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PHELAN HALLINAN & SCHMIEG, LLP
Matthew Brushwood, Esq., Id No. 310592
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
350 HIGHLAND DRIVE
LEWISVILLE, TX 75067
Plaintiff
V.
STACI L. HAIR
TODD R. HAIR
169 EAST NORTH STREET
CARLISLE, PA 17013-2431
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. /a-" 3v?(
CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
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File #: 288386
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 #: 288386
I. 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:
STACI L. HAIR
TODD R. HAIR
169 EAST NORTH STREET
CARLISLE, PA 17013-2431
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 04/27/2005 STACI L. HAIR and TODD R. HAIR made, executed and delivered a
mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is
recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book
1905, Page 2995.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.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 10/15/2010 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 #: 288386
6.
The following amounts are due on the mortgage
Principal Balance
Interest
09/15/2010 through 06/15/2012 @ 6.54% ($288.29 Monthly)
Escrow Total
Property Inspections
Appraisal/BPO
Non-Sufficient Funds Charge
Subtotal
Suspense Credit
TOTAL
7
8.
$52,934.32
$6,058.29
$2,808.07
$161.55
$653.00
$60.00
$3,682.62
$(471.55)
$62,203.68
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.
File #: 288386
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$62,203.68, 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.
AN & SCHMIEG, LLP
By:
Matth wood, Esq., Id No. 310592
Attorney or Plaintiff
File #: 288386
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the building thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly described as
follows:
BEGINNING at a point on the Northern side of East North Street, thence by a Northerly
direction 93 feet to a point; thence in an Easterly direction 16.9 feet to a point; thence in a
Southerly direction 93 feet to a point; thence in a Westerly direction along the Northern side of
East North Street, 16.9 feet to the place of BEGINNING.
AND BEING the Westerly house of a row of frame dwelling houses, the eastern boundary line of
said houses running through the partition separating the house on the East thereof, and being
known as No. 169 East North Street.
BEING THE SAME premises which Diane Brinton and Donna Brinton-Miller, Administrators of
the Estate of Leroy H. Brinton, by their deed dated December 15, 1994 and recorded December
16, 1994 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Deed Book 116, Page 296, granted and conveyed unto Kerry R. Henne and Joan M. Henne,
husband and wife.
AND ALSO BEING THE SAME premises which Kerry R. Henne and Joan M. Henne, husband
and wife, by their deed dated the 27th day of April, 2005 and recorded simultaneously herewith,
granted and conveyed unto Todd R. Hair and Staci L. Hair, husband and wife, MORTGAGORS
herein.
File #: 288386
PROPERTY ADDRESS: 169 EAST NORTH STREET, CARLISLE, PA 17013-2431
PARCEL # 02-21-0318-030
File #: 288386
VERIFICATION
Trametra Vemer Assistant Secrete
hereby states that he/she is gt
Title: Assistant Secretary
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
to unsworn falsification to authorities.
DATE: _ ell-711csj
subject to the penalties - Pa. C.S. ec. 4904 relat g
Nam .
Trametra err
NATIONSTAR MORTGAGE, LLC
File#: 288386
Name: HAIR
File #: 288386
FORM 1
NATIONSTAR MORTGAGE, LLC, F/K,/A
CENTEX HOME EQUITY COMPANY, LLC
Plaintiff(s)
vs.
STACI L. HAIR
TODD R. HAIR
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENISY LWNIKl
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NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
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.
Res
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for Plaintiff
Esq., Id No. 310592
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:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
State: Zip: _
Home:_ Office:
Cell: Other:
Email:
# of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number: _
Second Mortgage Lender:
Type of Loan: _
Loan Number:
State: _ Zip:
Yes El No F] Listing date: Price: $
Realtor Phone:
Yes ? No F-1 Home:
Cell:
State: -Zip:
Offi ce:
Other:
How long?
