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Home My WebLink About14-0360 Supreme Court -of Peiinsylvania Cout- of Common PIeas ForProthonotan, Use Only: { G`ivfl:Colter Sheet r C>d b,b rlaiid ` County Doc N o: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiding and service ofpleadings or other papers as required b law or rules of court. Commencement of Action: R Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: NATIONSTAR MORTGAGE, LLC TINA M. SWARTZ C JERRY W. SWARTZ JR. T I Dollar Amount Requested within arbitration limits p Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MD,I Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant'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 ❑ Employment dispute: ❑ Statutory Appeal: Other E mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑Employment Dispute: Other T ❑ Other: I Q MASS TORT ❑ Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ 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 CENTEP i ED -OF F I C E: 701 MARKET STREET L' , c,F PK 07f'!0' o /,RY PHILADELPHIA, PA 19106 (866) 413 -2311 ! `i JAN 17 AM H : : i 5 ♦�'1i�0` K�I I A1�`('ROi1P ('O'ti NATIONSTAR MORTGAGE, LLC C U CA B E P% L A N D v Y IN THE COURT OF COMMON PLEAS 350 Highland Drive FE,NNSYLVA IN ^ M Lewisville, TX 75067 OF Cumberland COUNTY Plaint vs. CIVIL ACTION - LAW TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. ACTION OF MORTGAGE FORECLOSURE Mortgagor and Record Owner .; ACTION: MOUGAGI 34 Southside Drive RQREC OS Newville, PA 17241 1 0. Defendant(s) Al .... -3bV out, r 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 1701.3 LEGAL SERVICES INC: - --- r r, , 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 AVISO r Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en ,aN paginas siguientes, usted tiene veinte (20) dias de plazo a] 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 provisiones 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 SERVCCO. VAYA EN PERSONA O LLAM)� POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DON.DE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 103. J?s ;k� , 74 n, M - y s"c -2 7 SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS .LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website wkyw.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 llttp• / /www plifa org/ consumers /luomeowners,`real_aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.piiilade]phiafed.oj 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 41.3 -2311 or via email at homeretentio .n�Lr)knallaw,�, 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 -631.8 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 124067FC. Para informacion en espanol puede communicarse con Loretta al 21.5- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is NATIONSTAR MORTGAGE, LLC, 350 Highland Drive, Lewisville, TX 75067. 2. The name(s) and address(es) of the Defendant(s) is /are TINA M. SWARTZ, 34 Southside Drive, Newville, PA 17241 who is the mortgagor only and JERRY W. SWARTZ JR., 34 Southside Drive, Newville, PA 17241, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On November 27, 2009 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY AS NOMINEE FOR EMBRACE HOME LOANS, INC., which mortgage is recorded in the Office of the .Recorder of Deeds of Cumberland County on December 11, 2009 as Instrument # 200941320. The mortgage has been assigned to: NATIONSTAR MORTGAGE, .LLC by assignment of Mortgage recorded on July 01, 2013 as Instrument # 201.321689. 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 10.19(g); which .Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 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: PrincipalBal ance ............................... ............................... ....................$108,607.73 Interest from 02/01 /2013 through 09/06/2013 at 5.0000 % . ......................$3,620.24 Monthly Interest $452.43 CorporateAdvance ................................ ............................... .........................$12.00 EscrowAdvance ................................... ............................... ............ ..........$1,718.16 $113,958.13 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $113,958.13, together with monthly interest at $452.53, 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 GROUP, P Michael McKeev r 1 ID 561.29 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61 858 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 31 2912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION David Chen hereby states that he /she is Assistant Secretary 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: David Chen Assistant Secretary #124067FC - TINA M. SWARTZ and JERRY W. SWARTZ JR. 34 Southside Drive Newville, PA 17241 . Ey,fiibitA i 34 Southside Drive Newville, Pennsylvania 17241 Jerry W. Swartz, Jr. and Tina M. Swartz I EXHIBIT A r i LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT CERTAIN z PROPERTY SITUATED IN TOWNSHIP OF PENN IN THE COUNTY OF CUMBERLAND, AND STATE OF j PENNSYLVANIA AND BEING DESCRIBED IN A DEED DATED 08/02/1996 AND RECORDED 08/0911996 IN BOOK 143 ! PAGE 1 147 AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, AND REFERENCED AS FOLLOWS: I ALL THAT CERTAIN TRACT OR PARCEL OF LAND WITH BUILDINGS ERECTED THEREON, SITUATE IN PENN i TOWNSHIP, CUMBERLAND COUNTY, BOUNDED AND DESCRIBED PURSUANT TO { THE FINAL SUBDIVISION PLAN FOR DANIEL G. RHOADS AND LORIE L. RHOADS, DATED SEPTEMBER 22, i 1989, AS PREPARED BY EUGENE A. HOCKENSMITH, P.L.S., AND RECORDED IN THE RECORDER OF DEEDS I OFFICE IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 