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Home My WebLink About14-0862 Supreme Court of Pennsylvania Cou of Corn n Pleas �I Sheet For Prothonotary Use Only: -' il:Covet; CIIIBE t NQ County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Nationstar Mortgage LLC Lead Defendant's Name: Robert L.Crum C T Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) X outside arbitration limits O N Is this a Class Action Suit? ❑Yes ® No Is this an MDJ Appeal? ❑Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC A ❑ Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability(does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T _ ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste F1 Other: [:1 Ejectment El Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B ❑ Ground Rent El Mandamus ❑ Landlord/Tenant Dispute _ El Non-Domestic`Relations E 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r NATIONSTAR MORTGAGE LLC, CIVIL DIVISION c-'> Plaintiff, -NO.: )q— (1�1 ^°W `7- VS. lr j rn -.r,'...., TYPE OF PLEADINGc.E Robert L. Crum; :w CIVIL ACTION -COMPLAINT -- Defendant. � IN MORTGAGE FORECLOSURE . TO: DEFENDANT FILED ON BEHALF OF: _4 YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Nationstar Mortgage LLC FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: v I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER, GOLDBERG &ACKERMAN, LLC 350 Highland Drive Lewisville,Tx 75067 Scott A. Dietterick, Esquire-Pa. I.D.#55650 AND THE DEFENDANT: Kimberly A. Bonner, Esquire- Pa. I.D.#89705 416 North East street Joel A. Ackerman, Esquire-Pa I.D.#202729 Carlisle,PA 17013 Ashleigh Levy Marin, Esquire-Pa I.D.#306799 Ralph M. Salvia, Esquire-Pa I.D.#202946 Jaime R.Ackerman, Esquire-Pa I.D.#311032 CERTIFICATE OF LOCATION Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 1 HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS Brian Nicholas, Esquire-Pa l).#317240 416 North East street.Carlisle PA 17013 Denise Carlon, Esquire-Pa I.D.#317226 Municipality: Carlisle 200 Sheffield Street,Suite 101 ATTORNEY R PLAINTIFF Mountainside, NJ 07092 (908) 233-8500 ATTY FILE NO.: XFP 185777 (908) 233-1390 FAX office @zuckergoldberg.com File No.:XFP-185777/TKU Q # � (0 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: , PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED.TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE'COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED.THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT; THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage LLC CIVIL DIVISION Plaintiff, VS. NO.. Robert L. Crum; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty(20) days after this 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 claimed in the complaint or 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage LLC CIVIL.DIVISION Plaintiff, vs. NO.. - Robert L,Crum; Defendant. AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada. en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Listed puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 -NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street f Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage LLC CIVIL DIVISION Plaintiff, vs. NO.: Robert L.Crum; Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Nationstar Mortgage LLC, by its attorneys,Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Nationstar Mortgage LLC, (hereinafter "plaintiff") having its principal place of business at 350 Highland Drive, Lewisville,TX 75067. 2. The Defendant, Robert L. Crum, is an individual whose last known address is 416 North East Street, Carlisle, PA 17013. 3. Nationstar Mortgage LLC, directly or through an agent, has possession of the Promissory Note. Nationstar Mortgage LLC is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A' attached hereto and made a part hereof. 4. On or about July 27, 2009, Robert L. Crum and Linda J. Crum, husband and wife, made, executed and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Bank of America, N.A., its successors and assigns a Mortgage in the original principal amount of$90,436.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on August 17, 2009, Instrument #200928850. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. By Assignment of Mortgage recorded April 2, 2013, the mortgage was assigned to Bank fo America, N.A. which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201310326. The Assignment is a matter of public record and is Zucker,Goldberg&Ackerman, LLC incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By further Assignment of Mortgage recorded September 23,2013,the mortgage was assigned to Nationstar Mortgage, LLC,which assignment is recorded in the Office of the Register of Deeds for Cumberland County, Instrument#201331365. The Assignment is a matter of public record and is incorporated herein•by reference in accordance with Pa.R.C.P. 1019(g),which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. Defendants Robert L. Crum and Linda J.Crum, husband and wife, are the last known record owners of the aforesaid mortgaged premises. Linda J. Crum died prior to the execution of the aforesaid Note and Mortgage, vesting all of her interest in the aforesaid mortgaged premises to Robert L.Crum, by operation of law. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due March 1, 2013.. 9. As of 01/09/2014 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $85,097.04 Interest from 02/01/2013 through 01/31/2014 $4,361.16 Escrow Advance $3,452.84 Late Charge $0.00 Corporate Advance Balance $99.00 NSF• $10.00 Forbearance $(10,601.61) Total $82,418.43 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses.- Plaintiff reserves the right to file a motion in the above-captioned action to .add such additional .sums authorized under the Mortgage- and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). Zucker,Goldberg&Ackerman,LLC 11. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$82,418.43 with interest thereon plus additional costs (including additional escrow advances), additional attorneys'fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,GOLDBERG &ACKERMAN, LLC BY: Dated: '� Scott A. ffietlerick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M. Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226' Attorneys for Plaintiff XFP-185777/TKU 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX . Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman, LLC EXHIBIT A Zucker,Goldberg&Ackerman, LLC CRPRDNRB543a 2/13/2013 3 :59:55 PM PAGE 84/119 888-294-5658 Aft "?rap rea-bye*]CATHY 2ONS'�r Multistate NOTE FHA Case No. LOAN #: 209920676 PA44191.76392703 3TSLY 27, 2009 (Aare] 416 N EAST ST, CARLISLE, PA 17013-2009 [Property Address] I. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means BANK OF AMERICA, N.A. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY;INTEREST In return for a loan received from Lender.Borrower promises to pay the principal sum of NINETY THOUSAND FOUR HUNDRED THIRTY SIX and 00/300 Dollars ((J.S. $90,436.00 },plus interest,to the order of Lender.Interest will be charged on unpaid principal,from the date of disbursement of the loan proceeds by Lender, at the rate of FIVE & ONE-EIGHTH percent ( 5.125%) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a Mortgage,Deed of Trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4- MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and-interest to Lender on the first day of each month beginning on SEPTEMBER 01, 2009 Any principal and interest remaining on the first day of AUGUST, .203.9 will be due on that date,which is called the "Maturity Date." (la) Plane Payment shall be made at P.O. Box 660694, Dallas, TX 75266-0694 or at such place as Lender may designate in writing by notice to Borrower. {C) Amount Each monthly payment of principal and Interest will be in the amount of U.S. $492.4:1 .This amount will be part of a larger monthly payment required by the Security Instrument,that shall be applied to principal,interest and other Items in the order described in the Security Instrument. (D) A Honge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note. the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑ Graduated Payment A.11onge . ❑ Growing Equity Allonge ❑ Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note,in whole or in part,without charge or penalty, on the fast day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month,to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees In writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Cbarge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(Q of this Note.