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HomeMy WebLinkAbout12-6080KML LAW GROUP, P.C. ;~~ ~~ ~ ~ _ ~ ~ ~. ~ ~ ~. SUTI'E 5000 - BNY MELLON INDEPENDENCE CE R_ ,,. 701 MARKET STREET ~- . t r ~ ~~ C ~~ ~ 1 ~ ~ ~ ~ ! A ~ i PHILADELPHIA, PA 19106 (866) 413-2311 t ~ ~ ~ ~ ~ ~ ~ ~ ~` NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaint vs. OF Cumberland COUNTY CIVIL ACTION -LAW SYEDA ALI HAFEEZ KAHN ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 112 OldMill Drive 'UI'I Camp Hill, PA 17011 No. ~~ ~Q~ Defendant(s) C:l~ll~ !~~, NOTICE You have been sued in court. If you wish to defend against the claims wing pages, you must take action within twenty (20) days after the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, 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 WTI'H INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 h',.# a ~ ~ ~ L -~ i ~ DI C O (J N T ~N THE COURT OF COMMON PLEAS ~'~~~l~SYL~~Nl~, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demands y la notification. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notification. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. SI NO POR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ~~,~ ~~ D,3, ~~I C~~ ~dl 3I 3 I ~~ a8' 33~ LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLA _Q TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR ~l SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. og_v for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org~consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.or~/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention cni,kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 114382FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is NATIONSTAR MORTGAGE, LLC, 350 Highland Drive, Lewisville, TX 75067. 2. The name(s) and address(es) of the Defendant(s) is/are SYEDA ALI, 112 Old Mill Drive, Camp Hill, PA 17011 and HAFEEZ KAHN, 112 Old Mill Drive, Camp Hill, PA 17011, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On October 23, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR NFM, INC,. D/B/A NFM CONSULTANTS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on November 13, 2006 as Book 1972 page 2570. The mortgage has been assigned to: NATIONSTAR MORTGAGE, LLC by assignment of Mortgage recorded on March 23, 2010 as Instrument # 201007229. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February O1, 2012 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$146,738.95 Interest from 01/01/2012 through 06/30/2012 at 3.7500% .......................$2,730.00 Per Diem interest rate at $15.08 Corporate Advance ......................................................................................$475.00 $149,943.95 7. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiffdemands a de terris judgment in mortgage foreclosure in the sum of $149,943.95, together with interest at the rate of $15.08, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: KML LAW RO , P.C. Mich el Mc Bever Pa. ID 5 29 Jay . Kivit Pa. ID 267 Lisa Lee Pa. 780 Kristina Murth a. ID 61858 David Fein Pa. ID 82628 ~mas Puleo Pa. ID 27615 oshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. 1D 306588 Attorneys for Plaintiff VERIFICATION ~~.gsG G C~~~~l{.. hereby states that he/she is,L~ls-~,~- ~~~.{~~v of Nationstar Mortgage, LLC, Plaintiff in this matter, that he/she is authorized to and do make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure aze 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. Date: f~2~n1~2* C /~z •~I ysxa ~ C1 Jlr~~+;t la .4ss~s~t Sccr~~ary #114382FC - SYEDA ALI and HAFEEZ KAHN 112 Old Mill Drive Camp Hill, PA 17011 ~E,~hi6itA ALL THAT CERTAIN tot, parcel or tract oP laud situate is Lower Allen Towaahip, Cus~berlsed County, Penesylvasla boarded and described as follows: BEGINNING at a stare on the northern side o! a proposed 50 toot wide read now or to be known as OW Mil! Drive, which :tske L located South S3 de8~ West 1931bet fr+am a .pout at the sswttters side ~ the said OW Mill Drive ZS ket sosthwert of the tester lice of a psblic road ksews a TowwYp Route Na 641 (which point is the sostheart corner of a lot heretofore cosvey~ed ro J.W. Goaett, Jr. asd wldeh point is tented SSoath 37 decrees East 158.35 feet from another point 25 tat wnthwat of the cease of the said To~s~ship Roste at corner of lands now or late of Labe It. Allen et az.); thew aioq the iarthers side of the said 50 foot wile road sow or to be knows