Date You Closed Your Loan:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ? No El
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 motorcycles): Model:
Year: Amount owed: Value
Year:
Year:
Monthly Net
Monthly Net
Monthly Net
Borrower Pay Days:_ Co-Borrower Pay Days:
Monthly Income
Name of Employers:
I . Monthly Gross
2. Monthly Gross.
3. Monthly Gross
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2nd 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:
Phone (Office):
Fax:
Counselor:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ? No F-1
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 M No F-1
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):
Servicing Company (Name):
Contact:
Phone:
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
Co-Borrower Signature
Date
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)
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY -- R_
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Ronny R Anderson r-
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Sheriff u
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Jody S Smith r- sy
Chief Deputy
Richard W Stewart
Solicitor ,4 ,-?RiF" `ri
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Nationstar Mortgage LLC Case Number
vs.
2012-4036
Staci L. Hair (et al.)
SHERIFF'S RETURN OF SERVICE
07/09/2012 09:15 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on July ,
2012 at 2115 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
to wit: Todd R. Hair, by making known unto himself personally, at 169 E. Nort
within named defendant
,
Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing t
him personally the said true and correct copy of the same.
RONALD HOOVER, DEPUTY
07/09/2012 09:15 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on July ,
2012 at 2115 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Staci L. Hair, by making known unto herself personally, at 169 E. NortStreet, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing t
her personally the said true and correct copy of the same.
SHERIFF COST: $50.00
RONALD HOOVER, DEPUTY
SO ANSWERS,
July 11, 2012
RONNY R ANDERSON, SHERIFF
i'Curtysuae. the..,
PHELAN HALLINAN & SCHMIEG, LLP
Zachary Jones, Esq., Id. No.310721
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.
STACI L. HAIR
TODD R. HAIR
lL4. +1 ~~,.~1 i ilr l..
Attorney for Plaintiff
~~~1 SEA' -5 A!110~ 3Q
~:1rf~S~trRLAN~ CQU~ITY
"ct~FtSYLVANIA
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 12-4036-CIVIL TERM
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 STACI L. HAIR and TODD
R. HAIR, Defendants 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
$62,203.68
$62,203.68
I hereby certify that (1) the Defendants' last known address is 169 EAST NORTH
STREET, CARLISLE, PA 17013-2431, and (2) that notice has been given in accordance with
Rule Pa.R.C.P 237.1.
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Date
Z ~ r s, squire amp ~~~, SD~
o f laintiff
~~.~ ~a2~ras
DAMAGES ARE HEREBY ASSESSED AS INDICATED. v?$'b9c7t
~ p~ u
DATE: - 1 S~~
TH T Y
288386
PHELAN HALLINAN & SCHMIEG, LLP
Zachary Jones, Esq., Id. No.310721
1617 JFK Boulevard, Suite 1400
Attorney for Plaintiff
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC,
F/K/A CENTEX HOME EQUITY
COMPANY, LLC
vs.
STACI L. HAIR
TODD R. HAIR
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 12-4036-CIVIL TERM
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendants are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of
Congress of 1940, as amended.
(b) that defendant STACI L. HAIR is over 18 years of age and resides at 169
EAST NORTH STREET, CARLISLE, PA 17013-2431.
(c) that defendant TODD R. HAIR is over 18 years of age and resides at 169
EAST NORTH STREET, CARLISLE, PA 17013-2431.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date ~ ~ ~` ~ f
Zac ry quire
rn f aintiff
288386
(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
STACI L. HAIR No. 12-4036-CIVIL TERM
TODD R. HAIR .
