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HomeMy WebLinkAbout14-2334 t For Prothonotary Use Only: supreme 0ourt_,wf Pennsylvania co U "on P lea s I it s rr ,�r�1 et. r' ' ' Docket No. Cumberla nd w';33q 0 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S : Complaint 9 Writ of Summons 9 Petition E 9 Transfer from Another Jurisdiction 9 Declaration of Taking C Lead Plaintiffs Name: Nationstar Mortgage LLC Lead Defendant's Name: Amy N. Eppley T I Are there money damages requested? 9 Yes : No Dollar Amount Requested: 9 within arbitration limits 0 (check one) 9 outside arbitration limits N Is this a Class Action Suit? 9 Yes : No Is this an MDJ Appeal? 9 Yes = No A Name of Plaintiff /Appellant's Attorney: McCabe Weisberg & Conway, P.C. 9 Check here if you have no attorney (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 9 Intentional 9 Buyer Plaintiff Administrative Agencies 9 Malicious Prosecution 9 Debt Collection: Credit Card 9 Board of Assessment 9 Motor Vehicle 9 Debt Collection: Other 9 Board of Elections 9 Nuisance 9 Department of Transportation 9 Premises Liability (does not include 9 Statutory Appeal: Other S mass tort) E 9 Slander/Libel/ Defamation 9 Employment Dispute: 9 Other: Discrimination C 9 Employment Dispute: Other 9 Zoning Board . 9 Other I. O 9 Other MASS TORT N 9 Asbestos 9 Tobacco 9 Toxic Tort - DES 9 Toxic Tort - Implant MISCELLANEOUS B 9 Toxic Waste REAL PROPERTY 9 Ejectment 9 Common Law /Statutory Arbitration 9 Other: 9 Eminent Domain /Condemnation 9 Declaratory Judgment 9 Ground Rent 9 Mandamus 9 Landlord/Tenant Disput 9 Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 9 Mortgage Foreclosure: Commercial 9 Quo Warranto 9 Dental 9 Partition 9 Replevin 9 Legal 9 Quiet Title 9 Other: 9 Medical 9 Other: 9 Other Professional: Updated 1/1/2011 McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 �= CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 -0X �• -- BRIAN T. LAMANNA, ESQUIRE - ID # 310321 rn i= ANN E. SWARTZ, ESQUIRE - ID # 201926 � ate JOSEPH F. RIGA, ESQUIRE - ID # 57716 -•- -� JOSEPH L FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109.. (215) 790 -1010 Nationstar Mortgage LLC Cumberland County 350 Highland Drive Court of Common Pleas Lewisville, TX 75067 /� Number (4- cWq (.�iv o 1 Term V. Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 and Eugene R. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 COMPLAINT IN MORTGAGE FORECLOSURE 4103,T5 PA ATN #1 1 33o q 30 '� 5q l File # 75605 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisioner de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. 1NFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, Pennsylvania 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990 -9108 File # 75605 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Nationstar Mortgage LLC, duly organized and doing business at the above - captioned address. 2. The Defendant is Amy N. Eppley, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 70 North Conley Lane, Etters, Pennsylvania 17319. 3. The Defendant is Eugene R. Eppley, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 70 North Conley Lane, Etters, Pennsylvania 17319. 4. On March 31, 2006, Amy N. Eppley, and Eugene R. Eppley, mortgagors, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean & Whitaker Mortgage Corp., its Successors and Assigns which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1945, Page 1739 ( "the Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. On August 6, 2013, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean & Whitaker Mortgage Corp., its Successors and Assigns to Nationstar Mortgage, LLC, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201330489, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 1109 West Trindle Road, Carlisle, Pennsylvania 17013. File # 75605 Page 3 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $ 97,118.82 Interest through February 20, 2014 $ 6,891.76 (Plus 16.63 per diem thereafter) Corporate Advance $ 766.00 Escrow Advance $2,154.48 GRAND TOTAL $ 106,931.06 9. Plaintiff complied with all notice requirements as prescribed by 41 P.S. §101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of 106,931.06 together with interest at the rate of 16.63 diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG & CONWAY, P.C. BY: ] Terrence J. McCabe, Esquire -1arc S. Weisberg, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire Attorneys for Plaintiff RE: / Property Address: 1109 West Trindle Road, Carlisle, Pennsylvania 17013 FILE #: 75605 File # 75605 Page 4 VERIFICATION Albert Nguende hereby states that he /she is Assistant Sec retary of Nationstar Mortgage