HomeMy WebLinkAbout13-3747 For Prothonotary Use Only:
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The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by late or rules o court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E C3 Transfer from Another Jurisdiction ❑ Declaration of Taking
j C Lead Plaintiffs Name: Nationstar Mortgage LLC Lead Defendants Name: John S. Rosenberry, Jr.
T
I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits
O (check one) ❑ outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg and Conway,
L O Check here if you have no attorney (a Self - Represented IPro Sel Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
O Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Department of Transportation
❑ Premises Liability (does not include ❑ Statutory Appeal: Other
S mass tort)
E ❑ Slander/Libel /Defamation ❑ Employment Dispute:
❑ Other: Discrimination
C O Employment Dispute: Other ❑ Zoning Board
T ❑ Other
I
O ❑ Other
MASSTORT
N
❑ Asbestos
❑ Tobacco
O Toxic Tort - DES
❑ Toxic Tort -Implant I B O Toxic Waste REAL PROPERTY MISCELLANEOUS
❑ Ejectment ❑ Common Law /Statutory Arbitration
O Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent O Mandamus
O Landlord/Tenant Disput O Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY � rra
g
❑ Mortgage e Foreclosure: Commercial ❑ Quo Wanto
❑ Dental
❑ Partition O Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
2013 JUH 28 AM 10- tt 5
CUMBERLAND COUNTY
PENNSYLVANIA
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID #314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
215 790 -1010
Nationstar Mortgage LLC Cumberland County
350 Highland Drive Court of Common Pleas
Lewisville, TX 75067 ?
V. Number 13_ J ? / (f
) v�
John S. Rosenberry, Jr.
6 West Main Street
Newburg, PA 17240
and
Lisa E. Cordle
6 West Main Street
Newburg, PA 17240
COMPLAINT IN MORTGAGE FORECLOSURE
P 61 - )!5p&
&141g0419
File # 68804
Page I
NOTICE AVISO
You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted quiere
against the claims set forth in the following pages, you defenderse de estas demandas ex- puestas en las paginas
must take action within twenty (20) days after this siguientes, usted tiene veinte (20) dias de plazo al partir
complaint and notice are served, by entering a written de la fecha de la demanda y la notificacion. Hace falta
appearance personally or by attorney and filing in asentar una comparencia escrita o en persona o con un
writing with the court your defenses or objections to the abogado y entregar a la corte en forma escrita sus
claims set forth against you. You are warned that ifyou defensas o sus objeciones a las demandas en contra de
fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la
judgment may be entered against you by the court corte tomara medidas y puede continuar la demanda en
without further notice for any money claimed in the contra suya sin previo aviso o notificacion. Ademas, la
complaint or for any other claim or relief requested by corte puede decidir a favor del demandante y requiere
the plaintiff. You may lose money or property or other que usted cumpla con todas ]as provisioner de esta
rights important to you. demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU DO NOT USTED LE DEBE TOMAR ESTE PAPEL A
HAVE A LAWYER, GO TO OR TELEPHONE THE SU ABOGADO INMEDIATAMENTE. SI USTED NO
OFFICE SET FORTH BELOW. THIS OFFICE CAN TIENE A UN ABOGADO, VA A O TELEFONEA LA
PROVIDE YOU WITH INFORMATION ABOUT OFICINA EXPUSO ABAJO. ESTA OFICINA LO
HIRING A LAWYER. PUEDE PROPORCIONAR CON INFORMATION
IF YOU CANNOT AFFORD TO HIRE A ACERCA DE EMPLEAR A UN ABOGADO.
LAWYER, THIS OFFICE MAY BE ABLE TO SI USTED NO PUEDE PROPORCIONAR
PROVIDE YOU WITH INFORMATION ABOUT PARA EMPLEAR UN ABOGADO, ESTA OFICINA
AGENCIES THAT MAY OFFER LEGAL SERVICES PUEDE SER CAPAZ DE PROPORCIONARLO CON
TO ELIGIBLE PERSONS AT A REDUCED FEE OR INFORMACION ACERCA DE LAS AGENCIAS
NO FEE. QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
Cumberland County Bar Association HONORARIO REDUCIDO NI NINGUN
32 South Bedford Street HONORARIO.
Carlisle, PA 17013
(800) 990 -9108 Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990 -9108
File 4 68804
Page 2
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is Nationstar Mortgage LLC, duly organized and doing business at the above -
captioned address.
2. The Defendant is John S. Rosenberry, Jr., who is a mortgagor and real owner ofthe mortgage
property hereinafter described, and his/her last -known address is 6 West Main Street, Newburg, PA 17240.
3. The Defendant is Lisa E. Cordle, who is a mortgagor and real owner ofthe mortgage property
hereinafter described, and his /her last -known address is 6 West Main Street, Newburg, PA 17240.
