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Home My WebLink About13-7464 Supreme Court of Pennsylvania Cour`6; Comfi on Pleas f ` For Prothonotart• Use Onit -: Gi� Corer; Sheet - Cu.mberlan'd'i County Do&el -No: 13- 7 1 �IviI �Tern? The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the and service ofpleadings or other papers as required bylaw or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: NATIONSTAR MORTGAGE LLC, F/K/A CENTEX STACI L. HAIR C T HOME EQUITY COMPANY, LLC TODD R. HAIR I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits 1 Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintifflappellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se 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 APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute: Other T ❑ Other: 0 MASS TORT ❑ Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste B ❑Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. _ SUITE 5000 - BNY MELLON INDEPENDENCE CENTER ' F. 701 MARKET STREET C §" P ffiLADELPHLA, PA 19106 E� JJ I (866) 413 -2311' 8 l CD �1 V ! Tam WWW.KMI,LAW(:ROI P.COM NATIONSTAR MORTGAGE LLC, F/K /A CENTE0MBi.R ,6 ND C(QIfJTHE COURT OF COMMON PLEAS HOME EQUITY COMPANY, LLC r ENIN YLVA I 350 Highland Drive OF Cumberland COUNTY Lewisville, TX 75067 Plaintiff CIVIL ACTION - LAW vs. STACI L. HAIR ACTION OF MORTGAGE FORECLOSURE TODD R. HAIR Mortgagor(s) and Record Owner(s) CIVEL 4gMN: �VMORTGAGI 169 East North Street Carlisle, PA 17013 IFORECWS Defendant (s) 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 Pb AmP .8 Irvine Row e rls 4 of Carlisle, PA 17013 Q4 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 notificacion. 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 notificacion. 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 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC, 350 Highland Drive, Lewisville, TX 75067. 2. The name(s) and address(es) of the Defendant(s) is /are STACI L. HAIR, 169 East North Street, Carlisle, PA 17013 and TODD R. HAIR, 169 East North Street, Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On April 27, 2005 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to CENTEX HOME EQUITY COMPANY, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on May 02, 2005 as Book 1905 Page 2995. 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. A loan modification agreement was executed on January 9, 2010 and is hereby attached as Exhibit C. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 15, 2013 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 ................................ ............................... .....................$68,022.03 Interest from 02/15/2013 through 11/21/2013 at 5.0630 % . ......................$2,639.61 Per Diem interest rate at $9.44 EscrowAdvance .................................. ............................... ......................$2,597.87 CorporateAdvance ......................................................... ............................... $81.60 ForbearanceBalance ................................................... .................... ($123.56) $73,217.55 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 and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $73,217.55, together with interest at the rate of $9.44, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: ✓/ ' KML LAW GRYA, 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 1. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION Juimiler Huynh , hereby states that he /she is Assistant Secret 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: VZ) 1 1172 13 ennifer H ssistant Secretary #123056FC - STACI L. HAIR and TODD R. HAIR 169 East North Street Carlisle, PA 17013 Ey,FiiditA ALL THAT CERTAIN tract of land with the building thereon erected situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a point on the Northern side of East North Street, thence by a Northerly direction 93 feet to a point; thence in an Easterly direction 16.9 feet to a point; thence in a Southerly direction 93 feet to a point; thence in a Westerly direction along the Northern side of East North Street, 16.9 feet to the place of BEGINNING. AND BEING the Westerly house of a row of frame dwelling houses, the eastern boundary line of said houses running through the partition separating the house on the East thereof, and being known as No. 169 East North Street. BEING THE SAME premises which Diane Brinton and Donna Brinton- Miller, Administrators of the Estate of Leroy H. Brinton, by their deed dated December 15, 1994 and recorded December 16, 1994 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 116, Page 296, granted and conveyed unto Kerry R. Henne and Joan M. Henne, husband and wife. AND ALSO BEING THE SAME premises which Kerry R. Henne and Joan M. Henne, husband and wife, by their deed dated the ' Jn - day of April, 2005 and recorded simultaneously herewith, granted and conveyed unto Todd R. Hair and Staci L. Hair, husband and wife, MORTGAGORS herein. Ey� *Exhibit has been redacted to remove all personally identifiable information or non-public information Nationstar Mortgage, LLC PRESORT PO Box 9095 First-Class Mail Temecula, CA 92589 -9095 U.S. Postage and Fees Paid WSO 7196 9006 9296 7111 4255 Send Payments to: Nationstar Mortgage 350 Highland Drive Lewisville, TX 75067 -4177 20130514 -160 STACI L HAIR 169 E NORTH ST CARLISLE, PA 17013 -2431 H PA —N01 Nationstar Mortgage, LLC PRESORT PO Box 9095 Temecula, CA 92589 -9095 First -Class Mail U.S. Postage and Fees Paid W SO 7196 9006 9296 7111 4262 Send Payments to: Nationstar Mortgage 350 Highland Drive Lewisville, TX 75067 -4177 20130514 -160 tlll. Ilf I�ul�llllnnlllli II „ I , II „ IIIIIII , I , Iu , lE�liill TODD R HAIR 169 E NORTH ST CARLISLE, PA 