HomeMy WebLinkAbout13-1417 KML LAW GROUP, P.C.
SUITE 5000- BNY MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413 -2311
NN'WW.KMLLAWGR0IIP.00N1
NATIONSTAR MORTGAGE LLC IN THE COURT Of" COMMON PLEAS
350 Highland Drive
Lewisville, TX 75067 OF CUMBERLAND COUNTY CIVIL
Plaint
vs. ACTION - LAW
AMY S. MAURICE
JEREMIAH W. MAURICE ACTION OF MORTGAGE FORECLOSURE
Mortgagors and Record Owners
16th Street
New Cumberland, PA 17070 i;NL
Defendants FORECIASM,
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 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 WITH 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 _
LEGAL SERVICES INC '
8 Irvine Row a
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) dias de plazo al partir de la fecha de la demanda y la notifieacion.
Hace 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 demanda en contra suya sin previo aviso o notifieacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAMBI�
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 0J"4'6 g-3
3 t# 2/ 7
2w Q c?6 Q
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
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COL.LF.CT
A DEBT OWED TO OUR CLIENT ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COL.L.ECTING THE DEBT.
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.gov 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.asl)x
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 .org/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(_& kmllawup.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 118333FC.
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
1. Plaintiff is NATIONSTAR MORTGAGE LLC, 350 Highland Drive, Lewisville, TX 75067.
2. The names and addresses of the Defendants are AMY S. MAURICE, 305 16th Street, New Cumberland,
PA 17070 and JEREMIAH W. MAURICE, 305 16th Street, New Cumberland, PA 17070, who are the
mortgagors and record owners of the mortgaged premises hereinafter described.
�. On October 12, 2010 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR NATIONSTAR MORTGAGE LLC, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County on October 22, 2010 as Instrument # 201030334. The
mortgage has been assigned to: NATIONSTAR MORTGAGE LLC by assignment of Mortgage.
Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as
Exhibit C. 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
112N" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for August 01, 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 ............................... ............................... ....................$123,563.44
Interest from 07/01/2012 through 02/26/2013 at 4.5000 % . ......................$3,706.88
Per Month interest rate at $463.36
Escrow Advances .................................... ............................... ......................$1,366.67
PropertyInspections ............................... ............................... .........................$9.15
PropertyPreservation .................................. ............................... ...... ................$1,655.0 0
$130,301.14
7. Plaintiff is not seeking a judgment of personal liability (or an " 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, as required by Act 6 of
1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such
Notice attached and incorporated as Exhibit "B ".
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $130,301.14,
together with interest at the rate of 4.500% 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 Sheriffs Sale of the Property.
.r
By:
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047
,fill P. Jenkins Pa. ID 306588
' Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
VERIFICATION
Myssa Qu+ntaniila hereby
states that he /she is
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 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.
Date:
�ll/l
Alysm QuIntaiiHIL-
Assistant Serretary
#118333FC - AMY S. MAURICE and JEREMIAH W. MAURICE
3 05 16th Street New Cumberland, PA 17070
Ex,hibit A
ALL THAT CERTAIN tract or parcel of land situated in the Borough of New Cumberland, County of
Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described according to a
survey of D.P. Raffensperger, Registered Surveyor, dated January 14, 1956, as follows:
BEGINNING at a point on the northwestern side of 16th Street two hundred fifty (250) feet southwest of
the intersection of 16th Street and Bridge Street; thence southwardly along the same twenty-five (25) feet
to a point at the dividing line between Lots Nos. 91 and 92 on the hereinafter mentioned Plan of Lots;
thence northwestwardly along the same at right angles to 16th Street, one hundred ninety-six (196) feet to
a point on the southeastern side of twenty (20) feet wide alley; thence northeastwardly along the same
twenty -five (25) feet to a point; thence southeastwardly through part of Lot No. 92 at right angles to 16th
Street through the center of partition wall and beyond, one hundred ninety -six (196 ) feet to a point, the
place of BEGINNING.
BEING the western one -half of Lot No. 92 on Plan of Haldeman Plat, recorded in Plan Book "A ", Page
48.
HAVING THEREON ERECTED a two and one -half story brick and frame dwelling house known and
numbered as 305 16th Street.
Meaning and intending to describe the same premises as conveyed to Jeremiah W. Maurice and Amy S.
Maurice, last deed filed March 19, 2003 and recorded in Book 256 Page 780 of the Cumberland County,
Pennsylvania Records.
305 16th Street , New Cumberland, PA 17070
Permanent Parcel No.: 26 -23- 0541 -057
E.xhibit B
Nationstar Mortgage, LLC
PO Box 9095 PRESORT First -
Temecula, CA 92589 -9095 Class Mail U.S.
Postage and Fees
Paid
WSO
Send Payments to: 7196 9006 9296 2693 6529
Nationstar Mortgage
PO Box 650783
Dallas, TX 75265 -0783
20121004 -160
'l 11'I'il'll lol Ill l l "111111 11111111 111 I I' 1' I I I I I l l l l l i l l l l l
AMY S MAURICE
30516TH ST
NEW CUMBERLAND, PA 17070 -1316
PA_ACT6
Nationstar Mortgage, LLC
PO Box 9095 PRESORT First -
Temecula, CA 92589 -9095 Class Mail U.S.
Postage and Fees
Paid
WSO
Send Payments to: 2266395230
Nationstar Mortgage
PO Box 650783
Dallas, TX 75265 -0783
20121004 -160
l llll'11 11 "11111'1 ••1 •• 1 1111 '1'
JEREMIAH W MAURICE
30516TH ST
NEW CUMBERLAND, PA 17070 -1316
PA_ACT6
> i r'
Sent Via Certified Mail
7 19 6 9006 9296 2693 6529
10/04/2012
AMY S MAURICE
305 16TH ST
NEW CUMBERLAND, PA 17070 -1316
Loan Nwnber: _,304
Property Address: 305 16TH ST
NEW CUMBERLAND, PA 17070
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear AMY S MAURICE:
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 your
property located at
305 16TH ST
NEW CUMBERLAND, PA 17070
IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the
months of08 /01 /2012 through 10/04/2012 as follows:
Next Payment Due Date 08/01/2012
Total Monthly Payments Due: $3,754.80
Late Charges: $123.42
Other Charges: Uncollected NSF Fees: $0.00
Other Fees: $0.00
Corporate Advance Balance: $0.00
Unapplied Balance ($41.14)
TOTAL YOU MUST PAY TO CURE DEFAULT: $3,837.08
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 $3,837.08.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $3,837.08, plus any additional monthly payments and late charge which may fall due during this
period. Such payment must be made either by cash, cashier's check, certified check or money order.
PA ACT6
Page Iot3 7196 9006 9296 2693 6529
Please include your loan number and property address with your payment and send to:
Nationstar 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 " 11 be considered due
inunediately and you may lose the chance to pay off the original mortgage in monthly installments. 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 mortgaged
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 $50.00. 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 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 Sheriffs 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 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 six (6)
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 Sheriffs 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 Sheriffs 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 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 TRA \ISFEREE 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 occurred.
However, you are not entitled to this right to cure your default more than three times in any calendar year.
PA ACT6
Paget of3 7196 9006 9296 2693 6529
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nationstar Mortgage, LLC' offers
conswner 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:OOA.M.- 7:OOP.M. Central Time. WE ARE VERY
INTERESTED IN ASSTSTTNG 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 nine (9) months, AND
joined after signing the Note and Security Instrument now in default, please notifYNationstar Mortgage, LLC
immediately. 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 asswned 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 agencies
immediately. These agencies specialize in helping homeowners who are facing financial difficulty. 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 homes. To obtain a list of approved counseling
agencies, please call (800) 569 -4287 or visit http: / /www.hud.gov /offices /bsg /sfb /hcc /hcs.efrn.
You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure
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.
Sincerelv,
Krystal Starr
Assigned Foreclosure Prevention Specialist
Nationstar Mortgage, LLC
8888115281 ext. 73115
350 Highland Drive
Lewisville, TX 75067
FEDERAL LAW REQUIRES 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 BEE'! 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
Page3 of3 7196 9006 9296 2693 6 52 9
onstae
at09T C, AG
10/04/2012
JEREMIAH W MAURICE
305 16TH ST
NEW CUMBERLAND, PA 17070 -1316
Loan Nwnber: 3 04
Property Address: 305 16TH ST
NEW CUMBERLAND, PA 17070
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear JEREMIAH W MAURICE:
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 your
property located at
305 16TH ST
NEW CUMBERLAND, PA 17070
IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the
months of08/01/2012 through 10/04/2012 as follows:
Next Payment Due Date 08/01/2012
Total Monthly Payments Due: $3,754.80
Late Charges: $123.42
Other Charges: Uncollected NSF Fees: $0.00
Other Fees: $0.00
Corporate Advance Balance: $0.00
Unapplied Balance ($41.14)
TOTAL YOU MUST PAY TO CURE DEFAULT: $3,837.08
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 $3,837.08.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $3,837.08, plus any additional monthly payments and late charge which may fall due during this
period. Such payment must be made either by cash, cashier's check, certified check or money order.
