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HomeMy WebLinkAbout11-5412Phelan 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 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 267020 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 Plaintiff V. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 Defendants "I?.P PROTHONOTARYY AM10:37 'UMBERLANQ COUNTY PENNSYLVANIA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Il-?jy?o? CIV11 CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 267020 qg•00 d a µ? alM? s c? J C1C t IOQ s ? 9- 4-- AI(4ts 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 #: 267020 1. Plaintiff is NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 HIGHLAND DRIVE LEWISVILLE, TX 75067 2. The name(s) and last known address(es) of the Defendant(s) are: JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 03/26/2003 JEFFREY T. BARRY and MICHELLE L. HAAS A/K/A MICHELLE L. BARRY made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book No. 1802, Page 3883. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 267020 6. The following amounts are due on the mortgage as of 04/12/2011: Principal Balance $107,199.00 Interest $2,630.54 09/01/2010 through 04/12/2011 Late Charges $196.57 Property Inspections $10.58 Escrow Deficit $220.98 Subtotal $110,257.67 Suspense Credit ($1,561.75) TOTAL $108,695.92 7 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 267020 r WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $108,695.92, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. By: PHELAN HALLINAN ?J Lawrende T. Phelan ., o. 2227 ? =mei s S. Hal ' n, Esq., IdX No 2695 G. Sch mieg, Esq Michele ., I20M. Bradford, Es . o. 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 ? Courte 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 Attorneys for Plaintiff File #: 267020 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Borough of Lemoyne, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described according to Survey of D.P. Raffensperger Registered Surveyor, dated October 28, 1954, as follows: BEGINNING at a point on the northerly side of Lowther Street 105 feet eastwardly of the northeasterly corner of the intersection of Lowther Street and Seventh Street, also at the dividing line between Lots Nos. 19 and 31, Section 'A' on hereinafter mentioned plan of lots, thence North 36 degrees 31 minutes West, along the same and along Lot No. 30, Section'A' on said Plan 105 feet to a point at the dividing line between Lots Nos. 19 and 28, Section'A'; thence North 53 degrees 29 minutes East along the same 60 feet to a point at the dividing line between Lots Nos. 18 and 19, Section'A' on said plan; thence South 36 degrees 31 minutes East, along the same 105 feet to a point on the northerly side of Lowther Street; thence westwardly along the same, 60 feet to a point, the place of beginning. BEING Lot No. 19, Section'A' on Plan of Waldon Terrace, as recorded in Plan Book 4, page 99, Cumberland County records, House No. 631 Lowther Street. HAVING THEREON erected a one story brick and block dwelling house. PROPERTY ADDRESS: 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 PARCEL # 12-22-0822-165 File #: 267020 VERIFICATION hereby states that he/she is of, NATIONSTAR MORTGAGE, LLC, Plaintiff in this matter, that he/she is authorized to make 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: / Servicer: NATIONSTAR MORTGAGE, LLC File #: 267020 Name: BARRY File #: 267020 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F ICED-OFF Ifc CF THE PPOTHODNOT :.r Nationstar Mortgage LLC vs. Jeffrey T. Barry (et al.) 2011 JUL 13 PM 2: D 8 CUMBERLAND COUP'' 'l' PENNSYLVANIA Case Number 2011-5412 SHERIFF'S RETURN OF SERVICE 07/08/2011 08:07 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2011 at 2007 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey T. Barry, by making known unto Stephen Haas, Step Son of Defendant at 631 Lowther Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct cop of the same. AMANDA COBAUGH, DEP 07/08/2011 08:07 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2011 at 2007 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michelle L. Barry, by making known unto Stephen Haas, Son of Defendant at 631 Lowther Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. AMANDA COBAUGH, DER SHERIFF COST: $60.00 July 11, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ',Cj' GoWlf4'SWI 3 `e ;'f i9!ac;SO?t 8,c. i?