Notice is given that a Judgment in the above captioned matter has been entered
against you on
By: w
If you have any questions concerning this matter please contact:
Phelan Hallinan & Schmieg, LLP
Zachary Jones, 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 YDU
HAVE PREVIO USL Y RECEIVED A DISCHARGE IN BANKR UPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT
ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. **
288386
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTNf OF PENNSYLVANIA) NO. 12•-4036 Civil
COUNTY' OF CUMEERLAND) CIVIL ACTION - LAW
TC) THE SHERIFF CAF CUMBERLAND COUNTY:
To satisfy the debt, interest and cosrs due NATIONSTAR MORTGAGE, LLC, F/K/A CF:NTEX
HOME; EQUITY COMPANY, LLC Plaintiff (s)
From STACI L. HAIR, TODD R. HAIR
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
f 2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
G.ARNISHEE(S) as follows:
and to notify the garn.ishee(s) that: (a) an attachment has been issued; (bj the garnishee(s) is ei~ji~ined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s 1 or other~~~ise 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: $62,203.68 L.L.: $.50
Interest. FROM 9/6/2012 TO DATE OF SALE ($10.23 PER DIEM) - 51,861.86
Attv's Comm: '% Due Prothy: $2.25
Arty Paid: 5201.25 Other Casts:
Plaintil•f Paid:
Da[e: 11/1/2012 -~ ~
David D. Buell, Protho~~
r'r
t Sea]) ~ ~Y _
Deputy
I'~i_QUESTINv }'.ARTY:
Name: ANDREW J. MARLEY, ESQUIRE
,Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK BOULEVARD, SUITE 1400
ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
fa~lephone: 215-563-7000
Supreme Court ID No. 312314
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECI:~OSURE)
P.R.C.P.3180-3183
NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COURT OF COMMON PLEAS
COMPANY, LLC
Plaintiff CIVIL DIVISION
STACI L. HAIR
TODD R. HAIR
Defendant(s)
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 09/06/2012 to Date of Sale
($10.23 per diem)
NO.: 12-4036-CIVIL TERM
CUMBERLAND COUNTY
$62,203.68
X861.86
TOTAL X64,065.54
elan Hall-nan chmieg,
Andrew J. Marley, Esq., Id. .12314
Attorney for Plaintiff
Note: Please attach description of property. :__:
PHS # 288386 ~ ~`
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LEGAL DESCRIPTION
ALL 'THAT CERTAIN tract of land with the building thereon erected situate in the First Ward of the
Borough of Carlisle, Camberland Count}, Pennsylvania, more particul~u-ly described as follo~~~s.
BEGINNING at a point: on the Northern side of Fast North Street, thence by a Northerly direction 93 feet to a
point: thence in an Easterly direction 16.9 feet to a point; thence in a Southerly direction 93 feet to a }point;
thence in a Westerly direction along the Northern side of East North Street, 16.9 feet to the place of
BEGINNTNC~.
AND BEING the Westerly house of a row of frame dwelling houses, the eastern boundary line of said houses
running through the partition separating 1:he house on the East thereof, and being known as No. 169 East
North Street.
1'ITL,E TD SAID PREMISES VESTED IN: "Todd R. Hair and Staci L. Hair, husband and wife
by Deed Kerry R. Henne and Joan M. Henne, husband and wife dated 04/27/2005 and recorded
OS/0?/2005 in Bok 268, Page 3373 and instrument # 2005-O14896.
YREMISE,S BEING: 169 EAST NORTH STREET, CARLISLE, PA 17013-2431
PAR(:'EL NO. 02-21-0318-030
Pl ALAN HALL[lJAN & SCI-IMIEG, LLP
Andrew J. Marley, Esq., Id. No.312314
1617 JFK Boulevard, Suite 1400 ~ ~ ,,
One Penn Center Plana -
Philadelphia. PA 1910
215-563-7000 ~ ~ "~~. '~
,r ~~ E ,•°al,;; ;
,r ,. ~~
NATIONSTAR MORTGAGE, LLC, F/K/A CENT~EX!~`O~
EQUITY COMPANY, LLC
Plaintif f
v.
STACI L. HAIR.
