HomeMy WebLinkAbout14-0980 Court of Common Pleas
Civil Cover Sheet For Prothonotary Use Only:
Docket No:
Cumberland County 1
9
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff's Name: Nationstar Mortgage LLC Lead Defendant's Name: Bakary Traore
C
T
Dollar Amount Requested: within arbitration limits
I Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits
O
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No
A Name of Plaintiff/Appellant's Attorney: Christopher A. DeNardo, Esquire
❑ Check here if you have no attorney (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 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 ❑ Employment Dispute:
include mass tort) Discrimination
E ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other
❑Zoning Board
C ❑ Other:
T ❑ Other:
I ❑ Other:
O MASS TORT
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
B
Fl Toxic Waste El Ejectment ❑ Common Law /Statutory Arbitration
❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447., "`"'
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 { '''�i? °, fit',`' �=
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
3600 HORIZON DRIVE SUITE 150 AJ - 110:
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278 -6800 PE= tjS YLVi 1 Y
S & D FILE NO. 13- 043766 141
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
DEFENDANT ,
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
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 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 DO 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.
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.
I
?z I yl/
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717 - 249 -3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE RAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECRA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717 -249 -3166
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278 -6800
S & D FILE NO. 13- 043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
DEFENDANT ;
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, Nationstar Mortgage LLC, the address of which is, 350 Highland Dr.,
Lewisville, Texas 75067, brings this action of mortgage foreclosure upon the following cause of
action:
1. (a) Parties to Mortgage
Mortgagee Mortgage Electronic Registration Systems, Inc., as Nominee for Bank
of America, N.A., its successors and assigns
Mort ag�aor(s) Bakary Traore
(b) Date of Mortgage January 29, 2010
(c) Place and Date of Record of Mortgage
Recorder of Deeds
Cumberland County Document ID# 201005426
Date: March 3, 2010
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Assignments
Assignor: Mortgage Electronic Registration Systems, Inc.
Assignee: Bank of America, N.A., Successor by Merger to BAC Home Loans
Servicing, LP FKA Countrywide Home Loans Servicing, LP
Date of Assignment: February 28, 2012
Recording Date: March 1, 2012
Instrument No.: 201206091
Assignor: Bank of America, N.A.
Assignee: Nationstar Mortgage, LLC
Date of Assignment: June 20, 2013
Recording Date: July 8, 2013
Instrument No.: 201322524
2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original Mortgagee, or is the present holder of the mortgage by
operation of law.
3. The real property which is subject to the Mortgage is generally known as 1007 East
Coover Street, Mechanicsburg, PA 17055 and is more specifically described as attached
as part of Exhibit "A ".
4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as
Exhibit "B ".
5. The name and mailing address of the Defendant is: Bakary Traore, 1007 East Coover
Street, Mechanicsburg, PA 17055.
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both.
7. The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of December 1,
2011 and have not been paid, and upon failure to snake such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of October 29, 2013:.
Principal Balance Due $143,137.42
Interest Currently Due and Owing at 4.75% $13,597.92
From November 1, 2011 through October 29, 2013
Escrow Advances $6,078.99
Property Inspection $63.00
TOTAL $162,877.83
9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff
may incur other expenses, costs and charges collectible under the Note and Mortgage.
10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be
sought by Plaintiff and included in any request for judgment.
11. A Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403
commonly known as Act 6 and demand for payment was sent to each individual Defendant
by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ".
12. The Mortgage is insured by the Federal Housing Administration under Title II of the
National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners'
Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 8 and 9, together
with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note
and Mortgage and for the foreclosure and sale of the mortgaged premises.
ft
SHAPIRO & DeNARDO, LLC
Date:
BY:
for aintiff C fli — o i r . neys
TPLIN M. DONNELLY, ESQ
S & D File No. 13- 043766 t
a
OOOAOK
Prepared By:
ANNE MARIE MOSSER
SANK OF AMERICA, N.A.
2733 PAPER KILL RD, SUITE 7
WYOMISSING
PA 1.9610
After Reoordtng Return To:
BANK OF AMERICA, N.A.
ReconTrust Co. /TX2- 979 -01 -07
P.O. Box 619003
Dallas, TX 75261-9003
Parcel Number:
17 -23- 0561 -053
premises:
1007 E COOVER ST
MECHANICSBURG
PA 17055 -3420
(Space Above This Line For Recording Data]
AAa4•-
��ase ifj (Doc ID #]
Commonwealth of ponmivants MORTGAGE FHA Caen Nn, �
MIN
THIS MORTGAGE ( "Secur1tylnstruvnen1 ") is given on JANUARY 29, 2010
FHA PennsyWnte MoAMO with Mf WO - 41N
MFRS FHA Mortgage-PA
1004N-PA (06f08)(df) Page 1 of 10 Aswnded 8102
2 3 9 9 1 ` - - - - - - - - - -
IL
4- A
CASE #: DOC ID #_
The Mortgagor is
BAKARY TRAORE
CBorrower "), This Security Instrument Is given to Mortgage Electronic Registration Systems, Inc. ( "MERS "),
(solely as nominee for Lender, as hereinafter defined, and Lender`s successors and assigns), as mortgagee.
MERS is organized and existin under the laws of Delaware, and has an address and telephone number of P.O.
Box 2026. Flint, MI 48501 - 20213, tel. (888) 679 -MERS.
BANK OF AMERICA, N.A.
CLender ") Is organized and existing under the laws of THE UNITED STATES , and has an
address of
101 South Tryon Street, Charlotte, NC 28255
Borrower owes Lender the principal sum of
ONE HUNDRED FORTY SEVEN THOUSAND ONE HUNDRED EIGHTY FOUR and
00 /100
Doliars (U.S. $ 147,184.00 ). This debt Is evidenced by Borrower's note dated the same date as
Q* Security Instrument ( "Note "), whicb provides for monthly payments, with the fall debt, if not paid earlier,
due and payable on FEBRUARY 01, 2040 . This Security Instrument secures to Lender; (a) the
repayment of the debt evidenced by the Note, with Interest, and all renewals, extensions and modifications of the
Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this
Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security
Instrument and the Note, For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely
as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, tine
following described property located In CUMBERLAND
County, Pennsylvania-
MERS FHA Mort age•Pq
1004N -PA (os l Page z of 10
CASE #: _ -_ DOC ID #:
SEE EXHIBIT "A" ATTACHED HERETO AND MADE A PART HEREOF,
which has the address of
1007 E COOVER ST, MECHANICSBURG
)Storer, City)
Pennsylvania 17055 ("Property Address'7;
[Zip Code)
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property." Borrower understands and agrees that MFRS holds only legal title to the interests granted by
Borrower in this Security Instrument; but, if necessary to comply with law or custom, MFRS, (as nominee for
Lender aad Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but
not limited to, thec1ght to foreclose and sell the Property; and to take any action required of Lender including,
but not limited to, releasing or canceling this Security Instrument,
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property acid that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims
and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUWNT combines uniform covenants for national use and non - Uniform
covenants with Horned variations by jurtsdictlon to constitute a uniform security instrument covering real
Property.
