HomeMy WebLinkAbout12-2897
?r YLVAt11A
PHELAN HALLINAN & SCHMIEG, LLP
Robert W. Cusick, Esq., Id. No.80193
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC
350 HIGHLAND DRIVE
LEWISVILLE, TX 75067
Plaintiff
v.
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
Defendant
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. lot - a?
CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File 4: 291577
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2x-71'937
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 #: 291577
Plaintiff is
NATIONSTAR MORTGAGE, LLC
350 HIGHLAND DRIVE
LEWISVILLE, TX 75067
2. The name(s) and last known address(es) of the Defendant(s) are:
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
On 07/08/2008 MARK A. COLLINS and JAMIE COLLINS made, executed and
delivered a mortgage upon the premises hereinafter described to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE
FOR AMTRUST BANK which mortgage is recorded in the Office of the Recorder of
Deeds of CUMBERLAND County, in Mortgage Instrument No. 200824396. The
PLAINTIFF is now the mortgagee and is in the process of formalizing an assignment of
same. Said mortgage was modified as set forth in the modification agreement recorded
11/12/2010, in Mortgage Instrument Number 201033004. 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 11/0 1 /2011 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
File #: 291577
by written notice sent to Mortgagor, the entire principal balance and all interest due
6
thereon are collectible forthwith.
The following amounts are due on the mortgage as of 04/30/2012:
Principal Balance $258,350.86
Interest
10/01/2011 through 04/30/2012 $3,368.31
Property Inspections $18.30
Escrow Deficit $2,543.69
TOTAL $264,281.16
7
9
10
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 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.
The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
Plaintiff hereby releases JAMIE COLLINS A/K/A JAMIE L. COLLINS, from liability
for the debt secured by the mortgage.
File #; 291577
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$264,281.16, 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.
HALLIN)kN & SCHMIEG, UP
By:
Robert'YV:<usick, Esquire
Attorney for Plaintiff
File #: 291577
LEGAL DESCRIPTION
All that certain parcel of land and improvements therein situate in the Township of Eat
Pennsboro, County of Cumberland, and Commonwealth of Pennsylvania, and designated as
Parcel No. 09-11-2006-0028 and more fully described in a Deed dated October 29, 2004 and
recorded November 4, 2004 in Cumberland County in Deed Book 266, Page 445, granted and
conveyed unto Mark A. Collins and Jamie L. Collins, husband and wife.
SUBJECT to the restrictions recorded and as of record in Miscellaneous Book 260, Page 42, in
the office for the recording in and for Cumberland County.
PROPERTY ADDRESS: 721 TRAIL LANE, ENOLA, PA 17025-1323
PARCEL # 09-11-3006-028
C
File #: 291577
VERIFICATION
Megan Ensenberaer, hereby states that he/she is Assistant Secretary 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 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.
Name: Megan Ensenberger
DATE: (-°? _'D:) a-01
a
Title: Assistant Secretary
NATIONSTAR MORTGAGE, LLC
File#: 291577
Name: COLLINS
File #: 291577
FORM 1
NATIONSTAR MORTGAGE, LLC
Plaintiff(s)
VS.
MARK A. COLLINS
Defendant(s)
NOTICE OF RESIDENTIAL
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
7 7
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MORTGAGE FORECLOSE y
DIVERSION PROGRAM . .
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400
extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative, you must promptly meet with that legal representative within
twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your
lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all requested financial information so that a loan resolution
proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
v
Date
FORM 2
Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
State: Zip:
Yes ? No ? Listing date: Price: $
Realtor Phone:
Yes ? No ?
Home:
Cell:
State: Zip:
Office:
Other:
Email:
# of people in household: _ How long?
Mailing Address:
City:
Phone Numbers:
Home:
Cell:
State: Zip:
Email:
# of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number:
Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Office:
Other:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile # 1: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other transportation (automobiles. boats. motorcvcles): Model:
Year: Amount owed: Value
Year:
Year:
Monthly Income
Name of Employers:
I . _ Monthly Gross
2. Monthly Gross
3. Monthly Gross
Additional Income Description (not wages):
I . monthly amount:
2. monthly amount:
Monthly Net
Monthly Net
Monthly Net
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
-Mortgage Food
2" Mortgage Utilities
Car Pa ment(s) Condo/Nei h. Fees
Auto Insurance
Med. not covered _
Auto fuel/re airs
Other prop. payment _
Install. Loan Payment Cable TV
Child Su ort/Alim.
