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The information collected on this form is used solely for court administration purposes.. This form does not
supplement or replace the filing and service of leadin s or other papers as required by lmv or rules o court.
�— -� Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction 11 Declaration of Taking
C Lead Plaintiffs Name: Nationstar Mortgage LLC Lead Defendant's Name: Luke J. Slother
T
I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits
O (check one) ❑ outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this a_ n MDJAppeal? ❑ Yes ® No
I
! A Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C.
❑ Check here if you have no attorney (a Self- Represented (Pro Sel Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
• Intentional ❑ Buyer Plaintiff Administrative Agencies
• Malicious Prosecution ❑ Debt Collection: Credit, Card ❑ Board of Assessment
• Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
• Nuisance ❑ Department of Transportation
• Premises Liability (does not include ❑ Statutory Appeal: Other
S mass tort)
E ❑ Slander/Libel/ Defamation ❑ Employment Dispute:
❑ Other: Discrimination
C ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other
I
O ❑ Other
N MASS TORT
❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS
B ❑ Toxic Waste
❑ Ejectment _ ❑Common Law /Statutory Arbitration
❑ Other:
❑ Eminent Domain/Condemnation C3 Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Disput ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY Mortgage
❑ Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/12011
JDEC T"1 f? y
PENS �'C V C� f
ANl
McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
215 790 -1010
Nationstar Mortgage LLC Cumberland County
350 Highland Drive Court of Common Pleas
Lewisville, TX 75067 .�' w ^
Number I lJd p(
v.
Luke J. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
and
Michelle K. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
COMPLAINT IN MORTGAGE FORECLOSURE
IC16 9. ��zw
File # 76551
Paoe 1 a
NOTICE AVISO
You have been sued in court. If you wish to Le han demandado a usted en la corte. Si
defend against the claims set forth in the usted quiere defenderse de estas demandas
following pages, you must take action within ex- puestas en las paginas siguientes, usted
twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la
notice are served, by entering a written fecha de la demanda y la notificacion. Hace
appearance personally or by attorney and falta asentar una comparencia escrita o en
filing in writing with the court your defenses persona o con un abogado y entregar a la corte
or objections to the claims set forth against en forma escrita sus defensas o sus objeciones
you. You f are warned that if you fail to do so a las demandas en contra de su persona. Sea
the case may proceed without you and a avisado que si usted no se defiende, la corte
judgment may be entered against you by the tomara medidas.y puede continuar la demanda
court without further notice for any money en contra suya sin previo aviso o notificacion.
claimed in the complaint or for any other Ademas, la Corte puede decidir a favor del
claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con
may lose money or property or other rights todas las provisions de esta demanda. Usted
important to you. puede perder dinero o sus propiedades u otros
derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER
TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE
DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO
TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO
BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O
YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO
HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE
IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION
HIRE A LAWYER, THIS OFFICE MAY BE ACERCA DE EMPLEAR A UN ABOGADO.
ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE
INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN
THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER
ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON
OR NO FEE. INFORMACION ACERCA DE LAS
AGENCIES QUE PUEDEN OFRECER LOS
Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS
32 South Bedford Street ELEGIBLES EN UN HONORARIO
Carlisle, Pennsylvania 17013 REDUCIDO NI NINGUN HONORARIO.
(800) 990 -9108
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990 -9108
File # 76551
Page 2
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is Nationstar Mortgage LLC, duly organized and doing business at the
above- captioned address.
2. The Defendant is Luke J. Slother, who is a mortgagor and real owner of the
mortgaged property hereinafter described, whose last -known address is 802 Darla Road,
Mechanicsburg, Pennsylvania 17055.
3. The Defendant is Michelle K. Slother, who is a mortgagor and real owner of the
mortgaged property hereinafter described, whose last -known address is 802 Darla Road,
Mechanicsburg, Pennsylvania 17055.
