is vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any problems at the mortgaged premises, then the mortgage company may proceed to take whatever steps are necessary to secure the collateral, such as boarding windows, winterizing, removing hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks, which are referred to in the industry as "property preservation". These services avoid code violations and avoid the property becoming an eyesore in the neighborhood. Property preservation helps maintain property values in the neighborhood. Accordingly, line items included in Motions to Reassess Damages for property inspections and property preservation represent amounts which the mortgage company has paid out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract. Since the terms of the mortgage provide that such expenses by the mortgage company become part of the borrower's debt secured by the mortgage, those expenses are properly included in the Plaintiff's Motion to Reassess Damages. 250781 IV. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage, then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. DATE: By: Q r ?Lawrence =TPhelan, LP 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 1. 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 ? W' liam E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Attorney for Plaintiff 250781 Exhibit "A" 250781 tl 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC VS. LEILANI MCBETH RYAN FERREE Attorney for Plaintiff L"7 G rnC x =v ? cn A ? ?o ?C-) =a a 1411 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-6594 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSwSSMI?N'I' tJI+' UAMA+GES TO THE PROTHONOTARY: Kindly enter judgment in favor of 11?p Plaintiff and against LEILANI MCBETH and RYAN FERREE, 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: C:ti --a rn ? UM C) ?1 --ic (D--n XF 4 M 250781 As set forth in Complaint $153,458.65 Interest - 09/10/2010 to 02/28/2011 $5.192.68 TOTAL $158,651.33 I hereby certify that (1) the Defendants, last known address is 773 HAMILTON COURT, CARLISLE, PA 17013-1519, and mortgaged premises located at 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. t ,.a ce i . t'tyetan, t . q., Id. No. 32227 Fre cis S. allinan, EA., Id. No. 62695 I;1A10 G. S ie sq.,_Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 F-1 Judith T. Romano, Esq., Id. No. 58745 El Sheetal R. Shah-Jani, Esq., Id. No. 81760 Ej Jenine R. Davey, Esq., Id. No. 87077 E] 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 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: !? S `' I I PHS N 250781 250781 Exhibit "B" 250781 PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan & Schmieg, LLP Representing Lenders in Pennsylvania and New Jersey June 22, 2011 LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 RE: NATIONSTAR MORTGAGE LLC v. LEILANI MCBETH and RYAN FERREE Premises Address: 95 GREEN HOUSE ROAD GARDNERS, PA 17324 CUMBERLAND County CCP, No. 10-6594 CIVIL TERM Dear Defendants, Enclosed please find a true and correct copy of my proposed Moion to and Order. In accordance with Cumberland County Local Rule 208.3(9) t I am seeking y Damages concurrence' with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by June 27, 2011. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. V ;Cy truly you Lawrence T. Phelan, Esquire Francis S. Hallman, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire 250781 Jenne R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esquire Joshua L Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire William E. Miller, E uir Melissa J. Scheiner, Esquire Enclosure 250781 °? to A w N p `D oo J rn v, •P N ?,._... t.., rG CD 3 R A . ? O " x a a C ?aw 00 r CL m N Vi G J I ct ati ?? r C r o:R A b3 'C K a a 37 z z ?? ? z n n 'z'J `r1 A7 C ? 00 ? ? Cr1 ? b ? x n ? Cl1 _ y ? o a U J '7 O 0 Cn C n G7 w r a A ti Y z r ? ?= zs o ? °' o C ?d a 3?. °• ^ 0 t il a m Z •R u v o n a d R a vy tD n b p C p 0 3 3 ? 0 ? a3.? v m " n. a ? O _ c o - OQ f m ? a ° I I 0 0 ? `0 c_b n m t s r 3?- r ? _ r ? o ? n ? ? ' I r a ? o Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff V. LEILANI MCBETH RYAN FERREE Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-6594 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individuals on the date indicated below. LEILANI MCBETH RYAN FERREE 773 HAMILTON COURT CARLISLE, PA 17013-1519 DATE: By: LEILANI MCBETH RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 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 250781 ? 