as Old M~1 ~Drlve 8esth 53 de;rea West S2.i5 feet to a stake at a point of carve, the radian of which is 50.13 feet; thence oostlsdq aleq the northers skk of the said read aow or bo be kso~vs ~s Oki MiN Drive and ak+q the and adrve a iYd~soe with a choi+i isgth of .93 feet and a chard iiatr~ of South 52 dnrees_ S6 atiaata -Wert to a rtake; theses slag bsub aw or formerly of Willard F. Keiser, Jr. North 38 dgrees 15 missies West 119.16 feet to a staloe; thane cattinniq aba8 the came North 18 de=revs Z6 mhetes lfast 24.31 l~ to a stake at flee corner of Eberly's Mills Ces~etery; thecae aloq the iiae of Eberly'e l4I#le Ces~elery North 60 de~re~a 59'sil~Nea Eieet 63.53 feet to a stake at other iss~ds new or fonserly of W3lard I+'. Kdser, Jr. Sonth 37 de;rea East 1Z3.9S feet to a stake, being the pohtt.aml.p~e-of BEGINNING.. _ . ~-- --- - - -- - -_---- ----- For Informatioeal Pnrposts Osly: The improvements theriwn being lusown as 112 Old M81 Drive, Caotp Hill, Peassyivas~ 17011. BEING a8 and the same lot of 3ronnd which by Dad dated Apr117,.2806, and cccu~t~dpl anoq the Land. . Reeoede o[~Cymberhtrd County, Pennryivaaia in Libor No. Z74, folio 160, was =ras/ed and cssrveyed by Syeda Ali, ante Syeda Ali and Hafeez Kaba. Pared No.: -13-240805.106 ~Fiidit B *Exhibit has been redacted to remove all personally identifiable information or non public information Nationstar Mortgage, LLC PO l3ox 9095 Temecula, CA 92589-9095 Send Payments to: Nationstar Morlgage PO Bcec 650783 DaNas, TX 75265-0783 5':.: 7196 9006 9295 9151 2810 20120413-160 I~'~I'III~IIIIII"~11~1~~'~~~II~I~~i~'Ill'~'~11~'~~III~~~~II~~I~i SYEDA ALI 112 OLD MILL DR CAMP HILL, PA 17011-8201 PRESORT First-Class Mail U.S. Postage and Fees Paid wso PA_ACT6 7~~4~. a~. lSC3~Ttr~lr:~ 04/13/2012 SYEDA ALI 112 OLD MILL DR CAMP HILL, PA 17011-8201 Loan Number: -0727 Property Address: 112 OLD MILL DR CAMP HILL, PA 17011 Sent Via Certified Mail 7196 9006 9295 9151 281 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear SYEDA ALI: You are hereby provided formal notice by Nationstar Mortgage, LLC, the servicer for the above-referenced loan, on behalf of Federal National Mortgage Association, the creditor to whom the debt is owed, that yow property located at 112 OLD MILL DR CAMP HILL, FA 17011 IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the months of 02/0112012 through 0411 3/20 1 2 as follows: Next Payment Due Date 02/01/2012 Total Monthly Payments Due: $3,006.48 Late Charges: $609.46 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $0.00 Corporate Advance Balance: $250.00 Unapplied Balance {$0.00} TOTAL YOU MUST PAY TO CURE DEFAULT: $3,865.94 L The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $3,865.94. You may cure this default within THIRTY (30} DAYS of the date of this letter, by paying to us the above amount of $3,865.94, plus airy additional monthly payments and late charge which may fall due dwing this period. Such payment must be made either by cash, cashier's check, certified check or money order. PA_ACT6 Psge 1 of 3 7196 9006 9295 9151 2810 Please include yow loan number and property address with yow payment and send to: Nationstar Mortgage, LLC 350 Highland Drive Lewisville, TX 75067 Attn: Default Management If you do not cwe the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage paymants. This means that. whatever is owing on the original aunt borrowed will be considered due immediately and you may lose the chance to pay off tbe original mortgage in monthly installmaits. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct ow attorneys to start. a lawsuit to foreclose yow mortgaged property. If the mortgage is foreclosed yow mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer yow case to ow attorneys, but you cure the default before they begin legal proccedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are ova $50.00. Any attorney's fees will be added to whatever you owe us, which may also include ow reasonable costs. If you cwe the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the forecloswe sale (and perform any other requirements ands the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately siz (6) tenths from the date of this notice. A notice of the date of the Sheriff sale will be salt to you before the sale. Of cowse, the amount needed to cure the default will increase the longs you wait. You may find out at any time exactly what the required payment will be by calling us at 1-888-480-2432. This