4. On September 21, 2011, Luke J. Slother, and Michelle K. Slother, mortgagors, made,
executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic
Registration Systems, Inc. as nominee for Stearns Lending, Inc. which mortgage is recorded in the
Office of the Recorder of Cumberland County as Instrument Number 201126734 ( "the Mortgage "),
such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.
5. On August 21, 2013, the Mortgage was assigned by Mortgage Electronic Registration
Systems, Inc., as nominee for Stearns Lending, Inc., it successors and assigns to Nationstar
Mortgage LLC, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland
County as Instrument Number 201327919, such Assignment of Mortgage being incorporated herein
by reference pursuant to Rule 1019(g) Pa. R. C. P.
6. The premises subject to said mortgage is described in the legal description attached as
Exhibit "A" and is known as 802 Darla Road, Mechanicsburg, Pennsylvania_ 17055.
File # 76551
Page 3
7. The mortgage is in default because monthly payments of principal and interest upon
said mortgage due June 1, 2013 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon default in such payments for a period of one month, the entire principal balance
and all interest due thereon are collectible forthwith.
8. The following amounts are due on the mortgage:
Principal Balance $ 174,152.33
Interest through December 20, 2013 $ 4,644.08
(Plus $580.51 per month thereafter)
Escrow Advance $ 2,080.77
Mortgage Insurance Premiums (MIP) $ 789.66
Property Inspections $ 60.00
GRAND TOTAL $ 180,937.18
9. Plaintiff complied with all notice requirements as prescribed by 41 P.S. § 101, et seq.
(Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable.
WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of
$180,937.18, together with interest at the rate of $580.51 per month and other costs and charges
collectible under the mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG & CONWAY, P.C.
BY:
[ ] Terrence f McCabe, Esquire [ arc S... eisberg, Esquire
[ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire
[ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire
[ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire
[ ] Celine P. DerKrikorian, Esquire
Attorneys for Plaintiff
RE: / Property Address: 802 Darla Road, Mechanicsburg, Pennsylvania 17055
FILE #: 76551
File # 76551
Page 4
VERIFICATION
w >4V'e w hereby states that he /she is Assis tant Secretary
of Nationstar Mortgage LLC, Plaintiff in this matter, that he /she is authorized to make this
Verification, and verify that the statements of fact made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and
belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
/ Name:
C A ndve�e, i�a>�Q
DATE: I — a01 Title: Assistant Secretary
File #: 76551
Name: Nationstar Mortgage LLC v. Luke I Slother and Michelle K. Slother
File # 76551
Page 5
i • f
• n
i
j EXHIBIT "A"
i
-1
ALL TWAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg,
Cumberland County, Pennsylvania, bounded and descan'bed as follows, to wit:
BEGINNING at a point on the western line of Darla Road, said point being at the dividing line
betwcen Lots Nos.199 and 142 -A on the hereinaRermentionet plan of lots; thcncecoatin ing along
said dividing line, South 73 degrees 13 minutes West one hundred ten (114.00) feet to a point;
thence North 16 degrees 47 minutes West eighty -fivc (85.00) feetto apoint; thc=North 73 degrees
13 minutes Past one hundred ten (110.00) feet to a point on the western line of Darla Road; thence
along the western line of Darla Road, South 16 degrees 47 minutes East eighty -five (85.00) feet to
a point on the western line of Darla Road, said point being at the dividing line between Lots Nos.
199 and 142 -A on the hereinafter mentioned plan of lots, the place of BEGINNING.
BEING Lot No. 199 on Final Plan No. 10, Plot "B" of Heritage Acres, said plan being recorded in
the Cumberland County Recorder of Deeds Office in Plan Book 29, Page 120.
i
3
i
w
FORM 1.
Nationstar :Mortgage LLC IN THE COURT OF COMMON PLEAS OF ,
Plaintiff CUMBERLAND COUNTY, PENNSYL Ni
iii -0. N
vs. yy
Luke J. Slother and .Michelle K. Slother Civil y
n
Defendants
�
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
4
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
II Respectfully submitted:
Date Signature of Counsel for Plaint' fJ .