Spending Money _
Da /Child Care/Twit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone:
I/We,
authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to
use the counseling services provided by the above named
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
w . -lie defendant/borrower and counsel for the parties must attend the
Conciliation Conference in person and an authorized representative of the
plaintiff/lender must either attend the Conciliation Conference in person or be
available by telephone during the course of the Conciliation Conference. The
representative of the plaintiff/lender who participates in the Conciliation
Conference must possess the actual authority to reach a mutually acceptable
resolution, and counsel for the plaintiff/lender must discuss resolution
proposals with the authorized representative of the Conciliation Conference. If
the duly authorized representative of the plaintiff/lender is not available by
telephone during the Conciliation Conference, the Court will schedule another
Conciliation Conference and require the personal attendance of the authorized
representative of the plaintiff/lender at the rescheduled Conciliation
Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared
to discuss and explore all available resolution options which shall include:
bringing the mortgage current through a reinstatement; paying off the
mortgage; proposing a forbearance agreement or repayment plan to bring the
account current over time; agreeing to tender a monetary payment and to
vacate in the near future in exchange for not contesting the matter; offering the
lender a deed lieu of foreclosure; entering into a loan modification or a
reverse mortgage; paying the mortgage default over sixty months; and the
institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
g'?4'tr f ;r:3a ri r d
`.'LIMbk.'RLAN i t z?r? i'`3
PE SYINANIA
Nationstar Mortgage LLC I
vs.
Mark A. Collins
Case Number
=2=28x39'
SHERIFF'S RETURN OF SERVICE
05/30/2012 02:35 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on May 30,
2012 at 1435 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of
Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Mark A.
Collins, by making known unto himself personally, at 721 Trail Lane, Enola, Cumberland County,
Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct
copy of the same.
SHERIFF COST: $43.00
June 04, 2012
7e V<'Z---
TIM B CK, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) CcuntySuite Shenff, Teleosoft, Inc.
El ED-OF FII FL
PHELAN HALLINAN & SCHMIEG, LI OF PROTHONOTARY
Lauren R. Tabas, Esq., Id. No.93337 2012 JUL 9 AM 10: 10
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza CUMBERLAND
V?NA
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC
VS.
MARK A. COLLINS
Attorney for Plaintiff
. CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 12-2897-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 MARK A. COLLINS,
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 Plaintiffs damages ;
follows:
As set forth in Complaint
TOTAL
$264,281.16
$264,281.16
I hereby certify that (1) the Defendant's last kn n add ss s 721 TRAIL LANE,
ENOLA, PA 17025-1323, and (2) that notice has bee given ' acc rdance with Rule Pa.R.C
237.1.
Date !
Lauren R. Tabas, Esquire
Attorney for Plaintiff "?\ 7)
DAMAGES ARE HEREBY ASSESSED AS INDICATED. C
DATE: ?
PHS # 291577
cJ
PROTHONOTARY
291:
i77y?`?
PHELAN HALLINAN & SCHMIEG, LLP
Lauren R. Tabas, Esq., Id. No.93337
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC
VS.
MARK A. COLLINS
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 12-2897-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 know
of the following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the Unite
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act
Congress of 1940, as amended.
(b) that defendant MARK A. COLLINS is over 18 years of age and resides at
721 TRAIL LANE, ENOLA, PA 17025-1323.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
Date 1? 1 Z
Uuren R. Tabas, Esquire
Attorney for Plaintiff
291
• i
(Rule of Civil Procedure No. 236) - Revised
NATIONSTAR MORTGAGE, LLC CUMBERLAND COUNTY
VS. COURT OF COMMON PLEAS
MARK A. COLLINS
CIVIL DIVISION
No. 12-2897-CIVIL
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:
Phelan Hallinan & Schmieg, LLP
Lauren R. Tabas, 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
ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKR UPTCY, THIS IS NOT A
SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT
ONLYENFORCEMENT OFA LIENAGAINST PROPERTY**
2911577
1 -
NATIONSTAR MORTGAGE, LLC
V.
MARK A. COLLINS
Plaintiff
Defendant(s)
TO: MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
IN -
+9
DATE OF NOTICE: C I jq 6 r r
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-2897-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.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO 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.
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) 249-31166
By: i
shw od, Esquire
bat t
f
Attorney f urtiff
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
pHS # 291577
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-2897 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE, LLC., Plaintiff (s)
From MARK A. COLLINS
(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: $264,281.16 L.L.: .56
Interest from 7/20/12 To Date of Sale ($43.44 per diem) -- $6,038.16
Atty's,Comm: % Due Prothy: $2.25
Atty Paid: $194.25 Other Costs:
Plaintiff Paid:
Date: 8/31/12
?AA?_\1?? .1 Y
David D. Buell, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: ALLISON F. WELLS, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 309519
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
NATIONSTAR MORTGAGE, LLC
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
v
MARK A. COLLINS
Defendant(s)
NO.: 12-2897-CIVIL
CUMBERLAND COUNTY
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 07/20/2012 to Date of Sale
($413.44 per diem)
TOTAL
$264,281.16
$6,038.1
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Note: Please attach description of property.
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Allison F. Wells, Esq., Id. No.3 519
Attorney for Plaintiff
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PHELAN HALLINAN & SCHMIEG, LLP
Allison F. Wells, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC
Plaintiff
Attorneys for Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
V.
MARK A. COLLINS
Defendant(s)
NO.: 12-2897-CIVIL
: CUMBERLAND COUNTY
CERTIFICATION
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The undersigned attorney hereby states that he/she is the attorney for the Plaintiff e wiv eioned
matter and that the premises are not subject to the provisions of Act 91 because: a
( ) the mortgage is an FHA Mortgage ? za
the premises is non-owner occupied ?: -- _t
the premises is vacant
(;) Act 91 procedures have been fulfilled .? v, x
?°
(X) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943
authorities.
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
? 13y.
n & Schmieg, LLP
Allison F. Wells, Esq., Id. No.309519
Attorney for Plaintiff
NATIONSTAR MORTGAGE, LLC
Plaintiff
Name andl address of Defendant(s) in the judgment:
Name
CIVIL DIVISION
V.
MARK A. COLLINS
Defendant(s)
SAME AS ABOVE
PHS # 291577
AFFIDAVIT PURSUANT TO RULE 3129.1
NATION$TAR MORTGAGE, LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the
Praecipe for the Wr}t of Execution was filed, the following information concerning the real property located at 721 TRAIL LANE,
ENOLA, PA 1702$-1323.
Name andladdress of Owner(s) or reputed Owner(s):
Name
MARK A. COLLINS
2
3
4
5
COURT OF COMMON PLEAS
NO.: 12-2897-CIVIL
CUMBERLAND COUNTY
C")
C ra C. ; 't °,
Address (if address cannot be reasonably
ascertained, please so indicate) M
721 TRAIL LANE, W '
ENOLA, PA 17025-1323
3
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Address (if address cannot be reasonably
ascertained, please so indicate) --t tom "
-t rn
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)
None.
Name and address of last recorded holder of every mortgage of record:
Name Address (if address cannot be
reasonably ascertained, please indicate)
MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DR
MECHANICSBURG, PA 17055-4899
MEMBERS 1ST FEDERAL CREDIT UNION 341 SCIENCE PARK RD
C/O FIDELITY CLOSING SERVICES, LLC STE 203
STATE COLLEGE, PA 16803-2287
MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DR
C/O REAL ESTATE DEPT MECHANICSBURG, PA 17055
Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
to
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)
6.
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)
TENANTIOCCUPANT
JAMIE COLLINS
JAMIE L COLLINS
JAMIE COLLINS C/O JAMES C.
HAGGETY, ESQUIRE
JAMIE COLLINS C/O KEITH ORR
BRENNEMAN, ESQUIRE
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDIVIDUAL TAXES
INHERITANCE TAX DIVISION
721 TRAIL LANE
ENOLA, PA 17025-1323
721 TRAIL LANE
ENOLA, PA 17025
241 N MIDDLESEX RD
CARLISLE, PA 17013
50 S 16TH ST 28TH FLOOR
PHILADELPHIA, PA 19102
44 W MAIN ST
MECHANICSBURG, PA 17055-6249
6TH FLOOR, STRAWBERRY SQ.
DEPT 280601
HARRISBURG, PA 17128
DEPAR' MENT OF PUBLIC WELFARE, TPL P.O. BOX 8486
CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING
PROGRAM HARRISBURG, PA 17105
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE, PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675
DEPARTMENT OF WELFARE HARRISBURG, PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH, PA 15222
U.S. DEPARTMENT OF JUSTICE
U.S. AT ORNEY FOR THE MIDDLE
DISTRICT OF PA
FEDERAL BUILDING
228 WALNUT STREET, SUITE 220
PO BOX 11754
HARRISBURG, PA 17108-1754
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.
Date: 4Af?-/ By
Phelan Hallina Schmieg, LLP
Allison F. Wells, Esq., Id. No.309519
Attorney for Plaintiff
NATIONSTAR MORTGAGE, LLC
: COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
VS.
MARK A. COLLINS
: NO.: 12-2897-CIVIL
Defendant(s)
I COUNTY
29 -1
r*r?u a.