payment must be in cash, cashier's check, certified check or money order and made payable to us at khe address stated above. You should realize that a Sheriffs sale will aid your ownership of the mortgaged property and yow right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect yow interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occwred. However, you are not entitled to this right to cure yow default more than three times in any calendar year. PA_ACT6 Page2of3 7196 90x6 9295 9151 2810 IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nationstar Mortgage, LLC offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation Department at 1-888-480-2432, Monday -Friday 8:00 A.M. - 7:00 P.M. C~tral Time. WE ARE VERY INTERESTED IN ASSISTING YOU. Attention Service members and dependents: The Federal Service members' Civil Relief Act {"SCRA") and certain state laws provide important protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last nnie {9) months, AND joined after signing the Note and Security Instrument now in default, please notify Nationstar Mortgage, LLC immediately. Vb'hen contacting Nationstar Mortgage, LLC as to your military service, you must provide positive proof as to your military status. If you do not provide this information, it will be assumed that you are not entitled to protection under the above-mentioned Act. If you are experiencing financial difficulty, you should know that there are several options available to you that may help you keep your home. You may contact a government approved housing counseling agency which provides free or low-cost housing counseling. You should consider contacting one of these ageaacies immediately. These agencies specialize in helping homeowners who are facing financial diffiwlty. Housing counselors can help you assess your financial condition and work with us to explore the possibility of modifying your loan, establishing an easier payment plan for you, or even working out a period of loan forbearance. For your benefit and assistance, there are government approved homeownership counseling agencies designed to help homeowners avoid losing their horses. To obtain a list of approved counseling agencies, please call (800} 569-4287 or visit http://www.hud~ov/offices/hsg/sfh/hcc/hcs cfm You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclasure counseling agency. You may call the following toll-free number to request assistance from the Homeownership Preservation Foundation: (888) 995-HOPE. If you wish, you may also contact us directly at 1-888-480-2432 and ask to discuss possible options. This matter is very important. Please give it your immediate attention. sincerely, Nationstar Mortgage, LLC 350 Highland Drive Lewisville, TX 75067 1-8881180-2432 FEDERAL LAW REQUIRES U5 TO ADVISE YOU THAT NATIONSTAR MORTGAGE, LLC IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY A'~TD DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. ~ YOU ARE REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. PA_ACT6 Page3 of3 7196 9006 9295 9151 2810 Nattonstar Mortgage, LLC PO Box 9095 Temecula, CA 92589-9095 Send Payments to: Nationstar Mortgage PO Box 650783 Dallas, TX 75265-0783 Yi^y 7196 906 9295 9151 2827 20120413-160 I~iliii~ul111~illl~i~,~il~~~~l~~lll~i4~l~l°lilinin~ln~il~i~ HAFEEZ KAHN 112 OLD MILL DR CAMP HILL, PA 17011-8201 PRESORT First-Class Mail U.S. Postage and Fees Paid W SO PA_ACTB ~3f~~TC eL,€~ 04!1312012 HAFEEZ KAHN 112 OLD MILL DR CAMP HILL, PA 170 1 1-820 1 Loan Number: 727 Property Address: 112 OLD MILL DR CAMP HILL, PA 17011 Sent Via Certified Mail 7196 906 9295 9151 2827 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear HAFEEZ KAHN: You aze hereby provided formal notice by Nationstar Mortgage, LLC, the servicer for the abovereferenced loan, on behalf of Federal National Mortgage Association, the creditor to whom the debt is owed, that your property located at 112 OLD MILL DR CAMP HILL, PA 17011 IS IN SERIOUS DEFAULT because you have not made the monthly payment (s} and other charges for the months of 02/01/2012 through 04/ 13/2012 as follows: Next Payment Due Date 02/01/2012 Total Monthly Payments Due: $3,006.48 Late Charges: $609.46 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $0.00 Corporate Advance Balance: $250.00 Unapplied Balance ($0.00} TOTAL YOU MUST PAY TO CURE DEFAULT: $3,865.94 The total amount now required to cure this default, or in other wards, get caught up in your payments, as of the date of this letter, is $3,865.94. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $3,865.94, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be rna~ either by cash, cashier's check, certified check or money order. ~L• r _ J~+~. PA_AG 1'6 Page ] of 3 7896 9006 9295 9151 2827 Please include your loan number and property address with your payment and send [o: Nationstaz Mortgage, LLC 350 Highland Drive Lewisville, TX 75067 Attn: Default Management If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that. whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the anginal mortgage in monthly installm~ts. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your rortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but. you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $0.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attomey's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default. and prevent the sale at any time up to one hour before [he Sheriff s foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attomey's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately sia (b) months from the date of this notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at 1-888-480-2432. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TU BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occtared. However, you aze not entitled to this right to cure your default mare than three times in any calendar year. PA_ACT6 Paget of3 7196 9006 9295 9151 2827 IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nadon.star Mortgage, LLC offers consumed assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation Department at I-888-480-2432, Monday -Friday 8:00 A.M. - 7:00 P.M. Central Time. WE ARE VERY INTERESTED IN ASSISTING YOU. Attention Service members and dependents: The Federal Service members' Civil Relief Act ("SCRA") and certain state laws provide important protections for you, inchuling prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND ,joined after signing the Note and Security Instrument now in default, please notify Nationstar Mortgage, LLC inunediately. When contacting Nationstar Mortgage, LLC as to your military service, you must provide positive proof as to your military status. If you do not provide this information, it will be assumed that you are not entitled to protec~on under the above-mentioned Act. If you are experiencing financial difFiculty, you should know that there are several options available to you that may help you keep your home. You may contact a government approved housing counseling agency which provides free or low-cost housing counseling. You should consider contacting one of these agencies immediately. These agencies specialize in helping homeowners who are facing financial diffiwlty. Housing counselors can help you assess your financial condition and work with us to explore the possibility of modifying your loan, establishing an easier payment plan for you, or even working out a period of loan forbearance. For your benefit and assistance, there are government approved homeownership wunseling agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call (800} 569-4287 or visit httn://www.hudgov/officeslhsg/sfh/hcc/hes cfm You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure counseling agency. You may call the following toll-free munber to request assistance from the Homeownership Preservation Foundation: (888) 995-HOPE. If you wish, you may also contact us directly at 1-888-480-2432 and ask to discuss possible options. This matter is very important. Please give it your immediate attention. Sincerely, Nationstar Mortgage, LLC 350 Highland Drive Lewisville, TX 75067 1-88880-2432 FEDERAL LAW REQUIItES US TO ADVISE YOU THAT NATIONSTAR MORTGAGE, LLC IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE ~ REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND @~ TELEPHONE NUMBER PA ACT6 Page 3 of 3 7196 9006 9295 9151 2827 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~i ^' '*~ ~ ~ i'~ ~ -o ~ ~ ~ S ~ ~7 ~' NATIONSTAR MORTGAGE, LLC ra ~~ Plaintiff f 0_ ~~- ~ ~~ ~ ~ ~!'== vs. Case No, ,~,1 ~ ° :~ ~-'~ -ri ~ SYEDA ALI ~' ~" -' ~° ~ ~ ~ ~-... HAFEEZ KAHN ~~ c, %'' Defendant(s) 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 acourt-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 anal your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file 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 fmancial 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 arrangements 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. 