76551
Page 1
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland County Court of Common Pleas Docket #
G
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine possible
options while working with your
Please provide the following information to the best of your knowledge:
CUSTOM
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
CO-11011ROWEII
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
FINANCIAL INFOlIMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payment Amount $ Included Taxes & Insurance:
Date of Last Payment: '
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value
Home: $ $
Other Real, Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 " Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care /Tuit. I Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
a
M
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance?
Yes ❑No❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing company:
Lender's Contact (Name): Phone:
a
Servicing Company (Name):
Contact: Phone:
I /We, , authorize the above
named to use /refer this information to my lender /servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obiligation ,
to use the services provided by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
f Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
3
d
U
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _i i , {i i
Sheriff
��t of citIr o,,
Jody S Smith i# JAN rE r
S.i u
Chief Deputy
i
Richard W Stewart
Solicitor PENNSYLVANIA
SYLVANIA
r # r,: � � =
Nationstar Mortgage LLC
vs. Case Number
Luke J Slother(et al.) 2013-7625
SHERIFF'S RETURN OF SERVICE
12/30/2013 05:16 PM- Deputy Shawn Harrison, being duly sworn according to law, s- ed t,e req ested Affidavit by
"personally"handing a true copy to a person representing themselves t,, i'. = Defen.ant, to wit: Luke J
Slother at 802 Darla Road, Mechanicsburg Borough, Mechanicsburg, P' f S'•.
I.Air r
SH•" N H : . ■, DE'UTY
12/30/2013 05:16 PM- Deputy Shawn Harrison, being duly sworn according to law,
a
the req ested Affidavit by
"personally"handing a true copy to a person representing themselves t• - Defen',ant, to wit:
Michelle Slother at 802 Darla Road, Mechanicsburg Borough, Mechanic • PA 170 5. 1
4, 41,S • r N HARD i , DEPUTY
SHERIFF COST: $60.95 SO ANSWERS,
'A":
December 31, 2013 RONNK R ANDERSON, SHERIFF
.....,t...( w. -(., )SG'i v.
MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
Cr'
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 13-7625
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
110:fj
i? C u}1-ry
Ili /A J j
Kindly enter judgment by default in favor of Plaintiff and against Defendants, Luke J. Slother and Michelle K.
Slother, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil
Procedure, and assess damages as follows:
Amount Due
Interest from 12/21/13 to 11/24/14
Total
Date: •\
$ 180,937.18
$ 6,385.61
$ 187,322.79
McCABE FISBE)RG & C9NWAY, P.C.
BY: 7 /
[] errence J. McCabe, Esq. [ ]Marc S. Weisberg, Esq.
[ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq.
[ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq.
[ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq.
[ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq.
[ ] Joseph F. Riga, Esq. [ ] Joseph 1. Foley, Esq.
[ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
AND NOW, this I day of . , 2014, Judgment is entered in favor of Plaintiff, Nationstar
Mortgage LLC, and against Defendants, Luke J. Slother and Michelle K. Slother, in rem only and not in personam, and
damages are assessed in the amount of $187,322.79, plus crest a ,costs.
BYTMPRONi°61)
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Nationstar Mortgage LLC CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
Attorneys for Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
Number 13-7625
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF PHILADELPHIA:
SS.
The undersigned, being duly sworn according to law, deposes and says that the Defendants, Luke J. Slother and
Michelle K. Slother, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendants, Luke J.
Slother and Michelle K. Slother, are over eighteen (18) years of age, and reside as follows:
Luke J. Slother,
802 Darla Road
Mechanicsburg, PA 17055
SWORN AND SUBSCRIBED
BEFORE ME THIS- m DAY
OF Jam. ._dA! . L_ 0
NOTARY PUB ' V
Michelle K. Slother,
802 Darla Road
Mechanicsburg, PA 17055
Date: \,\ h
McCABE, WEISBERG & CONW , P.C.
BY:
OF PENNSYLV
NOTARIAL SEAL
BARBARA J. MOYER, Notary Mlle
City of Philadelphia, Phila. County
My Commission Expires 12, 2018
N, •
A
errence J. McCabe, Esq.
] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
] Marc S. Weisberg, Esq.
] Margaret Gairo, Esq.
] Heidi R. Spivak, Esq.
] Christine L. Graham, Esq.
] Ann E. Swartz, Esq.
] Joseph I. Foley, Esq.
] Lena Kravets, Esq.
Department of Defense Manpower Data Center
Status Report
Pursuant to Servrcern.ennbers Civil Relief Act.
Last Name: SLOTHER
First Name: LUKE J.
Middle Name:
Active Duty Status As Of: Nov -25-2014
Results as of : Nov -25-2014 08:50:52 AM
SCRA 3.0
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 Das 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 Data
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. § 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: RF26E29EJO6A1 C0
Department of Defense Manpower Data Center
Status Report
Pursuant to Servicemernbers Civil Relief Act
Last Name: SLOTHER
First Name: MICHELLE K.
Middle Name:
Active Duty Status As Of: Nov -25-2014
Results as of : Nov -25-2014 08:51:48 AM
SCRA 3.0
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
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Date
Active Duty End Dale
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.
�a-
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
a
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: 4FV9129E106AG60
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
Attorneys for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 13-7625
AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANTS
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF PHILADELPHIA:
The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby
deposes and says that the last -known mailing addresses of the Defendants are:
Luke J. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
SWORN AND SUBSCRIBED
BEFORE ME TH
OF
SS.
Michelle K. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Date:
DAY McCABE, WEISBERG
014
NOTARIAL SEAT
BARBARA J. MOYER, Notary Public
City of Philadelphia, Phila.,Cofunt2018
y
My Commission Expires ..
BY:
& CONWAY, P.C.
errence J. McCabe, Esq.
[ -] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
[ ] Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
[ ] Lena Kravets, Esq.
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE- ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 13-7625
CERTIFICATION
The undersigned hereby certifies that he/she is, the attorney for Plaintiff, being duly sworn according to law,
deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be
entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the
Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A".
SWORN AND SUBSCRIBED
BEFORE ME TH
DAY
14
OTARY P
CAS
NOTARIAL SEAL
BARBARA J. MOYER, Notary Pubic
My of Philadelphia, Phila. Cou nhr2018
Comnnssion5.xpir `. r!:
Date: \\) \
McCABE, WEISBERG & CONWAY, P.C.
BY: /- �'„` 3'
']Terrence J. McCabe, Esq. [ ] Marc S. Weisberg, Esq.
[ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq.
[ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq.
[ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq.
[ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq.
[ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq.
[ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse, Carlisle, Pennsylvania 17013
Curt Long
Prothonotary
March 13, 2014
To: Luke J. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Nationstar Mortgage LLC
vs.
Luke J. Slother
Michelle K. Slother
Cumberland County
Court of Common Pleas
Number 13-7625
NOTICE PURSUANT TO RULE 237.5
NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.
You SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
mjs
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER
PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA
PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR
ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS
RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA
ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA
NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA Y USTED PODRIA PERDERBIENES U OTROS
DERECHOS IMPORTANTES.
USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0
TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE
PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN
ABOGADO.
SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO,
ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS
SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO
REDUCIDO NI NINON HONORARIO.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
McCABE, WEISBERG AND CONWAY, P.C.
BY:
[ ] Tei'Ience J. McCabe, Esquire (/
[ ] Edward D. Conway, Esquire
[ ] Andrew L. Markowitz, Esquire
[ ] Marisa J. Cohen, Esquire
[ ] Brian T. LaManna, Esquire
[ ] Joseph F. Riga, Esquire
[ ] Celine P. DerKrikorian, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
[ ] Marc S. Weisberg, Esquire
[ ] Margaret Gairo, Esquire
[ ] Heidi R. Spivak, Esquire
[ ] Christine L. Graham, Esquire
[ ] Ann E. Swartz, Esquire
[ ] Joseph I. Foley, Esquire
[ ] fifer L. Wunder, Esquire
Carol A. DiPrinzio, Esquire
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse, Carlisle, Pennsylvania 17013
Curt Long
Prothonotary
March 13, 2014
To: Michelle K. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Nationstar Mortgage LLC
vs.