17013 -2431 s PA N0l Sent Via Certified Mail 7196 9006 9296 7111 4255 05/14/2013 ACT 91 NOTICE TA'Ivr%- ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save Your home. This Notice explains how. the progr,, am works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY `'VITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when You meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counselin, A -genies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at 1 -800- 342 -2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADRJNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONUINUAR VTVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAM.ANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. O AF PA N01 PageIof6 7196 9006 9296 7111 4255 HOMEOWNER'S NAME(S): STACI L HAIR TODD R HAIR PROPERTY ADDRESS: 169 EAST NORTH STREET CARLISLE, PA 17013 LOAN ACCT_ NO.: M791 ORIGINAL LENDER: "CENTEX HOME EQUITY COMPANY, LLC" CURRENT LENDERISERVICER: Nationstar Mortgage, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1993 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must, arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice_ THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING_ YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseliniz agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION OTTH PHFA WITHIN 30 DAYS OF THAT MEETLPYG, THEN THE LENDER WILL BE TE.VPORARILY PREYEATTED FROM STARTING A FORECLOSURE AGAEVST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." PA N01 Page 2of6 7196 9006 9296 7111 4255 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EYEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREYENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EYENTUALLY APPROYED AT ANY TI41E BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brints it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 169 EAST NORTH STREET CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Next Payment Due Date: 03 {15/2013 Total Monthly Payments Due: $1,211.28 Late Charges: $43.05 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $0.00 Corporate Advance Balance: $454.15 Unapplied Balance: $1( 23.56) TOTAL AMOUNT PAST DUE: $1,584.92 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,584.92 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check, or money order made payable and sent to: Nationstar Mortgage, LLC 350 Highland Drive Lewisville, TX 75067 -4177 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins PA Page 3of6 7196 9006 9296 7111 4255 legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paving the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs 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 or action will be by contacting the lender. HOB' TO CONTACT THE LENDER: Name of Lender: Nationstar Mortgage, LLC Address: 350 Highland Drive Lewisville, TX 750674177 Phone Number: 1-888- 480 -2432 Fax Number: 1- 972 -315 -6827 Contact Person: Kevin Gerdes E -Mail Address: customer .service @nationstarmail.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You X may or , may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that other requirements of the mortgage are satisfied YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROVd MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOVdEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN.ANY CALENDAR YEAR.) PA_NOt Page4of6 7196 9006 9296 7111 4255 • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(8), you may dispute the validity of this debt, or any portion thereof, if you do so in writing within thirty (30) days after the receipt of this notice. If you dispute the validity of this debt, or any portion thereof, within this thirty (30) days period we will provide you with written verification thereof, otherwise the debt will be assumed to be valid. Sincerely, Kevin Gerdes Foreclosure Prevention Specialist Nationstar Mortgage, LLC 1- 888 - 850 -9398 ext. 8067100 350 Highland Drive Lewisville, TX 75067 -4177 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 BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE S F" REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER- PA Page 5of6 7196 9006 9296 7111 42SS HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updatui: 03I20i2013 02:18 PM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 7000 Linglestown Road 1514 Deny Street Harrisburg, PA 17102 Harrisburg, PA 17104 888- 511 -2227 717 - 232 -9757 Housing Alliance of YorktY Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717- 855 -2752 717- 762 -3235 PathStone Corporation PatMone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717- 234 -6616 717 -264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 -334 -1518 717- 780 -3940 800 -342 -2397 I Page 6of6 7196 9006 9296 7111 4255 Ey hibit C (Page 7 of 9) WUhG: 6 OLOZ /LO /LO t.oAW WDI1F7CA AGRCEMLMr— Up,ta4(rrap H.eddevl 01^36te owil/r) [Space Above Ibis Line For Recording Dsta) Loan o: 91 LOAN MODMCATION AGREEMENT (Providiaz for Temporary Pitted Intereil Riti then Adjustable lntemi Rale) This Loci Modification Agreement ( "Agmcneot"), mado this 6;h day of )artuary, 2010, between Sraci L. Hair and Todd R. Ha r ( "Borrower") and Nadorstar Mortgage LLC formerly known as Centex Home Equity Company NLenden amet ds and s% .4lements (1) the Mortgage, Deed of Taut, or Security Deed (the " Security Instrument'), and Timely Payment Rewards Rider, if any, dated April 27, 2005 and recorded in Book or Lber _ . at page(s) , of the Records of (Vaoe of Retards) (C.