LLC, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. O �C9 r��I t� DATE: V� 1 H O c, 2v� uen Name: Albert Ng e Title: Assistant Secretary File #: 75605 Name: Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley File # 75605 Page 7 (Page 21 of 29) • , ,. First American Title Insurance Company I::e�l�lt rrArr Commitment Number: 06065 t l SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the Northern side of the Trindle Springs Road and at the corner of land now or formerly of John Leppard and Wife; thence by the latter land, North 8 degrees 30 minutes East, 264.55 feet to a post on the Southern side of a 20 foot alley; thence by the latter, North 80 degrees 40 minutes West, 115 feet, more or less, to a stake at land now or formerlyof James Albert Robinson and Wife; thence by the latter land, in a Southerly direction, 250.78 feet to a stake on the Northern side of the Trindle Springs Road; thence by the latter, South 83 degrees 20 minutes East, 94 feet, more or less, to the post at the place of Beginning. SUBJECT, however, to the right of James Albert Robinson and Mabel Sarah Robinson, their heirs and assigns to use the Eastern 8.5 feet strip of the above described land as a driveway, in common with the grantees, their heirs, and assigns, to reach the said 20 foot wide alley in the rear. Being improved with a two and one -half story frame dwelling house, frame chicken house and other outbuildings. BEING all of Lot No. 39, the Eastern 31 feet of Lot No. 40 and part of the Alley to the rear of said Lots, said alley having been moved Northward 14.55 feet by James Albert Robinson and Mabel Sarah Robinson, owners of the land on bothside of said alley; the aforementioned Lots being those as shown on the John L. Glass Plan of Lots as recorded in the office of the Recorder of Deeds in and for Cumberland County in Plan Book No. 3, Page 73. BEING also subject to the restrictions that nothing shall be erected within 25 feet of the North line of the Trindle Springs Road. BEING the same premises which Larry E. Carter and Janet A. Carter by their deed dated January 14, 1994 and recorded in the Recorder of Deeds Office in and for Cumberland County in Book T -36, Page 447 granted and conveyed unto Eva Chance and Debra A. Sturtz. ALTA Commitment Schedule C (06065/06065/15) FORM 1 rn _T Nationstar Mortgage LLC IN THE COURT OF COMMON PLEA Plaintiff CUMBERLAND COUNTY, PENNSYL IA-.J ': —Icy vs. C - r) L �A 2 T. S A 7j. C— r r Amy N. Eppley and Eugene R. Eppley 14 a35q Civil `1 rn 4 ' r Defendants 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: Date ISignature of Counsel for Plaintiff] This is a communication from a debt collector. 75605 This letter maybe an attempt to collect a debt and any information obtained will be used for that purpose. Pagc i 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: CUSTOM ER/PRIMARNAPPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? CO- Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? INFORMATION FINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile 41: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2n Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements I Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 r.! c:iJ-(�r r �r THE: PROTHONOTARY 2lliti MAY 19 PM 3: 33 CUMBERLAND COUNTY PENNSYLVANIA McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14-2334 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above -captioned matter. McCABE SBERG BY: �ff/I [ ] Terren J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff CONWXY P.C. [-tMarc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. c.0.2,1-613 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY u r A. J1 411/1'1' 1411/i'r 28 PM 2: 5 CUMBERLAND COUNTY PENNSYLVANI Nationstar Mortgage LLC vs. Case Number Amy N. Eppley (et al.) 2014 -2334 SHERIFF'S RETURN OF SERVICE 04/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Amy N. Eppley, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Eugene R Eppley, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/29/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Amy N. Eppley, personally, at 70 North Conley Lane, Etters, PA 17319. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 04/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Amy N. Eppley, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 1948 W. Trindle Road, n /k/a 1948 W. Trindle Road, Carlisle, PA 17013. Residence is vacant. 04/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Eugene R Eppley, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as Not Found" at 1948 W. Trindle Road, n /k/a 1948 W. Trindle Road, Carlisle, PA 17013. Residence is vacant. 