+ C,?1 1 v 1- PHELAN HALLINAN & SCHMIEG,+ LLP °' 0 ?' i Attorney for Plaintiff Melissa Schemer, Esq., Id. No.308912 I CCT _ J ??? 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza -3 BLAND CQUNT't Philadelphia, PA 19103 ;dNSYLVi" PIA 215-563-7000 NATIONSTAR MORTGAGE, LLC, CUMBERLAND COUNTY F/K/A CENTEX HOME EQUITY COMPANY, LLC VS. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS . COURT OF COMMON PLEAS : CIVIL DIVISION . No. 11-5412-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JEFFREY T. BARRY, and MICHELLE L. BARRY A/K/A MICHELLE L. HAAS, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $108,695.92 $108,695.92 I hereby certify that (1) the Defendants' last known address is 631 LOWTHER STREET, LEMOYNE, PA 17043-2019, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Melissa Schemer, Esquire co} o ly.c6 d a Attorney for Plaintiff ??Iw It 164 S4 DAMAGES ARE HEREBY ASSESSED AS INDICATED. 1 .? ,..? vz.w,? s?a,? lei DATE: ? PHS P 267020 267020 4 . ryy a ,? , 4 ?{ „a PHELAN HALLINAN & SCHMIEG, LLP Melissa Scheiner, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC VS. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : No. 11-5412-CIVIL 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 Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant JEFFREY T. BARRY is over 18 years of age and resides at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019. (c) that defendant MICHELLE L. BARRY A/K/A MICHELLE L. HAAS is over 18 years of age and resides at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Melissa cheiner, Esquire Attorney for Plaintiff 267020 (Rule of Civil Procedure No. 236) - Revised NATIONSTAR MORTGAGE, LLC, F/K/A CUMBERLAND COUNTY CENTEX HOME EQUITY COMPANY, LLC COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY T. BARRY MICHELLE L. BARRY A/K/A No. 11-5412-CIVIL MICHELLE L. HAAS Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: Melissa Scheiner, Esquire Attorney for Plaintiff 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 PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENT OFA LIEN AGAINST PROPERTY. ** NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff v. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) TO: JEFFREY T. BARRY 631 LOWTHER STREET LEMOYNE, PA 17043-2019 DATE OF NOTICE: August 3, 2011 COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-5412-CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IIMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER 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. PHS # 267020 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: R. Dunn, Esq., Id. No.206779 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 267020 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff V. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-5412-CIVIL CUMBERLAND COUNTY TO: MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 DATE OF NOTICE: August 3, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. E"ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER 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. PHS # 267020 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: Courtv%WR. Dunn, Esq., Id. No.206779 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 267020 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOII-5412 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff (s) From JEFFREY T. BARRY AND MICHELLE L. BARRY A/K/A MICHELLE L. HAAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $108,695.92 L.L.: { 56 Interest from 10/04/2011 to Date of Sale ($17.87 per diem) - $2,787.77 Atty's Comm: % Atty Paid: $192.50 Plaintiff Paid: Date: 12/112011 Due Prothy: $2.00 Other Costs: David D. Buell, Prothonotary (Seal) REQUESTING PARTY: By: Name: ANDREW MARLEY, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Deputy Supreme Court ID No. 312314 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 NATIONSTAR MORTGAGE, LLC, FWA CENTEX HOME EQUITY COURT OF COMMON PLEAS COMPANY, LLC Plaintiff CIVIL DIVISION v JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 10/04/2011 to Date of Sale ($17.87 per diem) TOTAL Note: Please attach description of property. PHS # 267020 or) /4{ oo .2.SU - if ij lQ2.sv - '`` 