=
NOTICE OF SHERIFF'S SALE OF REAL PROPERT
`
TO: MARK A. COLLINS
721 TRAIL LANE m ® *?- C?-T
ENOLAI, PA 17025-1323
m 7 l
°
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INF6RIiRTIa OBTAINED
WILL BE USE FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN B
O ANKRUPTCY
,
THIS IS N
T 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 721 TRAIL LANE, ENOLA, PA 17025-1323 is scheduled to be sold at the
Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street,
Carlisle, PA 17t 13 to enforce the court judgment of $264,281.16 obtained by NATIONSTAR MORTGAGE,
LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale
in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You ma}' 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.)
YO
ABLE
TAKE
OTHER
1. If the Sheriffs 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 schdule will state who will be receiving that money. The money will be paid out in accordance
with this sched le 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 ORCANNOT 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 tract or parcel of land and premises, situate, lying and being in the Township of East
Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows:
BEGINNING at a point in the center line of a 50 feet wide private right-of-way at line of lands of Merle L.
Chronister as shown on a final Subdivision Plan for Arthur R. Zimmerli recorded in Plan Book 39, Page 14;
thence by' aforementioned line of lands North 44 degrees 17 minutes 49 seconds West 255.84 feet to a point
on line of lands of N/F Appalachian Trail Ranch, Inc.; thence by aforementioned line of lands North 59
degrees 1 ? minutes 00 seconds East 822.54 feet to a point; thence South 26 degrees 30 minutes 00 seconds
East 27.3 feet to the centerline of a 50 feet private right-of-way; thence by aforementioned centerline South
39 degrees 41 minutes 47 seconds West 186.68 feet to a point; thence by same by a curve to the right having
a radius of 400.00 feet an arc length of 110.03 feet to a point; thence by same South 55 degrees 27 minutes 26
seconds West 295.36 feet to a point; thence by same by a curve to the left having a radius of 150.00 feet an
arc length of 96.97 feet to a point; thence by same South 18 degrees 24 minutes 56 seconds West 124.74 feet
to a point) being the place of BEGINNING.
BEING Lot # 15 on a final subdivision plan for Arthur R. Zimmerli recorded in Plan Book 39, Page 14,
Decembe'F 5, 1980.
CONTAINING 2,225 acres including 0.469 acre, for a 50 feet private right-of-way.
SUBJECT to the restrictions recorded and as of record in Miscellaneous Book 260, Page 42, in the office for
the recording in and for Cumberland County.
TITLE O SAID PREMISES VESTED IN Mark A. Collins, single man, by Deed from Jamie L.
Shirey, f rmerly, Jamie L. Collins and Mark A. Collins, single man, dated 11/28/2011, recorded
11/30/2011 in Instrument Number 201133243.
PREMISES BEING: 721 TRAIL LANE, ENOLA, PA 17025-1323
PARCEL; NO. 09-11-3006-028
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 12-2897-CIVIL
NATIONSTAR MORTGAGE, LLC
vs.
MARK A. COLLINS
owner(s) of property situate in the EAST PENNSBORO TOWNSHIP, Cumberland
County, (Pennsylvania, being
(Municipality)
721 T L LANE ENOLA PA 17025-1323
Parcel o.09-11-3006-028
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMIENT AMOUNT: $264,281.16
Phelan Hhllinan & Schmieg, LLP
Attorney for Plaintiff
1617 JFKIBoulevard, Suite 1400
Philadelphia, PA 19103
215-563-'000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
NATIONSTAR MORTGI'1GE. LLC Court of Conlinon Pleas
Plaintiff
Civil Division
~.
CUMBERLAND County
MARK A. COLLINS
Defendant
No.: 12-2897-CIVIL
RULE
AND NOW. this~~~_ clay of l~~'c c~~==~= 2012, a Rule is entered upon the Defendant
to shoe- cause ~~ by an Order should not he entered granting Plaintiffs Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response to
Plaintiffs 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 THE COURT
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;Alison F. Fells, Esq.. Id. No.309519
Phelan Nallinan & Sclunieg, LLP
1617 JFK F3oulevard, Suite 100
Philadelphia, PA 19103
~fEL: (215) X63-7000
I~AX: (215) 563-3459
MARK A. COLLIIyS
721 TRAIL LAN>/
I:NOLA. PA 170?-I >2
29177
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PHELAN HALLINAN & SCHMIEG, LLP
by: Allison F. Wells, Esquire, Atty. LD. No. 309519
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(2151563-7000
NATIONSTAR MORTGAGE, LLC
Plaintiff
v.