°A ACT6
Page Ioi 2266395230
Please include your loan number and property address with your payment and send to:
Nationstar 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 '" 11 be considered due
inunediately and you may lose the chance to pay off the original mortgage in monthly instalhnents. 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 mortgaged
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 $50.00. 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 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 Sheriffs 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 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 six (6)
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 Sheriffs 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 Sheriffs 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 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 TRA \ISFEREE 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 occurred.
However, you are not entitled to this right to cure your default more than three times in any calendar year.
PA ACT6
Page2 ot3 2266395230
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nationstar Mortgage, LLC offers
conswner 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:OOA.M.- 7:OOP.M. Central Time. WI? 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 nine (9) months, AND
joined after signing the Note and Security Instrument now in default, please notifYNationstar Mortgage, LLC
immediately. 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 asswned 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 horne. 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 fmancial difficulty. Housing
counselors can help you assess your fmancial condition and work with us to explore the possibility of
modifl ing 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 homes. To obtain a list of approved counseling
agencies, please call (800) 569 -4287 or visit http: / /www.hud.gov /offices /hsg /sfh /hcc /hcs.cfi
You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure
counseling agency. You may call the following toll -free numher 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,
Krystal Starr
Assigned Foreclosure Prevention Specialist
Nationstar Mortgage, LLC
8888115281 ext. 73115
350 Highland Drive
Lewisville, TX 75067
FEDERAL LAW REQUIRES 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 BEE'! 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
Page3 ot3 2266395230
Exhibit C
When Recorded Return To:
DOCUMENT ADMINISTRATION
Nationstar Mortgage
2617 COLLEGE PARK
SCOTTSBLUFF, NE 69361
Parcel No. 26 -23- 0541 -057
Illlllllllllllllllllillllllllllllllllllllllllllmlllllllll
CORPORATE ASSIGNMENT OF MORTGAGE
Cumberland, Pennsylvanjiailla
SELLER'S SERVICING #: 304 "MAURICE"
MERS #: —3045 SIS #: 1- 888 - 679 -6377
Date of Assignment January 22nd, 2013
Assignor: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
NATIONSTAR MORTGAGE LLC, ITS SUCCESSORS AND /OR ASSIGNS
Assignee: NATIONSTAR MORTGAGE LLC
Ihereby certifyte -p T,es within named Assignor is P.O._BOX2026 FONT, MI 48501.
1 hereby certify the precise ithin named Assignee is 350 HIGHLAND DRIVE,
LEWISVILLE, TX 75 1 - -,
MORTGAGE ELECTRONIC RE ISTRATION SYSTEMS, INC is at 1901 E Voorhees Street, Suite C,
Danville, .IL 61834, P.O. BOX 2026, FLINT, M148501 -2026
Executed By: JEREMIAH W MAURICE AND AMY S MAURICE HUSBAND AND WIFE To:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NATIONSTAR
MORTGAGE LLC
Date of Mortgage: 10/12/2010 Recorded: 10/22/2010 in Book!Reei /Liber: N/A Page /Folio: N /Aas
Instrument/Document 201030334 In the County of Cumberland, State of Pennsylvania.
305 16TH ST, NEW CUMBERLAND, PA 17070 in the Borough of NEW CUMBERLAND
I do certify ha be precise address of NATIONSTAR MORTGAGE LLC is 350 HIGHLAND DRIVE,
LEWISVIL , TX 730U" I
Attested By: — ?
KNOW ALL MEN BY THESE PRESENTS, that for good and valuable consideration, the receipt and
sufficiency of which is hereby acknowledged, the said Assignor hereby assigns unto the above -named
Assignee, the said Mortgage having an original principal sum of $134,431.00 with interest, secured
thereby, with all moneys now owing or that may hereafter become due or owing in respect thereof, and
the full benefit of all the powers and of all the covenants and provisos therein contained, and the said
assignor hereby grants and conveys unto the said assignee, the assignor's beneficial interest under the
Security Instrument.
TO HAVE AND TO HOLD the said Security Instrument, and the said property unto the said assignee
'T G 1'111iTl3RANATN *01/2212013 04:01:40 PM* NATT01NATNA000000000000000030749* PACUMBE*
304 PASTATE MORT ASSIGN ASSN *'TRANATN*
CORPORATE ASSIGNMENT OF MORTGAGE Page 2 of 2
forever, subject to the terms contained in said Security Instrument.
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NATIONSTAR
MORTGAGE LLC, ITS SUCCESSORS AND /OR ASSIGNS
On
By:
REGINA L HL esident
�Mlllllfllll�
STATE OF Nebraska
COUNTY OF Scotts Bluff
On \ d,l;S-( , before me, IRENE GUERRERO, a Notary Public in and for Scotts Bluff in the
State of Nebrasa, personally appeared REGINA LASHLEY, Vice - President of MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NATIONSTAR MORTGAGE LLC,
ITS SUCCESSORS AND /OR ASSIGNS, personally known to me (or proved to me on the basis of
satisfactory evidence) to be the person(s) whose name(s) is /are subscribed to the within instrument and
acknowledged to me that he /she /they executed the same in his /her /their authorized capacity, and that by
his /her /their signature on the instrument the person(s), or the entity upon behalf of which the person(s)
acted, executed the instrument.
WITNESS my hand and official seal,
n GEUEPAL NOTARY - State of Nebraska
JlrM -01 \AguJ 01 IR
M Comm, IRENE GUERRO
Notary Expires: 09/14/2013
(This area for notarial seal)
*TG1 *TRANATN *01 / 22 / 2013 04:01:40 PM* NATI01NATNA000000000000000030749* PACUMBE*
304 PASTATE_MORT_ASSIGN_ASSN * *TRANATN*
IN THE COURT OF COMMON PLEAS OF -
CUMBERLAND COUNTY, PENNSYLVANfA
NATIONSTAR MORTGAGE LLC
Plaintiff
vs. Case No.
AMY S. MAURICE
el"Vil
JE REMIAH W. MAURICE
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 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 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 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
m
forat 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.
Respectfully submitted:
(Signature o Counsel for Plaintiff)
Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Dockct #
BORRO`vVER REQUEST FOR HARDSHIP ASSIST ANCE
To complete -your request for hardship assistance, your lender must consider your
C :
rcumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name
Property Address:
City: _ State: _ Zip: - --
Is the property for sale? Yes L - No Listing date: Price: $
Realtor Name: Real tor Phone.
Borrower Occupied'? Yes E�r ii No ]—
Mailing Address (if different):
City: ^rt __ State..._
Phone Numbers: Home: Office:
Cell: — Other:
Email: _
# of people in household: How long?
Mailing Address:
City: -- State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email: - -- - - --
# of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Tyne of Loan: 4
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance;__
Date of Last Payment: _�_
Primar Reason for Default:
Is the loan in Bankruptcy? Yes 0 No [�
'f yes, provide names, location of court, case nuinbcr & attorney:
Assets A mount Owed Value:
Home: ....
Other Real Estate: $
Retirement Funds: S
investments: $_
Checking: S
Savings: $ S
Other: �� 5--- ..__ —_____
Automo 91: Model:
Amount owed: Value:
Automobile #2 : Model: � � Yea-
Amount owed: Value: _
Other transportation (automobiles boats motors Iles) Model:
Year Amount owed: Value
Month[y Income
Name of Employers:
L..
Additional income Description (not wages):
monthly amount:
L- mon&Jy amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses- (Please only include expenses you are currently paying)
EXPENSE AMOUNT l I~XPENSE AR40UNT
MortgaRe Food
T MqqLaLe Utilities
Car Pa ens CondoNei . Fees
Auto Insurance Mod. (not covered
Auto fuellre irs Other prop. p ayment
Install. Loan Payment Cable TV I _ -
Child Su rt/Atim. S pending
Day /Child Care/Tuit. Other Ex nses
,Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes t No [-"
If yes, please provide the following information:
Counseling Agency: _
Counselor:
Phone (Office): t Fax: _
Have yo z r:ade application for Homeowners Emergency Mortgage Assistance I'ragram
(MEMAP) assistance?