4. On August 25, 2006, John S. Rosenberry, Jr., Lisa E. Cordle, and Ruth E. Rosenberry,
mortgagors, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage
Electronic Registration Systems, Inc as nominee for Countrywide Home Loans, Inc. which mortgage is
recorded in the Office of the Recorder of Cumberland County in Mortgage .Book 1965, Page 1168 ( "the
Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.
5. On April 26, 2012, the Mortgage was assigned by Mortgage Electronic Registration Systems,
Inc as nominee for Countrywide Home Loans, Inc. to Bank of America, N.A., successor by merger to BAC
Home Loans Servicing, LP f /k/a Countrywide Home Loans Servicing, LP, by Assignment of Mortgage,
recorded in the Office ofthe Recorder of Cumberland County in Assignment of Mortgage Instrument Number
201212454, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)
Pa. R. C. P.
6. On October 17, 2012, the Mortgage was assigned by Bank of America, N.A., sucessor by
merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP to Nationstar
Mortgage LLC, Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of
Cumberland County in Assignment of Mortgage Instrument Number 201233391, such Assignment of
Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.
7. On November 15, 2001, Ruth E. Rosenberry departed this life leaving title vested solely in
the names of John S. Rosenberry, Jr. and Lisa E. Cordle by operation of law.
File 4 68804
Page 3
8. The premises subject to said mortgage is described in the legal description attached as Exhibit
"A" and is known as 6 West Main Street, Newburg, Pennsylvania 17240.
9. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due May 1, 2012 and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
10. The following amounts are due on the mortgage:
Principal Balance $ 57,569.28
Interest April 1, 2012 to June 20, 2013 $ 4,823.51
(Plus $10.84 per diem thereafter)
Corporate Advance - Property Inspection $ 93.25
Escrow Advance $ 2,161.83
GRAND TOTAL $ 64,647.87
The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law,
and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated
prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction
provisions of Act 6, if applicable.
11. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice
required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail
with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $64,647.87,
together with interest at the rate of $10.84 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG AND CONWAY, P.C.
BY:
[ ] Terrence J. M Cabe, Esquire [ arc S. Weisberg, squire
[ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire
[ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire
[ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire
[ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire
Attorneys for Plaintiff
File # 68804
Page 4
VERIFICATION
Evie Nguyen hereby states that he /she is Assistant Secretary of
Nationstar Mortgage LLC, Plaintiff in this matter, that he /she is authorized to make this Verification, and
verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of his /her knowledge, information and belief. The undersigned understands that this
statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
Name: vie Nguyen
DATE: Qi o20 Title:
staet Secretary
File #: 68804
Name: Nationstar Mortgage LLC v. John S. Rosenberry, Jr. and Lisa E. Cordle
File # 68804
Page 5
(Page 18 of 18)
Exhibit A
Exhibit "A"
" Legal Description
All that certain parcel of land situate on Main Street in the Borough of Newburg, County of
All that certain parcel of land situate on Main Street in the Borough of Newburg, County of
Cumberland and Commonwealth of Pennsylvania, being known and designated as follows:
Beginning at a point on the South side of Main Street; thence along the South side of Main
Street, Estwardly 50 feet to a lot of the Independent Order of Odd Fellows of the said
Borough and known as No. 18; thence by said Independent Order of Odd Fellows lot
Southwardly 169 feet to an alley; thence by said alley, Westwardly 50 feet to coiner of lot of
Anna Mae Cramer, known as No. 16; thence by said Cramer lot, Northwardly 169 feet to the
place of Beginning; known in the general plan of said Borough as Lot No. 17.
Tax/PareelID: 24- 21- 0390 -064
I Certify this to tie reeor - c ed
In C:uxnbearland County PA
Recorder of Deeds
BK 1.3i6.&PG:.t 18
FORM .l
Nat.io.nstar Mortgage L,L.,C IN THE COURT OF COMMON PLEAS 01�'c--
Plaintiff CUMBERLAND COUNTY, PENNSYLV *9
VS.
r " N
CJ C:
John S. Rosenberry, Jr., Lisa E. Cordle and Ruth E. ✓ 7 0civil r— p --- r
Rosenberry < �—
Cw3
Defendants i
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 format attached hereto, your lawyer 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submi ed: ��
Date [Signature of Counsef for Plaintiff]
68804
Page 1
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine possible
options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payment Amount $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorc cY les): Model
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 ° Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes O No O
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance?
Yes 0 No 0
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency?
