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Home My WebLink About14-0637 * � a For Prothonotary Use Only. Supreme Coulrt,cf' P'ennsyivalnia. C10 U l� ;a 1O n1rTkq t P l ea' s C! jl r il"C6w r t } ` " : Docket No. Cumbe 9l nd ,Own,ty V Q L The information collected on this form is used solely for court administration purposes. This form does not supplement or rep lace the Alin . and service of pleadin >s or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition 3 ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking 'E C _..`. Lead Plaintiffs Name: First Horizon Home Loans a division of First Lead Defendant's Name: Rose Smith T. '.. Tennessee Bank National Association I Are there money damages requested? ❑ Yes N No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conwgy, P.C. ❑ Check Here if you have no attorney (a Self-Represented I Pro Sel .Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance I ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑Slander /Libel / Defamation ❑ Employment Dispute: ❑ other: Discrimination ❑ Employment Dispute: Other ❑Zoning Board ❑ Other 0 ❑ Other MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ '1'oxic'I'orl - Implant B 11 Toxic Waste REAL 1'ROl'El2'CY MISCELLANEOUS ❑ Other. ❑ E.jecnnent ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ Non - Domestic Relations N Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 rr1 A McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAIiAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pelinsylvania 19109 (215) 790 -1010 First Horizon Home Loans a division of First Cumberland County Tennessee Bank National Association Court of Common Pleas 35011ighland Drive r n Lewisville, TX 75067 Number �- l� V cu V, Rose Smith 9611 Dollarway Road Apartment A White Hall, Arkansas 71602 COMPLAINT IN MORTGAGE FORECLOSURE 4; 4 4 0,01 aa`) Ll NO File # 77674 Page I NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la Corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisioner de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW, THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A 0 TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO, ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. WFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, Pennsylvania 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990 -9108 File tl 77674 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed, we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt, we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: First I orizon IIome Loans a division of First Tennessee Bank National Association v. Rose Smith Cumberland County File # 77674 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is First Horizon Home Loans a division of First Tennessee Bank National Association. 2. The Defendant is Rose Smith, who is the mortgagor and owner of the mortgaged property hereinafter described, whose last -known address is 9611 Dollarway Road Apartment A, White Hall, Arkansas 71602. 3. On May 23, 2007, Rose Smith, mortgagor, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee for First Horizon Home Loan Corporation, its successors and assigns which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1993, Page 1484 ( "the Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On August 19, 2008, the Mortgage was assigned by Mortgage Electronic Registration Systems Inc. as Nominee for First Horizon Home Loan Corporation to First Horizon Home Loans a division of First Tennessee Bank National Association, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 200831919, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 331 F Street, Carlisle, Pennsylvania 17013. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due August 1, 2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance Pile # 77674 Page 4 and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance $ 172,648.66 Interest through January 6, 2014 $ 1,773.80 (Plus $9.46 per diem thereafter) Escrow Advance $ 3,257.82 Property Inspections $ 12.00 Forbearance $ $(16.90) GRAND TOTAL $ 17 7, 6 7 5.3 8 8. Plaintiff complied with all notice requirements as prescribed by 41 P.S. § 101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $17 7, 6 7 S. 3 8, together with interest at the rate of $9.46 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG & CONWAY, P.C. BY: AAL [ ] Terrence J. cCabe, Esquire [ 1 Marc S. Weisberg, Esquire [ ] Edward D. gonway, Esquire „ [,J-Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ 1 Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ J Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff RE: / Property Address: 331 F Street, Carlisle, Pennsylvania 17013 FILE #: 77674 File # 77674 Page 5 VERIFICATION The undersigned, Olivi McAdams does hereby certify that he /she is Assistant Secretal y of Nationstar Mortgage LLC and that Nationstar Mortgage LLC