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS,
L Payment of'Prindpal, Interest and lute Charge. Borrower shall pay when due the principal of, and
interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Traced, Insurance and Other Charges. Borrower shall include in each
monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for
(a) taxes and spacial assessments levied or to be levied against the Property, (b) leasehold payments or ground
rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year In which the
MFRS FHAMortgaga�PA
1004N -PA (08108) Pegs 3 of 10
CASE #: ` _J DOC ID #
Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development
( "Secretary"), or in any year in which such premium would have been requited if Lender still held the Security
Instrument, each monthly payment shall also include either: (1) a sum for the annual mortgage Insurance
premium to be paid by Lender to the Secretary, or (ti) a monthly charge Instead of a mortgage Insurance
premium if this Security Instrument is held by the Secretary, to a reasonable amount to be determined by the
Secretary. Except for the monthly charge by the. Secretary, these items are called "Escrow Items" and the sums
paid to Lender are called "Escrow Funds."
Lender may, at any time, collect and hold amounts for Escrow Itoms In an aggregate amount not to exceed
the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement
Procedures Act of 1874, 12 U.S.C, Section 2601 et seq, and implementing regulations, 24 CFR Part 3500, as
they may be amended from time to time ( "RESPA "), except that the cushion or reserve permitted by RESPA for
unanticipated disbursements or disbursements before the Borrower's payments are available in the account may
not be based on amounts due for the mortgage Insurance premium.
If the amounts held by Lender for Escrow Items exceed the. amounts permitted to be held by RESPA,
Lender shall account to Borrower for the excess funds as required by RE$PA. If the amounts of funds held by
Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and
require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for ail sums secured by this Security Instrument, If
Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the
balance remaining for all installment items (a), (b), and (c) and any mortgage Insurance premium installment that
Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to
Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's
account shall be credited with any balance remaining for all Installments for items (a), (b), and (c),
3. Applictden of Payments. All payments under paragraphs I and 2 shall be applied by Lender as
follows:
E, to the mortgage Insurance premium to be paid by Lender to the Secretary or to the monthly charge by
the Secretary instead of the monthly mortgage Insurance premium;
SepgII to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other
hazard Insurance premiums, as required;
DW, to interest due under the Note;
Fah, to amortization of the principal of the Note; and
M. to late charges due under the No%
4. Fire, Flood and Other Hazard Issursaae. Borrower shall insure all Improvements on the Property,
whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, Including
fire, for which Lender requires insurance. This insurance shall be maintained In the amounts and for the periods
that Lender requim, Borrower shall also insure all Improvements on the Property, whether now In existence or
subsequently erected, against loss by floods to the extent required by the Secretary. All Insurance shall be carried
with companies approved by Lander. The insurance policies and any renewals shall be held by Lender and shall
include loss payable clauses In favor of, and In a form acceptable to, Lender,
In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss
if not made promptly by Borrower, Each Insurance company concerned Is hereby authorized and directed to
make payment for such loss directly to Lender, instead of to Borrower and to Lender Jolntty, AU or any part of
the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness
under the Note and this Security Instrument, First to any delinquent amounts applied In the order in paragraph 3,
and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application
MFRS FHAMort9ogaPA
10G4N -PA (06108) Page 4 of 10
CASE #r - DOC ID #: - - - - - -- 0
of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are
referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over, an
amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to
the entity legally entitled thereto.
In the event of foreclosure of this Security Instrument or other transfer of tide to the Property that
extinguishes the Indebtedness, all right, title and interest of Borrower In and to insurance policies in force shall
pass to the purchaser.
S. Occupancy, Prveervation, ,lUiutonsuce and Protection of the Property; Borrower's ]Loan
Applicatdoa; Lersekoldtr. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence wtthin sixty days after the execution of this Security Instrument (or within sixty days of a later sale or
transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least
one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for
Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify
Lender of any extenuating circumstances. Borrower shall not conurilt waste or destroy, damage or substantially
change the Property or allow the Pr opg4ty a w- .atc,_r-easonable wear -aod .tear- excepted. - Lender- may4mpw- - - - - --
e Property if the Property is vacant or abandoned or the loan Is in default. Lender may take reasonable action to
protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during
the loan application process, gave materially false or inaccurate Information or statements to Lender (or failed to
provide Lender with any material Information) in connection with the loan evidenced by the Note. Including, but
not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this
Security instrument Is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower
acquires fee title to the Property, the leasehold and fee tide shall not be merged unless Lender agrees to the
merger In writing.
d. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or outer taking of any part of the Property, or for conveyance in place of
condemnation. are hereby assigned and shall be paid to Lender to the extent of the full amount of the
Indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds
to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts
applied In the order provided In paragraph 3. and then to prepayment of principal. Any application of The
proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred
to to paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay
all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally
entitled thereto.
7. Charges to Borrower and Protection of Lender's itlghts In the Property. Borrower shall pay all
governmental or municipal charges, fines and impositions that are not included In paragraph 2. Borrower shall
pay these obligations on time directly to The entity which is owed the payment. If failure to pay would adversely
affect Lender's interest in the Property, upon Lenders request Borrower shall promptly furnish to Lender receipts
evidencing these payments.
If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any
other covenants and agreements contained in this Security Instrument, or there Is a legal proceeding that may
significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to
enforce .laws or regulations), then Lender may do and pay whatever is necessary to protect the value of Me
Property and Lender's rights in the Property. Including payment of taxes, hazard insurance and other Items
mentioned in paragraph 2.
MERE FHAMongage•PA
1004N -PA (06108) Page b of 10
CASE #: - - -- DOC ID #: ^
Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and
be secured by this Security Instrument, These amounts shall bear interest from the date of disbursement, at the
Note rate, and at the option of lender, shall be Immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security instrument unless
Btnrower: (a) agrees In writing to the payment of the obligation secured by the lien In a manner acceptable to
Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien In, legal proceedings
which in the Lender's oplydon operate to prevent the enforcement of the lien; or (c) secures from the holder of the
lien an agreement satisfactory to Lender subordinating the ben to this Security Instrument If Leader determines
that any part of the Property is subject to alien which may attain priority over this Security Instrument, Lender
may give Borrower a notice Identifying the lien, Borrower shall satisfy the lien or take one or more of the actions
set forth above within 10 days of the giving of notice.
S. Btei. Lender tray collect fees and charges authorized by the Secretary.
9. Grounds for Aoaeleration ot"t.
(a) Dts4 WL Lender may, except as limited by regulations issued by the Secretary, in the case of
payment defaults, require immediate payment In full of all sums secured by this Security Instrument
0J Borrower defaults by falling to pay In full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment, or
01) Borrower defaults by failing, for a period of thirty days, to perform any other obligations
contained in this Securlty Instrument.
(b) Nth Without Cr4t ApprovaL Lender shall, If permitted by applicable law (including Section
341(d) of the Garr -St, Germain Depository Institutions Act of 1982.12 U.S.C, 1701] -3(d)) and with
the prior approval of the Secretary, require immediate payment in full of all sums secured by this
Security Instrument if:
(1) All or part of the Property, or a beneficial interest in a trust owning all or pan of the
Property. Is sold or otherwise transferred (other than by devise or descent), and
(it) The Property is not occupied by the purchaser or grantee as his or her principal residence,
or the purchaser. or grantee does so occupy the Property but his or her credit has not been
approved in accordance with the requirements of the Secretary.