MARK A. COLLINS
Defendant
ATTORNEY FOR PLAINT[FF
Court of Common fleas
Civil ]Division
Cumberland County
No.: 12-2897-CIVIL:
PRAECIPE TO SUBSTITUTE EXHIBIT
To the Prothonotary:
Please attach the following Concurrence letter and Certificate of Mailing as Exhibit "B"
to Plaintiff s Motion t:o Reassess Damages which was filed with the court on or aboi.rt October
12, 2012.
DATE:: ~/L--~
Phelan Hallinan & Schmie , LL ,_._
_ _~ ~~.--
- ' /'
Allison F. Wells, Esquire
Attorney for Plaintiff
EXHIBIT "B"
PHEI~AN HALLINAN & S~CHMIEG, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215)563-7000
FAX#: (215) 563-3459
Phelan Hallman & Schmieg, LLP Representing Lenders in
Pennsylvania and New Jersey
October 2, 2012
MARK A. COLLINS
721 "T"RAIL LANE
ENOLA, PA 17025-1323
IZE: NATIONSTAR MORTGAGE, LLC v. MARK A. COLLINS
Premises Address: 721 TRAIL LANE ENOL,A, PA, 17025
Ci ~MBERI_,AND County CCP, No. 12-2897-CIVIL,
Dear Defendant,
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 zne within 5 days, by 10/09/2012.
Should you have further questions or concerns, please. do not hesitate to contact zne,
Otherwise, please be guided accordingly.
Ver,~ truly yours, --°`"~~
Alli:~~:nr~f'~~t~tl~~"ld. No.309519
Attorney fczr Plaintiff
Enclosure
291577
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By: Allison F. Wells, Esq., Id. No. 309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-Sf3-7000
NATIONS"I'AR MORTGAGE, LLC
Plaintiff
v.
MARK A. COLLIN'S
Defendant
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil ]Division
Cumberland Countw
No.: 12-2897-CIVIL
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of Plaintiff s Praecipe to Substitute Exhibit
was sent to the following individuals on the date indicated below.
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
DATE. ~~
_ ,y~__,~
Phelan Hallinarl ~y"ieg, LLP
r~
----"_°'"~ ~_i
Allison F'. Wells, Esq., Id. No. 3095 I9
ATTORNEY FOR PLAINTIFF
Phelan Hallinan & Sehmieg, LLP
Alison F. Wells, Esq., Id. No.309519
1617 :IFK: Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
21:~-~63-7000
NATIONSTAR MORTGAGE, LLC
Plaintiff
vs.
MARK A.. COLLINS
Coui•1: of Common Pleas
Civil Division
CUMBERLAND County
No.: a 2-2897-CIV1I:
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's October 17, 2012 Rule
directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should
not be granted was served upon the fallowing individual on the date indicated belorh~.
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
DATE: ~
Phelan Hallinan-&" ~ mieg, LLP
--- - `°
-~- ---
Alliso .ells, Esq., Id. No.309519
Att rney for Plaintiff
2.91577
-~ [;s;,- ~ i t;
Phelan Hallinan & Schmieg, LLP I ' ~ ~~ H~~~~~~~~~~
Melissa J. Cantwell, Esq., Id. No.308912 r'~ ~ ~ ~Q~' ~- ~ M~'~BRNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ~~ i~ { ~~~ ~~~ ~~~~~
Philadelphia, PA 19103 ~``~~~~~'~'~~~~~
215-563-7000
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
vs.
MARK A. COLLINS
Defendant
Civil Division
CUMBERLAND County
No.: 12-2897-CIVIL
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 October 12, 2012.
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 Defendant on October 2, 2012 and
requested the Defendant's Concurrence. Plaintiff did not receive any response from the
Defendant. 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 Christylee L. Peck on or about October 17,
2012 directing the Defendant to show cause by November 6, 2012 why the Motion to Reassess
Damages should not be 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 October 31, 2012
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".
5. Defendant failed to respond or otherwise plead by the Rule Returnable date of
November 6, 2012.
291577
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiffl s Motion to Reassess Damages.
Q Phelan Hallinan & Schmieg, LLP
DATE: ~ Q ~ gy;
' sa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
291577
Exhibit "A"
291577
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
October 2, 2012
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
Representing Lenders in
Pennsylvania and New Jersey
RE: NATIONSTAR MORTGAGE, LLC v. MARK A. COLLINS
Premises Address: 721 TRAIL LANE ENOLA, PA 17025
CUMBERLAND County CCP, No. 12-2897-CIVIL
Dear Defendant,
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 10/0912012.