Yes 0 No 0
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I /We , authorize the above named
to use /refer this information to my lender /servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I /We understand that I /we am /are under no obiligation 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:
V Proof of income
f Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
f Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
3
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
����.yk�yr D�c:,tdidflro�r�Y,�� t`e t }..�-�F��
Jody S Smith _ 1
Chief Deputy .;.. H €R !�'ii) 0
Richard W Stewart f� :
Solicitor OFFICE OF Ti-E S3.ERIF-
CUMBERLAND COUNTY
PENNSYLVANIA
Nationstar Mortgage LLC
Case Number
vs.
John Samual Rosenberry, Jr(et al.) 2013-3747
SHERIFF'S RETURN OF SERVICE
07/12/2013 07:17 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Lisa E.
Cordle at 6 W. Main Street, Newburg Borough, Newburg, PA 17240.
JOON KINSLER, DEPUTY
07/15/2013 03:51 PM- Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: John
Samual Rosenberry, Jr at 3005 Ritner Highway, West Pennsboro Township, Carlisle, PA 1701
i
DE IS FRY, DE UTY
SHERIFF COST: $73.38 SO ANSWERS,
July 16, 2013 RON , R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft.Inc.
Nationstar Mortgage LLC : IN THE COURT OF COMMON PLEAS
350 Highland Drive : CUMBERLAND COUNTY,
Lewisville, TX 75067 : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-3747 ,
MCC) ca ==
John S. Rosenberry =M rn
Lisa E. Cordle ;=
6 West Main Street : CIVIL ACTION- ��
Newburg, PA 17240 : MORTGAGE FORECLOSURE ,
r
Defendants z' .-_,'
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012, governing the
Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned
hereby certifies as follows:
I. Defendant is owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
(0 cr
Si nature of Defendant's Counsel ppointed Date
Legal Representative
�10, 0L 9 a)MA� Q_
Signature of Defendant Date
Nationstar Mortgage LLC : IN THE COURT OF COMMON PLEAS
350 Highland Drive : CUMBERLAND COUNTY,
Lewisville, TX 75067 : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-3747
John S. Rosenberry
Lisa E. Cordle :
6 West Main Street : CIVIL ACTION-
Newburg, PA 17240 : MORTGAGE FORECLOSURE
Defendants
CERTIFICATE OF SERVICE
I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant, Lisa
E. Cordle N/K/A Lisa E. Martin, hereby certify that I am serving a copy of the Praecipe for Entry
of Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney,
on the following date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Mark S. Weisberg,Esq.
McCabe,Weisberg and Conway,P.C.
123 South Broad Street, Suite 1400
Philadelphia,PA 19109
MIDPENN LEGAL SERVICES
DATE: 0C(/oC(1ZO (�
Jaime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
Nationstar Mortgage LLC : IN THE COURT OF COMMON PLEAS
350 Highland Drive : CUMBERLAND COUNTY,
Lewisville, TX 75067 : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-3 747
John S. Roseberry
Lisa E. Cordle
6 West Main Street : CIVIL ACTION- c
Newburg, PA 17240 : MORTGAGE FORECLOSURE-a Z3 —;
rn Co C'o Zr
Defendants zrr' rrn
x,:;o
°
_=C� _
PRAECIPE FOR ENTRY OF APPEARANCE
rM
TO THE PROTHONOTARY:
Please enter the appearance of MidPenn Legal Services on behalf of the Defendant, Lisa
E. Cordle, in the above matter, representing the Defendant in the Cumberland County Residential
Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE: co( 0 �'Z��13 C
aime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 1701.3
(717)243-9400
Nationstar Mortgage LLC : IN THE COURT OF COMMON PLEAS
350 Highland Drive : CUMBERLAND COUNTY,
Lewisville, TX 75067 : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-3747 --
-<> qty
John S. Rosenberry <CD
Lisa E. Cordle
6 West Main Street : CIVIL ACTION-
Newburg, PA 17240 : MORTGAGE FORECLOSURE< r a
Defendants
CASE MANAGEMENT ORDER
AND NOW, this /b day of 40p, 2013, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the.Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on �� /_ do/3 at R NdA in
at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure.Diversion Program,Financial
Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon
• 1
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendantiborrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of the
plaintiff/lender is not available by telephone during the Conciliation Conference, the
court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintifFlender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a .
forbearance agreement or repayment plan to bring the account current over time;
I
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
r
J.
DISTRIBUTION:
aime M.Haley,Esquire
MidPenn Legal Services
401 E. Louther Street, Ste 103
Carlisle,PA 17013
For the Defendants
ark S.Weisberg,Esq.
McCabe,Weisberg and Conway,P.C.