—Y sd Salt or oiler hcisdiamo) ad (3) the Note, boxing the same dale a9, and secured by, the Smurity Dwramen% which covers the trill mid pmonal prtglcrty described in the Security Instrument and defined therein as the `Propety", located to 169 East Forth Street Carlisle Pa 17013 Rroptry ndhrrf the real property described being sr, forth as follows: THE NOTE CONTAINS PROVISIONS ALLOWING FOR CHANCES IN THE INTEREST RATE AND THE MONTHLY PAYMENT, THE NOTE LRVIM THE AMOLI T THE BORROWER'S INTEREST RATE CAN CHANCE AT A.NY ONE TIME AND THE MAXrWUSI RATE THE BORROWER MUST PAY. In consideration of the munW promins and op menti exchmacd, the pluUes bison ag= as fallon-3 Cnotlrithltandine anyrhing to the eanlrary contained in the , rote or Security lnstrtmcrt): L As of Merck 15, 2010, the amount payable under the Note and die Security Instrument (the 'Unpaid Principal Balance") Is U.S. S 55,429. 13, consisting of the unpaid amounts) loaned to Burrower by Lender plus any hiteimt and other aanm= capitalized. 2. Borrower promises to pay the Unpaid Principal Balance, phis interest, to $.c order of tender. hseren will be charged on the Unpaid Principal Balance at the yearly rate of 6S4'h, from February 15, 2010 until February 15, 2035. Borrower promises to Hoke el0111W pUM -211ti of prirlCWI and inteml of U.S. S 360.67, be inning an the 15th day of Marrli,1010, ad a ntinuing thereafter on the rare day of each succeeding month until February 15, 2035 (the "Fixed Rare Period"). After expiral�on of die Fixed Rate Period, the interest rate Borrower will pay may change is accordance with the terms ofthe original vote. Aft - expiration of the Fired Rate Period, the amount of Borrower's monthly payments may change in accordance with t!e terns of the original Note. Borrower will continue to hake monthly payments on the cams day of each succeeding month until principal and interest are peld in Atli, except that, if not sooner paid, the final payment of principal and interest shall be due and payable on the NU 15, 2035, which is the .manuity Date. 3. If on the Mahirity D21e, liet<ts V Still awes am6ur is Hader & Mote and the Security fuseumem, as amended by this Agreement, Borrower will pay three arooents in full or, the Maturity Data, 4. Failure m Timely Remit Nymerts• If el any time during the effective dates of this Modifienion Agreetcenl the Borrower fails to timely make payments as specified haeinabove and such default or failure continues for mare than thirty (31) days, then this Modif - lou A&—vn% at the option of Leader, ship terminata and all terns of the Note as originally executed shall be remsce -ad in full, effective as of the date of this Modification Agreement, end the amoanro due and payable under the term of the Note shall be as originally stated therein, as if this Modification Agreement had newer existed. Time is of the essence with regard to all payments SpeCi5td herdlader. Nothhtg eanWfled hefaia jW pWa,,t or preclude Lender from ar1&reiag any of Leader's rights or remedies under the Note, or under any documart or instrument evideae ng or secadag the indebtedness created by' or under the Note, or titan be Construed as a waiver of any of Leader's rights or teemclies tbereby created. ZoolA .LLI.703 axon Y3DM 1a1CW1191' 1Vd Wor 0102 /10/10 (Page 8 of 9) WVW 6 OLOZ /LOILO Ack Ur. - Escrow t of t 0 1 /06!2010 Letter of Acknowledgment Letter of Acknowledgment )enttmy 06.2010 Sia:i L Hair Todd 1t. Hair 169 East North Street Carlisle Pe 17013 RE: Loan \amber. �791 Dear Staci L. & Todd R Hair, Al>ached for 6CifWc6 is OK W41 gtion AXGemem for Your loan serviced by 3vationsw Mor%mg , LLC. T e Modification Agramtt:itts fbob the furore terms of mpsymumt for your loon and ma include apitartzaAon of certain outstan past due amounts. The spetWe terms are identified in the ModlOcatfop Agreemea% and may includes period of time for Wideb your Payment will consist only offnim it payments (resulting In no principal reduction) and/or change In the amortization term of your loan (Such a change may result in you owing a ltarip stem paymet upon maturity of your Iona). By executing Wt Letter of Ac and the Modifiadon Agreement, you are agreeing to make a qualifying. payment of 5934.24 dollars (° Qualifying PaymenO for your Modification Agreement to become afleetivn This Qualifying Payment will be Applied first to a Modifadoa Fee of 5350.00 dollars to Nodoastat Mortgage, nest to any outstanding foes and charges dust are not capttalized under the tt:cma of the Modffleadon Agmmcn; next to any unpaid non•capitalimd interest and finally to unpaid principal. If you fall to make this qualifying payment (or such payment is returned for non - sufficient funds or otherwise denied by the issuing bank), the Modification: Agreement %ball be deemed imratid Arid Nationster Mortgage, LLC shall have no obligation to modify your lato l0 accordance with the tern of th Mo&scaton AgrecmcaL In addition to the foregoing, in corzideration of Nationstar Mortgage agreeing to rho modification ofyou toes account. You aclmawledge and agree that Natiortstar Mortgage may malottdn an escrow account to trolled funds for the payment of fitmm texas and insurance in -cc "4231 with tho terms of the attached Agreement to MnL.ttain Escrow Account. Should you have Arty gmcstieos rq;ardirg the terms of this Letter of Achmowledgmtm or the Modifluxtlon Agreemen; pease do net hesitate to eatls,-t at Sincerely, Nationstar Mortssm LLC Aclmowtedgrd and agreed to by: I Steel L Hour- orrowar Klemm) (Data) 1 -9 -Zorn Todd It Hei - (Bortow t. Name) (Date) SOOT$ L1.03 350$ rM. aa L6 TYd BS :01 OTOZ /LO /IO I (Page 9 of 9) Wtii9:6 OIOZ /LO /10 r LOAN MOOWTCATMALe xxa(Eh`r— CvAtW(ro ?F-"_) alALnalo QgeI • Loan tlt'-7T91 . Loan tk'1WL S. Borrower uuderstmds and agrees that (a) All the fthts and remedies, stiputsEcas, and conditions comained in the Security Insimmert fel erine to default In the making of payments under the Security Instrtrnert shall else apply to default In the making of The modified payments