-by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR percent ( 4-000%) of the overdue amount of each payment - (B) Default If Borrower defaults by failing to pay in full any monthly payment.then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment•in full of the principal balance remaining due and all acdrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default.In many circumstances regulations issued by the Secretary will limit Lenders rights to require immediate payment in full in the ewe-of FHA Fixed Rate Note 2001 R-XX(02108)(d/n Page 1 or 2 PHA MuttKlate Foxed Rate Note-10195 ' 2 3 9 9 1 2 0 9 9 2 0 6 7 6 0 0 0 0 0 2 0 0 1 R ' CRPRDNRBS43a 2/13/2013 3:59:55 PM . PAGE 86/119 888-294-5658 RW W_Aft AWL CASE #t: PA4419176392703 LOAN #= 209920676 payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this. Note, Secretary"means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above. Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment"means the right to require Lender to demand payment of amounts due."Notice of dishonor"means the right to require Lender to give notice to other persons that amounts due have not been paid. &. GIVING OF NOTICI~S Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be gived•by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of thts Ngle is also obligated to do these things.Any person who takes over these obligations,including the obligations of a guarantor,surety or endorser of this Note,is also obligated to keep all of the promises made in this Note.Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under ibis Note. BY SIGNING BELOW,Borrower accepts and agrees to the terms and covenants contained in this Note. PAY TO THE ORDER OF (Seal) BERT L CRUM -Borrower WTTHOUT RECOURSE BANK OF AMERICA, [CIA_ (Seal) BY - � � -Borrower i1i4tCHELE S.1 NICER SENIOR VICE PRESIDENT (Seal) -Borrower (Seal) -Borrower FHA Fixed Rate Note 2001 R-XX(02/08) Page 2 or 2 FHA MuRistate Fixed Rate Note-10195 EXHIBIT B' Zucker,Goldberg&Ackerman,LLC (Pagel 5 of 20) Exhibit"A" Legal Description ALL THAT CERTAIN PARCEL OF LAND SITUATED IN BOROUGH OF CARLISLE, CUMBERLAND COUNTY,COMMONWEALTH OF PENNSYLVANIA,BEING KNOWN AND DESIGNATED AS METES AND BOUNDS PROPERTY. DEED FROM JOHN E.SMITH AND THORMA M.SMITH,HUSBAND ND WIFE,EACH BY AND THROUGH HIS/HER RESPECTIVE ATTORNEYS-IN-FACT,CALVING J. SMITH AND LINDA L.SMTIH AS SET FORTH IN DEED BOOK 206,PAGE 807 DATED 08/30/1999 AND RECORDED 08/30/1999,CUMBERLAND COUNTY RECORDS,COMMONWEALTH OF PENNSYLVANIA. Tax/ParcelID:02-20-1800-100 1970839 VERIFICATION I Olivia McAdams Assistant Secretai y (title), depose and say subject to the penalties of 18 Pa.C.S.A., sec.4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. By: Nationstar Mortga LC Name: Title: Assistant Secretary Olivia McAdams File No: 185777 Borrower Name: Robert L. Crum NATIONSTAR MORTGAGE LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION—LAW • NO. 14-862 CIVIL ROBERT L. CRUM, Defendant : MORTGAGAE FORECLOSURE ORDER AND NOW,this Z "1 day of February, 2014, action on captioned mortgage foreclosure action is stayed pending service upon the defendant of the documents giving notice of the Cumberland County Mortgage Diversion Program. BY THE COURT, ' 4 494 Kevin :Y Hess, P.J. ✓Ashleigh Marin, Esquire 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 obert L. Crum 416 North East Street Carlisle, PA 17013 ;-, :rim -.0 a r- . m� -n sr,• Copie.s 172, -Ltsr.c.L =7) to 24V/1i 1-.0.. ....--,/9 > cad« ---f..< -, Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of cirotafrt4 OFF CE OF T 514, ERIPF Nationstar Mortgage LLC vs. Robert L Crum (-) -r - 171. r CD rZ -10 CD -77 c.) • 4- Case Number 2014-862 SHERIFF'S RETURN OF SERVICE 03/04/2014 11:11 AM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Robert L Crum at 416 North East Street, Carlisle Borough, Carlisle, PA 17013. JASCN2fFt 141- 6 E1UTY SHERIFF COST: $41.56 SO ANSWERS, March 05, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC, Plaintiff vs. Robert L. Crum; Defendant(s). Mortgaged Premises: 416 North East Street, Carlisle, PA 17013 CIVIL DIVISION No.: 14-862 ISSUE NUMBER: TYPE OF PLEADING: PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Nationstar Mortgage, LLC Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh L. Marin, Esquire -Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire- PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-185777 °ju+ g `IG. SO ai+i _*-33•Mcl Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-185777 Q.J. e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC CIVIL DIVISION Plaintiff, vs. Robert L. Crum; Defendant. NO.: 14-862 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $82,418.43 plus interest on the judgment amount ($82,418.43) from February 1, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 416 North East Street address is: ,Carlisle, P 17013 Dated: r"i 1 Lf BY: 0 °Joel A. Ackerman, Esquire; PA I.D. #202729 O Ashleigh L. Marin, Esquire; PA I.D. #306799 0 Jaime R. Ackerman, Esquire; PA I.D. #311032 O Denise Carlon, Esquire; PA I.D. #317226 O Brian Nicholas, Esquire; PA I.D. #317240 Roger Fay, Esquire; PA I.D. #315987 7 Ralph M. Salvia, Esquire; PA I.D. #202946 Attorneys for Plaintiff XFP-185777 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office ckerg DAMAGES ARE HEREBY ASSESSED AS INDICATED . Date G & ACKERMAN, LLC Prothonota IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC CIVIL DIVISION Plaintiff, vs. Robert L. Crum; Defendant. NO.: 14-862 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated:1 17 11 Sworn to and subscribed before me This 17 day of Jtc_!.� , 20 /'i -r—ru Notary Public My Commission Expires: Cheryl Debeneadto Notary Public, My Comm. Expires Oct. 16, 2Q.1G ID # 2280276 State of New Jersey BY: Joel A. Ackerman, Esquire; PA I.D. #202729 ▪ Ashleigh L. Marin, Esquire; PA I.D. #306799 • Jaime R. Ackerman, Esquire; PA I.D. #311032 ▪ Denise Carlon, Esquire; PA I.D. #317226 fl Brian Nicholas, Esquire; PA I.D. #317240 ❑ Roger Fay, Esquire; PA I.D. #315987 97 Ralph M. Salvia, Esquire; Pa I.D. #202946 Attorneys for Plaintiff XFP-185777 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com RG & ACKERMAN, LLC Zucker, Goldberg & Ackerman, LLC XFP-185777 Department of Defense Manpower Data Center Results as of : Jul -16-2014 10:30:26 AM SCRA 3.0 Status Report Pursuant to ServiceCivil Relief Act Last Name: CRUM First Name: ROBERT Middle Name: L Active Duty Status As Of: Jul -16-2014 On Active Duty On Active. Duty Status Date Active Duty Start Date . Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date I 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 Statue Date Order Notification Stall 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, NOM, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. A. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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: DBT6FA66T0F1JBO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC CIVIL DIVISION Plaintiff, vs. Robert L. Crum; Defendant. NO.: 14-862 NOTICE OF ORDER, DECREE OR JUDGMENT TO: Robert L. Crum 416 North East Street Carlisle, PA 17013 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on [] or [V] The judgment is as follows: $82,418.43 A copy of the Order or Decree is enclosed, Zucker, Goldberg & Ackerman, LLC XFP-185777 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC vs. Robert L. Crum Plaintiff, Defendant. TO: Robert L. Crum 416 North East Street Carlisle, PA 17013 DATE OF NOTICE: 6/19/2014 CIVIL DIVISION NO.: 14-862 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 again 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationstar Mortgage, LLC vs. Robert L. Crum Plaintiff, Defendant. TO: Robert L. Crum 416 North East Street Carlisle, PA 17013 CIVIL DIVISION NO.: 14-862 AVISO IMPORTANTE FECHA DEL AVISO:6/19/2014 USTED ESTA EN REBELDIA PORQUE HA FALL.ADO DE TOMAR LA ACCION REQUERMA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDTATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFIC NA ABAJO IIlTDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scoff- A. D i,efte4-ick. Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 185777 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY v.o9 c!'Cal:nOrr , c,ort d OFFICE QF THE $IERIFF Nationstar Mortgage LLC vs. Robert L Crum Case Number 2014-862 SHERIFF'S RETURN OF SERVICE 03/04/2014 11:11 AM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint In Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Robert L Crum at 416 North East Street, Carlisle Borough, Carlisle, SPA 17013. JASON KIN L DE UTY SHERIFF COST: $41.56 March 05, 2014 (c) Countysulte Sheriff, Teleosort, Inc. SO ANSWERS, RONNS' R ANDERSON, SHERIFF