Luke J. Slother
Michelle K. Slother
Cumberland County
Court of Common Pleas
Number 13-7625
NOTICE PURSUANT TO RULE 237.5
NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.
YOu SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
mjs
McCABE, WEISBER
BY: 4
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER
PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA
PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR
ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS
RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA
ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA
NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS
DERECHOS IMPORTANTES.
USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0
TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE
PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN
ABOGADO.
SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO,
ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS
SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO
REDUCIDO NI NINON HONORARIO.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
AND CONWAY, P.C.
[ ] Terrence J. McCabe, Esquire
[ ] Edward D. Conway, Esquire
[ ] Andrew L. Markowitz, Esquire
[ ] Marisa J. Cohen, Esquire
[ ] Brian T. LaManna, Esquire
[ ] Joseph F. Riga, Esquire
[ ] Celine P. DerKrikorian, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
c„\-,
[ ] Marc S. Weisberg, Esquire
[ ] Margaret Gairo, Esquire
[ ] Heidi R. Spivak, Esquire
[ ] Christine L. Graham, Esquire
[ ] Ann E. Swartz, Esquire
[ ] Joseph I. Foley, Esquire
[ ] J_ennifer L. Wunder, Esquire
[ Carol A. DiPrinzio, Esquire
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Prothonotary
To: Luke J. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 13-7625
NOTICE
Pursuant to Rule 236, you are hereby notified that a JUDGMENT~has been teredi above proce
as indicated below.
X Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway,
P.C. at (215) 790-1010.
I
Prothonotary " r�
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Prothonotary
To: Michelle K. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 13-7625
NOTICE
Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding
as indicated below.77)5A,
Prothonotary
X Judgment by Default
Money Judgment 10/1/IN
g
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway,
P.C. at (215) 790-1010.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
FILE NO.: 13-7625 Civil Term
Nationstar Mortgage LLC
v. AMOUNT DUE: $187,322.79
Luke J. Slother and Michelle K. Slother
TO THE PROTHONOTARY OF SAID COURT:
INTEREST: from 11/25/14
$5,880.89 at $30.79
ATTY'S COMM.:
COSTS:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account=
based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to
Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the
following described property of the defendant(s)
802 Darla Road, Mechanicsburg, Pennsylvania 17055
(More fully described as attached)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies
of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s)
described in the attached exhibit.
DATE: 2-
McCABE, WEISBERG & CONWAY, P.C.
CL"t ("A
BY:
[ ] Terrence J. McCabe, Esq. [ J Marc S. Weisberg, Esq.
[ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq.
[ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq.
[ ] Marisa J. Cohen, Esq. [✓]'Christine L. Graham, Esq.
[ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq.
[ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq.
[ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
jytog '° a
(00.a CdF"
w3.-75 u <<
((0 sort
Address:123 S. Broad Street, Suite 1400
Philadelphia, PA 19109
Attorney for: Plaintiff
Telephone: (215) 790 1010
Supreme Court ID No.
sa. ash
caki
a3 0
CL-il O�LSSCP
k4-314/40177
LEGAL DESCRIPTION
AT CERT pig :* tai B lechmica
County,g! vNb d ss (1 „to wit:.
BEGINNING at point on the western lii of 9arla Reed, said point being , the dividing .line.
bei WaiNos, and 142.A'the heni tormenlioned Plan of `, t 1ccc ntbnUznpion
said dividing lige, Std 13 &pees 13 minutes Went one huffed ten (110,00) feet to a pant
dieneeNnitt16idell47 utesWcsty-fivv(SS.0iyi€ettoapomtthem No73 does
1,3 minutc91?aSt OM hundred ten (110,00) feet to apoint on the western line ofDade Ro thence
dog the week= line of Dula Road, South 16 41 minutes East eighty -,five (0.00) feet to
e point en the 1,ventin lino of Dar .Road, aid point: being at tho dividing lime between LOU Nes,.