0.Z, "P6 Ca NO.: 11-5412-CIVIL CUMBERLAND COUNTY $108,695.92 $2,787.72 'elan Hallinan & Schmieg, LLP Andrew Marley, Esq., Id. No.312, Attorney for Plaintiff ?? c.t? ?iaz?s? f2? .2?7gc.p P10 cnr' o {w, , ? CD Z c1) ,r.? a d O N d x W Yd,, U ,.a w a ? H O Q Q V ? w O? Oa ? d ifJ 4 Y 4+" j O" C) C) ISO 1? d d a a ? O J G ? y d o? ? d 0 F=] d ?i ?, !sn W as a w? G,W's a v 3 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Borough of Lemoyne, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described according to Survey of D.P. Raffensperger Registered Surveyor, dated October 28, 1954, as follows: BEGINNING at a point on the northerly side of Lowther Street 105 feet eastwardly of the northeasterly corner of the intersection of Lowther Street and Seventh Street, also at the dividing line between Lots Nos. 19 and 31, Section'A' on hereinafter mentioned plan of lots, thence North 36 degrees 31 minutes West, along the same and along Lot No. 30, Section'A' on said Plan 105 feet to a point at the dividing line between Lots Nos. 19 and 28, Section 'A'; thence North 53 degrees 29 minutes East along the same 60 feet to a point at the dividing line between Lots Nos. 18 and 19, Section'A' on said plan; thence South 36 degrees 31 minutes East, along the same 105 feet to a point on the northerly side of Lowther Street; thence westwardly along the same, 60 feet to a point, the place of beginning. BEING Lot No. 19, Section'A' on Plan of Waldon Terrace, as recorded in Plan Book 4, page 99, Cumberland County records, House No. 631 Lowther Street. HAVING THEREON erected a one story brick and block dwelling house. TITLE TO SAID PREMISES IS VESTED IN Jeffrey T. Barry and Michelle L. Hass, by Deed from David G. Kennerly and Kimberly A. Kennerly, dated 10/26/2000, recorded 11/02/2000 in Book 233, Page 165. PREMISES BEING: 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 PARCEL NO. 12-22-0822-165 PHELAN HALLINAN & SCHMIEG, LLP Andrew Marley, Esq., Id. No.312314 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff V. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-5412-CIVIL CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. By: Zylelan Hallinan & Schmieg, LLP Andrew Marley, Esq., Id. No.3123 Attorney for Plaintiff C..j w a?J > 1 :;ru f it CF) Q..1 l 1 z a ( te .2 C) O J -'A 4: NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff V. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-5412-CIVIL CUMBERLAND COUNTY PUS # 267020 AFFIDAVIT PURSUANT TO RULE 3129.1 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019. Name and address of Owner(s) or reputed Owner(s): Name JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) - ? --} 631 LOWTHER STREET M U? ' C: ) ) -_ r LEMOYNE, PA 17043-2019 to t ::u C) c: 631 LOWTHER STREET ma LEMOYNE, PA 17043-2019 . mac? Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND COUNTY ADULT 1 COURTHOUSE SQUARE PROBATION CARLISLE, PA 17013-3387 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE 211 N. FRONT STREET AGENCY HARRISBURG, PA 17101-1406 PENNSYLVANIA HOUSING FINANCE ROBERTA A. SHEAFFER, PHFA/HEMAP AGENCY PO BOX 15530 HARRISBURG, PA 17105-5530 PENNSYLVANIA HOUSING FINANCE 211 NORTH FRONT STREET AGENCY / HOMEOWNER'S EMERGENCY P.O. BOX 15530 MORTGAGE ASSISTANCE PROGRAM HARRISBURG, PA 17105-5530 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) r BOROUGH OF LEMOYNE BOROUGH OF LEMOYNE / LEMOYNE BOROUGH BOROUGH OF LEMOYNE / LEMOYNE BOROUGH BOROUGH OF LEMOYNE / LEMOYNE BOROUGH C/O HOWARD E. DOUGHERTY, CMC LEMOYNE BOROUGH LEMOYNE BOROUGH 665 MARKET STREET LEMOYNE, PA 17043 1200 MARKET STREET LEMOYNE, PA 17043-1417 510 HERMAN AVENUE LEMOYNE, PA 17043-1856 510 HERMAN AVENUE LEMOYNE, PA 17043-1856 20 GLEN RIDGE DRIVE LEMOYNE, PA 17043 20 GLENRIDGE DRIVE LEMOYNE, PA 17043 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE INTERNAL REVENUE SERVICE ADVISORY 631 LOWTHER STREET LEMOYNE, PA 17043-2019 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE DISTRICT 228 WALNUT STREET OF PA HARRISBURG, PA 17108 COMMONWEALTH OF PENNSYLVANIA, BUREAU OF INDIVIDUAL TAX, INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM 6T" FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A § 904 relating to? orn falsification to authorities. Date: ! ( ll By: Phadn Hallinan & Sc'hmieg, LLP Andrew Marley, Esq., Id. No.312314 Attorney for Plaintiff NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME COURT OF COMMON PLEAS EQUITY COMPANY, LLC CIVIL DIVISION Plaintiff NO.:11-5412-CIVIL VS. JEFFREY T. BARRY CUMBERLANDff0t?NTy1 MICHELLE L. BARRY A/K/A MICHELLE L. HAAS - , Defendant(s) m NOTICE OF SHERIFF'S SALE OF REAL PROPERTY 3 M TO: JEFFREY T. BARRY" MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 is scheduled to be sold at the Sheriffs Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $108,695.92 obtained by NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Borough of Lemoyne, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described according to Survey of D.P. Raffensperger Registered Surveyor, dated October 28, 1954, as follows: BEGINNING at a point on the northerly side of Lowther Street 105 feet eastwardly of the northeasterly corner of the intersection of Lowther Street and Seventh Street, also at the dividing line between Lots Nos. 19 and 31, Section 'A' on hereinafter mentioned plan of lots, thence North 36 degrees 31 minutes West, along the same and along Lot No. 30, Section 'A' on said Plan 105 feet to a point at the dividing line between Lots Nos. 19 and 28, Section 'A'; thence North 53 degrees 29 minutes East along the same 60 feet to a point at the dividing line between Lots Nos. 18 and 19, Section'A' on said plan; thence South 36 degrees 31 minutes East, along the same 105 feet to a point on the northerly side of Lowther Street; thence westwardly along the same, 60 feet to a point, the place of beginning. BEING Lot No. 19, Section'A' on Plan of Waldon Terrace, as recorded in Plan Book 4, page 99, Cumberland County records, House No. 631 Lowther Street. HAVING THEREON erected a one story brick and block dwelling house. TITLE TO SAID PREMISES IS VESTED IN Jeffrey T. Barry and Michelle L. Hass, by Deed from David G. Kennerly and Kimberly A. Kennerly, dated 10/26/2000, recorded 11/02/2000 in Book 233, Page 165. PREMISES BEING: 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 PARCEL NO. 12-22-0822-165 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-5412-CIVIL NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC vs. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania, being (Municipality) 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 Parcel No. 12-22-0822-165 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $108,695.92 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC PHS # 267020 DEFENDANT SERVICE TEAM/ Ixh JEFFREY T. BARRY COURT NO.: 11-5412-CIVIL MICHELLE L. BARRY A/K/A MICHELLE L. HAAS TYPE OF ACTION SERVE JEFFREY T. BARRY AT: ' ,.,> r+ C-t ,-I s Sale 631 LOWTHER STREET XX Notice of Sheriff 2012 March 7 SALE DATE G ? - -.4 Z- , : LEMOYNE, PA 17043-2019 r, C'7 't7 rTI SERVED S day of bU 20 , Defendant on the BARRY rved and made known to JEFFREY T S ?- a s =Ct Cs , C+ , . e - o clot . M., at (p3 t (o gA- 50 _,in the manner described below: 0 7rr C>-n r/ Defendant ersonally served. =? Cn r* 1 Adult family member with whom Defendant(s) reside(s). --4 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: Description: AgeSb-SS Height to Weight '196 Race "o Sex l`~ Other 14A-,VL ' I)?. ? , 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 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE:" ?? NAME: PRINTED NAME: TITLE: V &,er,S 50-z-*? 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 Jay B. Jones, Esq., Id. No. 86657 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. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 AFFIDAVITOF SERVICE PLAINTIFF CUMBERLAND COUNTY NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC PHS # 267020 DEFENDANT SERVICE TEAM/ Ixh JEFFREY T. BARRY COURT NO.: 11-5412-CIVIL MICHELLE L. BARRY A/K/A MICHELLE L. HAAS SERVE MICHELLE L. BARRY A/K/A MICHELLE L. HAAS AT: TYPE OF ACTION 631 LOWTHER STREET XX Notice of Sheriff's Sale LEMOYNE, PA 17043-2019 SALE DATE: March 7, 2012 SERVED Served and made known to MICHELLE L. BARRY A/KJA MICHELLE L. HAAS, Defendant on ,20 V, at &~a, d clock ., at (O'M L DwTb4'r-t 4> , in the manner described below: De dant pe sonally served. dult family member with whom Defegt(s) reside(s). Relationship is v5(3?? . '?-'? _ Adult in charge of Defendant's residencewho 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. C') G -- -mss --t F?7Kp t? 1 t't't l~'"' tom"' ? ...