has been duly nominated and appointed by First horizon Home Loans a division of First Tennessee Bank National Association, plaintiff herein, as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action (the "Mortgage "). First Horizon Home Loans a division of First Tennessee Bank National Association lacks sufficient information to make this verification because Plaintiff is not the entity that maintains the business records for the Mortgage. Nationstar Mortgage LLC, in its capacity as mortgage servicing agent for First Horizon Home Loans a division of First Tennessee Bank National Association, maintains the business records for the Mortgage, and therefore does have sufficient information to make this verification in accordance with Pa.R.C.P. 1024(c)(1). I am authorized to make this Verification on Plaintiff s behalf and do hereby verify that the facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief. I have access to and have reviewed the business records of Nationstar Mortgage LLC for and relating to the Mortgage, and I make this Verification based on my review of those records, which are maintained by Nationstar Mortgage LLC in the course of its regularly conducted business activities and are made at or near the time of the event, by or from information transmitted by a person with knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 1 �23/ y Dated: �/ 23 B e: Oli a McAdams Title: Assistant Secretary Name: First Horizon Home Loans a division of First Tennessee Bank National Association v. Rose Smith Loan Number ending with: 0647 File # 77674 Page 6 Exhibit jlEi'Li k F, P. OF GF << .t.ttn r.... tDO� MY 23 PM 3 37 Tax Parcel No. THIS DEED MADE THE Z day of May in the year of our Lord two thousand seven (2007), BETWEEN JAMES M. CRAWFORD and JODY L. CRAWFORD, husband and wife, of the Borough of Carlisle, Cumberland County, Pennsylvania, parties of the first pan, Grantors, and ROSE SMITH, unmarried woman, of the Borough of Carlisle, Cumberland County, Pennsylvania, party of the second part, Grantee: WITNESSETH, that in consideration of One Hundred Fifty-seven Thousand •- •($157,090.00) —Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey to the said Grantee, her heirs and assigns, ALL THAT CERTAIN tract of land with the improvements thereon erected, situate on the North side of "F" Street in the Fifth Ward of the Borough of Carlisle, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of "F" Street 50 feet West of a 16 foot wide alley and 266 feet West of College Street and at line of Lot No. 14 on the hereinafter mentioned Plan of Lots: thence by the North side of "F" Street West 50 feet to the line of Lot No. 17 on said Plan; thence by the line of Lot No. 17, North 150 feet to a 16 feet wide public alley; thence by said alley. Fast 50 feet to the line of Lot No. 14; thence by Lot No. 14, South 150 feet to the North side of "F" Street, the Place of BEGINNING. BEING Lots Nos. 15 and 16, Block 34 of the Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Docket 11, Page 572. BEING improved with a one -story brick dwelling known as No. 331 "F" Street, Carlisle, Pennsylvania. BEING the same premises which James G. Thomas and Connie L. Thomas, husband and wife, by deed dated September 19, 2003, and recorded September 19, 2003 in the office of the Recorder of Deeds, in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book 259, Page 1986, granted and conveyed to James M. Crawford and Jody L. Crawford, husband and wife, the Grantors herein. ti�U' 280 i • . S54 . .. ` FORM First Horizon 1-forne Loans a divi of First IN THE OOIJRT OF COMMON PLEAS OF o 'rennessee Bank National Association CtJM COUNTY, r P .Plaintiff C_ co cVcivil ^`.~~~..^. Defendant 7��'��X� ��'�� l� ��l[�� ~ �,��n~�� '^��u�u��z�� r��=�cm�� ^�"�^��^��`�v�m�u� DIVER �� U�� SION ��z��r'� You have been served with a foreclosure complaint that could cause you to lose your horne. If you ovvo and live in the n:o|deuduJ property which is the subject of this foreclosure action, you may be able to participate inu court-supervised conciliation conference inun effort to resolve this matter with your lender. If you do not have u lawyer, you must take the KnDovpiog steps to be eligible for uumulliudou conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services ui(7l7) 243'94OO ext 25lOor(8OO)022-528Q extension 25lO and request appointment ofu legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that lo&u| representative within twenty (2O) days uf the appointment date. During that meeting, you must provide the legal representative with all requested financial information oo that u |ouo resolution proposal can 6o prepared on your behalf If you and your legal representative complete ufivano(u\ worksheet in the format attached hereto, the legal representative will prepare and 6|e u 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 arrangernents with your lender before