Yes ] No 7
If yes, please indicate the status of the application:__,
Have you had any prior negotiations with your lender or tender's 'oan servicing company
to resolve your delinquency?
Yes Non
If yes, please indicate the status of those negotiatio ls:
Please provide the following information, if know, regarding your Iender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Flame):
Contact: Phone:
authorize the above
named to uselrefer this information to my lender /servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. VWe
understand that I/we am/are under no obligation to use the 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:
N Proof of income
y` Past 2 bank statements
f
N Proof of any expected income for the last 45 days
r
N Copy of a current utility bill
N Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
ti Listing agreement (if property is currently on the market)
�y
SHERIFF'S OFFICE OF CUMBERLAND COUNTY-o':K
Ronny R Anderson ter'
Sheriff cnr `
tit lr'ataGr, �� C3
Jody S Smith
Chief Deputy � � 7>n ;r-�=�.
Richard W Stewart
Solicitor
OFFICE, THE '.SRIFF �� •_«
Nationstar Mortgage, LLC .
Case Number
vs.
2013-1417
Amy S Maurice(et al.)
SHERIFF'S RETURN OF SERVICE
03/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Amy S Maurice, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not
Found"at 392 W. Pine Street, South Middleton, Mt. Holly Springs, PA 17065. Per the Mt. Holly Springs
Postmaster mail is still delivered to this address.
03/25/2013 05:20 PM-Deputy Valerie Weary, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diverion Program &Complaint in Mortgage Foreclosure by handing a
true copy to a person representing themselves to be Rita Maurice-Mom,who accepted as"Adult Person
in Charge"for Jeremiah Maurice at 392 W. Pine Street, South Middleton, Mt. Holly Springs, PA 17065.
VALERIE WEARY, DEPUTY
04/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Jeremiah Maurice, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not
Found"at 305 16th Street, New Cumberland Borough, New Cumberland, PA 17070. Residence is vacant.
04/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Amy S Maurice, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diverion Program &Complaint in Mortgage Foreclosureas"Not Found"at 314 3rd Street, New
Cumberland, PA 17070.
SHERIFF COST: $100.00 SO ANSWERS,
April 22, 2013 RONPV R ANDERSON, SHERIFF
(c)Gounty8uito 8heritf,'T'oteosoft.Inc.
KML Law Group,P.C. 2013 TA R
Suite 5000-BNY Independence Center 10: 56
701 Market Street COIJN
Philadelphia,PA 19106-1532 PEWS
215-627-1322 YL VAWI� T y
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT OF COMMON PLEAS
Lewisville,TX 75067
VS. OF Cumberland COUNTY
AMY S.MAURICE and JEREMIAH W. MAURICE
305 16th Street
New Cumberland,PA 17070 No. 13-1417
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P.430(a)
-Plaintiff,by and through its attorney,in support of its Motion for Substituted Service,
represents as follows:
1. Plaintiff is the holder of a mortgage upon the premises 305 16th Street,New Cumberland,
PA, 17070,hereinafter,the "mortgaged premises".
2. Defendants, AMY S.MAURICE and JEREMIAH W. MAURICE,are the mortgagors
and real owners of the mortgaged premises.
3. Pursuant to Cumberland County Local Rule 208.3(a)(2)and/or Rule 208.3(a)(9),I
hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not
aware that the Defendant has obtained counsel. Moreover,due to the nature of this motion, it was not
possible to locate or contact the Defendant to request his concurrence.
4. The last known address of Defendant,Amy S.Maurice, is 305 16th Street,Cumberland,
PA 17070 from our investigative search.
5. The Sheriff has been unable to effect service of the Complaint upon Defendant,Amy S.
Maurice. Service was attempted at the mortgaged premises 305 16th Street,Cumberland,PA 17070. The
property is vacant. Service was attempted on Defendant,Amy S.Maurice at 314 P Street,New
Cumberland,PA 17070. The return of service indicates Defendant,Amy S. Maurice was not found at
said address. Service was attempted on Defendant,Amy S.Maurice at 392 W.Pine Street, South
Middleton,Mt Holly Springs,PA 17065. The return of service indicates Defendant,Amy S.Maurice was
not found at said address.
6. The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendant,Amy S.Maurice.
WHEREFORE,Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Complaint upon Defendant,Amy S.Maurice,by posting the premises and certified and
regular mail to the Defendant's last known address.
-e�7
-, ,1
KML LAW GR I ,P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ED 78020
Kristina Murtha Pa. ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
JilV.Jenkins Pa. ID 306588
cMyk Oflazian Pa. ID 312912
Attorneys for Plaintiff
'
Affidavit of Good Faith Investigation
At the request of the law firm identified below|initiated an investigation into the whereabouts cdthe -------
defendant identified ao the subject below. The following is true and accurate representation ofmy
investigation,
Client provided infonnation: File Number: 118333FC
Attorney/Law Firm:KML LAW GROUP, P.C
Subject Name:AMY S. MAURICE
Property Address:Street: 305 16th Street
City: New Cumberland State: PA Zip: 17070
SIdp Results: Date of Birth:411IM11111111111111111111111 ProVest File Number:3623423
Last Known Address(as of 4119/2013)Street:305 16Th St
City: New Cumberland State:PA Zip: 17070
Death Record Search As of 04/19/2013,the Social Security Administration has no death
record on file for Amy S.Maurice
Social Security Number [XI Verifed[I Not Verified
ployment Search During a search for employment of our defendant no employment
information was provided prior to the investigation or found during the
Business Records Search No verifiable business records found.
Creditor Header Inquiry The latest address from the credit header info is:
Address:305 16TH ST, NEW CUMBERLAND, PA 17070 1316
Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania.
Vehicle Records Search*
Drivers Ucense Information Search No current records found,
Professional Licenses Search No current records found.
Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal
Made to U.S.Postal Service inspector at the zip code listed with no return information to date:
305 16TH STREET I NEW CUMBERLAND I PA 1170701
CUMBERLAND COUNTY
Military Search Not on Active Duty;Did not leave Active Duty within the past 367 days;
Has not been notified of a future call up to Active Duty
Inquiry of Relatives, 717-770-1207: Called possible number of defendant,Amy S Maurice,
Neighbors,&Friends voicemail identifies Susan Black,no message left.
717-655-5620: Called possible relative,Chris Tresler,answering
machine answered,no message left.
717-774-0215: Called possible neighbor, Russell King,answering
machine answered,no message left-
717-774-6505: Called possible neighbor, Russell King, unknown
female does not know defendant.
717-486-7506: Called possible relative,Terry Maurice,unknown
female does not know defendant.
717-731-3466: Called possible relative,Teodora T Bonney,answering
machine answered, no message left.
Comments: 717-805-0422: Called possible mobile phone number of defendant,
Amy S Maurice, a generic answering machine answered,no message
717-770-0863: Called possible number of defendant,Amy S Maurice,
number has been disconnected.
Also showing current for defendant: 314 3RD 01 NEW CUMBERLAND
PA 17070
'Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA."•Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND,
SC,WV.
+Data available in CO,CT,DE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY.
The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A.
§4904 relating to unswom falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and
that the facts stated in it are true.
7 ,
f ,
r STATE OF FLORIDA
COUNTY OF HILLSBOROUGH APR 2 2 2013
Cassey Hanks ProV ile Number:3623423 Sworn to or affirmed and signed before me on this_day of
Provest.Services (Seal)
Date:
JOSHUA H.PIMENTEL,
Notary Public State of Florida
My t6ffiffi.Expires May 24,2015 Signature of lot Public
No.EE 97050
I VA
Printed Name of Notary Public
ersonally Known
( )Produced
as identification
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith ,
Chief Deputy
Richard W Stewart
Solicitor CIMCE OF THS$RGRrl±
Nationstar Mortgage, LLC
Case Number
vs. 2013-1417
Amy S Maurice(et al.)
SHERIFF'S RETURN OF SERVICE
03/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry
for the within named Defendant to wit:Amy S Maurice, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not
Found"at 392 W. Pine Street, South Middleton, Mt. Holly Springs, PA 17065. Per the Mt.Holly Springs
Postmaster mail is still delivered to this address.