9/27/2012 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Daeket # I30RROWER REQ[JEST l~OR HARDSHIP ASSISTANCE To aomplete•your request for hardship assistance, your lender must consider your circumstances to determine gossiblc options while working with your Please provide the fo]lowing information to the best of your knowlalgc: Borrower name(s): Property Address: City: State:__ __ _ Zip. is the property for sale? Yes (~ No ^ Listing date: _ _ - _ Price: $ Realtor Name: _ Realtor Phone: Borrower Occupitd? Ycs No Mailing Address (if different): City: State:___,_Zip; Phone Numbers:. Home: Office: Cell: Other Email: # of people in household: ,How long? Mailing Address; City: State: Zip: ~„ Phone Numbers: Home: Office: _ Ccil: Other: __ . _. ., Email: # ofpeople in household. How long? First Mortgage Lender: _ Type of Loan: Loan. Number: Second Mortgage Lender:. Type of Loan: _ _ -_- --. Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary ReasQn_forDel'ault: Date You Closed 1'aur Loan: Included Taxes 8z I:astarance; Is the loan in Bankruptcy? Yes ^ Na [~ rf ye5, provide names, location of court, case nunnber & attorney: Assets Amount Owed: Value: Home; $ $ Other Real Estate: $ $ __ Retirement Funds: $~ $ IAYBStIAent5: $ Checking: $ Savings: $ $ Other: $ $ Automobile #l: Model Year: , Amount owed: Value: Autamab~le #2: Model: Year: Amount awed: Value: Other trenstyartatian (automobiles,, boats, m t, g arc yale~)i Madcl: 'Year: Amount owed; Value Monfhity Income Namo ofErnployers: I . ~. 3. Additional Income Description (not wages}: 1. monthly amount• 2. _.___ _ monthly amount: Borrower Pay Days: Co-Borrower Pay T?ays: Monthly Exaenses: (Please only include expenses you are contently paying) F.~P'ENSE AMOUNT EXPENSE AMOUNT Mo Toad 2 M Utilities Car Pa ens Cpndo/Nei .Fees AuW Iuaursnce Med. not coy Auto foe its Other a mcnt Install. Loan Pa mcnt Cablo TV Child S rtlAlirn. S is Mo»e Da f~CSild CatelTuit, Other Ex s Amannt Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? 'Y`es [] No [] Tf yes, please provide the fallowing information: Counseling Agency: CouciseloF: Phone (Office): Fax: --- Email, ____ ___w.a..u___....~._.~ ..~._...__ Have you made application for Homeowners Emergency Mortgage Assistance Program (1~EMAl') assistance? Yes ^ Ho If yes, please indicate the status of the application: Have you had any prior negotiations with your tender or lender's loan servicing company to resolve your delinquency? Ye5^ NO^ If yes, please indicate the status of those negatiatio»s: please provide the following infotmation, if lutow, regarding your lender or lender"s loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: T1We, ,authorize the above named to use/refer this information to my lender/servicer for the sale purpose of evaluating my financial situation far possible mortgage options. VWe understand that Uwe am/are under no obligation to use the services provided by the above Warned Borrower Signature Date Co-Borrower Signature Date Please Forward this document along with the foUavving information to tinder snd lender's counsel: Proof of income -Vf Past 2 bank statements __Y++ Proof of at-y eacpected income for the last ~5 days -Y Copy of a current utility bill -Y Letter expluinitig reason For d~linttirdsty and any supporting, documentatlore {hardship letter) Listing agreement (if property is currently on the nnarket) t'hone: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF -E epI r AM G 1.., -4 4 F???3 a?!4tj??t f??i .,?.. Nationstar Mortgage LLC vs. Syeda Ali (et al.) Case Number 2012-6080 SHERIFF'S RETURN OF SERVICE 10/08/2012 05:35 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 8, 2012 at 1735 hours, she 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: Syeda Ali, by making known unto Waj Wajihullah, Son of Syeda Ali at 112 Old Mill Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him pers ally the said true and correct copy of the same. VALERI WEARY, DEPUTY 10/08/2012 05:35 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 8, 2012 at 1735 hours, she 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: Hafeez Kahn, by making known unto Waj Wajihullah, Step Son of Syeda Ali at 112 Old Mill Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. VALERIE WEARY, DEPUTY SHERIFF COST: $59.00 October 10, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ,vS;.nte