60, PAGE 93 AS FOLLOWS: BEGINNING AT AN EXISTING RAILROAD SPIKE IN THE CENTERLINE OF TOWNSHIP ROUTE 349 (SOUTHSIDE DRIVE) AT CORNERS COMMON WITH LOT NO.3 OF THE ABOVE - MENTIONED SUBDIVISION PLAN; THENCE ALONG SAID CENTERLINE SOUTH 60 DEGREES I 1 MINUTES 51 SECONDS WEST, A DISTANCE OF 151.73 FEET TO AN EXISTING RAILROAD SPIKE IN THE CENTERLINE OF SAID TOWNSHIP ROUTE AT CORNERS COMMON WITH LANDS NOW OR FORMERLY OF MICHAEL L. FAILOR, ET, UX; THENCE ALONG SAID FAILOR LANDS NORTH 6 DEGREES 58 MINUTES 59 SECONDS EAST A DISTANCE OF 175.18 FEET THROUGH AN EXISTING IRON PIPE TO A SECOND IRON PIPE; THENCE ALONG SAME NORTH 87 DEGREES 20 MINUTES 30 SECONDS WEST A DISTANCE OF 131.47 FEET TO AN EXISTING IRON PIPE; THENCE ALONG LANDS NOW OR FORMERLY OF BETTY JANE DEITZEL NORTH 19 DEGREES 30 MINUTES 43 SECONDS EAST A DISTANCE OF 1 11.11 FEET TO EXISTING BOLT; THENCE ' r I J ALONG LOT NO. I OF THE i AFOREMENTIONED SUBDIVISION PLAN NORTH 89 DEGREES 58 MINUTES 16 SECONDS EAST A DISTANCE OF 233.52 FEET TO AN IRON PIN AT CORNERS COMMON WITH LOTS NOS. 1 AND 3 I OF THE AFOREMENTIONED SUBDIVISON PLAN; THENCE ALONG SAID LOT NO. 3 SOUTH 7 DEGREES 51 MINUTES i 57 SECONDS EAST A DISTANCE OF 211.40 FEET THROUGH A POINT ON THE DEDICATED RIGHT OF WAY LINE TO AN EXISTING RAILROAD SPIKE IN THE CENTERLINE OF TOWNSHIP ROUTE 349 (SOUTHSIDE DRIVE), BEING THE PLACE OF BEGINNING. II , BEING ALL OF LOT NO.2 OF THE AFOREMENTIONED SUBDIVISION PLAN. f PARCEL NO. 31-33-1910-033 i 1 I I I I ; 1 Ey,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information (Page 1 of 10) PRESORT First -Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589 -9048 Fees Paid 7196 9006 9296 6,900 2588 wso 20130430 -7 IIII�IIIIIII��III�I�IIII��II��I��I�III�IIII�I '1""111 "IIII��I JERRY W SWARTZ 34 Southside Dr Newville, PA 17241 -9550 C3 BLQPA2 14091 08/24/2011 (Page 3 of 10) April 30, 2013 Sent Certified Mail: 7196 9006 9296 69DO 2588 Return Receipt Requested Account No.: _5381 JERRY W SWARTZ 34 Southside Dr Newville, PA 17241 -9550 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear JERRY W SWARTZ, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafterwe, us or ours) on your property located at 34 Southside Dr Newville, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of 03/01/2013 - 04/30/2013. MonthlyCharaes: 03/01/2013 04/30/2013 @ $931.92 $1,863.84 Late Charges: 03/01/2013 - 04/30/2013 @ $37.27 S74.54 Other Char ecLs: Additional Uncollected Late Charges: $0.00 Uncollected Costs: $0.00 Partial Payment Balance: 0.00 TOTAL DUE: $1,938.38 Late charges and other charges have also accrued to this date in the amount of $74.54. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $1,938.38. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $9,938.38, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 19888 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. 7196 9006 9296 6900 2588 PRESORT First -Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589 -9048 Fees Paid 2272415266 WSQ 20130430 -7 I�IIIIII�I��I�II��I�II�' �I�II��I��I�� " "� TINA M SWARTZ 34 Southside Dr Nemille, PA 17241 -9550 C3 BLQPA2 14091 08/24/2011 April 30, 2013 Account No.: X5381 TINA M SWARTZ 34 Southside Dr Newville, PA 17241 -9550 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear TINA M SWARTZ, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafter we, us or ours) on your property located at 34 Southside Dr Newville, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of 03/01/2013 - 04/30/2013. Monthly Charges: 03/01/2013 - 04/30/2013 @ $931.92 $1,863.84 Late Charges: 03/01/2013 - 04/30/2013 @ $37.27 $74.54 Other Charges: Additional Uncollected Late Charges: $0.00 Uncollected Costs: $0.00 Partial Payment Balance: 0.00 TOTAL DUE: $1,938.38 Late charges and other charges have also accrued to this date in the amount of $74.54. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $1,938.38. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $1,938.38, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 19886 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period, you will not be required to pay attorney's fees. 2272415266 We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1- 800 - 669-4578. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR 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 THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year." C3 3222 BRECDISC 15352 09/24/12 IMPORTANT DISCLOSURES If you are currently in a bankruptcy proceeding, or have previously obtained a discharge of this debt under applicable bankruptcy law, this notice is for information only and is not an attempt to collect the debt, a demand for payment, or an attempt to impose personal liability for that debt. You are not obligated to discuss your home loan with us or enter into a loan modification or other loan- assistance program. You should consult with your bankruptcy attorney or other advisor about your legal rights and options. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector, There has been a payment default or other default on your loan that could result in acceleration of all sums due under the Note, As a result, Bank of America, N.A. will use companies, including its affiliates LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc,, LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, N.A., and LandSafe Appraisal Services, Inc., to provide services required to protect the Noteholder's interest and rights in the property and under the note and security instrument, including any remedies thereunder (the "Default Related Services "). Bank of America, N.A. will assess fees to your loan account for the Default Related Services, including those provided by its affiliates. A schedule of fees that may be charged to your account for Default Related Services is available at the following web address: hfto://www.bankofamerica.com/defaultfees If you do not have internet access, please contact us at 1- 800 - 669 -6607, Monday through Thursday 8 a,m. - 11 p.m, Eastern, Friday 8 a.m. - 9 p.m. Eastern, Saturday 9 a.m. - 3 p.m. Eastern, to have a fee schedule mailed to you. The fee schedule contains a complete list of the default - related services you could be charged, but does not include a complete list of all fees or charges that could be assessed on your loan account. MILITARY PERSONNEUSERVICEMEMBERS If you or your spouse is a member of the military, please contact us immediately. The federal Servicemembers Civil Relief Act and comparable state laws afford significant protections and benefits to eligible military service personnel, including protections from foreclosure as well as interest rate relief. For additional information and to determine eligibility please contact our Military Assistance Team toll free at 1- 877 - 430 -5434. If you are calling from outside the U.S, please. contact us at 1- 817 - 685 -6491. 2272415266 DIVULGACIONES IMPORTANTES Si usted se encuentra actualmente en un procedimiento de quiebra, o ha obtenido previamente una exoneraci6n de esta deuda bajo la ley aplicable sobre quiebra, este no es un intento de recaudaci6n, una demanda de pago o un intento de imponer una responsabilidad personal por esa deuda. Usted no est6 obligado(a) a hablar de su pr6stamo para vivienda con nosotros ni a participar en un programa de modificaci6n de prestamos u otro programa de asistencia para prestamos. Usted debe ccnsultar con su abogado especializado en quiebras u otro asesor acerca de sus opciones y derechos legales. Bank of America, N.A., el administrador de su pr6stamo para vivienda est6 obligado por ley a informarle a usted que esta comunicaci6n proviene de un cobrador de deudas. Ha ocurrido un incumplimiento de pago u otro tipo de incumplimiento con su pr6stamo que podria resultar en la aceleraci6n de todas las cantidades adeudadas bajo el Pagar6. Como resultado, Bank of America N.A. utilizar6 compafiias, incluyendo sus afiliados LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, NA, y Landsafe Appraisal Services, Inc., para proporcicnar servicios necesarios para proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagar6, incluyendo cualquiera de sus recursos (los " Servicios relacionados a un incumplimiento "). Bank of America, N.A, aplicare cargos a la cuenta de su pr6stamo por los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados. Una lista de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento esta disponible en el sitio de Internet: [hftg://www.bankofamerica.com/defauitfeeg. Si usted no tiene acceso a internet, por favor comuniquese con nosotros al 1 -800- 669 -6607 de lunes a jueves de 8 a, m. a 11 p. m. hors del este, viernes de 8 a. m. a 9 p. m. hora del este, sabados de 9 a, m. a 3 p. M. hora del este. para pedir que se le envie una lists de cargos por correo. La lista de cargos contiene una lists completa de los servicios relacionados por incumplimiento que le podian cobrar, pero no incluye una lista completa de todos los costos y cargos que podrian ser aplicados a la cuenta de su pr6stamo. PERSONAL MILITAR/ MIEMBROS DE LAS FUERZAS ARMADAS Si usted o su c6nyuge es un miembro del servicio militar, por favor comuniquese con nosotros inmediatamente, La Ley federal de Ayuda Civil para Miembros de las Fuerzas Armadas y las leyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar sue califioue induidas protecciones contra la ejecuci6n hipotecaria asi como tambi6n ayuda en la tasa de inter6s, Para obtener mes informaci6n y determinar su calificaci6n por favor Ilame sin costo a nuestro Equipo de Asistencia para el Servicio Militar al 1 -877- 430 -5434. Si usted llama desde fuera de los Estados Unidos por favor comuniquese con nosotros al 1- 817- 685 -6491. 2272415266 C3_5088 OPTAVDFC 15319 09/24/2012 Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home Home Affordable A federal government program that allows you to repay the loan on newly agreed upon terms, Modification which may include lowering the interest rate, placing past due amounts at the end of the loan, Program (HAMP) and/or extending the term of the loan. You may be eligible for this program if you meet the following requirements: • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have documented a financial hardship and represented that you do not have sufficient liquid assets to make the monthly mortgage payments. • Your mortgage was obtained before Jan. 1, 2009. • The property securing the mortgage loan has not been condemned or is not in such poor physical condition that it is not habitable even if not condemned • The mortgage is secured by a one to four unit property Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the Reinstatement loan up to date until the day of your foreclosure sale. Repayment Plan A repayment plan allows you to make your regularly scheduled mortgage payments, plus pay off a portion of the past due amounts over time. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments Forbearance for a period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Modification A loan modification is a change to the original terms of your loan. Loan modifications could (non-HAMP) include lowering your interest rate, extending the term or maturity date of the loan, moving from an adjustable to a fixed-rate loan, deferring some portion of the unpaid principal balance to the end of the loan, and/or forgiving some portion of the unpaid principal balance, Partial Claim (FHA If you have a Federal Housing Administration (FHA) loan and your payments are past due but loans only) you are now able to make your regular monthly mortgage payment, this program is designed to bring your loan up to date by creating a second mortgage /lien on your property for the amount I that is past due. Options to consider if you cannot or do not wish to stay in your home f -or Home Affordable Designed to help borrowers who are eligible for the Home Affordable Modification Program Foreclosure (HAMP) but were unsuccessful in securing a permanent modification through the program, Alternatives HAFA provides the option of a short safe and, if unsuccessful, a deed in lieu of foreclosure. A Program (HAFA) short sale is a transaction in which you sell your property for less than the total amount owed on the loan (subject to agreement by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ If you can no longer afford to make your mortgage payments and your home is worth less than Pre-foreclosure you owe, a short sale may allow you to sell your home to pay off the mortgage. In a short sale, Sale (non-HAFA) the lender agrees to accept an amount less than what is actually owed on the loan. Offered to borrowers who are not eligible for HAMP or other home retention alternatives. Deed in Lieu of Used as an alternative to foreclosure, with a deed in lieu of foreclosure, you transfer ownership Foreclosure of your house and all property secured by your mortgage loan. This may satisfy the total (non-HAFA) amount due on that mortgage. Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not able to sell the property through a short sale. We are here to help you. Please call us today. 2272415266 Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notificacion adjunta para obtener mas informacion Cuando (lame, por favor tenga a la mano la informacidn de sus ingresos y gastos para que podamos discutir cubles opciones podrian funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa ............ C1e : Home Affordable Es un programa del gobierno federal que le permite pagar el prbstamo bajo los nuevos Modification tbrminos acordados, que pueden incluir la reduccibn de la tasa de interbs, agregar Program (HAMP) cantidades vencidas al final del prbstamo, y/o extender el plazo del prbstamo. Usted puede calificar para este programa si cumple con los siguientes requisitos: • La cantidad que usted adeuda de su primera hipoteca es igual o menor que $729,750 dblares para una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250 dblares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Usted ha dccumentado que atraviesa por una dificultad financiera y declarado que no tiene suficiente liquidez para hacer los pagos mensuales de la hipoteca. • Obtuvo su hipoteca antes del 1 de enero de 2009. • La propiedad que garantiza el prbstamo hipotecario no ha sido condenada o no est6 en malas condiciones fisicas como para no poder habitarse incluso si no est'A condenada. • La hipoteca estb garantizada por una propiedad de una a cuatro unidades. Restablecimient Si usted puede poner al dia los pagos de su prbstamo, aceptaremos los fondos necesarios o del Pr6stamo para que el prbstamo estb al dia hasta la fecha de la venta por ejecucibn hipotecaria. Plan de Pago Un plan de pago le permite a usted hacer sus pagos hipotecarios regulares, adembs de pagar una porcibn de los montos vencidos a traves del tiempo. Esto puede incluir capital, interbs, cargos o costos aplicados a su prbstamo. Acuerdo Es un acuerdo en el cual aceptamos no proceder con la ejecucibn hipotecaria y/o el cobro Temporal de de los pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia por hacer los pagos requeridos, incumplimiento Modificacion de Una modificacibn del prbstamo es un cambio en los tbrminos originales de su prbstamo, Prbstamo Las modificaciones podrian incluir reducir su tasa de interbs, extender el tbrmino o la fecha (no por medio de pago del prbstamo, cambiar de un prbstamo de tasa de interbs ajustable a uno de tasa de HAMP) de interbs fija, diferir una parte del saldo del capital impagado al final del prbstamo, y/o condonar una parte del saldo de capital impagado. Reclamo Parcial Si usted tiene un prbstamo de la Administracibn Federal de Vivienda (FHA) y sus pagos (solamente estAn vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, prestamos de la este programa est� disenado para que su prestamo este al dia mediante la creacibn de FHA) una segunda hipoteca / gravamen sobre su propiedad por el monto que est� vencido. 2272415266 Opciones a considerar si no puede o no desea quedarse en su casa ....................................... ............................... Home Affordable Disenado para ayudar a los prestatarios que califican para el Programa de Home Foreclosure Affordable Modification (HAMP), pero no consiguieron obtener una modificaci6n Alternatives permanente a trav6s del programa. HAFA ofrece la posibilidad de una venta en Program (HAFA) descubierto y, si no tiene 6xito, una escritura de traspaso voluntario de propiedad en lugar de la ejecucibn hipotecaria. Una venta en descubierto es una transacci6n en la que usted vende su propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecucibn hipotecaria. Una escritura de traspaso voluntario de propiedad en lugar de la ejecucibn hipotecaria es una transacci6n en la que usted estb de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecucibn hipotecaria. Venta en Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de to que descubierto / usted adeuda, una vents en descubierto le podria permitir vender su vivienda para pagar Venta previa a la la hipoteca, En una vents en descubierto, el prestamista acepta recibir una monto menor ejecucion de to que actualmente se adeuda en el pr6stamo. Se ofrece a los prestatarios que no hipotecaria (no por califican para HAMP o para otras alternativas de retenci6n de la vivienda. medio de HAFA) Escritura de Se usa Como una alternativa de la ejecucibn hipotecaria. Con una escritura de traspaso traspaso de voluntario de propiedad en lugar de la ejecucibn hipotecaria, usted transfiere la titularidad propiedad en lugar de su vivienda y toda la propiedad que garantiza su pr6stamo hipotecario. Esto puede de la ejecucibn hacer que el monto total vencido de esa hipoteca se considere como pagado. Se ofrece a hipotecaria (no por prestatarios que no califican para HAMP u otras opciones de retenci6n de vivienda, y que medio de HAFA) no pudieron vender la propiedad a trav6s de una vents an descubierto. Estamos aqui para ayudarle. Por favor Ilamenos hoy. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE, LLC Plaintiff vs. Case No. r —;Z TINA M. SWARTZ JERRY W. SWARTZ JR. 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 ubmitted: (Signature of Counsel for Wtiff) 1/14/2014 Date 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 0 — No El Listing date:: Price: S Realtor Name: _ _ Realtor Phone: Borrower Occupied? Yes No El Mailing Address (if different); City: State' Zip: Phone .Numbers: Hanle; Office: Cell: Other; Email, of people in household.: How long? Mailing Address; City: State: Zip: Phone :Numbers: Home: Office: Cell: Other: Email: # of people in household: How Ionia? First Mortgage Lender: Type of Loan: Loan Number: Date 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 ❑ Non If yes, provide names, location of court, case number & attorney: T Assets Antount Owed: Valise: Horne: $ _ $ Other Real Estate: $ $ Retirement Funds: $ - $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #l: Model: Year. _____.._ Amount owed: Value; Autgmobile #2 : Model: Year: Amount owed: Value: Other trans . ortation automobiles boats motors cles • 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 Exncnses, (Please only include expenses you are currently paying) EXE'ENSE AMOUNT EXPENSE AMOUNT Mo a Food 2 Mortgage Utilities Car Pa ent s Condo/Neigh. Fees Auto Insurance Ivied. not cowered Auto fuel/repairs Other proe. payment Install. Loan Pa mcnt Cable TV Child §2 rt/Alim. Spending Mone Da = /Child Care/'Tuit. Mer Ex ensea Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes (j No [] If yes, please provide the following information Counseling Agency; _ Counselor. Phone.(Office): Fax: Enmal: 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 delinquency? Yes[] No E] If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Larne) Phone: Servicing Company (Name): Contact: Phone: authorize the above named to use /refer this information to my lender / servicer for the sole !purpose of evaluating any financial situation for possible mortgage options, irwe understand that Itwe am/are under no obligation to use the services provided by the above named Borrower Signature Hate Co- Borrower Signattae Date Please forivard this document slang with the .following information to lender and lender's counsel- Proof of income Past Z bank statements Y Proof of any expected trrcome for the last 45 days !� Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (bardship letter) y Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of al Jody Smith We,/ y Chief Deputy ? 1, FEB 28 PM Richard W Stewart Solicitor v, c}cE.,,F,HE5.1 :H1Pw CUMBERLAND CUNT PENNSYLVANIA Nationstar Mortgage LLC vs. Case Number Tina M Swartz (et al.) 2014-360 SHERIFF'S RETURN OF SERVICE 01/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tina M Swartz, 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 34 South Side Drive, Penn Township, Newville, PA 17241. Residence is vacant,this office was provided with an address of 17 East Main Street,Apt. 2, Newville, PA 17241 for the defendant. 01/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jerry W Swartz, Jr., 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 34 South Side Drive, Penn Township, Newville, PA 17241. Residence is vacant. 02/06/2014 12:39 PM - Deputy Shawn Gutshall, 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: Jerry W Swartz, Jr. at 227 South Side Drive, Penn Township, Newville, PA 17241. fit!GUTSHALL, DEPUTY 02/10/2014 02:07 PM- Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tina M Swartz, 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 Served"at 17 East Main Street Apt 2, Newville Boro, Newville, PA 17241. Four attempts at service were made but deputies were unable to make contact with anyone at the residence before the Complaint expired. SHERIFF COST: $98.24 SO ANSWERS, February 19, 2014 RONR ANDERSON, SHERIFF ;i)u^;iysui 2 herb;,':oi- so" KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 vs. TINA M SWARTZ JERRY W. SWARTZ JR. 34 Southside Drive Newville, PA 17241 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2014-00360 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: KML LAW GROUT', P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 eAlyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff 3:00 atat s 11.1 Ok_47140qc? '36-igqS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ° 4' Chief Deputy ;11` NI Richard W Stewart Solicitor ,E NSY LV / UL. Nationstar Mortgage LLC vs. Case Number Tina M Swartz (et al.) 2014-360 SHERIFF'S RETURN OF SERVICE 07/10/2014 04:25 PM- Chief Deputy Jody S. Smith 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: Tina M Swartz at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. JODY S.SI4ITH, DEPUTY SHERIFF COST: $55.12 SO ANSWERS, July 14, 2014 RON-R ANDERSON, SHERIFF In the Court of Common Pleas of Cumberland County NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 vs. TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 2014-00360 -10 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against TINA M. SWARTZ and JERRY W. SWARTZ JR. by default for want of an Answer. Assess damages as follows: $119,387.29 Debt Interest from 10/1/2014 to Date of Sale perMonthly diem at $452.43 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten da s -)rior to the date of the filing of this praecipe. A copy of the -notice is attached. R.C.P. 237 . it By: KML LAW GROUP, P.C. _Michael McKeever Pa. ID 56 Jay E. Kivitz Pa. ID 26769 _Lasa Lee Pa. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua L Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 _Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Freebie Pa ID 316160 Attorneys forlPPlaintiff AND NOW J (`t Judgment is entered in favor of arkk S I l0 5bec 0, at .9)1(Sb, ri \ Jo\,La ry)cu NATIONSTAR MORTGAGE, LLC and against TINA M. SWARTZ and JERRY W. S TART . by d! It for want of an Answer and damages assessed in the sum of $119,387.29 as per the above certifica Protho Rule of Civil Procedure No. 236 — Revised NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. Defendant(s) No. 2014-00360 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 uare oft,„, Prothonotary \), 8;13.3 Carlisle, PA 17 B wrd"� 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 124067 FC 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: TINA M. SWARTZ SWARTZ, TINA M. 34 Southside Drive Newville, PA 17241 NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. TINA M SWARTZ JERRY W. SWARTZ JR. (Mortgagor(s) and Record Owner(s)) 34 Southside. Drive Newville, PA 17241 Defendant(s) TO: TINA M. SWARTZ 34 Southside Drive Newville, PA 17241 DATE OF THIS NOTICE: September 11, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 2014-00360 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: 1\1\ KML LAW GRQUI?'j�P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 c 215-627-1322 Attorneys for Plaintiff 124067 FC 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: TINA M SWARTZ SWARTZ, TINA M. 227 South Side Drive Newville, PA 17241 NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. TINA M SWARTZ JERRY W. SWARTZ JR. (Mortgagor(s) and Record Owner(s)) 34 Southside_Drive Newville, PA 17241 Defendant(s) TO: TINA M SWARTZ 227 South Side Drive Newville, PA 17241 DATE OF THIS NOTICE: September 11, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No: 2014-00360 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW GRO Michael McKeever ' .. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 124067 FC THIS LAW FIRM ISA 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: JERRY W. SWARTZ JR. SWARTZ JR., JERRY W. 34 Southside Drive Newville, PA 17241 NATIONS TAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. TINA M SWARTZ JERRY W. SWARTZ JR. (Mortgagor(s) and Record Owner(s)) 34 Southside Drive Newville, PA 17241 Defendant(s) TO: JERRY W. SWARTZ JR. 34 Southside Drive Newville, PA 17241 DATE OF THIS NOTICE: September 11, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 2014-00360 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRII'IEN 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: 1\ KML LAW G 410 , P.C. Michael cK ver Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Freddie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 124067FC = 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: JERRY W. SWARTZ JR. SWARTZ JR., JERRY W. 227 South Side Drive Newville, PA 17241 NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. TINA M SWARTZ JERRY W. SWARTZ JR. (Mortgagor(s) and Record Owner(s)) 34 Southside Drive Newville, PA 17241 Defendant(s) TO: JERRY W. SWARTZ JR. 227 South Side Drive Newville, PA 17241 DATE OF THIS NOTICE: September 11, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 2014-00360 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: 11 KML LAW GR P P.C. Michael McKeev Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 124067 FC 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: TINA M. SWARTZ SWARTZ, TINA M. 17 East Main Street, Apt 2 Newville, PA 17241 NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. TINA M SWARTZ JERRY W. SWARTZ JR (Mortgagor(s) and Record Owner(s)) 34 Southside Drive_ Newville, PA 17241 Defendant(s) TO: TINA M. SWARTZ 17 East Main Street, Apt 2 Newville, PA 17241 DATE OF THIS NOTICE: September 11, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 2014-00360 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW G OL�Pj P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. 011azian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 7 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE, LLC. Plaintiff vs. TINA M. SWARTZ JERRY W. SWARTZ JR. Defendant(s) NO. 2014-00360 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): TINA M. SWARTZ, has a last known residence of 227 South Side Drive, Newville, PA 17241. 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. 4904 relating to unsworn falsification to authorities. By: KML LAW GROUP, P.C. Michael McKeever Pa. ID ' . 