-03/25/2013 05:20 PM-Deputy Valerie Weary, being duly sworn according to law,served the requested Notice of
Residential Mortgage Foreclosure Diverion Program&Complaint in Mortgage Foreclosure by handing a
true copy to a person representing themselves to be Rita Maurice_.Mom,who accepted as"Adult Person
in Charge"for Jeremiah Maurice at 392 W. Pine Street, South Middleton, Mt. Holly Springs, PA 17065.
VALERIE WEARY, DEPUTY
04/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Jeremiah Maurice, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not
Found"at 305 16th Street, New Cumberland Borough, New Cumberland, PA 17070. Residence is vacant.
04/1712013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Amy S Maurice, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within.requested Notice of Residential Mortgage Foreclosure
Diverion Program &Complaint in Mortgage Foreclosureas"Not Found"at 314 3rd Street, New
Cumberland, PA 17070.
SHERIFF COST:$100.00 SO ANSWERS,
April 22,2013 RONV.R ANDERSON, SHERIFF
(c)GountySuite SherH,7eleoso fl Inc.
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
215-627-1322
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC
350 Highland Drive
Lewisville,TX 75067" IN THE COURT OF COMMON PLEAS
vs. OF Cumberland COUNTY
AMY S. MAURICE and JEREMIAH W.MAUIZICE
305 16th Street
New Cumberland,PA 17070 No. 13-1417
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P.430(x)
Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant,Amy S.
Maurice,which the Sheriff has been unable to personally serve upon Defendant,Amy S.Maurice. As
noted in the attached Motion,Plaintiff has made a good faith attempt to ascertain Defendant's
whereabouts without success. Accordingly,the Court may approve alternative means of service. See
Pa.R.C.P.430(x).
CONCLUSION
For reasons stated above and in the attached Motion,the Court should enter an order
allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant,Amy S. Maurice, by
posting the premises and certified mail and regular mail to the Defendant's last known address.
By:
KML LAW GR UP,P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Ji P.Jenkins Pa. ID 306588
r/Alyk Oflazian Pa. ID 312912
Attorneys for Plaintiff
ICVVM Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
215-627-1322
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT
vs. OF COMMON PLEAS
Lewisville, TX 75067
of Cumberland County
AMY S.MAURICE
JEREMIAH W.MAURICE No. 13-1417
305 16th Street
New Cumberland,PA 17070
CERTIFICATE OF SERVICE
Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does
hereby certify that true and correct copies of the foregoing Motion for Substituted Service have
been served upon the Defendants,Amy S. Maurice and Jeremiah W. Maurice this /t day of May
2013, by first class mail,postage prepaid.
AMY S. MAURICE
305 16th Street
New Cumberland, PA 17070
AMY S. MAURICE
392 West Pine Street
Mount Holly Springs, PA 17065
AMY S. MAURICE
314 3rd Street
New Cumberland, PA 17070
JEREMIAH W. MAURICE
392 West Pine Street
Mount Holly Springs, PA 17065
By:
KML Law Group, P.C.
Marlene Powers, Legal Secretary
Direct Phone: 215-825-6340
L5
NATIONSTAR MORTGAGE LLC IN THE COURT OF COMMON PLEAS
350 Highland Drive
Lewisville,TX 75067 OF Cumberland COUNTY
VS.
MCD
AMY S.MAURICE and JEREMIAH W.MAURICE 13-1417
305 16th Street -<>
New Cumberland,PA 17070 CD
C-D
CD
ORDER
wo�
AND NOW,this A A day of/MY2013,upon consideration of the Pldl-&iffs-
Motion for Substituted Service under Pa.R.C.P.430(a)and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant,Amy S.Maurice,have been unsuccessful,
it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in
Mortgage Foreclosure upon Defendant,Amy S.Maurice,by posting a copy of the Complaint upon the
premises 305 16th Street,New Cumberland,PA, 17070, and Plaintiff is directed to serve the Complaint
by certified and regular mail to the Defendant's last known address at 305 16th treet NevjL Cumberland,
PA, 17070, d
UW11 V1 :yll
P 9 eriff
i goo
BY COURT:
J.
pD,igtriibution list:
Michael T. McKeever, Esquire, Suite 5000—BNY Independence Center, 701 Market Street,
P * 'Jelphia, PA 19106-1532
j-,
AMY S. MAURICE, 305 16th Street New Cumberland, PA 17070
07 IT 1'e-9 Na,-6L ,
KML Law Group, P.C.
SUITE 5 000–BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106-1532
(215)627-1322
ATTORNEY FOR PLAINTIFF
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT OF COMMON PLEAS
Lewisville,TX 75067 OF Cumberland COUNTY
Plaintiff
CIVIL ACTION-LAW
VS.
ACTION OF MORTGAGE FORECLOSURE
AMY S.MAURICE
JEREMIAH W. MAURICE Term
305 l6th Street No. 13-1417
New Cumberland,PA 17070
Defendant(s)
M'=
=M
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter. r
C:)
57> —d
By:
KML LAW GROUP,P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay E.Kivitz Pa. ID 26769
—Jir,Jenkins Pa. ID 306588
ua I*Goldman Pa.205047
yk L.Oflazian Pa.ID 312912
Attorneys for Plaintiff
$11.I5 pp AT-f
,-#
A
KML Law Group, P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532 ?L1 d JL
215-627-1322 - � 44 10: 7
Attorne for Plaintiff ' 1M B -) A
NSy,L� ! .
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT OF COMMON
Lewisville, TX 75067 PLEAS
OF Cumberland COUNTY
vs.
CIVIL ACTION-LAW
AMY S. MAURICE and JEREMIAH W. MAURICE
Mortgagor(s) ACTION OF MORTGAGE
305 16th Street FORECLOSURE
New Cumberland,PA 17070
Defendant(s) Term
No. 13-1417
CERTIFICATE OF SERVICE
The undersigned, on behalf of Plaintiff,hereby certifies that on "' 1 3
he did serve upon Defendant(s)AMY S. MAURICE and JEREMIAH W. MAURICE a true and correct
copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order
dated May 22nd 2013. The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
By: c j L
KML Law Group, P.C.
Nick Barone, Legal Assistant
NBarone @kmllawgroup.com
215-825-6365 (Direct Phone)
1
t
4
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff PLED-0F F-1 C�.
Jody S Smith
Chief Deputy y 2G 1 3 JL 1 1 A Its- G 9
Richard W Stewart ' -�
Solicitor i rI�trcOfT14E$4ERtr= CUMBERLAND COUNTY
PENNSYLVANIA
Nationstar Mortgage, LLC Case Number
vs.
Amy S Maurice(et al.) 2013-1417
SHERIFF'S RETURN OF SERVICE
07/01/2013 06:03 PM-Deputy Valerie Weary, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Amy S Maurice, pursuant to Order of Court by"Posting"the premises
located at 305 16th Street, New Cumberland Borough, New Cumberland, PA 17070 with a true and
correct copy according to law. U. 41"�,
VALERIE WEARY, DEPUTY
0710112013 06:03 PM-Deputy Valerie Weary, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: Jeremiah Maurice, pursuant to Order of Court by"Posting"the premises
located at 305 16th Street, New Cumberland Borough, New Cumberland, PA 17070 with a true a d"
correct copy according to law.
VALERIE WEAR , DEPUTY
SHERIFF COST: $55.21 SO ANSWERS,
July 05, 2013 RbNW R ANDERSON, SHERIFF
(C?CountySuAe Sheriff,Teieosott,Inc,
tA,Y t C G
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Jackie Cox,Director of Sales,of The Sentinel,of the County and State aforesaid,being
duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation
in the Borough of Carlisle,County and State aforesaid,was established December 13th,
1881,since which date THE SENTINEL has been regularly issued in said County,and
that the printed notice or publication attached hereto is exactly the same as was printed
and published in the regular editions and issues of
THE SENTINEL on the following day(s):
ulj y 2,2013
(-�
��
COPY OF NOTICE OF PUBLICATION C ��
U)f— r,3 8)o C-;
'�
C:.
C-) =� r
In The Court of Common Pleas Affiant further deposes that he/she%@t
Cumberland County "
Civil.Action-Law interested in the subject matter of the c:) >
No.13-1417
Notice of Action in Mortgage Foreclosure aforesaid notice or advertisement, and that r'
Nationstar Mortgage LLC,Plaintiff vs.Amy S.Maurice s Jeremiah W.
Maurice,Mortgagors and Real Owners,Defendants all allegations in the foregoing statement as :.