- " Z y"C ) the day of e' _ Other: Q Description: Age - !55 Height ?(G Weight ' Jo Race Sex k- Other ?`"1 t2 AAiv D 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. DATE: NAl4-7:7? PRINTED NAME: I £A f "yC> TITLE: '?J).) tGsS !5f k cfL 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 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 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 fm. Ti - PROTHONOTAIA PHELAN HALLINAN & SCHMIE(NWEB 13 AN 9: 4 Attorney for Plaintiff Andrew J. Marley, Esq., Id. No.312314 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX CUMBERLAND COUNTY HOME EQUITY COMPANY, LLC Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JEFFREY T. BARRY No.: 11-5412-CIVIL MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto hi it "A". e arley, E quire Attorney for Plaintiff Date: 4144 Zal - IMPORTAN NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the alaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 267020 VA o ,C X I O V ii 4 F ?y H w W r a z O o O M O ` e C 4 4 S '? b W U V PA 1% 1 >4 >1 W ? d a OW OVJo,V-?W F1 $a r O 4x+ A o"?L'ax ??©OC °Ad vN 7+E., O AODp+ M .., M O ?W? o ?Uw?Oa,W-*cdwd `nMC7 4Ww 1 ?' d r W ?wauF,?-'e cnQp doc?ae -Ina>Vx.? rind o acn.+.7F dw a Z ?p m m in H ?wa? ?a- ?aec??'dwHa0 ap >O > aOHa0 x W?rwa?>HO v'? p0 z4z o 4-0o zo o ?wit ,..pr po O x ?mm x mac o ?p OO GO? O ?C7???Ww? wce? adcya ? ? ova W r^,,a. W C? ?W.7 f?+ ?w.? t:o vi .a U r. 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N M zy - H n. w a d N O O O m NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC, PLAINTIFF V. JEFFREY T. BARRY, MICHELLE. L. BARRY, A/K/A MICHELLE L. HAAS DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-5412 CIVIL ORDER OF COURT AND NOW, this 22ndday of February, 2012, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendants will file an answer on or before March 14, 2012; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will deterriine if further Order or hearing is necessary. t. The Prothonotary is directed to forward said Answer to this Court. By the Court, V Rober_ \,TJ. Cusick, Esqui; Attorney for Plaintiff VJeffre T. Barry ?Micheile L. Barry ? a/k/a 1'.1ichelle L. Haas Defendants bas Jr., J. M. L. Ebert -; , r'n Y^? ? T3 Jf cn r•- -< r.,3 ,- - C-? C5 c:, r Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff vs. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendants CUMBERLAND Cory Mao No.: l l -5412-CIVI9? c -- U) CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's February 22, 2012 Rule rns?_ C') -r wi ?t 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. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 DATE: ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division By: (77, allinan & S eg, LLP Melissa J. Cantwell, Esquire Attorney for Plaintiff 267020 HMO?? l 20 121tilR 19 al 9: j 5 f3UMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff vs. JEFFREY T. BARRY MICHELLE. L. BARRY A/K/A MICHELLE L. HAAS Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 11-5412-CIVIL PRAECIPE TO WITHDRAW MOTION TO REASSESS DAMAGES TO THE PROTHONOTARY: Plaintiff hereby withdraws its Motion to Reassess Damages, filed on February 16, 2012 in the above referenced action. elan allinan & Sch , LLP DATE: 11L By: Melissa J. Cantwell, Esquire Attorney for Plaintiff 267020 i Phelan Hallman & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff vs. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 11-5412-CIVIL CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Withdraw its Motion to Reassess Damages was served upon the following interested parties on the date indicated below. JEFFREY T. BARRY MICHELLE; L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 helan H linan & Sc eg, LLP DATE: By: Melissa J. Cantwell, Esquire Attorney for Plaintiff 267020 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor otWatlratarr'Ir'y r t etV {r=2APP 26 AM 8:L, CUMBERLAND CUU?j,ry PENNSYLVA ,IIA Nationstar Mortgage LLC I Case Number vs. 2011-5412 Jeffrey T. Barry (et al.) SHERIFF'S RETURN OF SERVICE 12/28/2011 08:20 PM - Deputy Gerald Worthington, 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 631 Lowther Street, Lemoyne, Cumberland County, PA 17043. 12/28/2011 08:20 PM - Deputy Gerald Worthington, 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: Jeffrey T. Barry at 631 Lowther Street, Lemoyne Borough, Lemoyne, Cumberland County, PA 17043. 