05/12/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within named Defendant Eugene R Eppley, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 05/20/2014 04:58 PM - Deputy Dawn Kell, 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 Traci Miller, Girlfriend, who accepted as "Adult Person in Charge" for Eugene R Eppley at 584 Gutshall Road, Monroe Township, Boiling Springs, PA 17007. DAWN KELL, DEPUTY SHERIFF COST: sQG.S8 SO ANSWERS, May 21.2014 R ANDERSON, SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations NATIONSTAR MORTGAGE LLC vs. AMY N. EPPLEY (et al.) PETER J. MANGAN, ES Solici Richard E Rice Chief Deputy, Administrate Case Number 14 -2334 CIVIL SHERIFF'S RETURN OF SERVICE 04/29/2014 07:19 PM - DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: AMY N. EPPLEY AT 70 NORTH CONLEY LANE, ETTERS, PA 17319. OD#1,4%. D STA N L, DEPUTY 05/12/2014 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: EUGENE R. EPPLEY, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED NOTICE AS "NOT FOUND" AT 70 NORTH CONLEY LANE, ETTERS, PA 17319. DEFT. NEWADDRESS IS 584 GUTSHALL ROAD, BOILING SPRINGS PA. SHERIFF COST: $83.76 SO RS, RICHA D P KEUERLEBER, 13, 2014 NOTARY Affirmed and subscribed to before me this 13TH day of MAY 2014 d UERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shi>.la E. Cook, Notary Public city of York, York County Div '_o rnission Ex'ires Feb. 1, 2017 '`��1: pE ;;;Ni :CANIA ASSOCIATION OF NOTARIES McCABE, WEISBERG AND CONWAY, P.C. 8Y: TERRENCE J. McCABE, ESQUIRE -1D # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants Attorneys for Plaintiff OF.. 11` P Q HO Zl�I�,JUL _ ��`�TA��'r CUMSERL ANp PENNS YLVANIANT Y CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2334-CivilTerm ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants, Amy N. Eppley and Eugene R. Eppley, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount Due Interest from 02/21/14 to 06/27/14 Total AND NOW, this $ 106,931.06 $ 2,112.01 $ 109,043.07 McCABE, WE 1 ERG & CON BY: AY, P.C. [ ] Terrence J. McC. e [ ] Edward D. Co ay, sq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff q. Marc S. Weisberg, Esq. Margaret Gairo, Esq. Heidi R. Spivak, Esq. Christine L. Graham, Esq. Ann E. Swartz, Esq. Joseph I. Foley, Esq. Jennifer L. Wunder, Esq. Carol A. DiPrinzio, Esq. kl day of , 2014, Judgment is entered in favor of Plaintiff, Nationstar Mortgage LLC, and against Defendants, Amy N. Eppley and Eugene R. Eppley, in rem only and not in damages are assessed in the amount of $109,043.07, plus inter and BY THEAOTH ersonam, and CILA a 1 ct 159_ .+3111d7s Ivo hce Department of Defense Manpower Data Center Results as of : Jun -27-2014 06:34:27 AM SCRA 3.0 Status Rept Pursuant to Senficementhers Civil Relief Act Last Name: EPPLEY First Name: AMY Middle Name: Active Duty Status As Of: Jun -27-2014 On Active Duty On Active Duty Status Date Active Duty Start Date NA Active Duty End Date Status Service Component NAf • No', NA This response reflects the individuals' active duty status beset on the Aitive Duty Status Date Left Active Duty Within 367 Da a of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 1':"u 'NA _ r y ,- '-.No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Hor Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Statue Service Component NA : NA ; '\. .' • ,No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower, Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOM, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 wiw`,IC41114,Phow, 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 fall 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: VA860DAE40827F0 Department of Defense Manpower Data Center Results en of : Jun -27-2014 06:34:33 AM SORA 3.0 Status Report Pursuant to Senricemembers Civil Relief Act Last Name: EPPLEY First Name: EUGENE Middle Name: Active Duty Status As Of: Jun -27-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Steles Service Component NA NA '' _ ' ...'"' . No ' A, NA This response reflects the individuals' active duly status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Statue Service Component NA , r" ' No . NA This re posse reflects tihereihe Individual left active duly status within367days preceding the Active Duty Status Date 1 The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA , r" ' No . NA _ ,... This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of ,....... . - the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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: UAU7ZD7EU082T20 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2334-CivilTerm AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Amy