To:Amy S.Maurice s Jeremiah Maurice,Mortgagors and Real Owners, to time,place and character of publication
Defendants, whose last known n address is 305 16th Street,New
Cumberland,PA 17070.This firm is a debt collector and we are attempting
to collect a debt owed to our client.Any information obtained from you will be a e.
used for the purpose of collecting the debt.You are hereby notified that
Plaintiff,Nationstar Mortgage LLC,has filed a Mortgage Foreclosure
Complaint endorsed with a notice to defend against you in the Court of
Common Pleas of Cumberland County,Pennsylvania,docketed to No.
13-1417,wherein Plaintiff seeks to foreclose on the mortgage secured on
your property located,305 16th Street,New Cumberland,PA 17070,
whereupon your property will be sold by the Sheriff of Cumberland County.
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 the Complaint and notice are served,by entering d 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 Sworn to and subscribed before me this
that if you fail to do so the case may proceed without you and a judgment
may entered against you by the Court without further notice for any
money claimed in the Complaint 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 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 Bar Association,2 Liberty
Avenue,Carlisle,PA 17013.Legal Services Inc.,8 Irvine Row,Carlisle,PA
17013,717-243-9400.Michael T.McKeever,Attorney for Plaintiff,KML Law Notary ubhc
Group,P.C.,Suite 5000,Mellon Independence Center.701 Market Street, ,
Philadelphia,PA 19106-1532,215-627-1322.
My commission expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Bethany M.Holtry,Notary Public
Carlisle Bom,Cumberland County
My Commission Expires Sept.26,2015
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES °
r
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
July 5, 2013
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.
In the Court of Common Pleas
Cumberland County
Civil Action—Law
t-
No. 13-1417
Nationstar Mortgage LLC, 1sa Marie Coyne,tditor
Plaintiff
Amy S. Maurice&Jeremiah SWORN TO AND SUBSCRIBED before me this
W. Maurice,Mortgagors 5 day of July, 2013
and Real Owners,
Defendants
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
To: Amy S. Maurice&Jeremiah W. Notary
Maurice, Mortgagors and Real
Owners, Defendants, whose last
known address is 305 16th Street,
New Cumberland,PA 17070
This firm is a debt collector and NOTARIAL SEAL
we are attempting to collect a debt DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
Owed to c,.. went. Any information
obtained from you will be used for
the purpose of collecting the debt.
You are hereby notified that Plaintiff
Nationstar Mortgage LLC,has filed a
Mortgage Foreclosure Complaint en-
dorsed with a notice to defend against
You in the Court of Common Pleas of
Cumberland County, Pennsylvania,
docketed to No. 13-1417, wherein
Plaintiff seeks to foreclose on the
mortgage secured on your property
located, 305 16th Street, New Cum-
berland,PA 17070,whereupon your
property will be sold by the Sheriff
of Cumberland County. 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 the Complaint and notice are
served,by entering a written appear-
ance 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 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 with information about
agencies that may offer legal services
to eligible persons at a reduced fee
or no fee.
Cumberland County Bar Assoc.
32 S.Bedford St.
Carlisle,PA 17013
MidPenn Legal Services Inc.
401 E. Louther St.
Carlisle,PA 17013
(717)243-9400
MICHAEL T.McKEEVER,
ESQUIRE
KML LAW GROUP,P.C.
Attys.for Plaintiff
Mellon Independence Center
701 Market St.
Ste. 5000
Philadelphia,PA 19106-1532
(215)627-1322
July 5
(610)254-9980 KML
Fax: (610)254-9982 WjM Invoice#:2013060370
Email: orders@mansfic-Idads.com William J. Mansfield, Inc. Date: 7/16/2013
Legal Advertising
Suite 1209
998 Old Eagle School Road
Wayne,PA 19087-1805
Your cboiec for legal advertising
Since 1939
KML Law Group,P.C.
Attn:Nick Barone
Mellon Independence Center
701 Market St., Ste. 5000
Philadelphia,PA 19106-1532
In Re:Mortgage Foreclosure
NATIONSTAR vs.MAURICE(NO. 13-1417)(118333FC)
Service Charge: 20.00
Publications:
The Carlisle Sentinel;Carlisle,PA 17013 237.98
Published: 7/02/2013
Cumberland Law Journal;Carlisle, PA 17013 265.00
Published: 7/05/2013
Total Due: $522.98
INVOICE
PAYMENT NOT CONTINGENT ON CLIENT REIMBURSEMENT.
ALL INVOICES ARE NET 30 DAYS
Note: Customer copy
This copy is for your records.
In the Court of Common Pleas of Cumberland County
NATIONSTAR MORTGAGE LLC
co XW ITI
350 Highland Drive r"M C--
cr)
Lewisville,TX 75067
Plaintiff No. 13-1417
VS.
AMY S.MAURICE
JEREMIAH W.MAURICE Z-p
(Mortgagor(s)and Record Owner(s))
305 16th Street Lt
New Cumberland,PA 17070
Defendant(s)
PRAECIEPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against AMY S.MAURICE and JEREMIAH W.MAURICE by default
for want of an Answer.
Assess damages as follows:
$132,61794
Debt
Interest from 81112013 to
Date of Sale monthly them at$463.36
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mIlled o d livere to the party against whom judgment
'r
is to be entered and to his attorney of record,if any,after the defF.L'u-'I't 'd nd at st ten days prior to the date of the
a
filing of this praecipe.A copy of the notice is attached.R.C.P.2,37.1
By: 1J A
KML LAW jtV'
Michael MgcKyer Fa, 56129
—Jay E.Kivitz Pa ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615 ll
Joshua I Goldman Pa 205047 ff -7 07
:) Jill P.Jenkins Pa.ID 306588
Andrew F.Gomall Pa.0 92382 y,
Attorneys fur Plaintiff
AND NOW OM At 2D/.J � ,Judgment is entered in favor of
NATIONSTAR,MORTGAGE LLC and'against AMY S.MAURICE and JEREMIA fault for wan f
an Answer and damages assessed in the sum of$132,617.94 as per the above certifica '
th
MAURICE
OF
h
Rule of Civil Procedure No.236—Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY,PENNSYLVANIA
CIVIL ACTION-LAW
NATIONSTAR MORTGAGE LLC
350 Highland Drive
Lewisville,TX 75067
Plaintiff
No. 13-1417
vs.
AMY S.MAURICE
JEREMIAH W.MAURICE
(Mortgagors and Record Owner(s))
305 16th Street
New Cumberland,PA 17070
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
David D.Buell
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle,PA 17013
Prothonotary
By:
uty
If you have any questions concerning the above,please contact: x
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
118333FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: July 26,2013
TO:
AMY S.MAURICE
305 16th Street
New Cumberland,PA 17070
In the Court of
NATIONSTAR MORTGAGE LLC Common Pleas
350 Highland Drive of Cumberland County
Lewisville,TX 75067 Plaintiff
VS. CIVIL ACTION-LAW
AMY S.MAURICE
JEREMIAH W.MAURICE Action of
(Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure
305 16th Street
New Cumberland,PA 17070 No. 13-1417
Defendant(s)
TO: AMY S.MAURICE
305 16th Street
New Cumberland,PA 17070
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPF,ARANCE 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 (10) 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 DIRING 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 BAIL ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
By:
KML LAW ROUP,P.C.
Michael McKeever Pa.1D 56129
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.1D 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
.Jill P.Jenkins Pa.ID 306588
�AIyk L.Oflazian Pa.ID 312912
Salvatore Filippello Pa.ID 313897
Michael J.Coskey Pa ID 311835
215-627-1322
Attorneys for Plaintiff
118333FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: July 26,2013
TO:
JEREMIAH W.MAURICE
305 16th Street
New Cumberland,PA 17070
In the Court of
NATIONSTAR.MORTGAGE LLC Common Pleas
350 Highland Drive of Cumberland County
Lewisville,TX 75067 Plaint
VS. CIVIL ACTION-LAW
AMY S.MAURICE
JEREMIAH W.MAURICE Action of
(Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure
305 16th Street
New Cumberland,PA 17070 No. 13-1417
Defendant(s)
'in: JEREMIAH W.MAURICE
305 16th Street
New Cumberland,PA 17070
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 (10) DAYS FROM TIIE 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Lib«ty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400 L�--
By:
KML LAW tROUP,P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.1D 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.Ill 27615
Jill P.Jenkins Pa.ID 306588
ZAlyk L.Oflazian Pa.1D 312912
Salvatore Filippello Pa.ID 313897
Michael J.Coskey Pa ID 311835
21.5-627-1322
Attorneys for Plaintiff
118333FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: July 26,2013
TO:
JEREMIAH W.MAURICE
392 West Pine Street
Mount Holly Springs,PA 17065
In the Court of
NATIONSTAR MORTGAGE LLC Common Pleas
350 Highland Drive of Cumberland County
Lewisville,TX 75067 Plaintiff
vs. CIVIL ACTION-LAW
AMY S.MAURICE
JEREMIAD W.MAURICE Action of
(Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure
305 16th Street
New Cumberland,PA 17070 No. 13-1417
Defendant(s)
TO: JEREM[All W.MAURICE
392 West Pine Street
Mount Holly Springs,PA 17065
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 (10) 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2liberty Avcauc
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
By:
KML LAW 4ROUP,P.C.