(e) No waiver. If circumstances occur that would permit Lender to require immediate payment in
full, but Lender does not require such payments, Lender does not waive its rights with respect to
subsequent events.
(r1) Reguladoarr of HUD Secretary. In many circumstances regulations Issued by the Secretary will
limit Lender's rights, to the case of payment defaults, to requite immediate payment in full and
foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not
permitted by regulations of the Secretary.
(e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for Insurance under the National Housing Act within 80 days from the date
hereof, Lender tray, at its option, require immediate payment in fall of all sums secured by this
Security Instrument, A written statement of any authorized agent of the Secretary dated subsequent to
130 days from the date hereof, declining to insure this Security Instrument and the Note, shall be
deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not he
exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a
mortgage Insurance premium to the Secretary,
MERS FHA Mortgage -PA Page 6 of 10
1004N -PA (06/08)
CASE #: __ DOC ID #r a
10, Relo#tateureaL Borrower has a right to be reinstated if Lender has required Immediate payment in
full because of Borrower's failure to pay an amount due under the Note or this Security Instrument, This right
applies even after foreclosure proceedings are Instituted, To reinstate the Security Instrument, Borrower shall
tender in a lump sum all amounts requited to bring Borrower's account current including, to the extent they are
obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary
attorneys' fees and expenses properly associated with the foreclosure proceeding, Upon reinstatement by
Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not
required immediate payment In full. However, Lender is not required to permit reinstatement It (i) Lender has
accepted reinstatement after the commencement of foreclosure proceedings within two years immediately
preceding the commencement of a current foreclosure proceeding, (it) reinstatement will preclude foreclosure on
different grounds in the future, or (111) reinstatement will adversely affect the priority of the lien created by this
Security Instrument,
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to any
successor in Interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's
successor in Interest, Lender shall not be required to commence proceedings against any successor In Interest or
refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security
Instrument by reason of any demand made by the original Borrower or Borrowers successors in Interest. Any
forbearance by Lender In exercising any right or remedy shall not be .a waiver of or preclude the exercise of any
right or remedy,
12, Suteeo#sors and As#lgas Boned; Joint and Several L(abfEtyt Co-signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,
subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any
Borrower who co -signs this Security Instrument but does not execute Ike Note; (a) is co-signing this Security
Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this
Security Instrument; (b) Is not personally obligated to pay the sums secured by this Security Instrument; and
(c) agrees (bat Lender and any other Borrower may agree to extend, modify, forbear or make any
accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's
consent.
13. Notices, Any notice to Borrower provided for in this Security Instrument shall be given by delivering
it or by mailing it by first class mail unless applicable taw requires use of another method, The notice shall be
directed to the Property Address or any othet address Borrower designates by notice to Lender. Any notice to
Lender "I be given by first class mall to Lender's address stated herein or any address Lender designates by
notice to Borrower. Any notice provided for In this Security Instrument shall be deemed to have been given to
Borrower or Leader when given as provided in this paragraph,
14. Governing Law; S#verabpity. This Security Instrument shall be governed by Federal law and the
law of the jurisdiction in which the Property Is located. In the event that any provision or clause of this Security
Instrument or the Note conflicts with applicable law, such conflict shall not allect other provisions of this
Security Instrument or the Note which can be given effect without the conflicting provision. To this end the
provisions of this Security Instrument and the Note are declared to be severable.
19. Borrower'# Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument,
16. Razardou# Substances, Borrower shall not cause or permit the presence, use, disposal, storage, or
release of any Hazardous Substances on or in the Property. Borrower shall not do,, nor allow anyone else to do,
anything affecting the Property that is in violation of any Environmental Law, The preceding two sentences shall
MFRS FHA Mongage-RA
1004N-PA (06108) Page 7 of 10
CASE #r DOC ID #:
not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are
generally recognized to be appropriate to normal residential uses and to maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsult or other
action by any governmental or regulatory agency or private party involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by
any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances
affecting the Property is necessary. Borrower shall promptly take all necessary remedial actions in accordance
with Environmental Low,
As used In INS paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous
substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, -toxic pesticides and herbicides, volatile solvents, materials containing asbestos or
formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws
and taws of the judsdkdon where the Property IS located that relate to health, safety or environmental protection.
NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows;
17. Assignment of )gents. To the extent permitted by applicable law, Borrower unconditionally assigns
and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents
to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or
Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or
agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as
trustee for the benefit of lender and Borrower. This assignment of rents constitutes an absolute assignment and
not an assignment for additional security only.
If lender gives notice of breach to Borrower; (a) all rents received by Borrower shall be held by Borrower
as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument: (b) Lender
shalt be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall
pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act that
would prevent Lender from exorcising its rights under this paragraph 17,
Lender shall not be required to enter upon, take control of or maintain the Property before or after giving
notice of breach to Borrower. However, Lender or a Judicially appointed receiver may do so at any time there Is
a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of
Lender. This assignment of rents of the Property shall tenninate when the debt secured by the Security
Instrument is paid in full.
18. Foredosure Procedure. If Lender requires immediate payment in ib0 imder paragraph 9
Lender may foreclose Ibb Security Instrument by Judicial proceeding and Invoke any other roamedles
permitted by Applicable law. Lender shall be entitled to colleet ail expenses incurred in pursuing the
remediss provided to tkis paragraph 18, including, but not limited to, attorneys' tees and costs of title
evideaco.
if - the Lender's taterest in this Security Instrument Is held by the Secretary and the Secretary
requires immediate payment in NU under ) Paragrapb 9, the Secretary may Invoke the sronjudieial power
of sale provided in the S4rgle Family Mortgage Foreclosure Act of 1994 ( "Act ") (12 U.S.C. 3751 et seq.) by
requesting a foreclosure cominisstenor designated under Ike Act to commence foreelorare and to sell the
Property ss provided to the Ad. Nothlug In the preceding sentence shaft deprive the Secretary of any
rights otherwise available to a Leader under tits Paragraph 18 or applicable law.
MFRS FHA Mortgage -PA
1e04N.PA (06108) Page a of 10
CASE #: _ - -._- DOC ID #:
14. ReUsse. Upon payment of all sums secured by this Security Instrument, this Security Instrument and
the estate conveyed shall terminate and become void, After such occurrence, Lender shall discharge and satisfy
this Security Instrument without charge to Borrower, Borrower shall pay any recdrdalion costs.
20. Welven. Borrower, to the extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instnimeat, and hereby waives the benefit of any present or future
laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and
homestead exemption.
21, Rdlaatatement Period. Borrower's time to reinstate provided In paragraph 10 shall extend to one hour
prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
22. Pureh *se Money Mortgage, If any of the debt secured by this Security Instrument Is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage,
23. Intereat Rate After ,Fndgracat, Borrower agrees that the interest rate payable after a Judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note.