SherK, Teleosoft, Irc ~'=- ""':'iii F'K~TN(~~,~~`"~,~~~•a Nationstar Mortgage, LLC 350 Highland Drive ZQ12 ~~~ 20 R'INTI~I~ COURT OF COMMON PLEAS Lewisville, Texas 75067 ut1MBERLANa:~~RLAND COUNTY, PENNSYLVANIA Plaintiff PENNSYLVANIA v. :Docket No. 2012-6080 Syeda Ali and Hafeez Kahn, :CIVIL ACTION- MORTGAGE FORECLOSURE Defendants REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012, governing the Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned hereby certifies as follows: 1. Defendant is owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in acourt-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/App inted Legal Repre tative Signature o Defen ant ~.~--~ i( t2© ~ZO(Z Date Date I(~16~~v Signature of Defendant y Date Nationstar Mortgage, LLC 350 Highland Drive Lewisville, Texas 75067 Plaintiff v. Syeda Ali and Hafeez Kahn, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2012-6080 CIVIL ACTION- MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendants, Syeda Ali and Hafeez Kahn, hereby certify that I am serving a copy of the Praecipe for Entry of Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney, on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Joshua I. Goldman KML Law Group Suite 5000- BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 For the Plaintiff MIDPENN LEGAL SERVICES DATE: fr ~~ (zoc2 ~Q ~J~ d'~ Ja' e M. Haley, Esquire Attorney for Defendant Supreme Ct. ID # 205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 Nationstar Mortgage, LLC 350 Highland Drive Lewisville, Texas 75067 Plaintiff v. Syeda Ali and IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2012-6080 Hafeez Kahn, :CIVIL ACTION- MORTGAGE FORECLOSURE Defendants PRAECIPE FOR ENTRY OF APPEARANCE t!°,.,~ ~ w~~ -; x %d ~ -:~ rn C!)~ -<x'' N O ~%~ ~ r~ ~ °f ~, TO THE PROTHONOTARY: ~ ~ '~' :~ ~~ 1~, c ~ `?y=' ~' :~ _.~ .~ ~:,; " -~• ~ - Please enter the appearance of MidPenn Legal Services on behalf of the Defendant s, Syeda Ali and Hafeez Kahn, in the above matter, representing the Defendant in the Cumberland County Residential Mortgage Foreclosure Diversion Program. DATE: ~ I JZo (.Z.o ~ •Z Respectfully Submitted, MIDPENN LEGAL SERVICES . ~~.~ d" Jaime M. Haley, Esquire Attorney for Defendant Supreme Ct. ID # 205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 Nationstar Mortgage, LLC 350 Highland Drive : IN THE COURT OF COMMON PLEAS Lewisville, Texas 75067 :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. :Docket No. 2012-6080 Syeda Ali and Hafeez Kahn, :CIVIL ACTION- MORTGAGE FORECLOSURE Defendants c~ c ~, d ~~=} m~ PRAECIPE FOR ENTRY OF APPEARANCE z rn -~r 2~ .E -err c cs {~ n aa. a ~ ° TO THE PROTHONOTARY: Z ~ s ~ A~ `;a --~ --- ~' -f w =~ ~,. Please enter the appearance of MidPenn Legal Services on behalf of the Defendants, Syeda Ali and Hafeez Kahn, in the above matter, representing the Defendant in the Cumberland County Residential Mortgage Foreclosure Diversion Program. DATE: 1'20 (2ocZ Respectfully Submitted, MIDPENN LEGAL SERVICES Gl~u-c.~ -~C~c~ ~C~~~ Jaime M. Haley, Esquire ~" Attorney for Defendant Supreme Ct. ID # 205255 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 '-~ . Nationstar Mortgage, LLC 350 Highland Drive Lewisville, Texas 75067 Plaintiff v. Syeda Al and Hafeez Kahn, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2012-6080 CIVIL ACTION- MORTGAGE FORECLOSURE CASE MANAGEMENT ORDER AND NOW, this ~? day of / , 2012, the defendant/bo~rower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in acourt-supervised conciliation Conferecnce on /(o 02 CJ/,3 at ~ ,'~ in ~~~_r,~.~i.P/?,D # / at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made and may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form ~ with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The 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 must discuss resolution proposals with the authorized representative in advance 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 in lieu of foreclosure; entering into a loan modification or 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. DISTRIBUTION: / Jaime M. Haley, Esquire MidPenn Legal Services 401 E. Louther Street, Ste 103 Carlisle, PA 17013 For the Defendant a~ ~~ C~~~;,~~'d~e ~~ , .: _, ;... _~... _ r ~ ru -s-' ,_i , F-~ _ __,,_ - ~t ~ -- . > ~, „'~a, ~~ _ ' ~ - / Joshua I. Goldman KML Law Group Suite 5000- BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 For the Plaintiff BY THE COURT, NATIONSTAR MORTGAGE