'TODll R. HAIR
Defendant(s)
Attorneys I~~r Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: 12-4036-CIVIL TERM
CUMBERLAND COUNTY
CERTIFICATION
"I'he undersigned attorney hereby states that he/she is the attorney for the Plaintiff in. the ahove captioned
matter and that the premises are not subject to the provisions of Act 91 because:
~ ) the mortgage is an FI-IA Mortgage
the premises is non-owner occupied
~ ) the premises is vacant
(~:) Act 91 procedures have been fulfilled
Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No I 1-1197. 4l Pa.B. 3943
Phis certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
''
--
Phelan Hallman Schmieg, LIT
Andrew J. Marley, Esq., Id. N~;~V" 23 I4
Attorney for Plaintiff
~'`
t
NATIONS'TAR MORTGAGE, LLC, F/K/A CENTEX COURT OF COMMON PLEAS
HOME EQUITY" COMPANY, LLC -
Plaintiff- CIVIL DIVISION
~, NO.: 12-4036-~CIV1L TERM
S'I'ACI L. HAIR
TODD R. HAIR CUMBERLAND COUNTY
llefendant(s)
PHS # 288386
AFFIDAVIT PURSUANT TO RULE 3129.1
N.ATIONSTAR 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 169 EAST NORTH STREET„ CARLISLE, PA 17013-2431.
I . Name and address of Owner(s) or reputed Owner(s):
Name Address (if address cam~ot be reasonably
ascertained, please so indicate}
S"1'ACI L. HAIR 169 EAST NORTH STREET
CARLISLE, PA 17013-2431 _~
'TODD R. HAIR 169 EAST NORTH STREET
CARLISLE, PA 17013-2431 ~ ; , ~ i
~. Name and address of Defendant(s) in the judgment: ._
,r ; s. ;
Name Address (if address cannot be reasonably c ~ -'
,
_
ascertained, please so indicate]
SAMf': AS ABOVE
Name and Fast known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
3
.
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)
CITIFINANCIAL, INC. PO BOX 17170
BAL"TIMORE, MD 21203
CITIFINANCIAL, INC'. 1 VALLEY STREET
SUITE 103
CARLISLE, PA 17013
5. Name and address of every other person who has a ny record lien on the property:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
~-
6 Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
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
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDIVIDUAL TAXES
INHERITANCE TAX DIVISION
169 EAST NORTH STREE"I'
CARLISLE, PA 17013-2431
6TH FLOOR, STRAWBERRY SQ.
DEPT 280601
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 l3 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE, PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675
UEPARTI~1F.NT OF WELFARE HARRISBURG, PA 17105
INT'F.RNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH, PA 15222
U.S. DEPARTMENT OF JUSTICE
U.S. ATTORNEY FOR THE MIDDLE
llISTRICT` OF PA
FEDERAL BUILDING
228 WALNUT STREET, SUITE 220
PO BOX 11754
HARRISBURG, PA 17108-1754
I verity that the Statements made in this affidavit are true and correct to the best of n~ty personal
knowledge ar 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.
i
Date: id-- By.
i
Sian Hallman & Schmieg, LLP
Andrew J. Marley, Esq., [d. No.31
Attorney for Plaintiff
t
NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME
EQUITY COMPANY, LLC
Plaintiff
V S.
S'TACI L. HAIK
TOllD R. HAIR
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: 12-4036-CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY + ~~ ^=
'TO: S~I'ACI L. HAIR TODD R. HAIR ~~-~~~
169 EAST NORTH STREET 169 EAST NORTH STREET ~ '- ~ ``~~
CARLISLE, PA 17013-2431 CARLISLE, PA 17013-2431
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING "TO COLLECT' A UE:BT AND ANY INFORMATION OBTAINEll
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 169 EAST NORTH STREET', CARLISLE, PA 17013-231 is scheduled to
be sold at the Sheri ft's Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $62,203.68 obtained b}-' 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 I3E AISLE rI'O PREVENT THIS SHERIFF'S SALE
1~o 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.
~. 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 OTHEK RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
L 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 oi~your property.
3. "1'he sale v~ill go through only if the buyer pays the Sheriff the full amount due in the sale. "l~o find out if this
has happened, yoa- may call 2;15-563-7000.
~. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner o1:~ the property as if
the sale never happened.