24. Riders to this Security Xmtrament, If one or more riders are executed by Borrower and recorded
together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall
amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of
this Security Instrument. [Check applicable box ( I.
❑ Condominium Rider Q Growing r4ulty Rider
❑ Planned Unit Development Rider ❑ Graduated Payment Rider
❑ other Ispedify]
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument
and in any riders) executed by and recorded with it.
(Seat)
sAKARY TRA RE - Borrower
(Seal)
Borrower
(Seal)
- Borrower
(Seal)
Borrower
MFRS FHA Monggage•PA
1o04N•PA (06M) Page 0 of 10
> f
CASE #: DOC. ID
CQMMONWE H OF PENNSYLVANIA, � � y County $a:
On this., day of before me, the undersigned offker,
personally appeared
known to me (or satisfactorily proven) to be the
persons) whose names) islare subscribed to the within instrument and acknowledged that helshe/they executed
the same for the purposes herein contained.
IN WTFNESS WHEREOF, I hereunto set my hand d ci 1 Be].
My Commission Expires:
COMMONWEALTH 0111'IWNSYLVANIA 0 U b .
NOTARIALSEAL Title of Officer
R Ragan. Notary Public
E. HempfteldTwp., LancasterCotmty
My Commission Hxpin:*Au 15,2010 .
Certt11esteofRerid n
I, 1� , do hereby certify that the correct address of
the within -named Mortgagee Is 3 0 S.W. So Ave , Suite 101., Ocsia, FL 34474 or P.O. Box 2026, Flint,
MI 48501 -2026. n
Witness my hand this day of
Agent of Mortgagee
MFRS FHA Mortgage-PA . Page 10 of i4
1004N-PA (06108)
Fix st American
Title Insurance Compares
File No. 2008137A6 Policy No. 1102132254 -PAO
OWNER'S POLICY
SCHEDULE A
Nor►tinuecO
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground situate In Mechanicsburg Borough, County of
Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the Northern line of Coover Street at the corner of Lot No, 60 on the
hereinafter mentioned plan of lots; thence along the dividing lien between Lots Nos. 60 and 61,
North 22 degrees 47 minutes West, 134 feet, more or less, to a point; thence by the dividing line
between Lots No. 54 and 61, North 66 degrees 43 minutes East, 80 feet to a point; thence by the
dividing One between Lots No. 61 and 02, South 22 degrees 47 minutes East, 134 feet, more or
less, to a point on the Northern line of Coover Street; thence by the Northam ling of Coover
Street, South 86 degrees 43 minutes West, 80 feet to a point, the place of BEGINNING,
HAVING thereon erected a onerstory brick dwelling house and carport, being known and
numbered as 1007 E Coover Street, Mechanicsburg, Pennsylvania.
BEING Lot No. 61 on the Plan of Lots known as Orchard Crest - Section B, which said Plan is of
record In the Cumberland County Recorder's Office in Plan Hook 10, rage 24.
SUBJECT to all restrictions, reservations and easements of record.
BEING THE SAME PREMISES which Robert P. Murray, and Mae F. Murray, by Deed dated
December 5, 1974, and recorded In the Office of the Recorder of Deeds In and for Cumberland
County, Pennsylvania, In Book X 25, Page 520, granted and conveyed unto Mae F. Murray,
Amerlcan Land Title Assoclaoon Owner's Polloy (as modified by TIRSAP)
0611712009 and 41112007
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013 "
717 -240 -6370
Instrument Number - 201005426
Recorded On 3/3/2010 At 1:39:48 PM * Total Pages -12
* Instrument Type - MORTGAGE
Invoice Number - 61689 User ID - AF
* Mortgagor - TRAORE, BA.KARY
* Mortgagee - MORTGAGE ELECTRONIC REGISTRAT1ON SYSTEMS INC
* Customer - ABS OLUTE ABSTRACT
* Tess
STATE WR IT TAR $0.50 Certification Page
STATE aCS /ACCESS TO $23.50
JUST DO NOT DETACH
RECORDING FEES - $25.50
RHCORDZR OF DEEDS
PARCEI, CERTIFICATION $1 0 .00 This page is now part
FEES of this legal document.
AFFORDABLE HOUSING $11,50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $76.00
I Certify this to be recorded
in Cumberland County PA
RECORDER O D DS
"- Information denoted by an asterisk may change during
the verifleatfon process and may not be reflected on this page.
4
Illlilllll�lll�lllll�l
CRP,RDNRBS46a 12/16/2011 11:57:05 AM PAGE 153/262 888 -294 -5658
Prepared by, AM lD,RIE WSSBR
Multistate NOTE
rHA Case No.
LOAN t1
JANUARY 29, 2010
(Dale]
1007 E COOVER ST, MECHANICSBURG, PA 17055 -3420
(Property Address)
1, PA1RTiES
'Borrower' means each person signing at the end of this Note, and the person's successors and assigns. "Lender mmits
HANK OF AMERICA, N.A.
and Its successors and assigns. t
2. BORROWER'S PROMISE TO PAY; INl'IZRE.ST
in reran for a loan received from Gender. Borrower promises to pay the principal sum of
OWS HUNDRED FORTY SUM THODSAND ONE HUNDRED EIGHTY FOUR and 00 /100
Dollars (U.S. $147,18f-00 ), plus interest, to the order of Lender Interest will be charged oa unpaid principal, from the dale
of disbursement of the Ioan proceeds by Lender. at the rate of FOUR 6 THREE- QUARTERS percent ( 4.750%) pi:r
year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's premise to pay is setured by a Mortgage. Deed of Trust or similar security instrument that is dated the same date Its
this Note and called the 'Security lastruttrent.' The Security Instrument protects the Lender from losses which might resuh if
Borrower defaults under Uds Note.
4. MANNER OF PAYMI ENT
(A) Tine
Borrower sbail make a payment of principal and interest to Lender on the first day of each month beginning 0
MARCH 01, 2010 Any priaclped and interest remaining On die first day of FBBRUARY, 2040 , will be due on that
date which b called the "Maiurtty Date,"
(B) Place
Payment shall be made at
P.O. Box 660694, Dallas, TX 75266 -0694
or at such piece as Lender may designate in writing by notice to Borrower,
(C) Ameant
Each monthly payment of principal and Interest will be to the ammnt of U.S. 5767.7 a This amount wit(
pain of a larger monthly payment required by the Security Instrument. that shall be nppiled to principal. interest and otter Item in The
onler described in the Seawhy Instrument.
(D) Ailortge to this Note for payment adjustments
If an allonge providing for payrneat adjustments is executed by Borrower together with this Note, the covenants of the
uillooge shall be incorporated into and shall amead and supplement the covenants of this Note as if the allonge were a part of tills
Note. [Check applicable box]
❑ Graduated Payment Alloage ❑ Growing Equity Allonge ❑ Oil- [specify]
5. BORROWER`S RJGHT 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 fist day pf
any month. Lender shall aexcpt prepayment on other days provided that Borrower pays interust an the amount prepaid for t(re
remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partW
prepayment, there will be no changes In the due time or in the amount of the monthly payment unless Lender agrees in willing to those
changes.