Should you have further questions or concerns, please do not hesitate to contact me.
Otherwise, please be guided accordingly.
Very truly yours, °r,...-=~~~~'J~~~ J
AIliso ., ld. 0.309519
Attorney for Plaintiff
Enclosure
291577
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Exhibit "B"
291577
5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
Civil Division
`-. ,
CUMBERLAND County
MARK A. COLLINS
No.:12-2897-CIVIL
Defendant
RULE
AND NOW, this~~c~._~ day of ~` ,:~ 2012, a Rule is entered upon the Defendant
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response 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 THE COURT
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Exhibit "C"
291577
Phelan Hallinan & Schmieg, LLP
Allison F. Wells, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
ATTORNEY FOR PLAINTIFF
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
MARK A. COLLINS
No.:12-2897-CIVIL
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's October 17, 2012 Rule
directing the Defendant to show cause as to why Plaintiff s Motion to Reassess Damages should
not be granted was served upon the following individual on the date indicated below.
MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
DATE:..
Phelan T-l~~ilrtaFt=J, ~ tnit:g, LLP
;ells, Esq., rd. No.309519
for Plaintiff
291577
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
Plaintiff
vs.
MARK A. COLLINS
Defendant
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 12-2897-CIVIL
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of Plaintiff s Motion to Make Rule Absolute
was served upon the following individual on the date indicated below.
MARK A. COLLiNS
721 TRAIL LANE
ENOLA, PA 17025-1323
(~ Phelan allinan & ieg, LLP
DATE: ~~ ~ ~ g ;
elissa J. Cantwell, sq., Id. No.308912
Attorney for Plaintiff
291577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC
Plaintiff
vs.
MARK A. COLLINS
Defendant
ORDER
CIVIL DIVISION
N0.12-2897-CIVIL
.AND NOW, this day of~Gr7.~~'M-~.~ , 2012, after
consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of
Court, it is hereby:
ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is
permitted on Defendant MARK A. COLLINS by:
/ REGULAR MAIL TO MARK A. COLLINS at 721 TRAIL
LANE, ENOLA, PA 17025-1323
/
/ Service by mail is complete upon the date of mailing
/ CERTIFIED MAIL TO MARK A. COLLINS at 721 TRAIL
LANE, ENOLA, PA 17025.-1323
Service by mail is complete upon the date of mailing
POSTING 721 TRAIL LANE, ENOLA, PA 17025-1323
I
N ACCORDANCE WITH
N WHICH SHALL BE
PUBLICATIO
PA.R.C.P. 3129.2 (D).
BY THE COURT:
J.
PHS # 291 S77
/ CC PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
MARK A. COLLINS
721 TRAIL LANE, ENOLA, PA 17025-1323
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Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
iuii ~tde';1 I t"~ ~;~ C?' '
Attorney for Plainttff } tl ~'f' '~ ti `'
~.
~~~`w~'t'L4'~~€IA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC
Plaintiff,
v.
MARK A. COLLINS
Defendant(s)
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DNISION
No.: 12-2897-CIVIL
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 at ed hereto Exhibit "A".
J. Cantwell, Esquire
N~U 1 ~ 0.12 Attorney for Plaintiff
Date:
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS # 291577
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
;!
Sheriff ?1- a>-
���r�tx
Jody S Smith
#
Chief Deputy JUL 31 AM 9: 47
Richard W Stewart
Solicitor OFFICE OF THE$HERIFF DEP��4SYLV COU COUNTY
Nationstar Mortgage LLC
vs. Case Number
Mark A. Collins 2012-2897
SHERIFF'S RETURN OF SERVICE
09/27/2012 07:02 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 721 Trail Lane, East Pennsboro Township, Enola, PA
17025, Cumberland County.
10/12/2012 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: Mark A. Collins, 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 721 Trail Lane , Enola, PA 17025, property is vacant.
11/01/2012 04:25 PM - Deputy Jason Kinsler, 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:
Mark A. Collins at 757 Carol Street, New Cumberland, PA 17070, Cumberland County.
11/15/2012 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013
03/07/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold
the same for the sum of$ 1.00 to Attorney Joseph Schalk, on behalf of Federal Home Loan Mortgage
Corporation, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $879.60 SO ANSWERS,
July 01, 2013 RONIV R ANDERSON, SHERIFF
Mfg•DD "VI-
(c)CountySuite Sheriff:Teleosoft,Inc. '" • 3 7T 7
NATIONSTAR MORTGAGE, LLC COURT OF COMMON PLEAS
Plaintiff ,
CIVIL DIVISION
V.