' and 142-A on lc bereingtot mullioned phn of lois, the piece of fitalltiNINO.
Premises: 802 Darla Road, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which
Edel Traud R. Rugg, Trustee of The Rugg Family Trust and Restatement of The Rugg Family Trust by deed dated
September 17, 2011 and recorded September 27, 2011 in Instrument Number 201126733, granted and conveyed
unto Luke J. Slother and Michelle K. Slother, husband and wife.
TAX MAP PARCEL NUMBER: 17-24-0789-304
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - 1D # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - 1D # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Nationstar Mortgage LLC
Plaintiff
v.
Luke J. Slother and Michelle K. Slother
Defendants
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO: 13-7625
AFFIDAVIT PURSUANT TO RULE 3129.1
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property
located at: 802 Darla Road, Mechanicsburg, Pennsylvania 17055, as of the date the Praecipe for the Writ of Execution was filed. A copy
of the description of said property being attached hereto.
1. Name and address of Owner or Reputed Owner
Name Address
2. Name and address of Defendants in the judgment:
Name Address
Luke J. Slother 802 Darla Road
Mechanicsburg, Pennsylvania 17055
Michelle K. Slother 802 Darla Road
Mechanicsburg, Pennsylvania 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be
sold:
Name
Address
Plaintiff herein
4. Name and address of the last recorded holder of every mortgage of record:
Name
Plaintiff herein
Stearns Lending, Inc.
Mortgage Electronic Registration
Systems, Inc.
Address
4 Hutton Centre Drive, Suite 500
Santa Ana, California 92707-8710
P.O. Box 2026
Flint, Michigan 48501
5. Name and address of every other person who has any record lien on the property:
Name
Mechanicsburg Borough
Address
36 West Allen Street
Mechanicsburg, Pennsylvania 17055
6. Name and address of every other person who has any record interest in the property which may be affected by the sale:
Name
none
Address
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property
which may be affected by the sale:
Name
Tenants/Occupants
Commonwealth of Pennsylvania
Commonwealth of Pennsylvania
Inheritance Tax Office
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Address
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
110 North 8th Street
Suite #204
Philadelphia, PA 19107
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
PA Department of Revenue
PA Department of Revenue
Bureau of Compliance
Lien Section
Commonwealth of Pennsylvania
Department of Revenue Bureau of
Compliance
United States of America
Domestic Relations
Cumberland County
Tax Claim Bureau
Commonwealth of PA
Department of Revenue
United States of America
United States of America c/o
Atty General of the United States
United States of America c/o
Atty General of the United States
8. Name and address of Attorney of record:
Name
none
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105-8486
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
PO BOX 280948
Harrisburg PA 17128-0948
Clearance Support Department 281230
Harrisburg, PA 17128-1230
ATTN: Sheriff's Sales
Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
P.O. Box 320
Carlisle, PA 17013
1 Courthouse Square
Carlise, PA 17013
Bureau of Compliance
Department 280946
Harrisburg, PA 17128-0946
Attn: Sheriffs Sales
c/o United States Attorney for the
Middle District of PA
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
U.S. Dept of Justice, Room 5111
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
U.S. Dept of Justice, Room 4400
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
Address
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.
4(00
DATE
McCABE, WEISBERG & CW
ONAY, P.C.
BY: C "
%�.'
[ ] Terrence J. McCabe, Esq.
[ ] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Carol A. DiPrinzio, Esq.
Attorneys for Plaintiff
Nationstar Mortgage LLC v. Luke J. Slother and Michelle K. Slother
Cumberland County; Number: 13-7625
]
Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[,--(Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
[ ] Lena Kravets, Esq.