6. BORROWER'S FAILURE TO PAY
(A) We Charge lhr Dves+hm payments
If Gender has not received the full monthly payment requited by the Security Instrument. as described in Paragraph 4(
of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in t.
amount of FOUR percent ( 4.a00%) of die overdue amount of each payment .
(H) Defnit
If Borrower defaults by falling to pay in full any monthly payment, then Lender tray, except as limited by regulations pf
the Secretary in die case of payment defaults, require Immediate payment in full of the principal balance remaining due and *11
accrued d interest. Lender may choose not to exercise this option without waiving its rights in the event of arty slubscquent default In
many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment In full in the case of
FHA Fixed Rate mote
2001R -XX (0210e)(d10 Page 1 of 2 FHA Mw tate Fired Rate Nola - 10105
23991'
443 sf
CRP 12/16/2011 11:57:05 AM .PAGE 155/262 888 - 294 -5658
CAS 133 # : LOAN 1✓ .6
payment ueraults. This Note does not authorize acceleration when not permitted by HUD regulations. As uses to tills No)e.
"Secretary' means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Casts and F.rtpetues
If Lender bas required immediate payment in full, as described above, Lender may require Borrower to pay costs apd
expenses Including reasonable and customary attorneys' fees for enforcigg this Note to the extent not prohibited by applicable law.
Such fees and costs shall bear interest ftvm the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Bormwer and any other person who has obligations under this Note waive the lights of presentment and notice of dishon6r.
"Presenlm�nt" means the right to require Larder to demand payment of amounts due. "Notice of dishonor" means the fight to requf re
Lender to give notice to other persons that amounts due have not been paid.
IR GI IM OF NOTICES
Unless applicable law requires a different medhod, any notice that must he given to Borrower under this Note will be given �y
delivering it or by mailing it by first class trail to Borrower at the property address above or at a diffetrnt address if Borrower hu
given Lender a no*o of Borrowers different address.
Any notice that must be given to Leader under this Note w111 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 UNTIER 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 frill amount owed. Any person who is a guarantor, surely or endorser of this Now is also
obligated to do these things. Any person who takes over thew obligattons. Including the obligations of a guarantor. surety or endmter
of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Now against eaph
person Individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts
owed under tills Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms an covenants contained in this Note.
HAKARY TRA9R5 $eff0�'10f
(Seel)
- BeiTOwef
(Sell)
- Borrowter
- Borrower
FHA Fixed Rate Note
Zee iR•xx (02RM Page 2 or 2 FHA AWarstele Fixed Role Nole.10 B
CRPRDNRBS46a 12/16/2011 11:57:05 AM PAGE 156/262 888 - 294 -5658
E
imais3udMIAUar39
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% � A8
YN 'V3l83VW zIo )4vtie
3S nW3HInORUM
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d0 EGGAO �IHi Ol AVd
Nationstar Mortgage, LLC PRESORT
PO Box 9095 First -Class Mail
Temecula, CA 92589 -9095 U.S. Postage and
Fees Paid
WSO
7196 9006 9296 7752 7684
Send Payments to:
Nationstar Mortgage RETURN RECEIPT REQUESTED
350 Highland Drive
Lewisville, TX 75067.4177
20130619 -160
' I�111 "� "II
V 'I' I1 11 11- 111'I
BAKARY TRAORE
1007 E COOVER ST
MECHANICSBURG, PA 17055 -3420
r
PA_NOI
x
Sent Via Certified Mail
7196 9006 9296 7752 7684
06/19/2013
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortuap on your home is in default, and the lender
intends to foreclose Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
(HEMAP) may be able to help save your home. This Notice explains how the program
works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of the Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll -free at 1 -800- 342 -2397. (Persons with impaired
hearing can call 717) 780- 1869).
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N
OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
W A
PA
Page 2of8 7196 9006 9296 7752 7684
HOMEOWNER'S NAME(S): BAKARY TRAORE
PROPERTY ADDRESS: 1007 E COOVER ST
MECHANICSBURG, PA 17055
LOAN ACCT. NO.:
ORIGINAL LENDER: 'BANK OF AMERICA, N.A."
CURRENT LENDERISERVICER: Nationstar Mortgage, LLC
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR
HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you
must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end
of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF
THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling
agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date
of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for
the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one
face- to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in
this Notice (see following pages for specific information about the nature of your default). You have the right to apply
for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated
consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have
applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded
to PHFA and received within thirty (30) days of your face- to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HA YE A MEETING WITH
A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE
TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
PA
Page 3of8 7196 9006 9296 7752 7684
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A
LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,
BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANYTIME BEFORE A SHERIFF'S SALE,
THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date.)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
1007 E COOVER ST
MECHANICSBURG, PA 17055
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Next Payment Due Date: 12/01/2011
Total Monthly Payments Due: $20,367.24
Late Charges: $257.22
Other Charges: Uncollected NSF Fees: $0.00
Other Fees: $0.00
Corporate Advance Balance: $15.00
Unapplied Balance: 0.00
TOTAL AMOUNT PAST DUE: $20,639.46
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $20,639.46 PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made pavable and
sent to:
Nationstar Mortgage, LLC
350 Highland Drive
Lewisville, TX 75067 -4177
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage
in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the
lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins
PA
Page of 7196 9006 9296 7752 7684
legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the
THIRTY (30) 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 Sheriff's Sale. You may do so by paying the total amount then
past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure
sale, and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any
other requirements under the mortgag e . Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale of
the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the
actual date of the Sheriff's 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 or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Nationstar Mortgage, LLC
Address: 350 Highland Drive
Lewisville, TX 750674177
Phone Number: 1-888- 480 -2432
Fax Number: 1- 972 - 315 -6827
Contact Person: Brandon Tucker
E -Mail Address: customer .service @nationstarmail.com
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You X may or _ may not (CHECK ONE) sell or transfer your home 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 other requirements of the mortgage are satisfied
YOU MAY ALSO 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.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT
TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR)
PA_N01
Page 5of8 7196 9006 9296 7752 7684
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CAN BE LOCATED ON THE ATTACHED LIST
In accordance with the Fair Debt Collection Practices Act, Title 15, U.S.0 1692(8), you may dispute the validity of this
debt, or any portion thereof, if you do so in writing within thirty (30) days after the receipt of this notice. If you dispute
the validity of this debt, or any portion thereof, within this thirty (30) days period we will provide you with written
verification thereof, otherwise the debt will be assumed to be valid.
Sincerely,
Brandon Tucker
Foreclosure Prevention Specialist
Nationstar Mortgage, LLC
1- 877 - 783 -7491 ext. 8941035
350 Highland Drive
Lewisville, TX 75067 -4177
FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONSTAR MORTGAGE, LLC IS A DEBT
COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR
IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR
INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN
ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE
REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND
TELEPHONE NUMBER
PA
Page of8 7196 9006 9296 7752 7684
HEMAP Consumer Credit Counseling Agencies
YORK County
Report last updated: 05117/2013 01:52 PM
Advantage Credit Counseling Service/CCCS of Western PA Advantage Credit Counseling Service/CCCS of Western PA
2000 Linglestown Road 55 Clover Hill Road
Harrisburg, PA 17102 Dallastown, PA 17313
888 -511 -2227 888 -511 -2227
Base, Inc. Housing Alliance of York/Y Housing Resources
447 South Prince Street 290 West Market Street
Lancaster, PA 17603 York, PA 17401
717 - 392 -5467 717- 855 -2752
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717 -334 -1518
HC
Pagel of8 7196 9006 9296 7752 7684
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Repot last updated: 05/17/2013 01:52 PM
Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region
2000 Linglestown Road 1514 Derry Street
Harrisburg, PA 17102 Harrisburg, PA 17104
888 - 511 -2227 717 -232 -9757
Housing Alliance of York/Y Housing Resources Maranatha
290 West Market Street 43 Philadelphia Avenue
York, PA 17401 Waynesboro, PA 17268
717 -855 -2752 717- 762 -3285
PathStone Corporation PathStone Corporation
1625 North Front St 450 Cleveland Ave
Harrisburg, PA 17102 Chambersburg, PA 17201
717 -234 -6616 717 -264 -5913
PA Interfaith Community Programs Inc PHFA
40 E High Street 211 North Front Street
Gettysburg, PA 17325 Harrisburg, PA 17110
717 -334 -1518 717- 780 -3940 800 - 342 -2397
HC
Page 8of8 7196 9006 9296 7752 7684
VERIFICATION
Me McAda hereby states that he /she is Apg,,rtnnt Secretary
of Nationstar Mortgage LLC, servicing agent for Plaintiff, in this matter and is authorized to
make this Verification. The statements of fact contained in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his /her knowledge, information and
belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
Name: Olivia McA ams
DATE: f� Title: Assistant Secretary
Company: Nationstar Mortgage, LLC
S & D FILE NO: 13- 043766
Bakary Traore
FORM 1
IN THE COURT OF COMMON PLEAS OF
Nationstar Mortgage LLC : CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff(s)'
V S.
Bakary Traore C YJ
1007 East Coover Street � "CD �
c�
Mechanicsburg, PA 17055 � C
DEFENDANT
Defendants Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,
you may be able to participate in a court- supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact
MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and
request appointment of a legal representative at no charge to you. Once you have been appointed a legal
representative, you must promptly meet with that legal representative within twenty (20) days of the
appointment date. During that meeting, you must provide the legal representative with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal representative
will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the
Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your
lender in an attempt to work out reasonable arrangements with your lender before the mortgage
foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for
the appointment of a legal representative. However, you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
SHAPIRO & DeNARDO, LLC
Date ttorneys for Plaintiff
CAITLIN M. DONNELLY, E
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household How Long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household How Long?
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 ❑ No ❑
If yes, provide names, location of court, case number & attorney
Assets Amount Owed Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount Owed: Value:
Automobile #2: Model: Year:
Amount Owed: Value:
Other transportation (automobiles, boats, motorcycles). Model:
Year: Amount Owed: Value:
Monthly Income:
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: Please only include ex enses vou are currently a in
EXPENSE AMOUNT EXPENSE AMOUNT
Mortage 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 Su ort/Alim. Spending Mone
Day /Child Care /Tuft. 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 delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, 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 m financial situation for possible mortgage options. I /We
understand that I/We am/are under no obligation to use the services provided by the
above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting
documentation
(hardship letter)
Listing agreement (if property is currently on the market)
FORM 3
IN THE COURT OF COMMON PLEAS OF
Nationstar Mortgage LLC CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS.
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
DEFENDANT
Defendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this
mortgage foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court- supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel /Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
y
FORM 4
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s) Civil
CASE MANAGEMENT ORDER
AND NOW, this day of , 20, the defendant/borrower in the
above - captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court- supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendantiborrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the time
frame set forth herein or such other date as agreed upon by the parties in writing or
ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
J l
3. The defendant /borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone during
the course of the Conciliation Conference. The representative of the plaintiff /lender
who participates in the Conciliation Conference must possess the actual authority to
reach a mutually acceptable resolution, and counsel for the plaintiff /lender must
discuss resolution proposals with the authorized representative in advance of the
Conciliation Conference. If the duly authorized representative of the plaintiff /lender is
not available by telephone during the Conciliation Conference, the Court will schedule
another Conciliation Conference and require the personal attendance of the authorized
representative of the plaintiff /lender at the rescheduled Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson t.r`x ' IC,
Sheriff I bit_. RO HONC T
comb
Jody ssmith 2014 FEB 28 Pt9 3 3g
Chief Deputy
Richard W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
Nationstar Mortgage LLC Case Number
vs.
Bakary Traore(et al.) 2014-980
SHERIFF'S RETURN OF SERVICE
02/24/2014 01:07 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: Bakary
Traore at 1007 East Coover Street, Mechanicsburg Borough, Mechanicsb g, PA 17055.
tier 401,
• N G ALL, DEPUTY
02/24/2014 01:07 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 handing
a true copy to a person representing themselves to be Bakary Traore, Owner,who accepted as"Adult
Person in Charge"for Occupant at 1007 East Coover Street, Mechanicsburg Borough, Mechanicsburg,
PA 17055.
"' !GUT DEPUTY
SHERIFF COST: $55.30 SO ANSWERS,
February 25, 2014 RONNY R ANDERSON, SHERIFF
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 '
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
PLAINTIFF
VS.
Bakary Traore
DEFENDANT
T110/YiAh
OM 09
PENNsihT4C4N
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-980-Civil
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $169,518.82 in favor of the Plaintiff and
against the Defendant, for failure to file an answer to Plaintiffs Complaint in Mortgage
Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and
calculated as stated in the Complaint:
Principal of Mortgage Debt Due and Unpaid
Interest Accrued
Late Charges
Escrow Advances
Property Inspection
Attorney Fees & Costs of Foreclosure
TOTAL
BY:
B
AND NOW, judgment is entered in favor
damages are assessed as above in the sum of $169,
• 0
aintiff an
.82.
13-043766
$143,137.42
$16,997.40
$0.00
$7,903.95
$81.30
$1,398.75
$169,518.82
QUIRE Attorney for Plaintiff
ains ant and
oyvt4 p
CLH/(1619c/d_i
9057,
" /Vai,Jed
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
350 HIGHLAND DRIVE CUMBERLAND COUNTY
Lewisville, TX 75067
PLAINTIFF 14 -980 -Civil
VS.
Bakary Traore
DEFENDANT(S)
STATE OF: Pennsylvania
COUNTY OF: Montgomery
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen
years and competent to make this affidavit and the following aveitnents are based upon
information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that
the above captioned Defendants last known address is as set forth in the caption and they are
not to the best of our knowledge, information or belief, in the Military or Naval Service of the
United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended.