_>. 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 riot later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for ii~ispection in his
office. 1~his 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 SHOL~Lll 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
1'O 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 "t°IiA~I~ CEKTAIN tract of land with the building thereon erected situate in the First Ward of the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly described as follow,:
BEGINNING at a point on the Northern side of East North Street, thence by a Northerly direction 93 feet to a
point: thence in an Easterly direction 16.9 feet to a point; thence in a Southerly direction 93 teet to a point;
thence in a Westerly direction along the Northern side of East North Street, 16.9 feet to the pla~~e of
BEGINMNG.
AND BEING the Westerly house of a row of frame dwelling houses, the eastern boundary line of said houses
running through the partition separating the house on the East thereof, and being known as No 169 East
North Street.
"TITLE TO SAID PREMISES VESTED IN: Todd R. Hair and Staci L,. Hair, husband and wife
by Deed Kerry R. Henne and Joan 1VI. Henne, husband and wife dated 04/27/2005 and recorded
05/02/2005 in Bok 268, Page 3373 and instrument # 2005-OI4896.
PREMISES BEING: 169 EAST NORTH STREET, CARLISLE, PA 17013-2431
PARCEL, NO. 02-21-0318-030
SHORT DESCRIPTION
By virtue of~ a Writ of Execution NO. 12-4036-CIVIL TERM
NA'TIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY.,
LLC
vs.
STACI L„ HAIK
TODD R. HAIR
owner(s) of properly situate in CARLISLE BOROUGH, Cumberland County.
Pennsylvania, being
(Municipality)
169 EAST 1~1ORTH STREET, CARLISLE, PA 17013-2431
Parcel No. 02-21-0318-030
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMEN"h AMOUNT: $62,203.68
Phelan Hallman & Schmieg, LLP
Attorney for PlaintiB~
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
2 15-~6 ~-7000
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME
EQUITY COMPANY, LLC PHS # 288386
DEFENDANT SERVICE TEAMI ]xh
STACI L. HAIR COURT NO.: 12-4036-CIVIL TERM
TODD R. HAIR
SERVE STACI L. HAIR AT: TYPE OF ACTION
169 EAST NORTH STREET XX Notice of Sheriff s Sale
CARLISLE, PA 17013-2431 SALE DATE: March 6, 2013
SERVED
Served and made known to STACI L. HAIR, Defendant on the '.~'~. day of ~y , 2012
at
,
=35 , o'clock ~. M., at l6~ fcf~ST 0~ H ST(~t , in the manner described below:
_ Defendant personally served.
~C Adult family member with whom Defendant(s) reside(s). .,._
Relationship is tit~S6ANQ c =~;,'
_ Adult in charge of Defendant's residence who refused to give name or relationship. -w;,
Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~'l~~Y
'^
,
t ~.~ "°'~
...
tom' 4
- Agent or person in charge of Defendant's office or usual place of business. ~/
, .
~ .I
1 '~
....
c'>
`
"
- an officer of said Defendant's company.
cn!„~ ~
.
r1
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'
_ Other: ~~ W ~
,„',,
2^ C r
Description: Age ~ Height 6 ~ Weight ~~ Race W Sex ~ Other .~'1.`J
a.'• t .i~. ° kl
~ °"
I, P~NC~+iNA ~:.
a competent adult, hereby verify that I personally handed a true and correy o~ie ~ f
Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at t~hd adds .
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4
904 i'~lati ,
ng to ~-.
unsworn falsification to authorities.
~~~,s
DATE: _ ~ r\Z •2012 NAME: ~~'` I''~ ~~DN
PRINTED NAME: ~N6X7~NA- OCtIEoN
TITLE: Q~CFSS SfR-VpZ
NOT SERVED
On the day of , 20 , at o'clock . M., I, , a competent adult hereby
state that a endant cause: _
_ 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.