LLC, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 12-6080 SYEDA ALI and HAFEEZ KAHN, Defendants IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held April 30, 2013,were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley,Esquire, attorney for the defendants. There have been some changes in the marital situation of the defendants. It was agreed that the occupant of the home, Lee Star(formerly Hafeez Kahn), will provide to the plaintiff, within seven(7) days,updated pay stubs and bank statements. A continued conciliation conference will be.set by order of even date herewith. ORDER AND NOW,this :1 day of April, 2013,a continued conciliation conference is set in this matter for Friday,May 31, 2013, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevin ess, P. J. athan Wolf, Esquire For the Plaintiff me Haley, Esquire 'rnav :Z. For the Defendants, -Or-h Arn T— CD GrN :z) NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION—LAW NO. 12-6080 SYEDA ALI and HAFEEZ KAHN, Defendants IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held May 31, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the defendants. It appears that this matter continues under active consideration for some sort of loan modification. The bank requires a signed and dated tax return for the year 2012 as well as an updated hardship letter. That should complete the packet for the bank's consideration. A continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this 3/­day of May, 2013, a continued conciliation conference is set in this matter for Friday, July 26, 2013, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. Nathan Wolf, Esquire For the Plaintiff -o w ime Haley, Esquire T?For the Defendants, :rlm cz fts : - 6b NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 12-6080 SYEDA ALI and HAFEEZ KAHN, Defendants IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held July 26, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the defendants. A change in name in this case has caused some confusion and requires that the homeowners re-apply for loan modification consideration. A new packet will be submitted on or before August 16, 2013. It was further agreed that the loan modification packet would include a copy of the court order changing the name of Hafeez Kahn to Lee Star. A continued conciliation conference will be set by order of even date herewith. ORDER .AND NOW, this 25* day of July, 2013, a continued conciliation conference is set in this matter for Friday, September 27, 2013, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, Q-, r Kevin . Hess, P. J. i :. +Nathan Wolf, Esquire For the Plaintiff / � Jaime Haley, Esquire --3 For the Defendants Am � NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION—LAW NO. 12-6080 SYEDA ALI and HAFEEZ KAHN, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z ?' day of September, 2013, at the request of counsel for the parties, the conciliation conference set for September 27, 2013, is continued to Thursday, November 14, 2013, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, -4 10L Kevi . Hess, P. J. athan Wolf, Esquire For the Plaintiff Jaime Haley, Esquire For the Defendants :rlm . Z.-a' c- oo NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION—LAW : NO. 12-6080 SYEDA ALI and LEE STAR (formerly HAFEEZ KAHN), • Defendants • IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held November 14, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the defendant, Lee Star(formerly Hafeez Kahn). Updated documents including consecutive pay stubs and a current profit and loss statement will be submitted within seven(7) days. A continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this /S` day of November, 2013, continued conciliation conference is set for Friday, January 3, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, 4G Key' • . Hess, P. J. Nathan Wolf, Esquire For the Plaintiff "ate w rrt W ..M., ✓Jaime Haley, Esquire ° "11 ° For the Defendants -<> n :rim Q ,,,�1` / C aT 11/1s//3 3 NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION—LAW : NO. 12-6080 SYEDA ALI and LEE STAR • (formerly HAFEEZ KAHN), • Defendants ORDER AND NOW,this 6 day of January, 2014, following continued conciliation conference,this case is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is VACATED. BY THE COURT, Kevin . Hess, P. J. Xthan Wolf, Esquire For the Plaintiff Haley, Esquire For the Defendants :rim 0 4.614e-S Pe&I CELL cr /4 nel, -A 1