hereunder. (b) AD covenants, egmemenn, stipulations, and renditions in the Note and Security Instrument shall be and remain in fug force aid effect, except as basin modified, and none of the Borrower's obligations or liablEties under the Rote and Security lnstrtanent shall be dlmkished or released by any provisions hereof, nor shall this Agreement in any way impair, dirokisb, or effect any of tender's riglas under or remcd ?es on the Ntnc and Security faawmeak whether such rights or remedies arise theTwttder or by operation of laws. Also, all rights of recourse to wNch Lmder h pet cady entinled aid= any pTtlperty or my other persons ID emu way obliptw fm, to liable On, the *lose and Security (esauroent are expressly reserved by leader. (c) Borrower tats no ri& of set -off or counterclaim, or any defense to the obtigatlors of the Note or Security Instrument- (d) No-,hiog in this Agreement shall be understood or construed to be a satkfactlon or release in whole at in part of the Note and Security Tna trumen (e) All coats and expenses incurred by Lender in conamdon with this All .mmcn% intlaft recording feq tick exsminetian. and attorney's fees, shall be paid by the Borrower and shall be seamed by the Security Instrument, unless atipult ad otherwise by Lender. (t) Borrower agrees to make end execute such o•.her documems or papers as may be necessary or required to effcatuam the terms and condhions'of this Agreement which, if approved and accepted by Leader, shall bind and Inure to the Celts, executors, administtaa, and assigns of die Borrower. Nnm002YATlpaeL`.6Leader ',&d ndr- 13Mtv.r: err. ) ^ Todd 0. ItAi -a—, STATEOF Ct1R�V >ss. COMM OF w..��l l r, ) r') On the der 1 of L DQL1S- 2-0 10 penocatiy appeared before me personally known to me (or proved to me an the basis of sadsfaaory evidence) to be the person(s) whose name(s) iflam subscribed to the within Instrument end acknowledged to me that hersbdthey executed ate same in hisi7mmeir authorized CV;Ictty(its) and that by hiJLwMeir siv ume(s) on the instrument the pesora(s), or The entity upon behalf of which the persan(s) acted, executed the insbumenL Wih m 12Y hwd and ofricial Scam COU ONWEAMN 0: PENNSYLI'ANIA t:CFAR'AL SEAL j0D`' GOLGR:NV. Nc'ary Publle N Publ e M tment ire : C:IV of Hnrris�crg Djte,hin Cc!nfy Y apps m s �,'7 (- - ;«�cc czc ?•• or, O3, iG1� (Space Below TCu Line for Aekmowledgetneatsj 1 S00@j 'UH103 M(OH MUM Le TtMBOt TFd MOT OTOZ /LOiTe IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, NATIONSTAR MORTGAGE LLC, F/KIA CENTEX'r': HOME EQUITY COMPANY, LLC I _' Plaintiff Case No. .i3_ g46`I l .. vs. v t , CD CZ STACI L. HAIR TODD R. HAIR 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 format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted r (Signature of Counsel for P ' I `�- t3 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Plus Rocket BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your lender roust consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes Ej No L] Listing date: Price: Realtor Name: Realtor Phone: Borrower Occupied? Yes D No El ��— Mailing Address (if different) City: State: Zip; Phone .Numbers: Homer Office: Cell: Other; F..n�ail; of people in household.: How long? Mailing Address: City: State: Zip: ... .......... Phone ?Numbers: Horne: Office: Cell: Other: Email: # of people in household: How long? First Mortgage l-ender: Type of Loan: Loan. Number: bate You Closed Your Loan: Second Mortgage Lender: Type of Loan; Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: is the loan in Bankruptcy? Yes El No ff yes, provide names, location of court, case number & attorney: � Assets Amount Owed: Value: 140me: S S Other Real Estate: $ $ Retirement Funds; $ - Investments: S S Checking: $ $ Savings: S S Other: $ Automobile n1: Model: Year: Amount owed: Value- Automobile #2: Model: Year: Amount owed: Value; Other transp ortation automobiles boats motors cles Model: Year Amount owed: "Value Monthly Inouye Name vl "Employers: 11 2. 3. Additional Income Description (not wages): 1. monthly amount: 2:_ . monthly amount: Borrower Pay bays: Co- Borrower Pay bays: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT 13"EN AMOUNT Mortgage Food 2 Mort a . Utilities f Car Pa i Condo/Nei . Fees Auto Insurance Ivied. not covered Auto fuel /re airs Other prop. payment Install. Loan Payment Cable TV Child Su rt/Alim, Spending Mone L?a j /Child Cavell t it. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been wonting with a Housing Counseling Agency? Yes Cl No El If yes, please provide the Following information; Counseling Agency Counselor: Phone.(Office): Fax: – l✓n�ail; Have you made application for Homeowners Emergency Mortgage Assistance Program _(HEMAP) assistance? Yes Fj No �? if yes, please indicate the status of the application. Have you had any prior negotiations with your tender or lender's loan servicing company to resolve your delinquency? Yes ❑ No If yes, please indicate the status of those negotiatio Please provide the follo%.r ng information, if know, regarding your lender or leader's loam servicing company: Lender's Contact (game): .phone; Servicing Company (Name): Contact: Phone: lAve, , authorize the above named to uselrefer this information to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. Me 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 follovwing information to lender and lender's counsel; Proof of income V Fast 2 bank statements Proof of any expected income for the last 45 days [ Cope of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation . (hardship letter) V Listing agreement (if property is currently op the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 01 JU ,,/r Jody S Smith Chief Deputy i ; r[■ 11 ��""a° —6 P'€' ' p Richard W Stewart (te �, t�,, Solicitor ;3 e ;I ! R ..1-4t ! PENNSYLVANIa, Nationastar Mortgage LLC, f/k/a Centex Home Equity Company, LLC Case Number vs. Staci L. Hair(et al.) 2013-7464 SHERIFF'S RETURN OF SERVICE 12/26/2013 03:00 PM - Deputy Noah Cline, 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: Staci L. Hair at 169 E. North Street, Carlisle Borough, Carlisle, PA 17013. NOAH CLINE, DEPUTY 12/26/2013 03:00 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Staci Hair, Wife, who accepted as"Adult Person in Charge"for Todd R. Hair at 169 E. North Street, Carlisle Borough, Carlisle, PA 17013. NOAH CLINE, DEPUTY SHERIFF COST: $50.78 SO ANSWERS, December 27, 2013 RONNK R ANDERSON, SHERIFF PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180 -3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215- 627 -1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13 -7464 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 4/4/2014 to Date of Sale per diem at $9.44 (Costs to be added) cv So.1g Ct31: 163.-)S c c, " 1. 1 c0.5 S °i V By: $74,473.07 KML LAW'GROIJP, '.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. 205047 Mill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff r76 gear' Pc/4.5- Wi(-16,E CD • C. C`; Fr No. 13 -7464 IN THE COURT OF COMMON PLEAS NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC vs. STACI L. HAIR and TODD R. HAIR (Mortgagor(s) and Record Owner(s)) 169 East North Street Carlisle, PA 17013 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 ALL THAT CERTAIN tract of land with the building thereon erected situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a point on the northern side of East North Street, thence by Northerly direction 93 feet to a point; thence in an Easterly direction 16.9 feet to a point; thence in a Southerly direction 93 feet to a point; thence in a Westerly direction along the Northern side of East North Street, 16.9 feet to the place of BEGINNING. AND BEING the Westerly house of a row of frame dwelling houses, the eastern boundary line of said houses running through the partition separating the house on the , East thereof, and being known as No. 169 East North Street. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY First Ward of the Borough of Carlisle BEING PREMISES: 169 East North Street Carlisle PA 17013 SOLD as the property of Todd R. Hair and Staci L. Hair, husband and wife TAX PARCEL # 02 -21- 0318 -030 BEING the same premises which Kerry R. Henne and Joan M. Henne, husband and wife by deed dated 4/27/2005 and recorded 5/2/2005 in Cumberland County in Deed Book Volume 283 at Page 3372 granted and conveyed unto Todd R. Hair and Staci L. Hair, husband and wife. KML Law Group, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff HOTHONOTAI':' 20-R APR -7 AMID': 1 7 CUMBERLAND COUNTY PENNSYLV NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 VS. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 13-7464 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: KML LAW' 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. 205047 P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ' _-/ THCNO TA 2014 APR -7 AM 10; 17 NATIONSTAR MORTGAGE LLC, F/K/A CENTEX "HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 VS. STACI L. HAIR TODD R. HAIR (Mortgagor(s) and Record Owner(s)) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) ENNSYLVAA. IN THE III COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7464 AFFIDAVIT PURSUANT TO RULE 3129 NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, 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: 169 East North Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): STACI L. HAIR 169 East North Street Carlisle , PA 17013 TODD R. HAIR 169 East North Street Carlisle , PA 17013 2. Name and address of Defendant(s) in the judgment: STACI L. HAIR 169 East North Street Carlisle , PA 17013 TODD R. HAIR 169 East North Street Carlisle , PA 17013 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: CITIFINANCIAL, INC. 250 E Carpenter Freeway Irving, TX 75062 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 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 169 East North Street Carlisle , PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false s ments herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to au hori s. DATED: By: KML LAW GROUP, .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. 205047 ill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC IN THE COURT OF COMMON PLEAS 350 Highland Drive Lewisville, TX 75067 of Cumberland County 13 -7464 251aA'R —7 Ail 10. 17 COUNTY Plaintiff CIVIL ACTION - LAVV vs. STACI L. HAIR ACTION OF MORTGAGE TODD R. HAIR FORECLOSURE Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Defendant(s Docket No. 13 -7464 . 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: HAIR, STACI L. STACI L. HAIR 169 East North Street Carlisle , PA 17013 Your house at 169 East North Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $74,473.07 obtained by NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, 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, F /K/A CENTEX HOME EQUITY COMPANY, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find 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. 13-7464 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.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@kmllawgroup.