NO.: 12-2897-CIVIL
MARK A. COLLINS .
Defendant(s)
CUMBERLAND COUNTY
PHS #291577
A FFID e SaPURSUANT TO RULE 31291
NATIONSTAR MORTGAGE,LLC,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the
Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 721 TRAIL LANE,
ENOLA,PA 17025-1323.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably
ascertained,please so indicate)
MARK A.COLLINS 721 TRAIL LANE
ENOLA,PA 17025-1323
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
SAME AS ABOVE
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DR
MECHANICSBURG,PA 17055-4899
MEMBERS 1ST FEDERAL CREDIT UNION 341 SCIENCE PARK RD
C/O FIDELITY CLOSING SERVICES,LLC STE 203
STATE COLLEGE,PA 16803-2287
ME-M-BERS7ST-FEI3ER-A-L—C E Dff 0-00—WUISt—D
C/O REAL ESTATE DEPT MECHANICSBURG,PA 17055
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
T` 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.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 721 TRAIL LANE
ENOLA,PA 17025-1323
JAMIE COLLINS 721 TRAIL LANE
ENOLA,PA 17025
JAMIE L COLLINS 241 N MIDDLESEX RD
CARLISLE,PA 17013
JAMIE L COLLINS C/O JAMES C. 50 S 16TH ST 28TH FLOOR
HAGGERTY,ESQUIRE PHILADELPHIA,PA 19102
JAMIE L COLLINS C/O KEITH ORR 44 W MAIN ST '
BRENNEMAN,ESQUIRE MECHANICSBURG,PA 17055-6249
COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ.
BUREAU OF INDIVIDUAL TAXES DEPT 280601
INHERITANCE TAX DIVISION HARRISBURG,PA 17128
DEPARTMENT OF PUBLIC WELFARE,TPL P.O. BOX 8486
CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING
PROGRAM HARRISBURG,PA 17105
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S. DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S. ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
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.
Date: By.
Phelan Hallinan Schmieg,LLP
Allison F. Wells,Esq.,Id.No.309519
Attorney for Plaintiff
NATIONSTAR MORTGAGE, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
VS. NO.: 12-2897-CIVIL
MARK A. COLLINS
Defendant(s) CUMBERLAND COUNTY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARK A. COLLINS
721 TRAIL LANE
ENOLA, PA 17025-1323
"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 721 TRAIL LANE,ENOLA,PA 17025-1323 is scheduled to be sold at the
Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,
Carlisle,PA 17013 to enforce the court judgment of$264,281.16 obtained by NATIONSTAR MORTGAGE,
LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale
in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the -full amount due in the sale. To find out if this
has happened, you may 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 tract or parcel of land and premises,situate,lying and being in the Township of East
Per-Insboro in the County of Cumberland and Commonwealth of Pennsylvania,more particularly described as
follows:
BEGINNING at a point in the center line of a 50 feet wide private right-of-way at line of lands of Merle L.
Chronister as shown on a final Subdivision Plan for Arthur R.Zimmerli recorded in Plan Book 39,Page 14;
thence by aforementioned line of lands North 44 degrees 17 minutes 49 seconds West 255.84 feet to a point
on line of lands of N/F Appalachian Trail Ranch,Inc.;thence by aforementioned line of lands North 59
degrees 13 minutes 00 seconds East 822.54 feet to a point;thence South 26 degrees 30 minutes 00 seconds
East 27.32 feet to the centerline of a 50 feet private right-of-way;thence by aforementioned centerline South
39 degrees 41 minutes 47 seconds West 186.68 feet to a point;thence by same by a curve to the right having
a radius of 400.00 feet an arc length of 110.03 feet to a point;thence by same South 55 degrees 27 minutes 26
seconds West 295.36 feet to a point;thence by same by a curve to the left having a radius of 150.00 feet an
arc length of 96.97 feet to a point;thence by same South 18 degrees 24 minutes 56 seconds West 124.74 feet
to a point being the place of BEGINNING.
BEING Lot#15 on a final subdivision plan for Arthur R.Zimmerli recorded in Plan Book 39,Page 14,
December 5, 1980.
CONTAINING 2,225 acres including 0.469 acre,for a 50 feet private right-of-way.
SUBJECT to the restrictions recorded and as of record in Miscellaneous Book 260,Page 42,in the office for
the recording in and for Cumberland County.
TITLE TO SAID PREMISES VESTED IN Mark A. Collins,single man,by Deed from Jamie L.