Date:
Sworn to and subscribed
before me this 1. day
, 2014.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Denise L. Semetti, Notary Public
Upper Merlon Twp., Montgomery County
My Commission Expires July 22, 2014
Member, Pennsylvania Association of Notaries
BY:
SHAPIRO & DeNARDO, LLC
Department of Defense Manpower Data Center
Results as of : May -09-2014 05:24:19 AM
SCRA 3.0
Sta deport
Purs t'to &Mc= Civil Relief Act
Last Name: TRAORE
First Name: BAKARY
Middle Name:
Active Duty Status As Of: May -09-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA, `�` .%" r
•. --''''.. Na ✓
NA
This response reflects the Individuals' active duty status based on the Active Duty Status Date
t
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
/` �� .NA - 4 _- `;
- _ } .. No
NA
This response reflects where the individual left active defy' status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Cat -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification Enid. Date
Status
Service Component
NA
N' NA . i' \\,. . •
.;,tt No ... 1
NA
This response reflects whether the individual or:his/herunit has received early notification to report for active duty
•
Upon searching the data banks of the Department of Defense M power 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.
r�-
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: 09BB2298C0C5Y60
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 14 -980 -Civil
Bakary Traore
DEFENDANT
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe
for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their
attorney of record, if any, after the default occurred and at least (10) days prior to the date of
the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice
attached hereto, April 29, 2014 to the following Defendants:
Bakary Traore, 1007 East Coover Street, Mechanicsburg, PA 17055
Lig
Meghan Williams, Legal Assistant
to Christopher A. DeNardo, Esquire for
Shapiro & DeNardo, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO, 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
CUMBERLAND COUNTY
VS.
Bakary Traore
DEFENDANT
NO: 14 -980 -Civil
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Bakary Traore
DATE OF NOTICE: April 29, 2014
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 notice to a
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:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO lilts FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en,estado de rebeldia por no haber tornado la accion requirida de su parte
en este caso, Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha
de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar
preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos
importantes. Debe lievar esta notificacion a un abogado imrnediatamente. Si usted no tiene
abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a
la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir
assitencia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR MAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
BakaryTraore, 1007 East Coover Street, Mechanicsburg, PA 17055
Date: tt-99i
BY:
SHAPIRO & DeNARDO, LLC
ys for P ain
. DONNELLY, ESQL
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Bakary Traore
DEFENDANT NO:14-980-Civil
CERTIFICATE OF SERVICE
I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first
class mail, postage prepaid, true and correct copies of the attached papers upon the following
person(s) or their attorney of record:
Bakary Traore, 1007 East Coover Street, Mechanicsburg, PA 17055
Date Mailed:
Date:
BY:
SHAPIRO & DeNARDO, LLC
neys for Plainti
OSBORNE, ESQUIRE
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Bakary Traore
DEFENDANT NO:14-980-Civil
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
Nationstar Mortgage LLC
350 HIGHLAND DRIVE
Lewisville, TX 75067
and that the last known address of the judgment debtor (Defendant) is:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Date:
13-043766
BY:
SHAP
0 & DeNARDO, LLC
s for Plaintiff
BRAD ° ". ' •SBO", ESQUIRE
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
TO: Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Nationstar Mortgage LLC
PLAINTIFF
VS.
Bakary Traore
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14 -980 -Civil
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Default
[ ] Judgment for Possession
[ ] Judgment on Award of Arbitration
[ ] Judgment on Verdict
[ ] Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY BRADLEY J OSBORNE AT (610)278-6800.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Nationstar Mortgage LLC
PLAINTIFF
vs.
Bakary Traore
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
() Confessed Judgment
() Other / 7, 96e..)
File No.
Amount Due $169,518.82 -
Interest May 1, 2014 to Septembe 2074
is $2,779.69
Atty's Comm .(> ND
Costs
7-'3 Lid
CD I
err `CDr
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pend ns against real estate of the
defendant(s) described in the attached exhibit.
6-q\L\
Date:
asodisOspd
Io3.7s <<
(p.Sc"
if
1,
Signature:
Print Name:
Address: 360 Horizon Drive, Suite 150
ng of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 312169
Osborne
)1/t -e
Cu Pio1 qy&a
196S7�2.
i
ALL THAT CERTAIN lot or piece of ground situate In Mechanicsburg Borough, County of
Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the Northern line of Coover Street at the corner of Lot No. 60 on the
hereinafter mentioned plan of lots; thence along the dividing line between Lots Nos. 60 and 61
North 22 degrees 47 minutes West, 134 feet, more or less, to a point; thence by the dividing line
between Lots No. 54 and 61, North 66 degrees 43 minutes East, 80 feet to a point; thence by the
dividing line between Lots No. 61 and 62. South 22 degrees 47 minutes East, 134 feet, more or
less, to a point on the Northern line of Coover Street; thence by the Northern line of Coover
Street, South 66 degrees 43 minutes West, 80 feet to a point, the place of BEGINNING.
HAVING thereon erected a one-story brick dwelling house and carport, being known and
numbered as 1007 E Coover Street, Mechanicsburg, Pennsylvania.
BEING Lot No. 61 on the Plan of Lots known as Orchard Crest -Section B, which said Plan is of
record In the Cumberland County Recorder's Office in Plan Book 10, Page 24.
SUBJECT to all restrictions, reservations end easements of record.
PARCEL No. 17-23-0561-053
BEING the same premises which Estate of Mae F. Murray, deceased, by Mary Patrice Keener,
Executrix of the estate of Mae F. Murray, by Deed dated January 29, 2010 and recorded March
3, 2010 in the Cumberland County Recorder of Deeds office as Deed Instrument No. 201005425,
granted and conveyed unto Bakary Traore, an unmarried adult individual.
43, SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO,
ESQUIRE, ATTORNEY LD. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE,
ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D.
NO. 312169
CHANDRA M. ARKEMA, ATTORNEY
I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
PLAINTIFF
VS.
Bakary Traore
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
CASE NO. 14 -980 -Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
Nationstar Mortgage LLC, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 1007 East Coover Street, Mechanicsburg, PA 17055.
1. Name and address of Owner(s) or Reputed Owner(s)
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
2. Name and address of Defendant in the judgment:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Nationstar Mortgage LLC
350 HIGHLAND DRIVE
Lewisville, TX 75067
4. Name and address of the last recorded holder of every mortgage of record:
Nationstar Mortgage LLC
350 HIGHLAND DRIVE
Lewisville, TX 75067
5. Name and address of every other person who has any record lien on the property:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
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:
TENANT OR OCCUPANT
1007 East Coover Street
Mechanicsburg, PA 17055
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
BY:
13-043766
SHARO & DeNARDO, LLC
ey J Osborne
SHAPIRO & DeNARDO, LLC 204
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY LD. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY LD. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
PLAINTIFF
VS.
Bakary Traore
DEFENDANT
1/3
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 14 -980 -Civil
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Your house (real estate) at:
1007 East Coover Street, Mechanicsburg, PA 17055
17-23-0561-053
is scheduled to be sold at Sheriffs Sale on September 3, 2014 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00AM to enforce the court judgment of $169,518.82 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 back to Nationstar Mortgage LLC the amount of the
judgment plus costs or the back payments, late charges, costs, and reasonable attorney's
fees due. To find out how much you must pay, you may call: (610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
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 on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610)278-6800.