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 123056FC. Para infonnacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627 -1322 Attorney for Plaintiff 2 iAPR -7 tMi3;17 AN CC,�3 l e NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s 13 -7464 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13 -7464 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 SHERIFFS SALE OF REAL PROPERTY TO: HAIR, TODD R. TODD R. HAIR 169 East North Street Carlisle , PA 17013 Your house at 169 East North Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $74,473.07 obtained by NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, 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, F /K/A CENTEX HOME EQUITY COMPANY, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find 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. 13-7464 4. You may need an gttOrney 'to-Assert yob'. 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 SHERIFFS SALE DOESNOT 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.ivetititin the Cairn to set aside the sale if the bid price grOssly inadequate • , % compared to the value of your property. 4' t 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, ; • , 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 ne4r'happened.' " % 4 ' You have aright to remainin the Property until the ftill 'amount due is paid to the Sheriff and the Sheriff gives a deed to the bnyer. At that time,,the buyer nay bring legal prOceedings to evict you. 6. You may-be entitled to a shareof the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed,1;Yttlie Sheriff within thirty (30) days from the date of the Sheriffs Sale This schedule \yin-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 filedAvith the-Sheriff Within ten (10) dayi after the schedule dfdistribiitionis filed. • I a' F' 7.. < You may also have other rights and deferises;or-ways:of getting your house back, ifyou act immediately after the sale.. 41 b , 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 13-7464 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.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@kmllawgroup.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 123056FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC Vs. NO 13-7464 Civil Term CIVIL ACTION — LAW STACI L. HAIR TODD R. HAIR WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $74,473.07 L.L.: $.50 Interest FROM 4/4/2014 TO DATE OF SALE PER DIEM AT $9.44 Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.53 Other Costs: Plaintiff Paid: Date: 4/7/14 (Seal) LJL- DavidTi,el1 Prnthrmotary 13)L.,-,-Ateeseeamt-e_e ' Deputy 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 In the Court of Common Pleas of Cumberland County NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R. HAIR (Mortgagor(s) and Record Owner(s)) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 13 -74 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. Answer. Enter the Judgment in favor of Plaintiff and against STACI L. HAIR and TODD R. HAIR by default for want of an Assess damages as follows: Debt Interest from 4/4/2014 to Date of Sale per diem at $9.44 Total (Assessment of Damages attached) $74,473.07 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 mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default/occ,�rred1and a least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.G.P. 237. By: KML LA Michael Keever 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 I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 _Andrew F. Gomall Pa. ID 92382 Attorneys for Plaintiff AND NOW Pr7rt tN a LA► 7'l° y�pS Mate , Judgment is entered in favor of NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC and against STACI L. HAIR and TODD R. HAIR by default for want of an Answer and damages assessed in therm of $74,473.07, as per the above certification. Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 STACI L. HAIR TODD R. HAIR (Mortgagors and Record Owner(s)) 169 East North Street Carlisle, PA 17013 _ Plaintiff VS. Defendant(s) No. 13-7464 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 Deputy If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 123056FC 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. TO STACI L. HAIR HAIR, STACI L. 169 East North Street Carlisle , PA 17013 NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff" vs. STACI L. HAIR TODD R. HAIR (Mortgagor(s) and Record Owner(s)) 169 East North Street Carlisle , PA 17013 Defendant(s) TO: STACI L. HAIR 169 East North Street Carlisle , PA 17013 DATE OF THIS NOTICE: March 10, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13 -7464 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 IELEPHONE 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 Carlisle, PA 17013 717 -243 -9400 By: KML LAW ROUP, 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 Jill P. Jenkins Pa. ID 306588 Alyk L. (?flazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Michael J. Coskey Pa ID 311835 215- 627 -1322 Attorneys for Plaintiff 123056FC 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. TO: TODD R. HAIR HAIR, TODD R. 169 East North Street Carlisle , PA 17013 NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. STACI L. HAIR TODD R. HAIR (Mortgagor(s) and Record Owner(s)) 169 East North Street Carlisle , PA 17013 Defendant(s) TO: TODD R. HAIR 169 East North Street Carlisle , PA 17013 DATE OF THIS NOTICE: March 10, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13 -7464 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 1EN (10) DAYS FROM THE DALE 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 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Krishna Murtha Pa. ID 61858 David Fein Pa. ED 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 to Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Michael J. Coskey Pa ID 311835 215 - 627 -1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff vs. STACI L. HAIR TODD R. HAIR Defendant(s) NO. 13-7464 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): STACI L. HAIR, has a last known residence of 169 East North Street, Carlisle , PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X 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. 