123 South Broad Street, Suite 1400
Philadelphia,PA 19109
For the Plaintiff
,las lrzi.&
Q /�3
NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION—LAW
NO. 13-3747 CIVIL
JOHN S. ROSENBERRY, JR. and
LISA E.,CORDLE,
Defendants MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW,this ZV day of October, 2013, at the request of counsel for the
plaintiff and with the concurrence of counsel for the defendants,the conciliation conference set
for November 1, 2013, is continued to Friday,November 8, 2013, at 3:30 p.m. in Chambers of
the undersigned.
BY THE COURT,
'/
Kevi . Hess, P. J.
w- Nathan Wolf, Esquire
For the Plaintiff
✓ Jaime Haley, Esquire
For the Defendants
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NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. • CIVIL ACTION—LAW
•
NO. 13-3747 CIVIL
JOHN S. ROSENBERRY, JR. and •.
LISA E. CORDLE,
Defendants • MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this e- - day of November, 2013, at the request of counsel the
conciliation conference set for November 8, 2013, is continued to Wednesday, December 18,
2013, at 11:45 a.m. in Chambers of the undersigned.
BY THE COURT,
• 1
Kevin A. Hess, P. J.
t/ Nathan Wolf, Esquire
For the Plaintiff
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✓Jaime Haley, Esquire -133 '' �.
For the Defendants =fin c)
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NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION—LAW
• NO. 13-3747 CIVIL
JOHN S. ROSENBERRY, JR. and :
LISA E. CORDLE,
Defendants MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 19 • day of December, 2013, it appearing that the defendants are
making trial payments in this matter, by agreement of the parties, continued conciliation
conference is set for Friday, March 21, 2014, at 1:30 p.m. in Chambers of the undersigned.
BY THE COURT,
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Kevi . . Hess, P. J.
Nathan Wolf, Esquire
For he Plaintiff
Jaime Haley, Esquire
For the Defendants
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McCABE, WEISBERG AND CONWAY,P.C. t. T- / 1j -o f'1�.;
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 2�1 t C 1/io/;t,6`1.416.
MARC S.WEISBERG,ESQUIRE-ID#17616 �e( 0
EDWARD D.CONWAY,ESQUIRE -ID#34687 • 3•
MARGARET GAIRO,ESQUIRE-ID# 34419 CUp0EI?L 1 S
ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 ENNS a CO C
HEIDI R.SPIVAK,ESQUIRE-ID#74770 AID i, r
MARISA J.COHEN,ESQUIRE-ID#87830
CHRISTINE L.GRAHAM,ESQUIRE-1D#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
JENNIFER L.WUNDER,ESQUIRE-ID#315954
LENA KRAVETS,ESQUIRE-ID#31.6421
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1010
Nationstar Mortgage LLC CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
v. No. 13-3747 Civil
Lisa E. Cordle and John S.Rosenberry,Jr.
Defendants
PRAECIPE
TO THE PROTHONOTARY:
® Please mark the action Discontinued and Ended without prejudice.
❑ Please mark the above referenced case Settled,Discontinued and Ended.
❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
❑ Please Vacate the Judgment entered.
DATE: Z✓//d // Y McCABE,WEISBERG AND CONWAY,P.C.
BY:' -)W,(-erl (J(
[ ]Terrence J.McCabe,Esq. [Marc S. Weisberg,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
[ ]Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ ]Christine L. Graham,Esq.
[ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq.
[ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
[ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esq.
[ ]Lena Kravets,Esq.
Attorneys for Plaintiff
r a
McCABE,WEISBERG AND CONWAY, P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496
MARC S.WEISBERG,ESQUIRE-ID#17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET CAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID#28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
JENNIFER L.WUNDER,ESQUIRE-ID#315954
LENA KRAVETS,ESQUIRE-ID#316421
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1010
Nationstar Mortgage LLC CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
v. No. 13-3747 Civil
Lisa E.Cordle and John S.Rosenberry,Jr.
Defendants
CERTIFICATE OF SERVICE
The undersigned Attorney for Plaintiff,hereby certifies that a true and correct copy of the within Praecipe was
served on the below persons by regular first class mail,postage prepaid,on the / day of February,2014.
Lisa E.Cordle Jamie,M.Haley,Esquire
6 West Main Street 401.E.Louther Street, Ste 103
Newburg,Pennsylvania 17240 Carlisle,Pa 17013
John S.Rosenberry,Jr.
6 West Main Street
Newburg,Pennsylvania 17240
DATE: J(g/( McCABE,W.EISBERG AND CONWAY,P.C.
BY: vv
[ ]Terrence J.McCabe,Esq. [—Marc S. Weisberg,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
[ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
[ ]Marisa J. Cohen,Esq. [ ]Christine L.Graham,Esq.
[ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq.
[ ] Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
[ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esq.
[ ]Lena Kravets,Esq.
Attorneys for Plaintiff