Michael McKeever Pa.ID 56129
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ED 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ED 27615
Jill P.Jenkins Pa.ID 306588
Alyk L.Oflazian Pa.ED 312912
Salvatore Filippello Pa.ED 313897
Michael J.Coskey Pa ID 311835
215-627-1.322
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
NATIONSTAR MORTGAGE LLC
Plaintiff
VS.
AMY S.MAURICE NO. 13-1417
JEREMIAH W.MAURICE
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter,does hereby state to the best of his/her information and belief,as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do)
for the following individual(s): AMY S. MAURICE, has a last known residence of 305 16th Street,New
Cumberland, PA 17070. The following information was used to search the DMDC (check all that
apply):
X_Last Name
• First Name
• Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 49C elating to unswom falsification to authorities.
Date `b By: `
KML LAW GROttf,P.
Michael McKeever P . ID 5612
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa.ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
Jill P. Jenkins Pa. ID 306588
lyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
Department of Defense Manpower Data Center Results as of:Aug-07-2013 SCRARA 3.32
0
w Status Report
Pursuant to Slery ciemembers Civil Relief Act.
Last Name: MAURICE
First Name: AMY
Middle Name: S.
Active Duty Status As Of: Aug-07-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA - No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
i
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA - - ° - `•No - NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future CaIWp to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual of his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
xA
Avk�
•
e�
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: A4Y52950P071X20
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
NATIONSTAR MORTGAGE LLC
Plaintiff
vs.
AMY S.MAURICE NO. 13-1417
JEREMIAH W.MAURICE
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter,does hereby state to the best of his/her information and belief,as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.miUappj/scra/scraHome.do)
for the following individual(s): JEREMIAH W. MAURICE, has a last known residence of 305 16th
Street, New Cumberland, PA 17070. The following information was used to search the DMDC (check
all that apply):
X Last Name
• First Name
• Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 49 4 re ting to unsworn falsification to author-i' s.
Date �✓ By:
~
y
KML LAW GRO P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gomall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
Till P.Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
Results as of:Aug-07-2013 11:57:36
Department of Defense Manpower Data Center
SCRA 3.0
Stratus Report
f° Pursuant to Servicemem ers Civil Relief Act
Last Name: MAURICE
First Name: JEREMIAH
Middle Name: W.
Active Duty Status As Of: Aug-07-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA !' No NA
This response reflects the individuals active duty status based on the Active Duty Status Date
Left Active Duty within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA .. - No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
k
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale
Order Notification Start Date Order Notification End Date Status Service Component
NA NA '� _ No NA
This response reflects whether the individual or His/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
4hut 14. jo
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: V47859EOP07OR60
KNIL Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106
215-627-1322
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT OF COMMON PLEAS
Lewisville,TX 75067
Plaintiff of Cumberland County
vs.
AMY S.MAURICE CIVIL ACTION LAW
JEREMIAH W.MAURICE
(Mortgagor(s)and Record owner(s))
305 16th Street ACTION OF MORTGAGE FORECLOSURE
New Cumberland,PA 17070
Defendant(s)
No. 13-1417
ORDER FOR JUDGMENT
Please enter Judgment in favor of NATIONSTAR MORTGAGE LLC and again AMY S.MAURICE and
JEREMIAH W.MAURICE for failure to file an Answer in the above Vactit�hm 2Ids from the date of service of the
Complaint,in the sum of$132,617.94.
By
KML LAW��t0 .C.
Michael Mc ever PY P . ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Joshua 1. Goldman Pa.205047
Jill P.Jenkins Pa.ID 306588
Andrew F. Gornall Pa.ID 92382
Attorneys for Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is
NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville,T 75067 and that th ame(s)and last known
address(es)of the Defendant(s)is/are AMY S.MAURICE,305 16tl :eet ew C berl ,PA 17070 and JEREMIAH W.
MAURICE,305 16th Street New Cumberland,PA 17070;
By: A t11
KML LAWTTHOUPj fe.
Michael Mkteever Pa. 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa. ID 27615
Joshua L Goldman Pa.205047
gill P.Jenkins Pa. ID 306588
Andrew F. Gornall Pa.ID 92382
Attorneys for Plaintiff
■
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance. $123,563.44
Monthly Interest from 07/01/2012 $6,023.68
through 07/31/2013
Escrow Advances $1,366.67
Property Inspections $9.15
Property Preservation $1,655.00
"MichaelMcKel NerPa.P
By. !
56129
Jay E.Kivitz Pa. ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Joshua 1.Goldman Pa.205047
ill P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plaintiff
AND NOW,this day of ,2013 damages a assesse6t as abo
!1D
sq
`Pro Prothy
13-1417/118333FC
f
f' PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE -
P.R.C.P 3180-3183 0 c
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106 3-c 7 -"' '`"C_
215-627-1322 G
C _• ,
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC
350 Highland Drive
Lewisville,TX 75067 IN THE COURT OF COMMON PLEAS
Plaintiff
vs. of Cumberland County
AMY S.MAURICE CIVIL ACTION—LAW
JEREMIAH W.MAURICE
Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE
305 16th Street
New Cumberland,PA 17070
Defendant(s) No. 13-1417
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$132,617.94
Interest from 8/1/2013
to Date of Sale per
Monthly diem at
$463.36
O (Costs to be added)
a
a ,S6 ✓�
By.
to d . OO KML LA O .
Michael AKeever PaYW 56129
Jay E.Kivitz Pa.ID 26769
0 3 �s �� Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Joshua I.Goldman Pa.205047
Pd P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plaintiff
y o � �� I've�
No. 13-1417
IN THE COURT OF COMMON PLEAS
NATIONSTAR MORTGAGE LLC
vs.
AMY S.MAURICE and
JEREMIAH W.MAURICE
(Mortgagor(s)and Record Owner(s))
305 16th Street
New Cumberland,PA 17070
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
KML Law Group,P.C.
Attorney for Plaintiff
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106
215-627-1322
A
ALL THAT CERTAIN tract or parcel of land situated in the Borough of New Cumberland, County
of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described
according to a survey of D.P. Raffensperger, Registered Surveyor, dated January 14, 1956, as
follows:
BEGINNING at a point on the northwestern side of 16th Street two hundred fifty (250)feet
southwest of the intersection of 16th Street and Bridge Street;thence southwardly along the
same twenty-five (25)feet to a point at the dividing line between Lots Nos. 91 and 92 on the
hereinafter mentioned Plan of Lots;thence northwestwardly along the same at right angles to
16th Street, one hundred ninety-six (196) feet to a point on the southeastern side of twenty
(20)feet wide alley;thence northeastwardly along the same twenty-five (25)feet to a point;
thence southeastwardly through part of Lot No. 92 at right angles to 16th Street through the
center of partition wall and beyond, one hundred ninety-six (196) feet to a point, the place of
BEGINNING.
BEING the western one-half of Lot No. 92 on Plan of Haldeman Plat, recorded in Plan Book "A",
Page 48.
HAVING THEREON ERECTED a two and one-half story brick and frame dwelling house known
and numbered as 305 16th Street.
IMPROVEMENTS a two and one-half story brick and frame dwelling house.
MUNICIPALITY BOROUGH OF NEW CUMBERLAND
BEING PREMISES: 305 16th Street New Cumberland PA 17070
SOLD as the property of JEREMIAH W. MAURICE AND AMY S. MAURICE, HUSBAND AND WIFE
TAX PARCEL#26-23-0541-057
BEING the same premises which JEREMIAH W. MAURICE AND AMY S. COHICK, NOW KNOWN AS
AMY S. MAURICE, by deed dated 3/13/2003 and recorded 3/19/2003 in Cumberland County in
Deed Book Volume 256 at Page 780 granted and conveyed JEREMIAH W. MAURICE AND AMY S.