12/28/2011 08:20 PM - Deputy Gerald Worthington, 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 Jeffrey Barry - husband, who accepted as Adult Person in Charge" for Michelle L. Barry at 631 Lowther Street, Lemoyne Borough, Lemoyne, Cumberland County, PA 17043. 02/13/2012 Affidavit of Service to Lienholders Filed in Sheriffs Office 03/19/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 07, 2012 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Marley, on behalf of the Nationstar Mortgage, LLC., f/k/a Centex Home Equity Company, LLC. at 350 Highland Drive, Lewisville, TX 75067. Nationstar Mortgage, LLC., f/k/a Centex Home Equity Company, LLC., being the buyer in this execution, paid to the Sheriff the sum of $795.79. 03/19/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this Writ is returned STAYED. SHERIFF COST: $795.79 SO ANSWERS, March 19, 2012 RON R ANDERSON, SHERIFF W-DD ?? ? DD P? • ? . _s2= GC (Cj •countysuit( shef)fl. Teleo"nOft nc. L-7 Lr. NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff ' % V. JEFFREY T. BARRY MICHELLE L. BARRY Defendant(s) A/K/A MICHELLE L. HAAS COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-5412-CIVIL CUMBERLAND COUNTY PHS # 267020 AFFIDAVIT PURSUANT TO RULE 3129.1 NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019. 1. Name and address of Owner(s) or reputed Owner(s): Name JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 631 LOWTHER STREET LEMOYNE, PA 17043-2019 631 LOWTHER STREET LEMOYNE, PA 17043-2019 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND COUNTY ADULT 1 COURTHOUSE SQUARE PROBATION CARLISLE, PA 17013-3387 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE 211 N. FRONT STREET AGENCY HARRISBURG, PA 17101-1406 PENNSYLVANIA HOUSING FINANCE ROBERTA A. SHEAFFER, PHFA/HEMAP AGENCY PO BOX 15530 HARRISBURG, PA 17105-5530 PENNSYLVANIA HOUSING FINANCE 211 NORTH FRONT STREET AGENCY / HOMEOWNER'S EMERGENCY P.O. BOX 15530 MORTGAGE ASSISTANCE PROGRAM HARRISBURG, PA 17105-5530 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF LEMOYNE BOROUGH OF LEMOYNE / LEMOYNE BOROUGH BOROUGH OF LEMOYNE / LEMOYNE BOROUGH BOROUGH OF LEMOYNE / LEMOYNE BOROUGH C/O HOWARD E. DOUGHERTY, CMC LEMOYNE BOROUGH LEMOYNE BOROUGH 665 MARKET STREET LEMOYNE, PA 17043 1200 MARKET STREET LEMOYNE, PA 17043-1417 510 HERMAN AVENUE LEMOYNE, PA 17043-1856 510 HERMAN AVENUE LEMOYNE, PA 17043-1856 20 GLEN RIDGE DRIVE LEMOYNE, PA 17043 20 GLENRIDGE DRIVE LEMOYNE, PA 17043 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY 631 LOWTHER STREET LEMOYNE, PA 17043-2019 13 NORTH HANOVER STREET CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE INTERNAL REVENUE SERVICE ADVISORY P.O. BOX 2675 HARRISBURG, PA 17105 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE DISTRICT 228 WALNUT STREET OF PA HARRISBURG, PA 17108 COMMONWEALTH OF PENNSYLVANIA, BUREAU OF INDIVIDUAL TAX, INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. A _-n Date:'! l? PhtWn Hallinan & Se'limieg, LLP Andrew Marley, Esq., Id. No.312314 Attorney for Plaintiff By: s NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff VS. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS Defendant(s) : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.:11-5412-CIVIL : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS 631 LOWTHER STREET LEMOYNE, PA 17043-2019 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $108,695.92 obtained by NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX DOME EQUITY COMPANY, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Borough of Lemoyne, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described according to Survey of D.P. Raffensperger Registered Surveyor, dated October 28, 1954, as follows: BEGINNING at a point on the northerly side of Lowther Street 105 feet eastwardly of the northeasterly corner of the intersection of Lowther Street and Seventh Street, also at the dividing line between Lots Nos. 19 and 31, Section 'A' on hereinafter mentioned plan of lots, thence North 36 degrees 31 minutes West, along the same and along Lot No. 30, Section'A' on said Plan 105 feet to a point at the dividing line between Lots Nos. 19 and 28, Section'A'; thence North 53 degrees 29 minutes East along the same 60 feet to a point at the dividing line between