N. Eppley and Eugene R. Eppley, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendants, Amy N. Eppley and Eugene R. Eppley, are over eighteen (18) years of age, and reside as follows: Amy N. Eppley, 70 North Conley Lane Etters, PA 17319 SWORN AND SUBSCRIBED BEFORE ME THIS 21 DAY OF JLxv.l , 2014 Eugene R. Eppley, 584 Gutshall Road Boiling Springs, PA 17007 McCABE, WEISBERG & CO WAY, P.C. BY: [ ] Terrence J. M:e sq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [.Q] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. McCABE, WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2334-CivilTerm AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last -known mailing addresses of the Defendants are: Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 SS. Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 SWORN AND SUBSCRIBED McCABE, WEISBERG & CONWAY, P.C. BEFORE ME THIS 2:7 DAY OF J i' VZ , 2014 .�t� ti N TARP PUBLIC BY: [ ] Terrence J. • • , Esq. [] [l [] [ [] [ Attorneys for Plaintiff GOMMOW ALTH OF PENNSYLVANIA NOTARIAL SEAL HOPE KWIATKOWSKI, Notary Pubic City of Philadelphia, Phila. County In scion Expires January 2, 2018 Edward D. Conway, Esq. Andrew L. Markowitz, Esq. Marisa J. Cohen, Esq. Brian T. LaManna, Esq. Joseph F. Riga, Esq. Celine P. DerKrikorian, Esq. Lena Kravets, Esq. [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff V. Amy N. Eppley and Eugene R. Eppley Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2334-CivilTerm CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS 2:7 DAY McCABE, WEISBERG & CONWAY, P.C. BY: OF si Y14. , 2014 [ ) [ NOTARY PUBLIC COMIONWEALIN Of PENNSYLVANIA NOTARIAL SEAL HOPE KWIATKOWSKI. Notary Public C* of Philadelphia. Phila. County My Conm*ssion Expires Angela 2018 ] Terrence J. a Esq. ] Edward D. Conway, Esq. ] Andrew L. Markowitz, Esq. ] Marisa J. Cohen, Esq. ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff arc S. Weisberg, Esq. [ Margaret Gairo, Esq. [] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [yo] Jennifer L. Wunder, Esq. [ Carol A. DiPrinzio, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. Mc a. , E [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley Cumberland County; Number: 14-2334-CivilTerm [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [I Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 June 11, 2014 To: Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 Nationstar Mortgage LLC vs. Amy N. Eppley Eugene R. Eppley Cumberland County Court of Common Pleas Number 14-2334-CivilTerm NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. You SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990.9108 mce NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 FOR ABOOADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y LISTED PODRJA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACIbN ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff -1-Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 June 11, 2014 To: Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 Nationstar Mortgage LLC vs. Amy N. Eppley Eugene R. Eppley Cumberland County Court of Common Pleas Number 14-2334-CivilTerm NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TOPROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 mce McCABE, WEISBERG AN BY: (VC. NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO, AL NO TOMAR LA ACCION DEBIDA DENTRO IDE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BI ENES U OTROS DERECHOS IMPORTANTES, USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACI6N ACERCA DE EMPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON I NFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 CONWAY, P.C. I tic., [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff ]-c S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-23 3 4-C ivilTerm NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been etred inaaboceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-2334-CivilTerm NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary teb X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 14-2334-CivilTerm Civil Term Nationstar Mortgage LLC v. AMOUNT DUE: $109,043.07 Amy N. Eppley and Eugene R. Eppley TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, 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. INTEREST: from 06/28/14 $2,849.28 at $17.92 ATTY'S COMM.: COSTS: PRAECIPE FOR EXECUTION Issue writ or 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) 1109 West Trindle Road, Carlisle, Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT 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 garnishce(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: McCABE, WEISBERG & CONWAY, P.C. �W1 BY: [ ] Terrence J. MCabe, Esq. [ ] Marc S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Aim E. Swartz, Esq. ] Joseph I. Foley, Esq. ] Jennifer L. Wunder, Esq. ] Carol A. DiPrinzio, Esq. Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. / 7 1/ /'6> 4.1.8.50 PD PTlN qs.5(, CRF Ib3./5 " H. "75 " Ili"50 " -1/456. b((- #a.as com b 5o Ll. elle/Q9-14 pP3o853j RE X1,64 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-23 34-C ivi ]Tenn AFFIDAVIT PURSUANT TO RULE 3129.1 (77 rn The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1109 West Trindle Road, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Amy N. Epply Eugene R. Epply 2. Name and address of Defendants in the judgment: Name Amy N. Eppley Address 70 North Conley Lane Etters, Pennsylvania 17319 584 Gutshall Road Boiling Springs, Pennsylvania 17007 Address 70 North Conley Lane Etters, Pennsylvania 17319 Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein MERS, INC., AS NOMINEE FOR TAYLOR, BEAN AND WHITAKER MORTGAGE CORP MERS, INC., AS NOMINEE FOR TAYLOR, BEAN AND WHITAKER MORTGAGE CORP Address 1417 North Magnolia Avenue Ocala, Florida 34475 P.O. Box 2026 Flint, Michigan 48501 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 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: Name Address Tenants/Occupants 1109 West Trindle Road Carlisle, Pennsylvania 17013 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Depai tuient #280601 Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compl iance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name NONE Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 51 1 1 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 1 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 of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. HDATE McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. c S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Hsci. [ 1 Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ 1 Brian T. LaManna, Esq. [ ) Ann E. Swartz, Esq, [ ] Joseph F. Riga, Esq. [ ] Joseph 1. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ 1 Jennifer L. Wunder, Esq. [ 1 Lena Kravets, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley Cumberland County; Number: 14 -2334 -Civil Term McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2334-CivilTerrn NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 Your house (real estate) at 1109 West Trindle Road, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $109,043.07 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 Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Nationstar Mortgage LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 also be able to stop the sale through other legal proceedings. 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 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 McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2334-CivilTerm NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 Your house (real estate) at 1109 West Trindle Road, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $109,043.07 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 canceled if you pay to Nationstar Mortgage LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by fling 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 also be able to stop the sale through other legal proceedings. 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 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 McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE T() PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net NATIONSTAR MORTGAGE LLC Vs. NO 14-2334 Civil Term CIVIL ACTION — LAW AMY N. EPPLEY and EUGENE R. EPPLEY WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $109,043.07 L.L.: $ .50 Interest from 6/28/14 @ $17.92 -- $2,849.28 Atty's Comm: Due Prothy: $2.25 Atty Paid: $256.06 Other Costs: Plaintiff Paid: Date: 7/16/14 1,,,,„,C6 1de David D. Buell, Prothonotar (Seal)`. REQUESTING PARTY: Name: MARC S. WEISBERG, ESQUIRE Address: McCABE, WEISBERG & CONWAY, P.C. 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17610 Deputy M cCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2334-CivilTerm AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 29th day of October, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129.1 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED OF A BEFO ME THIS 2014 DAY AFI 411111NIVA ALA OTARY P J U I i 0 T. .•z 'ENNSVI., IA NOTARIAL SEAL BARBARA. J. MOYER, Notary Public City of Philadelphia, Phila. County Commission ,,,, :. 12 2018 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J cCabe, Esquire [ ] Edward . Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff [ ] Marc S. Weisberg, Esquire ,[/]Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire 2. Name and address of Defendants in the judgment: Name Address Amy N. Eppley 70 North Conley Lane Etters, Pennsylvania 17319 Eugene R. Eppley 584 Gutshall Road Boiling Springs, Pennsylvania 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Taylor, Bean & whitaker Mortgage 1417 North Magnolia Avenue Corp. Ocala, Florida 34475 "MERS" Mortgage Electronic P.O. Box 2026 Registration System, Inc. Flint, Michigan 48501 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 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: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Address 1109 West Trindle Road Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 171.28-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address NONE I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence . McCabe, Esq. [ ] Edward . Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Re: Nationstar Mortgage LLC v. Amy N. Eppley. et al. Cumberland County; Number: 14-2334-CivilTerm [ ] Marc S. Weisberg, Esq. 4 -1 -Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY-: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Nationstar Mortgage LLC Plaintiff v. Amy N. Eppley and Eugene R. Eppley Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2334-CivilTerm DATE: October 29, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Amy N. Eppley and Eugene R. Eppley PROPERTY: 1109 West Trindle Road, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $109,043.07 The above -captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisbergand Conway,P.C. y 123 S. Broad St., Suite 1400 Philadelphia, PSA 19109 Attn: SETH HAMRICK typeU.S. Check of mail or service: n Certified 0 Recorded Delivery (International) 0 COD 0 Registered 0 DeliveryConfirmation 0 Return Receipt for Merchandise p 0 Express Mail 0 Signature Confirmation o Insured Affix Stamp Here I • (if issued as a certificate of mailing, or for additional i copies of this bill) V rt: Postmark and Date of Receipt a;1�. ��`:•iy- , * {�• '* ,, • .•: 4. Value i=� ZIP 02 0001377494 POSTAGE»PITNE'BOWES Fee 19109 1P/ Fee �ws $ Fee Q21.6Q OCT. 29. Fee 0 2014 Fee if COD Line Article Number Addressee Name, Street and PO Address Postage Fee Charge if Registered Nationstar Mortgage LLC v. Amy N. Eppley and Eugene R. Eppley 1 Taylor, Bean & Whitaker Mortgage Corp. 1417 North Magnolia Avenue Ocala, Florida 34475 xy i: a, ' ' 0 2 "MERS" Mortgage Electronic Registration System, Inc. P.O. Box 2026 P.O. Flint, Michigan 48501 J i. Q��l ',i QgDELPN1P• P ,it- 3 Tenants 1109 West Trindle Road Carlisle, Pennsylvania 17013 4 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 5 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8`s Street Suite #204 Philadelphia, PA 19107 6 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 7 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 8 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 9 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 10 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales 11 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 12 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 13 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 14 Commonwealth of PA , Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriff's Sales 15 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 16 United States of America do United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 17 United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 18 United States of America do Atty General of the United States U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Total Number of Pieces Listed by Sender 18 Total Number of Pieces Received at Post Office Postmaster, Per (Name o f receiving employee) The full declaration of vulue s required on all domestic and international registered mail. re Thc maximum indemnity payable or the con In ction of nonnegotiable documents under Express Mail document reconstruction insurance is $500 per piece subject to additional limita ions for mul iple pieces lost or damages in a single catastrophic occurrence. The maximum indemnity payable on Express Mail merchandise insurance is $500, but optional Express Mad Service merchandise is available for up to $5,000 to some, but not all countries. The maximum indemnity payable is 425,000 for registered mail. See Domestic Mail Manual R900, 5913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels. PS Form 3877, August 2000 Complete by Typewriter, Ink, or Ball Point Pen