B Y:
PRINTED NAME:
ATTORIV)~Y 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
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
Courtenay R. Dunn, Esq., Id. No. 206779
Allison F. Wells, Esq., Id. No. 309519
Melissa J. Cantwell, Esq., Id. No. 308912
Mario J. Hanyon, Esq., Id. No. 203993
Andrew J. Marley, Esq., Id. No. 312314
Robert W. Cusick, Esq., Id. No. 80193
AFFIllAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
NATIONSTAR MORTGAGE, I,LC, F/K/A CENTEX HOME
EQUITY COMPANY, LLC PHS # 288386
DEFENDANT SERVICE TEAM/ lxh
STACI L. HAIR COURT NO.: 12-4036-CIVIL TERM
TODD R. HAIR
SERVE TODD R. HAIR AT: TYPE OF ACTION
169 EAST NORTH STREET XX Notice of Sheriff s Sale
CARLISLE, PA I70I3-2431 SALE DATE: March 6, 2013 „
;
,
SERVED
r`1-.».
~~'
r..~
Served and made known to TODD R. HAIR, Defendant on the ~~ day of
~~ , 20 ~, at ~ ~ ~ ~ t
_
~, o'clock ~. M., at ~6~ ~5 t- h~TH ST , in the manner described below: ~ r'~
cn..
t y~'~ ,.
~s'.W~
~ Defendant personally served. ~
-.~ ~ ~ ,
_ Adult family member with whom Defendant(s) reside(s). ~~
~ `"~""'
Relationship is 3
~,t-a ~ ~~--G-
_ Adult in charge of Defendant's residence who refused to give name or relationship. ~ ~ ~,;t`-~
~
Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~' ~ ~ ~~
Agent or person in chazge of Defendant's office or usual place of business. ~ ,~. .
_ an officer of said Defendant's company.
Other:
Description: Age ~ S Height,, ~ Weight ~~5 Race~I~~ex M Other
I, ~t~i~1~4 , 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
unsworn falsification to authorities.
DATE: Na (2 ' ~Z NAME: ~N~tNA~ P~.~on5
PRINTED
NAME: N~ Dc~S~l ly
b
TITLE: C ~'4 CAS ~~Z
NOT SERVED
On the dayy of , 20_, at o'clock . M., I, , a competent adult hereby
state that a endant OPIS~ecause: _
- 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.
B Y:
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
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
Courtenay R. Dunn, Esq., Id. No. 206779
Allison F. Wells, Esq., Id. No. 309519
Melissa J. Cantwell, Esq., Id. No. 30891 Z
Mario J. Hanyon, Esq., 1d. No. 203993
Andrew J. Marley, Esq., Id. No. 312314
Robert W. Cusick, Esq., Id. No. 80]93
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC, F/K/A Court of Common Pleas
CENTEX HOME EQUITY COMPANY,LLC
Plaintiff Civil Division
vs CUMBERLAND County
STACI L.HAIR No.12-4036-CIVIL TERM
TODD R.HAIR
Defendant
PRAECEPE
TO THE PROTHONOTARY:
❑Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑Please mark the above referenced case Settled,Discontinued and Ended.
Z Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
❑Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
❑Please Vacate the Judgment entered.
Date: APR 2 2013 PYELAN HPLUNAN,LLP
Mke ris--a/J�Cantwel _Id.No.308912
Attorney for Plaintiff ^s C--
PHS#288386 ZZ;
:::t CD
rZ. �---T!
4C-1 C)
C5
attd
Phelan Hallinan,LLP Attorney for Plaintiff
161.7 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 1.9103
21.5-563-7000
NATIONSTAR MORTGAGE, LLC, F/K/A Court of Common Pleas
CENTEX HOME EQUITY COMPANY,LLC
Plaintiff Civil Division
V. CUMBERLAND County
STACI L. HAIR No. 12-4036-CN1L TERM
TODD R.HAIR
Defendant PHS#288386
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
STACI L. HAIR
TODD R.HAIR
169 EAST NORTH STREET
CARLISLE,PA 17013-2431
Date: APR 12 2013
HELA HALLINAN LLP
Melissa J.Cantwell, Id.No.308912
Attorney for Plaintiff