the mortgage foreclosure suit proceeds forward. If you are represented 6vu lawyer, you and your lawyer must take the following steps to6m eligible for a conciliation conference. It is not necessary for you to contact MidPerin 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 ufinoucial worksheet (u the format attached hereto, your lawyer will prepare and fi|ou Request for Conciliation Conference with the Court, which must he filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you doxoand u conciliation conference ie scheduled, you will have an opportunity to meet with u representative ufyour 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 %8FREE. Respectfully submitted: Uu10 [uignmmpfozCounsel for Plaintiff] � ,mw Page FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? C O-BORRO WER Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? FINANCIAL INF ORMATIO N First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): I . monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Fxgenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 " Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑No❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes O No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I /We, , authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. Me understand that I/we am /are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: f Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson E L: Sheriff k+�x�,, i :<r,r, }1O3+ 5 ��.� Jody S Smith �Q 9 I31� ' Chief Deputy L Richard W Stewart CUMBERLAND ' Solicitor ' . v PENNSYLVANIA First Horizon Home Loans Case Number vs. 2014-637 Rose Smith SHERIFFS RETURN OF SERVICE 02/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Rose Smith, 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 331 F Street, Carlisle Borough, Carlisle, PA 17013. Deputies were advised by tenant that the defendant now resides at: 9611 A Dollarway Road, Whitehall,AR 71602. 02/12/2014 11:25 AM -Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Ericka Kirby, who accepted as"'dult Person in Charge"for Occupant at 331 F Street, Carlisle Borough, Carlisle, PA 17013. r L M CLINE, DEPUTY SHERIFF COST: $44.78 SO ANSWERS, February 12, 2014 RONNY R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CE.LINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 First Horizon Home Loans a division of First Tennessee Bank National Association Plaintiff TO THE PROTHONOTARY: THE PRO 3 ,T > „t 20141`1AR 17 PM 2: 147 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14- 637Civil PRAECIPE ❑ Please mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. C� Jy DATE: _.. ( l. 1 McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. { ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ -1-Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 First Horizon Home Loans a division of First Tennessee Bank National Association Plaintiff Rose Smith v. Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14-637Civil CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff, hereby certifies that a true and correct copy of the within Praecipe was served on the below person by regular first class mail, postage prepaid, on the ` day of March, 2014. Rose Smith 9611 Dollarway Road Apartment A White Hall, Arkansas 71602 DATE: l McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ -1Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY FIRST HORIZON HOME LOANS A DIVISION OF FIRST TENNESSEE BANK NATIONAL ASSOCIATION, Index No.: 14-637-CIVIL Date Issued: 02/04/20 Plaintiff(s), vs. ROSE SMITH, Defendant(s). STATE OF County of service over the ag On FOR SMITH a below: SS: AFFIDAVIT OF SER.: 1 1 , the undersigned being duly sworn, deposes and says that I was at the time of eighteen and not a party to this action. at AM / I served the within NOTICE OF RESIDENTIAL MORTGAGE 0 URE DIVERSION PROGRAM; COMPLAINT IN MORTGAGE FORECLOSURE on ROSE 9611 DOLLARWAY ROAD APARTMENT A, WHITE HALL, AR 71602 , in the manner indicated PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally; deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the Recipient. SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is ROSE SMITH's usual place of residence/place of abode/place of business, with: Recipient's Name: Relationship: , a family member or other person at said address. PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at AM / PM, on , at AM / PM, and on , at AM / PM. Additional Comments: Description of person process was left with: Sex: F Skin/Race: wir11k Weight: Other: Is defendant in the military? YES LJ NO E Approx. Age: Hair Color: ACC, Height: Signed And sworn this I day of 20 / Youree Crook County Of Pi slaski Notary Public - ru-kansas My Cowninion Exp, 03/21/2015 910011100900Finpv ClientRef#: 108-2664PA LawFirmRef#: 108-2664PA McCabe, Weisberg & Conway, P.C. CID #28 123 S. Broad Street Philadelphia, PA 19109