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 0 Allison F. Wells, Esq., Id. No. 309519 am E. Miller, Esq., Id. No. 308951 PfAelissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 v_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC Plaintiff V. LEILANI MCBETH RYAN FERREE Defendants Court of Common Pleas Civil Division CUMBERLAND County No.: 10-6594 CIVII. TERM 2 ? RULE AND NOW, this /? day of WA- 2011, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY COURT J. ???? e5 A a, i"d 71'(1" K jee C", 3 - - ate' r v ? cnr- t Qe3 r 250781 I8L0SZ 9906-t,Z£LI Vd `SHHNG'dVD AVON HSfIOH NHHND 96 HH2RIHd NVAN H,LHgDW INYTIR I 6I91-£IOLI Vd `H'ISPI'dVD ,LNf1OD NO,L'IIWVH UL HIREID ^i INVHIH'I 69V£-£99 (SIZ) :XVd OOOL-£99(91Z) :ZHZ £0161 Vd `uzgdlopulnld OOtbl a;ms `piunalnog XJf L191 d"I"I `3aRUgoS V uuuiltuH MINd Z 1680E 'oN 'PI ` bsg `jauiagos • f usstlaW 15680£ 'oN 'PI `•bsg `jaliTY?i 'H wuiIIIM 61960E 'oN 'PI '*bsg `sllaM •,q uosillV 9L£80Z 'oN 'PI '-bsg `iialquuujg •D maipud 6LL90Z 'oN 'PI `'bsg `uunQ •g ,tuuaunoD Lt,OSOZ 'ON 'PI `'?H `ueu?plo? •I ungso f OZ9b6 'oN 'PI '*bsg `soAatLq •d aluulunosugD 6£tt8 'oN 'PI '-bsg `jouAids •-I maipud 16L I9 'oN 'PI `•bsg `XquoInN 'f jolod L9998 'oN 'PI `'bsg `sauof •g ,Cu f I ££ZOZ 'oN 'PI `'bsg `unmsunuS )pAiA L£££6 'oN 'PI "bsg `suqu,L •g uamug LLOLS 'oN 'PI '-bsg `XOAUQ •g autua f 09LI8 'oN 'PI "bsg `ruuf-LIugS '2i IujaagS 9VL89 'oN 'pI '*bsg `ourwog •Z gl!pn f 61869 'oN •pl `•bsg `pjo3Pujg -W olago!W 9OZZ9 'ON 'pI '-bsg `2aRUgoS 'J IaiuuQ 969Z9 'ON 'PI '*bsg `uuugluH 'S stouuj3 LZZZ£ 'oN 'PI `'bsg `uulagd •,L aouajmu-l FILEO-OFFICe 0 TAR rPhelan Hallinan & Schmieg, LLP THE 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff vs. LEILANI MCBETH RYAN FERREE Defendants ?UMERLAND COUNTY PENNSYLVANIA poi t JUL I I AM 9: 2. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-6594 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's June 30, 2011 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. LEILANI MCBETH RYAN FERREE 773 HAMILTON COURT CARLISLE, PA 17013-1519 LEILANI MCBETH RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 250781 DATE: Phelan LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 E7rr-ancis S. Hal man, Id. No. 62695 ? Daniel G. Schmieg, Es Id. No. 62205 ? Michele M. Bradfo , sq., Id. No. 69849 ? Judith T. Rom , Esq., Id. No. 58745 ? Sheetal R. ah-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 ? Courtena R. Dunn, Esq., Id. No. 206779 ew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 F1 . L _ LJ is PROTHONOTA 's 2811 JUL 22 Ate 10: 26 rUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. LEILANI MCBETH RYAN FERREE CUMBERLAND County No.: 10-6594 CIVIL TERM Defendants MOTION TO MAKE RULE ABSOLUTE NATIONSTAR MORTGAGE LLC, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on June 29, 2011. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendants on June 22, 2011 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. 3. A Rule was issued by the Honorable Judge Guido on or about June 30, 2011 directing the Defendants to show cause why the Motion to Reassess Damages should not be 250781 granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 4. The Rule to Show Cause was timely served upon all parties on July 8, 2011 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. Defendants failed to respond or otherwise plead by the Rule Returnable date of July 20, 2011. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff s Motion to Reassess Damages. Ph Hall' an & Schmieg, LLP DATE: v? By: ? La ence . Phelan, Esq., Id. No. 32227 ? rancis 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 Exhibit "A" 250781 PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 PAX#: (215) 563-3459 Phelan Hallinan & Schmieg, LLP June 22, 2011 LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 Representing Lenders in Pennsylvania and New Jersey RE: NATIONSTAR MORTGAGE LLC v. LEILANI MCBETH and RYAN FERREE Premises Address: 95 GREEN HOUSE ROAD GARDNERS, PA 17324 CUMBERLAND County CCP, No. 10-6594 CIVIL TERM Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by June 27, 2011. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Lip,rouce T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esgtzire 250781 Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esquire Joshua X. Goldman, Esquire Courtenay R._ Dunn, Esquire Andrew C. Bramblett, EsquirAllison F. Wells, Esquir7- William E. Miller, Esqui, Melissa J, Scheiner, Esquire Enclosure 250781 0 0 d a. ? .-l m o i /) .fl b W 7 z . ¢?a tu a t a u zit a ri a e: v ? v zoo E cvyr L F- o u ,c C ? - C K ? Ep U W X Q { N W d E o rv u °? vee ,`u h h A ? N S'i F.O E E u E o, E? E ?- s U ? a o ? ? z u ? m ' M ? c a o ? L.1 W "fl ' f3' IX c W W N Cite GL v ? . ,.: z z E ?W a a y t!1 a? w uy o b a ON . z > 4 ha z U N N u` Q c 3 -- - - _. -q - - - ' . ... - - ?l ? _-, __ _J1 r _ Exhibit "B" 250781 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff Civil Division vx CUMBERLAND County LEILANI MCBETH t RYAN FERREE No.: 10-6599 CIVIL TERM Defendants RULE AND NOW, this 30 -v day of 2011, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY COURT ,x 250781 Exhibit "C" 250781 2011 UL I I Aid 9. 26 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff vs. LEILANI MCBETH RYAN FERREE ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-6594 CIVIL TERM Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's June 30, 2011 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. LEILANI MCBETH RYAN FERREE 773 HAMILTON COURT CARLISLE, PA 17013-1519 LEILANI MCBETH RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 250781 DATE: Phelan LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 irancis 5.1-1 hnan, Id. No. 62695 E] Daniel G. Schmieg, Es Id. No. 62205 Michele M. Bradbo sq., Id. No. 69849 ? Judith T. Rom Fsq., Id. No. 58745 ? Sheetal R. all-Jani, Esq., Id. No. 81760 ? Jenine I 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. N4ulcahy, Esq., Id. No. 61791 ? Andlew L. Spivack, Esq., Id. No. 84439 C] Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Coutlenayj& Dunn, Esq., Id. No. 206779 4e' C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE LLC Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. LEILANI MCBETH RYAN FERREE CUMBERLAND County No.: 10-6594 CIVIL TERM Defendants CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute thereof were served upon the following individuals on the date indicated below. LEILANI MCBETH RYAN FERREE 773 HAMILTON COURT CARLISLE, PA 17013-1519 LEILANI MCBETH RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 250781 DATE: 2,1 By: Schmieg, LLP U LaW ence 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 250781 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff Civil Division vs. ._ CUMBERLAND C ?-- r LEILANI MCBETH rr" RYAN FERREE No.: 10-6594 CIVIL4RN4 Defendants' _ ORDERc AND NOW, this day of 2011, upon consideration of Plaintiff's" Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $146,928.56 Interest Through September 7, 2011 $14,873.94 Per Diem $30.19 Late Charges $695.37 Legal fees $1,300.00 Cost of Suit and Title $1,621.00 Property Inspections/ Property Preservation $174.90 Appraisal/Brokers Price Opinion $125.00 Non Sufficient Funds Charge $20.00 Escrow Deficit $4,590.47 TOTAL $170,329.24 Plus interest from September 7, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. Michele, M. Ford, Lei lani Me&o k)an 1=er ree BY T: J. 250781 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE; LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION LEILANI MCBETH RYAN FERREE No.: 10-6594 CIVIL TERl1l[, x Defendant(s) M co ? r z? Q-') r -Or z" co AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 1 x :D I . , - 230 r COMMONWEALTH OF PENNSYLVANIA ) AC:) C) PHILADELPHIA COUNTY ) SS: G m , C) 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/ r Certified Mail Return Receipt stamped by the U.S. Postal Service is att?ted,4re?l?lq F,Wibit "A". 1 Date: H Lawrence`f. Phelan, Esq -I&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 ? Allison F. Wells, Esq., Id. No. 309519 ? Wily E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 Attorney for Plaintiff IMPORTA T 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 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 # 250781 EXHIBIT A - - - - - ---- T T FT - ? o :n p h T N O. N N £ 0 L6 ! 3003 dlZ 021j W v ! ! OZ seam 4371bW 9 o • U _? SZLL?Z`p OZjr,Zo Z0 E a ° p 506 A3Nlld O = rs. ?