4.04 elating to unsworn falsification to autho ities. Date t By: " KML LAW GR 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 Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello -Pa. ID 313897 7Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of : Apr-03-2014 09:42:18 AM SCRA 3,0 Status Report Pursuant to Service nate tubers Civil Relief Act Last Name: HAIR First Name: STACI Middle Name: L. Active Duty Status As Of: Apr -03 -2014 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 The Member or His/Her Unit Was Notified of a Future Call-Up 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 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. 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. 8501 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 currentl on active duty" responses, and has experienced only a small error rate. In the event the individual referenced abov , 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 "uemnuoxnx.miruecottv:mwww.00fenvonnxmi|mun/pis/p0000Lon.mm|. If you have evidence the person wa 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 day preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification mmnvrtuxom*o 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 muscO1o1(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 unde the SCRA is broade in some cases and include 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 time orders are amende to extend the perio of active duty, whic would extend SCRA protections. Persons seekin to rely on this websit certification should chec to mak sure the orders on whic 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: 58}{2E3B/\5003U20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC, F /K/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff vs. STACI L. HAIR TODD R. HAIR Defendant(s) NO. 13 -7464 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): TODD R. HAIR, has a last known residence of 169 East North Street, Carlisle , PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X 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. 4'04 elating to unsworn falsification to autho Date By: 7 V KML LA I ' S `' , 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 Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 .Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of : Apr -03 - 2014 09:43:54 AM SCRA 3.0 St to R part Pursuant 'to Sere icememi s Civil l of Act Last Name: HAIR ' First Name: TODD Middle Name: R. Active Duty Status As Of: Apr -03 -2014 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 The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Dale Order Notification End Date Status Service Component NA NA .._ No NA This response reflects whether the individual or his/her unit has received earty notification io 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. 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: N8B5K3AA6003460 KML Law Group,-P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 VS. STACI L. HAIR TODD R. HAIR (Mortgagor(s) and Record owner(s)) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7464 ORDER FOR JUDGMENT Please enter Judgment in favor of NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC, and against STACI L. HAIR and TODD R. HAIR for failure to file an i Answer in the above action within 14, (20) days from the date of service of the Complaint, in the sum of $74,473. 7 By: KML LAW OU , .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. 205047 ill 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, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 and that the name(s) and last known address(es) of the Defenc;ant(s) is/are ST CI L. HAIR, 169 East North Street Carlisle , PA 17013 and TODD R. HAIR, 169 East North Street Carlisle LPA 17 13; By: KML LA Michael McKeever PYi, 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 Jill 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 Interest from 02/15/2013 through 04/03/2014 Escrow Advance Corporate Advance Forbearance Balance AND NOW, this 7 day of 13-7464/123056FC $68,022.03 $3,895.13 $2,597.87 $81.60 ($123.56) $74,4 3.0 By: KML L 0 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. 205047 V- Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff , 2014 damages are assessed as above. Pro Prothy KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff t. THE PROTHONOTARY TA 1614 AUG 14 PM 2:22 riltlf3ERLAND COUNTY NATIONSTAR MORTGAGE LLC, F/K/A P E N N S ' L V NIA IN THE COURT OF COMMON PLEAS CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive of Cumberland County Lewisville, TX 75067 123056FC CF: 12/18/2013 SD: 09/03/2014 $74,473.07 vs. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-7464 Andrew Hauck, 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: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of 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. Premises was posted by Sheriffs Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by KML Law Group, P.C. (copy of 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, BY: Andrew Hauck Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC; et seq. Plaintiff (Petitioner) V. STACI L. HAIR; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13-7464 Sheriffs Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint 0 Summons 0 Other: NOTICE OF SALE I, KEVEN CHASE, 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 STACI L. HAIR the above process on the 24 day of April, 2014, at 3:34 o'clock, PM, at 169 EAST NORTH STREET CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: RI By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found * D By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides * El By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s) agent or to the person for the time being in charge thereof * * Name: TODD HAIR Relationship/Title/Position: Spouse Remarks: Description: Approximate Age 41-45 Height 6' Weight 275 Race WHITE Sex MALE Hair BLACK Military Status: El No 0 Yes Branch: Commonwealth/State of /s ) ) SS: County of fat e e t ) Before me, the undersigned notary public, this d y, personally, appeared V 4.0 e• C 4.4 f to me known, who being duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File Number:123056FC Case ID #:3956300 Subscribed and swo this ?f day e , 20 /r1 . COMMONWEALTH OF PENNSYLVANIA PIOTARlAL SEAL Eric M. Affierbach, Notary Public Washington Township, Berks County My Comsniaslon C-xpitcs_ November2017 _13, _-_ Notary Public IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC; et seq. Plaintiff (Petitioner) V. STACI L. HAIR; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13-7464 Sheriff's Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE 1 1- ❑ Complaint 0 Summons EJ Other: NOTICE OF SALE 1, KEVEN CHASE, certify that 1 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 TODD R. HAIR the above process on the 24 day of April, 2014, at 3:34 o'clock, PM, at 169 EAST NORTH STREET CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Q By handing a copy to the Defendant(s) Description: Approximate Age 41-45 Height 6' Weight 275 Race WHITE Sex MALE Hair BLACK Military Status: FiNo ❑ Yes Branch: Commonwealth/State of P` County of fI e t K,i ) SS: ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: u e v..+ (tag c to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) Subscribed and sw. .. or this ZP day o - ,, t , 20 "`1 File Number:123056FC Case ID #:3956300 Notary Public COMMONWEALTH OF PENNSYLVANIA_ NOTARIAL SEAL Eric M. Afilerbach, Notary Public Washington Township, Berks County My Commission Expires November 18, 2017 Name and Address of Sender )0LDBECK(If iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: ❑Certified El Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 • Carlisle, PA 17013 CITIFINANCIAL, 250 E Carpenter Irving, TX INC. Freeway 75062 ... ` GI,i ;�'•F - _ 1�t; -... .•. N1/4M • o a uNITFpsT oN 0. 0 •• Wi73 1:4 . 3 it,\\ ti) to 74G 2.GI �_----., PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 I Ii-INANUTAL, 1 Valley Carlisle, INU. Street, Suite PA 17013 103 -4.110t..../I• 9 44Ci 0 sOs 3• us • - �' s9 05 i r.. Harrisburg, PA 17105-2675 TENANTS/OCCUPANTS 169 Eas: Carlisle North Street• PA 17013 5. t''-0 40s 3, mw o � O N 6. 1 O O cs)n 7. 8. Total Number of Pieces.,,tal Number of Pie s Listed by SderSR eived at Post i Postmaster, Per ( e9 f r ceiving employee) See Privacy Act Statement on Reverse PS Form 3877, F6uary 2002 (Page 1 of 2) 123056FC Cumberland County Sale Date: 09/03/2014 STACI L. HAIR & TODD R. HAIR Complete by Typewriter, Ink, or Ball Point Pen 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, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-7464 AFFIDAVIT PURSUANT TO RULE 3129 NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, 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: 169 East North Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): STACI L. HAIR 169 East North Street Carlisle , PA 17013 TODD R. HAIR 169 East North Street Carlisle , PA 17013 2. Name and address of Defendant(s) in the judgment: STACI L. HAIR 169 East North Street Carlisle , PA 17013 TODD R. HAIR 169 East North Street Carlisle , PA 17013 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: CITIFINANCIAL, INC. 250 E Carpenter Freeway Irving, TX 75062 CITIFINANCIAL, INC. 1 Valley Street, Suite 103 Carlisle, PA 17013 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 169 East North Street Carlisle , PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 12, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant AW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center Philadelphia, PA 19106 215-825-6320 • Attorney for Plaintiff NATION STAR MORTGAGE LLC, F/IQA CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R: HAIR Mortgagor(s) arid Record Owner(s) 169 East North Street Carlisle, PA 17013 Defendant(s) Plaintiff FIL E r D -- Orr! CE — THE i3oNo ?IN NOV 12 Ph 2: 5 CUMBERLAND COUNTY P E i'v74 S YL NIA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13-7464 Book: Writ: NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for November 05, 2014 at 10:00 AM in the above matter has been continued until Janua 07,2015 at 1Qs0 AM Date: By: KML LAW GROUP, P.C. 701 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Michael McKeever Pa. ID 56129 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 /Jennifer Lynn Freebie Pa. 11) 316160 Attorneys for Plaintiff KW, LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center - - = 7D1. Market Street - - - - Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC 350 Highland Drive Lewisville, TX 75067 vs. STACI L. HAIR TODD R. HAIR Mortgagor(s) and Record Owner(s) 169 East North Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF FILING Term No. 13-7464 Book: Writ: I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of Continued Sheriff's Sale in the above upon the following parties on the date listed below: STACI L. HAIR 169 East North Street Carlisle , PA 17013 TODD R. HAIR 169 East North Street Carlisle , PA 17013 defendant(s) Steven P. Miner, Esquire Via fax: 717-724-9826 attorney for defendant SHERIFF OF CUMBERLAND COUNTY Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 (via facsimile or e-mail) PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 (via e -filing if applicable) Date:////3 KML LAW GROUP, P.C. 701 Market Street, Suite 5000 Philadelphia, PA 19106 (215) 825-6332 Veronica Cosme