Lots Nos. 18 and 19, Section'A' on said plan; thence South 36 degrees 31 minutes East, along the same 105 feet to a point on the northerly side of Lowther Street; thence westwardly along the same, 60 feet to a point, the place of beginning. BEING Lot No. 19, Section'A' on Plan of Waldon Terrace, as recorded in Plan . Book 4, page 99, Cumberland County records, House No. 631 Lowther Street. HAVING THEREON erected a one story brick and block dwelling house. TITLE TO SAID PREMISES IS VESTED IN Jeffrey T. Barry and Michelle L. Hass, by Deed from David G. Kennerly and Kimberly A. Kennerly, dated 10/26/2000, recorded 11/02/2000 in Book 233, Page 165. PREMISES BEING: 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 PARCEL NO. 12-22-0822-165 V SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-5412-CIVIL NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC VS. JEFFREY T. BARRY MICHELLE L. BARRY A/K/A MICHELLE L. HAAS owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania, being (Municipality) 631 LOWTHER STREET. LEMOYNE, PA 17043-2019 Parcel No. 12-22-0822-165 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $108,695.92 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N011-5412 Civil COUNTY OP CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff (s) From JEFFREY T. BARRY AND MICHELLE L. BARRY A/K/A MICHELLE L. HAAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $108,695.92 L.L.: A. C6 Interest from 10/04/2011 to Date of Sale ($17.87 per diem) - $2,787.77 Atty's Comm: % Atty Paid: $192.50 Plaintiff Paid: Date: 12/1/2011 (Seal) REQUESTING PARTY: Name: ANDREW MARLEY, ESQUIRE Due Prothy: $2.00 Other Costs: ZI/ Da d D. Buell, Prothonotary By: Deputy Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 312314 TRUE COPY FROPA RECORD In 7esti.-nony a,?hereof, ! here unto set my hand and the seal of said Court at Carlisle, Pa. This day of 20 It Prothonotary On December 14, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA, Known and numbered as, 631 Lowther Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date December 14, 2011 By: U ?X? Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-5412 Civil Term Nationstar Mortgage LLC VS. Jeffrey T. Barry Michelle L. Barry Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 11-5412-CIVIL NATIONSTAR MORTGAGE, LLC, f/k/a CENTEX HOME EQUITY COMPANY, LLC vs. JEFFREY T. BARRY, MICHELLE L. BARRY a/k/a MICHELLE L. HAAS owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumber- land County, Pennsylvania, being 631 LOWTHER STREET, LEMOYNE, PA 17043-2019. Parcel No. 12-22-0822-165. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $108,- 695.92. 24 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: January 27, February 3, and February 10, 2012 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 isa Marie Coyne, I?ditor SWORN TO AND SUBSCRIBED before me this 0 da of Februar 2012 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 the Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/27112 02/03/12 02/10/12 Sworn to and scribed f me this day of February, 2012 A. D. . Notary Public COMMONWEALTH OF PENNSYLVANIA Shea L. Owens, Nw? PW* County ???cpim Nov. 25 2015 MEMOK PEWASYLvrwu assoan - of IMAM 2011.5412 Chill Term Natlonstar Mortgage LLC vs ?Y T. Barry Michelle L. Barry Atty: Danlel3chmieg BY virtue of a Writ of Execution NO. 11-5412-CIVIL, NA77ONSTAR MORTGAGE, LLC, P/K/A CENTEX HOME EQUITY COMPANY. r t r vs. iMICHELLE JEFFREY T. BARRY L. BARRY AJK/A MICHELLE L. HAAS owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania, being (Municipality) 631 LOWTHER STREET, LEMOYNE, PA 17043-2019 Parcel No. 12-22-0822-165 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT,. $108,695.92 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Nationstar Mortgage LLC f/k/a Centex Home Equity Co LLC is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 1 day of December, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 5412, at the suit of Nationstar Mortgage LLC f/k/a Centex Home Equity Co LLC against Jeffrey T. Barry & Michelle L. Barry a/k/a Michelle L. Haas is duly recorded as Instrument Number 201211996. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this r?,5 day of L , A.D. ? 6 Recorder of Deeds 'ecorder of Deeds. Cw bedtd Cwny, frllsfe, PA ly commission E)#rss the Fret mm* of im 2014