+t e1sod dy6 ? !l0 2 •? ? ° 5 lJ ?6 ?Zt E ? ? ,c E A c ? As ? o? g'•2 0 r ?016Lda • ._ ?__.. ti o E ' .a KE [uEu =-arc c ? E ? ;? o ' = yUy O b O r ` ¢? ?J A d Q9 C O ,_w N O O V c ADO N m C h A V V ? o cv a.E c > w o Z` w C ;'C w e.3-E ucv 00 &' o E v "4 y A ry ., ; x h x a U d O t L Q f --• w E K, i i O a° a° C? Com va v ? 0 o, C a Y ¢ [ o a C,j C ti °' o C a ?O O a r CU cn o z¢o SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OF FiCF :fir THE P ,1! F OT HONOT RY 1011 AUG 30 AM 8: 35 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor Nationstar Mortgage LLC vs. Leilani McBeth (et al.) Case Number 2010-6594 SHERIFF'S RETURN OF SERVICE 06/21/2011 07:12 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 95 Green House Road, Gardners, PA 17324, Cumberland County. 06/21/2011 09:05 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Leilani McBeth, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 773 Hamilton Court, Carlisle, PA 17013, per previous Landlord, Deft moved in May 2011. 06/27/2011 08:58 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Ryan Ferree at 205 Hill Street, Mt. Holly Springs, PA 17065, Cumberland County. 07/13/2011 08:42 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Leilani McBeth at 402 West Shady Lane, Enola, PA 17025, Cumberland County. 08/26/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $675.80 August 26, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ,s41 X30 dv? 011' (oi CountySuke Sheriff Te'eosoft. Inc. CUMBERLAND LAW JOURNAL Writ No. 2010-6594 Civil Nationstar Mortgage LLC vs. Leilani McBeth Ryan Ferree Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 10-6594 CIVIL TERM, NATION- STAR MORTGAGE LLC vs. LEILANI McBETH, RYAN FERREE, owner(s) of property situate in DICKINSON TOWNSHIP, Cumberland County, Pennsylvania, being 95 GREEN HOUSE ROAD, GARDNERS, PA 17324-9055. Parcel No. 08-16-0210-060. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $158,741- .90. 46 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: July 15, July 22 and July 29, 2011 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. isa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 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 t4tpatriot-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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by tree stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/15/11 07/22/11 07/29/11 . ... Sworn to a su scribed b ore me thi 18,d'ay gust, 2011 A.D. Notary Public -?? COMMONWEALTH OF PENNSYLVANIA Notarial Seal °?"----? Sherrie L. Kisner, Notary Public Lower Paxton Twp., oauphin County my Commisslon Expires Nov. 26, 2011 Member. Pennsvlvanla Association or Notaries Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff PR0T1-10N0TA.rtY NATIONSTAR MORTGAGE LLC Court of Common Pleas Plaintiff pE R PENN Civil Division vs CUMBERLAND County LEILANI MCBETH RYAN FERREE No. 10-6594 CIVIL TERM Defendant 8 AM 10: 02 AND COUNTY YEVANIA PRAECIPE TO THE PROTHONOTARY: Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. X Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Date: PHELAN AN SCHMIEG, LLP PHS# 250781 ?L T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, sq., ,.,o.62695 Daniel G. Schmieg, Esq., Id. o. 62205 Michele M. Bradford, Esq., I . 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. 'Vo. 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 rew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 NATIONSTAR MORTGAGE LLC Plaintiff vs LEILANI MCBETH RYAN FERREE Defendant ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No. 10-6594 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe was served by regular mail to the person(s) on the date listed below: LEILANI MCBETH 773 HAMILTON COURT CARLISLE, PA 17013-1519 RYAN FERREE 95 GREEN HOUSE ROAD GARDNERS, PA 17324-9055 Date: : Lawre e T P elan, Esq., Id. No. 32227 man, Id. No. 62695 Daniel G. Schmieg, Esq.,'Id. No. 62205 Michele M. Bradford, Es ., Id. No. 69849 Judith T. Romano, Esq., d. No. 58745 Sheetal R. Shah-Jani, q., Id. No. 81760 Jenine R. Davey, Es ., 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 1. Goldman, Esq., Id. No. 205047 Courten R. Dunn, Esq., Id. No. 206779 rew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Attorney for Plaintiff