Shirey, formerly,Jamie L. Collins and Mark A. Collins, single man,dated 11/28/2011, recorded
11/30/2011 in Instrument Number 201133243.
PREMISES BEING: 721 TRAIL LANE,ENOLA,PA 17025-1323
PARCEL NO.09-11-3006-028
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 12-2897-CIVIL
NATIONSTAR MORTGAGE, LLC
vs.
MARK A. COLLINS
owner(s) of property situate in the EAST PENNSBORO TOWNSHIP, Cumberland
County, Pennsylvania, being
(Municipality)
721 TRAIL LANE, ENOLA, PA 17025-1323
Parcel No. 09-11-3006-028
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $264,281.16
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) NO. 12-2897 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONSTAR MORTGAGE,LLC., Plaintiff(s)
From MARK A.COLLINS
(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: $264,281.16 L.L.: 50
Interest from 7/20/12 To Date of Sale($43.44 per diem) $6,038.16
Atty's Comm: % Due Prothy: $2.25
Arty Paid: $194.25 Other Costs:
Plaintiff Paid:
Date: 8/31/12
David D.Buell,Prothonotary
(Seal)
Deputy C—
REQUESTING PARTY:
Name: ALLISON F.WELLS,ESQUIRE
Address:PHELAN HALLINAN&SCHMIEG,LLP TRUE COPY FROM RECORD
In Testimony whereof,I here unto set my hand
1617 JFK BOULEVARD,SUITE 1400 and the seat of said couq at Carlisle,Pa.
4 1-
S1-54_day of 44ug_20 14
This
PHILADELPHIA,PA 19103 Prothonotary
Attorney for:PLAINTIFF
Telephone:215-563-7000
Supreme Court ID No.309519
On September 14, 2012 the Sheriff levied upon the
I
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA,
Known and numbered as, 21 Trail Lane,
Enola, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: September 14, 2012
i
By:
Real Estate Coordinator
i
i i If d h— d3S ZIOZ
`hl qi 05 u
33lb3HS 3N1 A0 301330
CUMBERLAND LAW JOURNAL
Writ No. 2012-2897 Civil Term
NATIONSTAR MORTGAGE LLC
vs.
MARK A. COLLINS
Atty.: Daniel Schmieg
By virtue of a Writ of Execution
NO. 12-2897-CIVIL, NATIONSTAR
MORTGAGE,LLC vs.MARK A.COL-
LINS,owner(s) of property situate in
the EAST PENNSBORO TOWNSHIP,
Cumberland County, Pennsylvania,
being 721 TRAIL LANE. ENOLA. PA
17025-1323.
Parcel No. 09-11-3006-028.
Improvements thereon:RESIDEN-
TIAL DWELLING.
JUDGMENTAMOUNT:$264,281-
.16.
27
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 26, November 2 and November 9, 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.
isa Marie Coyne, Vitor
SWORN TO AND SUBSCRIBED before me this
9 da of November, 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 the atr1*otwXews
Suite 300 ' P
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
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:
10/26/12
2012-2897 Civil Term
11/02/12
TIONSTAR MORTGAGE LLC 11/09/12
VS.
MARK A.COLLINS !
Atty: Daniel Schmieg
By virtue of a Writ of Execution NO. . . . . . . . `.
12-2897-CIVIL
NATIONSTAR MORTGAGE,LLC
vs. So a subscribed be re m thi 9 of Nov mber, 2012 A.D.
MARK A.COLLINS
owner(s)of property situate in the EAST
PENNSBORO TOWNSHIP,Cumberland
County,Pennsylvania,being
(Municipality) Notary Public
721 TRAIL LANE.ENOLA.PA 17025.
13
Par I No.09-11-3006-028
(A age or street address)
Im ove COMMONWEALTH OF PENNP,,rt.VANIA
ments thereon:RESIDENTIAL Notgridl Seal
JUDGMENT AMOUNT:$264,281.16
DWELLING Sherrie L.Owens,Notary Public
Lower Paxton Twp.,®aunhln County
`— My Commission Expires ivo%;.26,iv, .
MEMBER PENNSYLVANIA AggSOCfI!?I0t OF NONO';Afa
ES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Home Loan Mortgage Corporation is the grantee the same having
been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution
issued on the 31 st day of AAu ust, A.D., 2012, out of the Court of Common Pleas of said County as of
Civil Term, 2012 Number 2897, at the suit of Nationstar Mortgage LLC against Mark A. Collins is duly
recorded as Instrument Number 201325238.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and al of said office this day of
A.D.
g!6
ecorder of Deeds
Of County,Ca%b.PA
My commission res#*Frst Monday of Jan.2414