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of tand itnte the Borough of Mechanicsburg,
wart County, rennsylvania, bounded and dmribed as follows, to wit
BEGINNING at a point on the western line. of Darla Road, said point being at the dividing tine
between Lots NOS, 199 and 142-A on the haeinaftermentioned plan f lots; thence corinuing along
said dividing lint. South 73 degrees 13 minutes Weill one ltundmi t (110,00) feet to g point;
thence North 16 dogre&-47minutesWest eighty -dive (85.00) feet to a point; thencnNorth 73 degrees
13 mirmto East one hundred ten 0 ItIOD) feet to a point on the wisterri line of Dada Road; thence
.bogthe west= line of Dada Road, South 16 degrees 47 minutes East cighty.five (AI) feet to
4point OH the, WeStefa line Of Darla, Road, said point being at the dividing tine between Lt Nos,
199 and 142-A on the lteretnaftea- inentioned plan of lots, the place of BEGINNING.
Premises: 802 Darla Road, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which
Edel Traud R. Rugg, Trustee of The Rugg Family Trust and Restatement of The Rugg Family Trust by deed dated
September 17, 2011 and recorded September 27, 2011 in Instrument Number 201126733, granted and conveyed
unto Luke J. Slother and Michelle K. Slother, husband and wife.
TAX MAP PARCEL NUMBER: 17-24-0789-304
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496"
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
l: 11, Attorneys for Plaintiff
CIVIL ACTION LAW
Nationstar Mortgage LLC
v.
Luke J. Slother and Michelle K. Slother
T V
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 13-7625
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
Luke J. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Michelle K. Slother
802 Darla Road
Mechanicsburg, Pennsylvania 17055
Your house (real estate) at 802 Darla Road, Mechanicsburg, Pennsylvania 17055 is scheduled to be sold at Sheriffs
Sale on June 3, 2015 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $187,322.79 obtained by
Nationstar Mortgage LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Nationstar Mortgage LLC the back payments, late charges, costs, and
reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and
Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale.
(See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES 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 by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to
the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this
has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the
sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives
a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of
the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff
within ten (10) days after the posting of the schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately
after the sale.
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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN pieee o pikrc*1 of land ,sinate in the Bolo* of Meehanjoshing,
Cumberland County, Pennsylvania, bounded and dexrdied as follows, to wit:
BEGINNING at a paint on the wtom line of Darla Road, said point being at the dividing Lino
haw= tAts Nos, 199 and 14M. on the hercinaflormotioned pl an oflo% thence co dmii rig along
said dividing line, South 73 degrees t3 minutes Wer4 one hundred ten (110,00) feet to A poiro4
thence North 16 (lop:es-47 minutes:West cifilttpilve(85,14) feet to a point; th moo Nutth 73 degrees
13 minuto btst one hunclml ten 0I0,00 fort to ci point art the I:MIMI:me of Dark Rout; tile=
along the western line of Data Road, South 16 degrees 47 minutes Etort eighty-five (85.00) fact to
point on this wattti tin of Ilaia Road, said point being at the dividing tine between Lots Nos,
199 and 142-A on the betreitlaftel mentioned plan °flats, the Once of BEGMINO.
Premises: 802 Darla Road, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which
Edel Traud R. Rugg, Trustee of The Rugg Family Trust and Restatement of The Rugg Family Trust by deed dated
September 17, 2011 and recorded September 27, 2011 in Instrument Number 201126733, granted and conveyed
unto Luke J. Slother and Michelle K. Slother, husband and wife.
TAX MAP PARCEL NUMBER: 17-24-0789-304
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
Vs. NO 13-7625 Civil Term
CIVIL ACTION — LAW
LUKE J. SLOTHER AND MICHELLE K. SLOTHER
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: $187,322.79 L.L.: $.50
Interest FROM 11/25/14 - $5,880.89 AT $30.79
Atty's Comm: Due Prothy: $2.25
Atty Paid: $209.70 Other Costs:
Plaintiff Paid:
Date: 12/17/14
(Seal)
David D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name: CHRISTINE L. GRAHAM, ESQUIRE
Address: MCCABE, WEISBERG & CONWAY, P.0
123 S. BROAD STREET, SUITE 1400
PHILADELPHIA, PA 19109
Attorney for: PLAINTIFF
Telephone: 215-790-1010
Supreme Court ID No.