29 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 )C 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 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: SWARTZ First Name: TINA Middle Name: M. Active Duty Status As Of: Sep -23-2014 Results as of : Sep -23-2014 10:37:10 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 Duly Status Date Left Active Duty Within 367 Da of Active Duty Status Date Active Duty Start Date Active Duty End Date I Status Service Component NA NA - No ti 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. v�. 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: 4DC9VF089OFF100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE, LLC Plaintiff vs. TINA M. SWARTZ JERRY W. SWARTZ JR. Defendant(s) NO. 2014-00360 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): JERRY W. SWARTZ JR., has a last known residence of 227 South Side Drive, Newville, PA 17241. 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. 4904 relating to unsworn falsification to authorities. / - // Date ( a a 3 141 By: KML LAW GROUP, P.C. �, Michael McKeever Pa. 6129 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 )G 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 Stats Report Pursuant to Servicemernbers Civil Relief Act. Last Name: SWARTZ First Name: JERRY Middle Name: W. Active Duty Status As Of: Sep -23-2014 Results as of : Sep -23-2014 10:35:07 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 reflectsr 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 autepN- 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/PCO9SLDR.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: 6DP71 F08TOFFU 10 Department of Defense Manpower Data Center Status Report Pursuant to Servicernembers Civil. Relief Act Last Name: SWARTZ JR. First Name: JERRY Middle Name: W. Active Duty Status As Of: Sep -23-2014 Results as of : Sep -23-2014 10:35:36 AM SCRA 3.0 On Active Duty On Active Duty Status Dale 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 Cell 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 hi:Jher 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/PCO9SLDR.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: YDD7VFC8XOFFQ90 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 350 Highland Drive Lewisville, TX 75067 vs. TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 Plaintiff _ _ _ - Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 2014-00360 ORDER FOR JUDGMENT Please enter Judgment in favor of NATIONSTAR MORTGAGE, LLC, and against TINA M. SWARTZ and JERRY W. SWARTZ JR. for failure to file an Answer in the above action within (20) days from the date of service of the Complaint, in the sum of $119,387.29. By: KML LAW GROUP, P. Michael McKeever Pa. 29 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 and that the name(s) and last known address(es) of the Defendant(s) is/are TINA M. SWARTZ, 227 South Side Drive Newville, PA 17241 and JER Y . SWARTZ JR 2, South Side Drive Newville, PA 17241; By: KML LAW GROUP, P.0 Michael McKeever Pa. ID 1 9 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 _vAndrew F. Gornall Pa. ID 92382 "Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Monthly Interest from 02/01/2013 through 09/01/2014 Corporate Advance Escrow Advance AND NOW, this Q S day of 2014-00360/124067FC By: $108,607.73 $9,049.40 $12.00 $1,718.16 $119,387.29 KML LAW GROUP, P. Michael McKeever Pa. ID 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 lc Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff , 2014 damages are assessed as above. Pro Prothy 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 350 Highland Drive Lewisville, TX 75067 TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 vs. Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 2014-00360 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter:, Amount Due Interest from 10/1/2014 to Date of Sale per Monthly diem at $452.43 (Costs to be added) a?,s� 1°1a } L1 \WV `'3 Flo \ a as el(471 --)5A"7 501 By: $119,387.29 KML LAW GROUP, P.0 Michael McKeever Pa. ID 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Land Referred To hl This Conenitment Is Described As All That Certain Prbperty Situated In Township Of Penn In The County Of Cumberland, And State Of Pennsylvania And Being Described In A Deed Dated 08/02/1996 And Recorded 08/09/1996 In Book 143 Page 1147 Among The Land Records Of The County And State Set Forth Above, And Referenced As Follows: All That Certain Tract Or Parcel Of Land With Buildings Erected Thereon, Situate In Penn Township, Cumberland County, Bounded And Described Pursuant To The Final Subdivision Plan For Daniel G. Rhoads And Lone L. Rhoads, Dated September 22, 1989, As Prepared By Eugene A. Hockensmith, P.L.S., And Recorded hi The Recorder Of Deeds Office In And For Cumberland County, Pennsylvania, In Plan Book 60, Page 93 As Follows: Beginning At An Existing Railroad Spike In The Centerline Of Township Route 349 (Southside Drive) At Corners Common With Lot No.3 Of The Above Mentioned Subdivision Plan; Thence Along Said Centerline South 60 Degrees 11 Minutes 51 Seconds West, A Distance Of 151.73 Feet To An Existing Railroad Spike -In The Centerline Of Said Township Route At Corners Common With Lands Now Or Formerly Of Michael L. Failor, Et, Ux; Thence Along Said Failor Lands North 6 Degrees 58 Minutes 59 Seconds East A Distance Of175.18 Feet Through An Existing Iron Pipe To A Second hon Pipe; Thence Along Same North 87 Degrees 20 Minutes 30 Seconds West A Distance Of 131.47 Feet To An Existing Iron Pipe; Thence Along Lands Now Or Formerly Of Betty Jane Deitzel North 19 Degrees 30 Minutes 43 Seconds East A Distance Of 111.11 Feet To Existing Bolt; Thence Along Lot No.1 Of The Aforementioned Subdivision Plan North 89 Degrees 58 Minutes 16 Seconds East A Distance Of 233.52 Feet To An Iron Pin At Corners Common With Lots Nos.1 And 3 Of The Aforementioned Subdivision Plan; Thence Along Said Lot No. 3 South 7 Degrees 51 Minutes 57 Seconds East A Distance Of 211.40 Feet Through A Point On The Dedicated Right Of Way Line To An Existing Railroad Spike In The Centerline Of Township Route 349 (Southside Drive), Being The Place Of Beginning. BEING ALL OF LOT NO.2 OF THE AFOREMENTIONED SUBDIVISION PLAN. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Township of Penn BEING PREMISES: 34 Southside Drive, Newville, PA 17241 SOLD as the property of Jerry W. Swartz, Jr. and Tina M. Swartz TAX PARCEL # 31-33-1910-033 BEING the same premises which Jerry W. Swartz Jr. and Tina M. Swartz, husband and wife, by deed dated 7/25/2013 and recorded 7/29/2013 in Cumberland County in Deed Book Instrument # 201324922 granted and conveyed unto Jerry W. Swartz Jr. KML Law Group, P.C. Suite 5000 — BNY Independence C 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff enter 71LEO-OF F OF THE PROTHONOTAk • 2111LISEP 25 19 rIjMRERL AND COUNTY NATIONSTAR MORTGAGE, LLC PENNSYLVANIA 350 Highland Drive Lewisville, TX 75067 TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 vs. Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 2014-00360 NATIONSTAR MORTGAGE, LLC, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 34 Southside Drive Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): TINA M. SWARTZ 227 South Side Drive Newville, PA 17241 JERRY W. SWARTZ JR. 227 South Side Drive Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: TINA M. SWARTZ 227 South Side Drive Newville, PA 17241 JERRY W. SWARTZ JR. 227 South Side Drive Newville, PA 17241 1, 4 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 — P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 34 Southside Drive Newville, PA 17241 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 statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DAIED: ig 3/ 141 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 5 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 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 350 Highland Drive Lewisville, TX 75067 vs. TINA M. SWARTZ JERRY W. SWARTZ JR. ACTION OF MORTGAGE Mortgagor(s) and Record Owner(s) FORECLOSURE 34 Southside Drive Newville, PA 17241 2014-00360 FILED-OF1= IC;S- �= T E PROTHO?;O`T/ 2014 SEP 25 41-1 11: ; 9 CUMBERL4ND COUP • ►,t.t e, mania IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW Defendant(s Docket No. 2014-00360 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: SWARTZ JR., JERRY W. JERRY W. SWARTZ JR. 227 South Side Drive Newville, PA 17241 Your house at 34 Southside Drive, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,387.29 obtained by NATIONSTAR MORTGAGE, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to NATIONSTAR MORTGAGE, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To 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. 2014-00360 • 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be • paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 2014-00360 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 124067FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. HILL Law Group, P.C. Suite 5000- BNY Independence Center-- 701 enter- 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff OF THE o �0N017 , 20I4SEP 25 Ji II: 19 CUMBERLAND COUP r estr7 rL NIA IN THE COURT OF COMMON PLEAS NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 vs. TINA M. SWARTZ JERRY W. SWARTZ JR. Mortgagor(s) and Record Owner(s) 34 Southside Drive Newville, PA 17241 Plaintiff Defendant(s 2014-00360 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 2014-00360 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: SWARTZ, TINA M. TINA M. SWARTZ 227 South Side Drive Newville, PA 17241 Your house at 34 Southside Drive, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment -of $119,387.29 obtained by NATIONSTAR MORTGAGE, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to NATIONSTAR MORTGAGE, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To 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. 2014-00360 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 A Resources available for Homeowners in Foreclosure ACT NOW! 2014-00360 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 124067FC. Para informacion 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 OF THE PRO THONOTA1 2014 SEP 25 X11 I I: 19 CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE, LLC 350 Highland Drive Lewisville, TX 75067 vs. TINA M. SWARTZ (Mortgagor) JERRY W. SWARTZ JR. Mortgagor and Record Owner 34 Southside Drive Newville, PA 17241 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 2014-00360 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. KML LAW GROUP, P.C. Michael McKeever Pa. ID 5 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 X Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff 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 14-360 Civil Term CIVIL ACTION — LAW TINA M. SWARTZ JERRY W. SWARTZ, JR. 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: $119,387.29 L.L.: $.50 Interest FROM 10/1/2014 TO DATE OF SALE PER MONTHLY DIEM AT $452.43 Atty's Comm: Due Prothy: $2.25 Atty Paid: $313.86 Other Costs: Plaintiff Paid: Date: 9/25/14 Prothonota (Seal) By: Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO, 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. 313897