MAURICE, HUSBAND AND WIFE
t
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street t figL( :
Philadelphia,PA 19106
215-627-1322 13 A �
Attorney for Plaintiff AN 1j:M4 rn
NATIONSTAR MORTGAGE LLC "' Cary f
350 Highland Drive - OURT OF COMMON PLEAS
Lewisville,TX 75067
Plaintiff of Cumberland County
vs.
AMY S.MAURICE CIVIL ACTION-LAW
JEREMIAH W.MAURICE
(Mortgagor(s)and Record Owner(s))
305 16th Street ACTION OF MORTGAGE FORECLOSURE
New Cumberland,PA 17070
Defendant(s)
No. 13-1417
AFFIDAVIT PURSUANT TO RULE 3129
NATIONSTAR MORTGAGE LLC,Plaintiff in the above action,by counsel,KML Law Group,P.C., sets forth as
of the date the praecipe for the writ of execution was filed the following information concerning the real property located at:
305 16th Street
New Cumberland,PA 17070
LName and address of Owner(s)or Reputed Owner(s):
AMY S.MAURICE
305 16th Street
New Cumberland,PA 17070
JEREMIAH W.MAURICE
305 16th Street
New Cumberland,PA 17070.
2.Name and address of Defendant(s)in the judgment:
AMY S.MAURICE
305 16th Street
New Cumberland,PA 17070
JEREMIAH W.MAURICE
305 16th Street
New Cumberland,PA 17070
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O.Box 2675
Harrisburg,PA 17105-2675
>r
4.Name and address of the last recorded holder of every mortgage of record:
5.Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
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.
TENANTS/OCCUPANTS
305 16th Street
New Cumberland,PA 17070
I verify that the state ents ade in this affidavit are true and correct to the best of my information and belief.I
understand that false statemer ts herc in are made subject to the penalties f 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: -
By:
KML LA ROUIVP.C.
Michael Mcl4eever Pa.ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa. ID 27615
Joshua I.Goldman Pa.205047
CZiJill P.Jenkins Pa. ID 306588
Andrew F.Gornall Pa. ID 92382
Attorneys for Plaintiff
13-1417
KML Law Group,P.C.
Suite 5000-BNY Independence Center , Ft I t TF;v. 1
701 Market Street
Philadelphia,PA 19106 J 1 1 J
(215)627-1322 r
Attorney for Plaintiff � BERL A'
NATIONSTAR MORTGAGE LLC
350 Highland Drive IN THE COURT OF COMMON PLEAS
Lewisville,TX 75067
of Cumberland County
Plaintiff
vs. CIVIL ACTION-LAW
AMY S. MAURICE
JEREMIAH W.MAURICE ACTION OF MORTGAGE
Mortgagor(s) and Record Owner(s) FORECLOSURE
305 16th Street
New Cumberland,PA 17070
Docket No. 13-1417
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MAURICE,AMY S.
AMY S. MAURICE
305 16th Street
New Cumberland,PA 17070
Your house at 305 16th Street,New Cumberland,PA 17070 is scheduled to be sold at Sheriffs
Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of$132,617.94 obtained by NATIONSTAR MORTGAGE LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to NATIONSTAR MORTGAGE LLC,the back payments,
late charges,costs and reasonable attorney's fees due.To fmd out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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.
f
13-1417
4. 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 below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a 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 schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale.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 schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
13-1417
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.gov 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/homeovmers/real.aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). 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(cr,kmllawgrout).com.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
118333FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 13-1417 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 AMY S.MAURICE,JEREMIAH W.MAURICE
(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 gamishee(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:$132,617.94 L.L.:$.50
Interest FROM 8/1/2013 TO DATE OF SALE PER MONTHLY DIEM AT$463.36
Arty's Comm: Due Prothy: $2.25
Atty Paid:$315.71 Other Costs:
Plaintiff Paid:
Date: August 9,2013 �#���� ^`
David D. Buell,Prothonotary
(Sea])
Deputy C-
REQUESTING PARTY:
Name:JILL P.JENKINS,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
Attorney for:PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No.306588
KML LAW GROUP,P.C. 118333FC
Suite 5000 CF: 03/18/2013
BNY Mellon Independence Center ; ° SD: 12/04/2013
a Iir lid., j �aiii'....f aa .,
701 Market Street $132,617.94
Philadelphia,PA 19106-1532
215-627-1322
Attorne for Plaintiff w(IM <F i-� t, + ,
NATIONSTAR MORTGAGE LLC PE1t NS Y BOA,P�11`, THE COURT OF COMMON PLEAS
350 Highland Drive
Lewisville, TX 75067 of Cumberland County
Plaintiff
VS. CIVIL ACTION—LAW
AMY S. MAURICE ACTION OF MORTGAGE FORECLOSURE
JEREMIAH W. MAURICE
Mortgagor(s)and Term
Record Owner(s) No. 13-1417
305 16th Street
New Cumberland,PA 17070
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P.3129.2 (c)(2)
Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff,hereby certifies that
service on the Defendants of the Notice of Sheriff Sale was made by:
(X) Personal Service by the Sheriffs Office/competent adult(copy of return attached).
{ } Certified mail by KML Law Group, P.C. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
{ } Ordinary mail by KML Law Group, P.C.to Attorney for Defendant(s)of record(proof of mailing
attached).
{ } Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
(X} Premises was posted by Sheriffs Office/competent adult(copy of return attached).
( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached).
(X} Certified Mail&ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail
attached).
( ) Published in accordance with court order(copy of publication attached).
Pursuant to the Affidavit under Rule 3129(copy attached), service on all lienholders(if any)has been made by
ordinary mail KML Law Group,P.C.(copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa.C.S.A.
Section 4904.
Respectfully submitted,
: Veronica Cosme
Legal Assistant
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
NATIONSTAR MORTGAGE LLC;et seq. ;CASE and/or DOCKET No.: 13-1417
Plaintiff(Petitioner)
Sheriffs Sale Date: 12/4/2013
V.
AMY S.MAURICE;et al.
Defendant(Respondent) I
AFFIDAVIT OF SERVICE
❑Complaint ❑Summons Other:NOTICE OF SALE
1,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I
served AMY S.MAURICE the above process on the 25 day of September,2013,at 1:30 o'clock,PM,at 305 16th Strect New Cumberland,PA 17070,
County of Cumberland,Commonwealth of Pennsylvania:
Manner of Service:
By posting a copy of the original process on the most public part of the property pursuant to an order of court
Service was attempted on the following daWtimes:
t} 2) 3)
CommonwealthtState of 0^ )
SS:
County of ,}sriat )
Before me,the undersigned notary public,this ,personally,appeared if,,+A^ MM°�l m me known,who being
duly sworn according to law, poses e o o ing:
I hereby swear or affirm th t th' a• orth in the foregoing Affidavit of Service are true and correct
1 �
Subscribed and sworn t lere-rt _�
( gnature o Affiant) this2L day of .� '�_ 20 1�
File Number:118 3FC
Case ID#:37638 2 Notary Public
CdINMpIyW
I- F I' NNSYLVANIA
EWE"C M p Hat Seal i
shingtonerrbw Notary Public nrrasslon 69 Ee v�°+ ty
ig,2013
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
i
I�
NATIONSTAR MORTGAGE LLC;et seq. CASE and/or DOCKET No.: 13-1417
Plaintiff(Petitioner) ;Sheriffs Sale Date: 12/4/2013
V.
AMY S.MAURICE;et al. '
Defendant(Respondent)
AFFIDAVIT OF SERVICE
❑Complaint t.._i Summons R Other:NOTICE OF SALE
I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action not an employee nor relative of a party,and that 1
served JEREMIAH W.MAURICE the above process on the 12 day of September,2013,at 5:00 o'clock,PM,at 392 W Pine St Mount Holly Springs,PA
17065,County of Cumberland,Commonwealth of Pennsylvania:
Manner of Service:
By handing a copy to the Defendant(s)
Description:Approximate Age 26_30 Height 5'10 Weight 205 Race W I-111 Sex MALE Hair BROWN
Military Status: C]No ;/Yes Branch:
Commonwealth/State of 9 )
^ )SS:
County of file-'so )
Before me,the undersigned notary public,W9 day,personally,appeared ✓Irl to me known,who being
duly sworn according to law,depo es "ollowing:
I hereby swear or affirm atf a pct forth in the foregoing Affidavit of Service are true and correct.
Subscribed and sworn to before me
[3FC ature o Affiant) this e3 day of . F �.
Pile Number:118Case ID tt:37556 Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notartal Seal
Eric M.Aff1erbach,Notary Outdlc
Washington Twp.,Berks County
My Commission Expires Nov.18,2013
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NATIONSTAR MORTGAGE LLC IN THE COURT OF COMMON V EAS;
350 Highland Drive -;` �,
Lewisville,TX 75467 OF Cumberland Ct& Y�
vs. .n r— tv c,:
r—=
w -'
AMY S.MAURICE and JEREMIAH W.MAURICE 13-1417 n ;
305 16th Street New Cumberland,PA 17070
ORDER
AND NOW,this ,+ " day of/MY2013,upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.R.C.P.430(a)and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant,Amy S.Maurice,have been unsuccessful,
it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in
Mortgage Foreclosure upon Defendant,Amy S.Maurice,by posting a copy of the Complaint upon the
premises 305 16th Street,New Cumberland,PA, 17070,and Plaintiff is directed to serve the Complaint
by certified and regular�tke nt pawn addressat 305 16th Ne Cumb land
eriff
Salad Pennsylvania Rule of Civil Procedure_12�,� „�� ^��PfP„�..-� '•�•
i
BY COURT:
1 J.
Distribution list:
Michael T. McKeever, Esquire,Suite 5000—BNY Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
AMY S. MAURICE, 305 16th Street New Cumberland,PA 17070
I
KML LAW GROUP,P.C.
Suite 5000—BNY Mellon Independence Center
701 Market Street
Philadelphia,PA 19106
215-825-6320
Attorney for Plaintiff
NATIONSTAR MORTGAGE LLC IN THE COURT OF COMMON PLEAS
350 Highland Drive
Lewisville,TX 75067 of Cumberland County
Plaintiff
VS. CIVIL ACTION-LAW
AMY S.MAURICE
JEREMIAH W.MAURICE ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s)and Record Owner(s)
Term
305 16th Street No. 13-1417
New Cumberland,PA 17070
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
NATIONSTAR MORTGAGE LLC, Plaintiff in the above action, by and through an authorized employee
of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed
the following information concerning the real property located at:
305 16th Street
New Cumberland, PA 17070
1.Name and address of Owner(s)or Reputed Owner(s):
AMY S. MAURICE
305 16th Street
New Cumberland, PA 17070
JEREMIAH W. MAURICE
392 West Pine Street
Mount Holly Springs, PA 17065
2.Name and address of Defendant(s) in the judgment:
AMY S. MAURICE
305 16th Street
New Cumberland, PA 17070
JEREMIAH W. MAURICE
392 West Pine Street
Mount Holly Springs, PA 17065
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg,PA 17105-2675
4.Name and address of the last recorded holder of every mortgage of record:
5.Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
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.
TENANTS/OCCUPANTS
305 16th Street
New Cumberland, PA 17070
1 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. Section 4904 relating to unsworn falsification to authorities.
DATED: November 12,2013
KML Law Group, P.C.
BY: Veronica Cosine
Legal Assistant
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,
Sheriff
ytlfi' ate;tir be i " t r
Jody S Smith � i'���+
Chief Deputy ;' 'Y 14 } ^ ';
Richard W Stewart CUMBERLAND
Solicitor =t U`
PENNSYLVANIA
Nationstar Mortgage, LLC
vs. Case Number
Amy S Maurice (et al.) 2013-1417
SHERIFF'S RETURN OF SERVICE
09/23/2013 08:08 PM - Deputy Stephen Bender, 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 305 16th Street, New Cumberland Borough, New
Cumberland, PA 17070, Cumberland County.
12/04/2013 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, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at
10:00 AM. He sold the same for the sum of$1.00 to Attorney Michael McKeever, on behalf of Nationstar
Mortgage, LLC, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,049.66 SO ANSWERS,
January 24, 2014 RONNY R ANDERSON, SHERIFF
4' .00 Pd •at.
3O/677
•
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No.2013-1417 Civil Term SOLD as the property of JER-
EMIAH W. MAURICE AND AMY S.
NATIONSTAR MORTGAGE,LLC MAURICE,HUSBAND AND WIFE.
vs. TAX PARCEL#26-23-0541-057.
Amy S.Maurice, BEING the same premises which
Jeremiah Maurice JEREMIAH W. MAURICE AND AMY
S.COHICK,NOW KNOWN AS AMY S.
Atty.:Michael McKeever MAURICE,by deed dated 3/13/2003
ALL THAT CERTAIN tract or and recorded 3/19/2003 in Cum-
parcel of land situated in the Bor- berland County in Deed Book Vol-
ough of New Cumberland, County ume 256 at Page 780 granted and
of Cumberland, Commonwealth of conveyed JEREMIAH W. MAURICE
Pennsylvania, more particularly AND AMY S. MAURICE, HUSBAND
bounded and described according AND WIFE.
to a survey of D.P. Raffensperger,
Registered Surveyor, dated January
14, 1956,as follows:
BEGINNING at a point on the
northwestern side of 16th Street two
hundred fifty(250)feet southwest of
the intersection of 16th Street and
Bridge Street; thence southwardly
along the same twenty-five (25) feet
to a point at the dividing line be-
tween Lots Nos. 91 and 92 on the
hereinafter mentioned Plan of Lots;
thence northwestwardly along the
same at right angles to 16th Street,
one hundred ninety-six(196) feet to
a point on the southeastern side of
twenty (20) feet wide alley; thence
northeastwardly along the same
twenty-five(25)feet to a point;thence
southeastwardly through part of Lot
No.92 at right angles to 16th Street
through the center of partition wall
and beyond,one hundred ninety-six
(196) feet to a point, the place of
BEGINNING.
BEING the western one-half of
Lot No.92 on Plan of Haldeman Plat,
recorded in Plan Book"A",Page 48.
HAVING THEREON ERECTED
a two and one-half story brick and
frame dwelling house known and
numbered as 305 16th Street.
IMPROVEMENTS a two and one-
half story brick and frame dwelling
house.
MUNICIPALITY BOROUGH OF
NEW CUMBERLAND.
BEING PREMISES: 305 16th
Street New Cumberland PA 17070.
83
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 11, October 18 and October 25, 2013
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.
___
l isa Marie Coyn , Editor
SWORN TO AND SUBSCRIBED before me this
25 da of October, 2013
g
Notary
r N(`JARIAL SEAL _...
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.-2020 Technology Pkwy e attiotXtws
Suite 300
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
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller 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.
ey7.,- .yY„L _t•., 0
y . This ad ran on the date(s)shown below:
2013-1417 Civil Term 10/13/13
TIONSTAR MORTGAGE LLC
Amy S Maurice -
10/20/13
Jeremiah Maurice
10/27/13
Atty: Michael McKeever
ALL THAT CERTAIN tract or parcel of land
situated in the Borough of New Cumberland, . aV
County of Cumberland,Commonwealth of • • • • ,frn
• •
Pennsylvania, more particularly bounded
and described according to a survey of D.P.
Raffensperger, Registered Surveyor, dated Swor . ..nd subscribed before - this 11 day of November, 2013 A.D.
January 14,1956,as follows: i '
BEGINNING at a point on the northwestern
side of 16th Street two hundred fifty(250). ' t I I i
feet southwest of the intersection of 16th O i, ,l' f�
Street and Bridge Street;thence southwardly Z i a ry P u•l i C `"
along the same.twenty-five(25)feet to a '
point at the dividing line between Lots Nos.
91 and 92 on the hereinafter mentioned
Plan of Lots;thence northwestwardly along CCZP�j�JpNs, E7N
the same at right angles to 16th Street one QF PENNSYLV A Tw hundred ninety-six(196)feet to a point on ?011;,•, yNotarla!Seal ANI
the southeastern side ) feet
°�+ashe"gt:$e-,wa�£l ° Otat' AtrE�7ic
wide alley;thence northeaslwardly along the y COrnmissi0n Ex C�u�hI1 County
same twenty-five(25)feet to a point;thence MEMBER,PENNSYtygN Ptres Dec,12,2016
southeastwardly through part of Lot No.92 at IA ASSOCfq�oN�F NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriffs Deed in which Nationstar Mortgage LLC is the grantee the same having been sold to said
grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the
9th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013
Number 1417, at the suit of Nationstar Mortgage LLC against Amy s. Maurice and Jeremiah W.
Maurice is duly recorded as Instrument Number 201403352.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this / L/ day of
Feb. , A.D. a DI Li
Recorder of Deedmberland County,Carlisle,PA Recorder of Deeds
My Commission Expires the First Monday of Jan.2018