6. 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.
7. 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 717-240-6390.
8. 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.
9. 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.
10. 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 no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
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 date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
13-043766
ALL THAT CERTAIN lot or piece of ground situate In Mechanicsburg Borough, County of
Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the Northern line of Coover Street at the corner of Lot No. 60 on the
hereinafter mentioned plan of lots; thence along the dividing line between Lots Nos. 60 and 61
North 22 degrees 47 minutes West, 134 feet, more or less, to a point; thence by the dividing line
between Lots No. 54 and 61, North 66 degrees 43 minutes East, 80 feet to a point; thence by the
dividing line between Lots No. 61 and 62. South 22 degrees 47 minutes East, 134 feet, more or
less, to a point on the Northern line of Coover Street; thence by the Northern line of Coover
Street, South 66 degrees 43 minutes West, 80 feet to a point, the place of BEGINNING.
HAVING thereon erected a one-story brick dwelling house and carport, being known and
numbered as 1007 E Coover Street, Mechanicsburg, Pennsylvania.
BEING Lot No. 61 on the Plan of Lots known as Orchard Crest -Section B, which said Plan is of
record In the Cumberland County Recorder's Office in Plan Book 10, Page 24.
SUBJECT to all restrictions, reservations end easements of record.
PARCEL No. 17-23-0561-053
BEING the same premises which Estate of Mae F. Murray, deceased, by Mary Patrice Keener,
Executrix of the estate of Mae F. Murray, by Deed dated January 29, 2010 and recorded March
3, 2010 in the Cumberland County Recorder of Deeds office as Deed Instrument No. 201005425,
granted and conveyed unto Bakary Traore, an unmarried adult individual.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suitel00 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
NATIONSTAR MORTGAGE LLC
Vs.
BAKARY TRAORE
WRIT OF EXECUTION
NO 14-980 Civil Term
CIVIL ACTION — LAW
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: $169,518.82 L.L.: $.50
Interest MAY 1, 2014 TO SEPTEMBER 3, 2014 1S $2,779.69
Atty's Comm: Due Prothy: $2.25
Atty Paid: $204.05 Other Costs:
Plaintiff Paid:
Date: 5/12/14 j4iir.zL.ITb0
(Seal)
REQUESTING PARTY:
Name: BRADLEY J. OSBORNE,.ESQUIRE
Address: SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 312169
David D. Buell, Prothonotary 62-P
Deputy
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,
ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE,
ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO.
312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO.
203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
PLAINTIFF
VS.
Bakary Traore
DEFENDANT
THE
F L[.I3- F F1(
OF E PR0`CH0 0 TA: -:Y
2014 AUG 1 PM 2: 36
CUMBERLPENNSYLV COUNTY A
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:14-980-Civil
CERTIFICATION OF NOTICE TO LIENHOLDERS
PURSUANT TO PA R.C.P 3129.2 (C) (2)
I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff,
Nationstar Mortgage LLC, hereby certify that Notice of Sale was served on all persons appearing on
Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of
Mailing on July 11, 2014, the originals of which are attached and that each of said persons appears
on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1.
The undersigned understands that the statements herein are subject to the penalties provided
by 18 P.S. Section 4904.
Date:
13-043766
SHAD IRO & DENARDO, LLC
2-6VX By:
Meghan Williams
Legal Assistant
U.S. POSTAGE» PITNEY BOWES
�ila,�®
Name and Address of Sender
Shapiro & DeNardo, LLC
3600 Horizon Drive
Suite 150
King of Prussia, PA 19406
Check type of mail or service:
0 Certified 0 Recorded Delivery (International)
0 COD 0 Registered
❑Delivery Confirmation 0 Retum Receipt for Merchandise
0 Express Mail 0 Signature Confirmation
0 Insured
Affix Stamp Here
(If issued as a„..%:;„4„-
certificate of mailing,
or for additional
copies of this bill)
postmark and i
Date of Receipt
.1.,:;,_••••,. ` i �
' ”
L 15'"
'� ' • '� �`.
~®
���"'111"' •
ZIP ; ry406 001 .41 O
0001387362 JUL. 11. 2014
Article Number
Addressee (Name, Street, City State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
RR
Fee
1.
13-043766 MW
Cumberland County
13 North Hanover
Carlisle, PA 17013
Tenant or Occupant
1007 East Coova
Mechanicsburg,
PA Department
Bureau of Compliance
P.O. Box 281230
.rrisburg, PA
Domestic Relations
Street
Street
PA 17055
of Revenue
17128-1230
-.
2.
3
4.
f
8
-t /
,
C.
BiN5.
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8
�ery Confirmation
Ignature Confirmation
ipecial Handling
II -T-)
aJ
al
6.
j
H
7.
8.
✓
T.
IA•rr
Total Number of Pieces
Listed by Sender 3
Total Number of Pieces
Received at Post Office
Postmaster, Per
(Namf reciting employee)
/
See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 1 of 1)
o tete by Typemtrifer, Ink or Ball Point Pen
...
,' , • I-1 .
SHAPIRO & DeNARDO, LLC
"I 1-11 0
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO '.7S447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 " SEP -8 0„
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 GUN ' " 2' 16
BERL A
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 PENNsN y u couNry
3600 HORIZON DRIVE, SUITE 150 LVANIA
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
350 HIGHLAND DRIVE
Lewisville, TX 75067
PLAINTIFF
VS.
Bakary Traore
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
14 -980 -Civil
Notice of the Date of Continued Sheriffs sale
The Sheriffs Sale scheduled for September 3, 2014 at 10:00 AM in the above -captioned matter
has been continued until November 5, 2014.
Date:
BY:
SHAPIRO & DeNARDO, LLC
Atto ys for Plaintiff
ft J.ESQUIRE
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
vs. CUMBERLAND COUNTY
Bakary Traore
DEFENDANT(S)
NO:14-980-Civil
CERTIFICATE OF SERVICE
I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first
class mail, postage prepaid, true and correct copies of the attached papers upon the following
person(s) or their attorney of record:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Date: 9-,, //
BY:
SHAPIRO & DeNARDO, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78441:!;
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC
350 HIGHLAND DRIVE
Lewisville, TX 75067
PLAINTIFF
VS.
Bakary Traore
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
14 -980 -Civil
Notice of the Date of Continued Sheriffs sale
The Sheriffs Sale scheduled for November 5, 2014 at 10:00 AM in the above -captioned matter
has been continued until January 7, 2015.
Date: 11/3//11
BY:
SHAPIRO & DeNARDO, LLC
Attys for Plaintiff
BRADLEY J. OSBORNE, ESQ.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169
CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437
LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 13-043766
Nationstar Mortgage LLC COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
vs. CUMBERLAND COUNTY
Bakary Traore
DEFENDANT(S) NO:14-980-Civil
CERTIFICATE OF SERVICE
I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first
class mail, postage prepaid, true and correct copies of the attached papers upon the following
person(s) or their attorney of record:
Bakary Traore
1007 East Coover Street
Mechanicsburg, PA 17055
Date: 11131N BY:
SHAPIRO & DeNARDO, LLC