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HomeMy WebLinkAbout14-0329 ' + i For Prothonotary Use Only: w p�r�em e Co u it ..,�of Pe n n sir I v an i a. C land n Docket No. Iq The information collected on this form is used solely for court administration purposes. This fonn does not supplement or re dace the filing and service of leadin s or other papers as required by lain or rules o court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintifrs Name: Nationstar Mortgage LLC Lead Defendant's Name: Jessica L. Mansberger T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits Q (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe. Weisberg & Conway, P.C. i ❑ Check here if you have no attorney (a Self - Represented 1Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE pase 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 E T ❑ Other I i O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort -Implant E B ❑Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ Non- Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order k PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title 13 Other: ❑ Medical ❑ Other: ❑ Other Professional: I 1. Updated 1/1/2011 It r Rt 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 q Number V. Jessica L. Mansberger 223 Reno Avenue New Cumberland, Pennsylvania 17070 and Linda S. Mateer 223 Reno Avenue New Cumberland, Pennsylvania 17070 COMPLAINT IN MORTGAGE FORECLOSURE S oAk�, S Ib3 a CL# a0 so a> � Fil '30 S3 e # 72697 Page 1 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 ]a 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 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 provisiones 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 1NMEDIATAMENTE. 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 AGENCIAS 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 # 72697 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 Jessica L. Mansberger, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 223 Reno Avenue, New Cumberland, Pennsylvania 17070. 3. The Defendant is Linda S. Mateer, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 223 Reno Avenue, New Cumberland, Pennsylvania 17070. 4. On January 26, 2007, Jessica L. Mansberger, and Linda S. Mateer, mortgagors, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for Countrywide Home Loans, Inc. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1981, Page 2609 ( "the Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. On June 13, 2011, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201117731, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. Mortgage Electronic Registration Systems, Inc. was acting in its capacity as Nominee for Countrywide Home Loans, Inc., its successors and assigns.. File # 72697 Page 3 6. On July 1, 2013, the Mortgage was assigned by Bank ofAmerica, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP by Nationstar Mortgage LLC its Attorney -in -Fact to Nationstar Mortgage LLC, Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201330960, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 223 Reno Avenue, New Cumberland, Pennsylvania 17070. 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2011 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. 9. The following amounts are due on the mortgage: Principal Balance $ 77,033.84 Interest from January 1, 2011 through November 13, $ 13,523.58 2013 (Plus $12.93 per diem thereafter) Escrow Advance $ 6,842.36 Property Inspections $ 231.00 Property Preservation $ 1,456.95 Tax Liens $ 3.39 GRAND TOTAL $ 99,091.12 10. 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. File # 72697 Page 4 WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $99,091.12, together with interest at the rate of $12.93 per diem 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 J. McCabe, Esquire [ ] Marc S. Weisberg, 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: 223 Reno Avenue, New Cumberland, Pennsylvania 17070 FILE #: 72697 File # 72697 Page 5 VERIFICATION Trey Cook , hereby states that he /she is Assistant Secretary of Nationstar Mortgage LLC, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. IIfli Name: Trey Cook DATE: 1/8/2014 Title: Assistant Secretary File 4: 72697 Name: Nationstar Mortgage LLC v. Jessica L. Mansberger and Linda S. Mateer File # 72697 Page 6 EXHIBIT " The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being in the Borough of New Cumberland in-the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Southeast comer of Reno and Taylor Avenue; thence Southwardly along said Reno Street 161/2 feet to the dividing line or all on property now or late of D.Y. Lenhart; thence Eastwardly along said dividing line and at right angles with Reno Street 140 feet to the line of Cedar Avenue; thence Northwardly along said Cedar Avenue and parallel with Reno Street 161 /2 feet to Taylor Avenue; thence Westwardly along the line of said Taylor Avenue 140 feet to the point or place of BEGINNING. HAVING THEREON ERECTED a frame dwelling house known and numbered as 223 Reno Street. BEING the Northerly 16 1/2 feet of Lot No. 12, Block A in the general plan of George W. Buttorffs Addition to the Borough of New Cumberland as recorded in the Office of the Recorder of Deeds in Deed Book 5 -N, Page 500. Parcel #25 -25 -0006 -256 I Certify this to be recorded In Cumbe land County PA Recorder of Deeds ALTA Commitment Schedule C (2007010024.PF'D/2007010024/14) BK 198 1 P6262.6 FORM l j Nationstar Mortgage LLC IN Tf]E COURT OF COMMON PLEA' Plaintiff CUMBERLAND COUNTY, PENNSYLT41At; .v "J vs. Cn C:) , Jessica L. Mansberger and Linda S. Mateer Civil p - Defendants i f NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial . information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respect � _ itted: Date [Signature of Counsel for Plaintiff) 72697 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: .Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? FINANCIAL INFOIINIATION 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. 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 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: 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 Copy of a current utility bill f Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ' 1G ` ,,,,,� Sheriff ,„cit i',�tt 414,, Jody S Smith -'i ��rr n r i±f : Chief Deputy Richard W Stewart CUMBERLAND COUNTY PENNSYLVANIA Solicitor °' Nationstar Mortgage LLC Case Number vs. 2014-329 Jessica L Mansberger(et al.) SHERIFF'S RETURN OF SERVICE 01/22/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jessica L Mansberger, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 223 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Residence is vancant and per the New Cumberland Postmaster the defendant is not known at the address provided. 02/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Linda Mateer, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1602 Elm Street, New Cumberland Borough, New Cumberland, PA 17070. This address was provided by New Cumberland Borough Secretary in March of 2013. Deputies were advised that the defendant now resides at 473 Avenue A,Apt.#3, Bayonne, NJ 07022. 02/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Linda Mateer, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 224 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Deputies were advised by current resident that the defendant moved over a year ago to New Jersey. 02/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Linda Mateer, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 223 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Deputies were advised that the defendant moved to New Jersey. SHERIFF COST: $83.21 SO ANSWERS, February 05, 2014 RONR ANDERSON, SHERIFF 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 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Linda S. Mateer and Jessica L. Mansberger Defendants TO THE PROTHONOTARY: V4 t1T I - F ' 2: 4-1 r m ■BERLA UI P Ei* S 'LV/ 1� CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14 -329 Civil PRAECIPE ❑ Please mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. DATE: McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] 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. [ ] Lena Kravets, Esq. Attorneys for Plaintiff {---]i tarc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, 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 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Nationstar Mortgage LLC Plaintiff v. Linda S. Mateer and Jessica L. Mansberger Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14 -329 Civil CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff, hereby certifies that a true and correct copy of the within Praecipe was P ((f served on the below persons by regular first class mail, postage prepaid, on the day of March, 2014. Linda S. Mateer 223 Reno Avenue New Cumberland, Pennsylvania 17070 Jessica L. Mansberger 223 Reno Avenue New Cumberland, Pennsylvania 17070 • DATE: • McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] 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. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ "Marti S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq.