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Home My WebLink About14-2838 Supreme. Caurt_nf Pennsylvania Cou1 Li Con-im" n Pleas Far Prothonotan,hese Onitr dh jt bo` der S,heet Cum beyrlanConn d =t', er Docket r : 7 fr ^ 5. 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 bylaw or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C NATIONSTAR MORTGAGE LLC DANITA J.LISK T I Dollar Amount Requested within arbitration limits p Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ®-NO A Name of Plaintiff/appellant's Attorney: KML Law Group,P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: C ❑ Slander/Libel Defamation Discrimination 13 Other ❑ Employment Dispute: Other T ❑ Other: I Q MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste $ ❑ Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 1r KML LAW GROUP, P.C. ;8: SUITE 5000-BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 } (866)413-2311 .J° ft>� ✓I r.fn 425 PhiNps ABRdMORTGAGE LLC P` ?j, LU �1 Wn THE COURT OF COMMON PLEAS Ewing,NJ 08618 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION-LAW DANITA J.LISK Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 5757 F Street # , d 7 gg L Carlisle,PA 17013 CIVIL ACTION:MO GAGI Defendant(s) FOS NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes,usted tiene veinte (20) dial de plazo a]partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escri"ta o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. /?n4.- v 6 S (Jnnr C� 7�5�� ►l ?nci-u Q SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://,,wvw.phfa.or.iz/consumers/homeowners/real.gs x. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawaroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 12948417C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is NATIONSTAR MORTGAGE LLC, 425 Phillips Blvd,Ewing,NJ 08618. 2. The name(s) and address(es) of the Defendant(s) is/are DANITA J. LISK, 57 F Street, Carlisle,PA 17013,who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On May 14, 2009 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR MEMBERS 1 ST FEDERAL CREDIT UNION, its successors and assigns which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on May 27, 2009 as Instrument#200917482. The mortgage has been assigned to: NATIONSTAR MORTGAGE LLC by assignment of Mortgage. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more,the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance..................................................................................$115,389.26 Interest from 09/01/2013 through 03/10/2014 at 4.6250%.......................$2,801.80 Per Diem interest rate at$14.82 LateCharges..................................................................................................$95.97 Pro Rata MIP/PMI......................................................... ..............................$168.00 Recoverable Balance......................................................................................$45.50 Reasonable Attorney's Fee.......................................................................$1,650.00 $120,150.53 7. If the Mortgage is reinstated prior to a Sheriff s Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing,title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an"in personam'judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy,but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit`B". The'Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$120,150.53, together with interest at the rate of$14.82,per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: KML LAW R UP, C. MichaelUiPa. eever Pa. ID 56129 Jay E. KID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff ✓�.�►�►�' ��tr�i e 3l�lbo VERIFICATION I, QV �a re J&;�'rt- for Cenlar FSB, servicing agent or NATIONSTAR MORTGAGE LLC, the Plaintiff herein, hereby verifies and says that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: 4.3D• #129484FC -DANITA J. LISK 57 F Street Carlisle,PA 17013 Eyhibi tA Policy No.: LP 1549372 ALL THAT CERTAIN tract or parcel of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and describe as follows: Lot# 136 in Home Acre Plan of Lots as recorded in the hereinafter named Recorder's Office in Plan Book 1, Page 93 said lot fronting twenty-five(25)feet on the Northern line of F Street and extending Northwardly therefrom at an even width, a distance of One Hundred Fifty-Eight(158)feet between Lots Nos. 135 and 137 to Lot No. 100 on the North. -.. . BEING PARCEL NO. 06-19-1641-142 Eyhibit �B j *Exhibit has been redacted to remove all personally identifiable information or non public information 4 Danita J Usk 57PSt Carlisle PA 17013 0031488943 HG Danita J Lisk DATE: December 04, 2013 57 F St Carlisle PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to forrgclose. Specific information about the nature of the default is provided in the attached_pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM(HEM.AP) mal be able to belg to savgv_Quf home. This Notice explains how the program works. To see if HEMAP can helil,vou must MFFT WITH A CONSUMERCREDIT COI; STN ELING AGENCY WITHIN 33 DAYS OF THF„�ATF QF THIS NOTICE Take this Notice with ou- when Xgu Wget with the Counseling Agency. The name address and phone number of Cgllsumer Credit Counseling Agencies serving lour !Counly are listed at the end of this Notice If lou have any que5tions.questions. you may call the . Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with imnaired hearing ca0 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 NOTIFICACION 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 TRADUCCION 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. XC111 009 JYH HG HOMEOWNER'S NAME(S): Danita J Lisk PROPERTY ADDRESS:57 F St Carlisle PA 17013 LOAN ACCT.NO.:—8943 ORIGINAL LENDER:MEMBERS 1 ST FEDERAL CREDIT UNION CURRENT SERVICER: Central Loan Administration&Reporting HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YET MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR H MF FROM FORECLOSURE AND HELP YOU-HAKE FUTURE ORTGAGE_PAMENTS 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. TEM!QRARY STAY OF FO ECLOS 7RE -- 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 MFF.TING MIIST QCCUR WI THIN THIRTY-THRF.E_(331 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 CRF.I)IT C011ZINELING AGENCIES— If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you f r 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 HAVE 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". 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 ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE STOPPED. XC 1 11009 JYH HG 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- ROTECTED 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 Bled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u„p to date]. NATURE OF THF DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 57 F St,Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 1.0/1/13- 1211113 DUE-3 PAYMENTS DUE @ $840.52=$2521.56 Late charges: $95.97 NSF: $.00 Less Suspense Funds: $.00 TOTAL AMOUNT PAST DUE: $2617.53 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: 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 $ $2617.53 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 payable and sentto: Central Loan Administration&Reporting Attn: Loan Servicing PO Box 986 Newark,NJ 07184-0986 You can cure any other default by taking the following action within THIRTY(30) DAYS of the date of this letter: NIA XC 111 009 JYH HG IF YOU DO NOT CURE IIM 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 fU eclose upan_lour mortgaged 2roperty. TF 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 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 with'n the THIRTY(30)DAY period.you will not be required to 1pav acv'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 Sheriffs 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 Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. 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 a Sheriffs Sale of the mortgaged property could be held. would be approximately FIVE months from the date of this Notice. A notice of the actual date of the Sheriffs 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 THF,L.FNDER:_ Central Loan Administration&Reporting 425 Phillips Blvd. Ewing,NJ 08618 Fax Number: 609-718-1616 Contact: Collections Department E-Mail Address: assetmanagement@loanadministraion.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. ASSTIMPTION OF MORTGAGE— You may or X_ 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 the other requirements of the mortgage are satisfied. XC 111 009 JYH HG \ . YOL 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 TIMES IN ANY CALENDAR YEAR.) • 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 XC111 009 JYH HG Cumberland County *CCCS of Western PA-York 55 Clover Hill Road Dallastown PA 17313 888.511.2227/888.511,2227 www.cccspa.org Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactricounty.org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority-Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907/717.249.0789 www.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.ruralisc.org/pathstone—Pa.htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org 041-01 Eyhibit C T' —i r -— ,-- a T T-- — li Ii l Prepared By and Return To:Referral Department KML LAW GROUP,P.C. BNY Mellon Independence Center-Suite 5000 701 Market Street Philadelphia,PA 19106-1532 215-825-6344 Case#: 129484FC i Parcel ID#: 06-19-1641-142 MERS MIN#: 100029500033392659 MERS PHONE#: 888-679-6377 PO Box 2026,Flint,MI 48501-2026, 1901 E. Voorhees ! Street,Suite C,Danville,IL 61834 j ASSIGNMENT OF MORTGAGE j MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,ACTING SOLELY AS NOMINEE FOR MEMBERS 1ST FEDERAL CREDIT UNION ITS SUCCESSORS I' AND ASSIGNS(Assignor),for good and valuable consideration,the receipt of which is acknowledged, .does grant,bargain,sell,assign and transfer to NATIONSTAR MORTGAGE LLC(Assignee),all of its i right,title and interest, as holder of,in,and to the following described mortgage,the property described and the indebtedness secured by the mortgage: Executed DANITA J.LISK,Mortgagor(s);to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,ACTING SOLELY AS NOMINEE FOR MEMBERS 1ST FEDERAL CREDIT UNION. Bearing date of:May 14,2009;Amount Secured: $124,450.00;Recorded on May 27,2009;in Instrument#200917482;in the Recorder of Deeds Office of Cumberland County,Commonwealth of Pennsylvania("Mortgage") Property:57 F Street,Carlisle,PA 17013 AS FURTHER DESCRIBED IN EXHIBIT"A",ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. I r i I r - L: r` 1 . Together with the obligation described in the Mortgage endorsed to the Assignee and all moneys due and to become due on the Mortgage,with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Mortgage forever,subject however,to the right and equity of redemption;if any,of the maker(s)of the Mortgage,their heirs and assigns forever. Assignor,by its appropriate corporate officers,has executed and sealed with its corporate seal this Assignment of Mortgage on this—10—day of . 20.�L. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,ACTING SOLELY AS NOMINEE FOR MEMBERS 1 ST FEDERAL CREDIT UNION ITS S=AND SSIGNS I (SEAL) Nam Title: JAMES T.DUNMEYER JR. Assistant Vice President i I hereby certify the address of the Assignee is: owe I Nam e. ES T. DUNMEYER JR, Title: Assistant Vice President ACKNOWLEDGMENT State of County of rh€CCC'.r OnNrA Q ,?Q)►c{ beforeme, 69Q,r-% 0';!A�nr• Personally appeared Who proved to me on the basis of satisfactory evidence to bet a person(s)whose name(s)is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies),and that by his/her/their signature(s)on the instrument the person(s),or the entity upon behalf of which the person(s)acted,executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of that the foregoing paragraph is true and correct. Witness my haand official seal. owA11111rr///m/ \��•�N •D E %, Signature (Seal) A1--0;.9%' TA q00 Case#: 129484FC = N !®� -A ' :• A(Je LAG i7 ;A'••gyp h NEW •�vQ� ��i�mnllu"J'o -- I. I I i Eyt h ALL THAT CERTAIN tractor Parcel of ground situate in the fifth Ward of the Borough of Carlisle, Cumber$and County,Penrrsylvanik bounded and dmribe as fokws: Lot# 136 in Home Acre Plan of Lots as recorded in the hereinafter named Recorder's Office In Plan Book 1,Page 93 said lot fronting b&,erity--five(25)feet on the Noftiern line of F Street and extending Northwardly therefrom at an even wWth,a distance of One Hundred Fffty-Sght(JSS)feet 6efween Lots Nos.335 and 137 to Lot No. 1DID on the:North. BEING PARCEL NO.06-19-1641-147 I I I i Case#: 129484FC t ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NATIONSTAR MORTGAGE LLC El Plaintiff vs. Case No. DANITA J. LISK `'�� t,, Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First, within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20) days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respe lly s fitted: (Signatu, o Cdqnsel for Plaintiff) 5/8/2014 Date Cumberland County Residential]Mortgage Foreclosure Diversion Prograva Financial Worksheet Date Cumberland County Court of Common Pleas locket# 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 names): Property Address: City: $tate' Zip: Is the property for sale? Yes Lj— No Ej Listing date Price: S Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): City: State zip: Phone Numbers: Home: 0ffiee: Cell: Other: Email: #of people in household: How lona? Mailing Address; City: State: Zip: Phone Numbers: Dome: Office: Cell; Other: Email: #ofpeople in household: How long? First Mortgage Lender: Type of Loan: Loan.Number: late 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 TIVInber&attorney: Assets Amotint Owed: Value: Dome: $ $ Other.Real Estate: $ Retirement Funds: Investments: $ $ Checking: Savings: Automobile 91: Model: Year: Amount owed: Value: Automobile#2. Model: Year: Amount owed: Value: Other transportation Lautomobiles, boats m #oro Iles , Model- Year; Amount owed: Value Monthly Income Name of Employers: la , 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) I:NX -NSE AMOUNT EXPENSE AMOUNT Mo a. ._ Food 2 Mort a e Utilities Car Pa ent s Condo/Neigh.pees Auto Insurance Med. snot clave Auto fuellre airs Other proe.payment InstalLLoan;l'a merit Cable.TV Child Sqpp2rt/Alini, Spending Mone Da lChild Caref uit, Other Ex arses 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: Email: Have you made application for Homeowners Emergency}Mortgage Assistance Program (HEMAP)assistance? Yes C❑ 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,plewe indicate the staters of those negotiations.- Please egotiations:Please provide the following information,if know, regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone.: Servicing Company(Nam ): Contact: Phone: Uwe, , authorize the above named to useirefer this information to my londerlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Ilwe 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: Y Proof of income Past 2 bank statements �f 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) Y Listing agreement(if property is currently on the market) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'HE PROTHONOTARY 46, 2014 NY 20 Pikl 3; f CUMBERLAND CCUNr`r PENNSYLVANIA OFFICE OF THE ERIfr Nationstar Mortgage LLC vs. Case Number Danita J Lisk 2014-2838 SHERIFF'S RETURN OF SERVICE 05/15/2014 03:15 PM - Deputy Dennis Fry, 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: Danita J Lisk at 57 F Street, Carlisle Borough, Carlisle, PA 17013. DENN FRY, DEP SHERIFF COST: $35.27 SO ANSWERS, May 16, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoff. Inc. v In the Court of Common Pleas of Cumberland County NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK (Mortgagor(s) and Record Owner(s)) 57 F Street Carlisle, PA 17013 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT t No. 2014-28 C.__ Z� cP p n Q E -i Cj CR THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DANITA J. LISK by default for want of an Answer. Assess damages as follows: Debt $122,477.27 Interest from 8/15/2014 to Date of Sale per diem at $14.82 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: KML LAW GROUP, C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Goma]] Pa. ID 92382 Attorneys for Plaintiff YAAA# &(Co AND NOW l • IS , .9)t? Judgment is entered in favor of NATIONSTAR MORTGAGE LLC an against DANITA J. LISK by default for want o an Anper an ages assessed in the sum of $122,477.27 as per the above certification. Prothono'ta y. awol \ke cM'\ \moo \\\\ a WtcH Rule of Civil Procedure No. 236 — Revised NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 DANITA J. LISK (Mortgagors and Record Owner(s)) 57 F Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. Defendant(s) No. 2014-2838 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothonotary By. Deputy If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 129484 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DANITA J. LISK LISK, DANITA J. 57 F Street Carlisle, PA 17013 NATIONS TAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 Plaintiff vs. DANITA J. LISK (Mortgagor(s) and Record Owner(s)) 57 F. Street Carlisle, PA 17013 Defendant(s) TO: DANITA J. LISK 57 F Street Carlisle, PA 17013 DATE OF THIS NOTICE: July 17, 2014 In the Court of Common Pleas of Cumberland County CIVIL, ACTION - LAW Action of Mortgage Foreclosure No. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW i ' I UP, P_C_ Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 / Salvatore Filippello Pa. ID 313897 / Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC Plaintiff vs. DANTTA J. LISK Defendant(s) NO. 2014-2838 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): DANITA J. LISK, has a last known residence of 57 F Street, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. 1\Aki By: KML LAW UP, P.C. Michael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicernemis Civil Relief Act Last Name: LISK First Name: DANITA Middle Name: J. Active Duty Status As Of: Aug -14-2014 Results as of : Aug -14-2014 06:25:32 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Noted of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 2CGF046720714B0 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK (Mortgagor(s) and Record owner(s)) 57 F Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 2014-2838 ORDER FOR JUDGMENT Please enter Judgment in favor of NATIONSTAR MORTGAGE LLC, and against DANITA J. LISK for failure to file an Answer in the above action within (20) days from the date of service,Qf ttle� Cfomplaint, in the sum of $122,477.27. By: KML LAW GRO�7Pie, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. -ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff f/rM 3lblbo I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 and that the name(s) and last known address(es) of the Defendant(s) is/are DANITA J. LISK, 57 F Street Carlisle, PA 17013; By: KML LAW GROUP, P. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff jUln Rtherb ,thao • ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $115,389.26 Interest from 09/01/2013 through $5,128.54 08/14/2014 Reasonable Attorney's Fee $1,650.00 Late Charges $95.97 Pro Rata MIP/PMI $168.00 Recoverable Balance $45.50 AND NOW, this , day of 2014-2838/129484FC By: $122,477.27 KML LAW GROJIt, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 ' n Andrew F. Gornall Pa. ID 92382 .--�,v 6l ( Attorneys for Plaintiff , 2014 damages are a' . ssed Bove. 71,i) L) Pro Prothy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK Mortgagor(s) and Record Owner(s) 57 F Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 2014-2838 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due 3S .a7) at )o3,75if l' ICo• sp/! d a s gq. P 4‘0 Interest from 8/15/2014 to Date of Sale per diem at $14.82 (Costs to be added) S ll� ejuri-23166 tc?947:01 By: —t1 $122,477.27 KML LAW GRO Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff feklik 3(c k Wri,/ KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK (Mortgagor(s) and Record Owner(s)) 57 F Street Carlisle, PA 17013 Plaintiff Defendant(s) ;:.b-01 f; PROTHON 214 AUG 1G AriiG:�� "i'MEI L A COUNT)/ PENNSI144111N OURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 2014-2838 AFFIDAVIT PURSUANT TO RULE 3129 NATIONSTAR MORTGAGE LLC, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 F Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DANITA J. LISK 57 F Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DANITA J. LISK 57 F Street Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: Members 1st Federal Credit Union 5000 Louise Drive, Mechanicsburg, , PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 57 F Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: KML LAV aROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff TtViVitdOr; 3ttho KML Law Group, P.C. Suite 5000- BNY Independence Center - 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff I. i- THONO 20(4 AUG 18 Ail 10. CU BERL PE ��ND COUNT 2014-2838 NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK Mortgagor(s) and Record Owner(s) 57 F Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s Docket No. 2014-2838 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LISK, DANITA J. DANITA J. LISK 57 F Street Carlisle, PA 17013 Your house at 57 F Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, December 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $122,477.27 obtained by NATIONSTAR MORTGAGE LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to NATIONSTAR MORTGAGE LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. M 2014-2838 4__ ---You may need anattorneyto assert your rights. The sooner you contact one, the more chance you -- - - will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 2014-2838 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@krrllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 129484FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK Mortgagor(s) and Record Owner(s) 57 F Street Carlisle, PA 17013 FILED-OFF L.E THE PROTiHONO Tia„ 20r4AUG IG Ali RI: 5 CUMBERLAND COUNT). { Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 2014-2838 CERTIFICATION ASTOTHE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: KML LAW GRO, Michael McKeever . ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff fwidor tycd/ta 3 v)1 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. DANITA J. LISK WRIT OF EXECUTION NO 2014-2838 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: $122,477.27 L.L.: $.50 Interest FROM 8/15/2014 TO DATE OF SALE PER DIEM AT $14.82 Atty's Comm: Due Prothy: $2.25 Atty Paid: $184.02 Plaintiff Paid: Date: 8/18/14 Other Costs: ANN air Davis I Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: JENNIFER FRECHIE, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215627-1322 Supreme Court ID No. 316160 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK 57 F Street Carlisle, PA 17013 or rL 4)4y ©c IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 2014-2838 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 57 F Street, Carlisle, PA, 17013, hereinafter, the "mortgaged premises". 2. Defendant, DANITA J. LISK, is the mortgagor and real owner of the mortgaged premises. 3. Pursuant to Cumberland County Local -Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Alyk Oflazian, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known address of Defendant, Danita J. Lisk, is 57 F Street, Carlisle, PA 17013 from our investigative search. 5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Danita J. Lisk. Service was attempted on Defendant, Danita J. Lisk at the mortgaged premises 57 F Street, Carlisle, PA 17013. The property is vacant. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Danita J. Lisk. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Danita J. Lisk, by posting the premises and certified and regular mail to the property address. By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. -ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 I4Myk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 - Attorneys for Plaintiff Affidavit of Good Faith Investigation Amended At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 129484FC Attorney/Law Firm: KML LAW GROUP, P.G. Subject Name: DAN/TA J. LISK Property Address: Street: 57 F Street City: Carlisle State: PA Zip: 17013 Slip Results: Date of Biro_ Last Known Address (as of 9/10/2014) Street: 57 F St City: Carlisle State: PA ProVest File Number: 4089201 Zip: 17013 1409 Death Record Search As of 09/10/2014, the Social Security Administration has no death record on file for Danita J Lisk. Social Security Number [X) Verifed [) Not Verified SSN Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 57 F ST, CARLISLE, PA 17013 1409 Department of Motor Vehicle Records Search' Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ 1 Govemmental"+ [X] Non-governmental No verifiable information. Professional Licenses Search No records found. Freedom Of Information Act Inquiry Made to U.S. Postal Service The following addresses were sent to the United States Postal inspector at the zip code listed with no return information to date: 57 F STREET I CARLISLE I PA 117013 I CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, Neighbors, & Friends 717-243-9409: Called possible relative, John Lisk, answering machine answered, no message left. 717-218-9885: Called possible relative, Courtney Cavanaugh, there was no answer. Comments: 717-241-4392: Called number listed to defendant, Danita Lisk, number has been disconnected. A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. • Data not available in AL, AR, CA, HI, NH, OR, PA, VA, WA. " Historical data in CO, DE, ID, IL, KY, LA, MD, MA, MS, MO, NH, ND, SC, WV. + Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, Ml, MN, MS, MO, NH, ND, OH, SC, TN, TX, WV, WI, WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the fads stated in it are true. STATE OF FLORIDA SES I 1 2014 COUNTY OF HILLSBOROUGH Gianna Hemandez ProVest File Number: 49$201 Sworn to or affirmed and signed before me on this _ day of Provest Services LLC Date: 9 (I 2.0 i (-( (Seal) JOSHUA N. PIMENTEL Notary Public. State of Florida My Comm. Expires May 24, 2015 No. EE 97050 Signature of Nis Printed Name of Notary Public ersonally Known ( ) Produced as identification IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC; et seq. Plaintiff (Petitioner) V. DANITA J. LISK; et al. Defendant (Respondent) CASE and/or DOCKET No.: 2014-2838 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF NON -SERVICE El Complaint ❑ Summons Ei Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve DANITA J. LISK the above process on the 3 day of September, 2014, at 2:03 o'clock, PM, at 57 F STREET CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: ❑ Moved ❑ Unknown ❑ No Answer 0 Vacant 0 Other: PROPERTY IS VACANT, EMPTY INSIDE, ELECTRIC IS OFF, PROPERTY IS OVERGROWN. Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of /„ ) ) SS: County of StrK/ ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: kartR CLAP. to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct. /1"—Y. (Signature of Affiant) File Number:129484FC Case ID #:4081452 Notary Public COMMONWEALTH OF PENNSYLVANIA Subscribed and sworn to befor me this Y day of . NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Berks County My Commission Expires November 1 8, 2017 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618" DANITA J. LISK 57 F Street Carlisle, PA 17013 vs. IN THE COURT OF COMMON PLEAS - OF Cumberland COUNTY No. 2014-2838 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Danita J. Lisk, which the Sheriff has been unable to personally serve upon Defendant, Danita J. Lisk. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Danita J. Lisk, by posting the premises and certified mail and regular mail to the property address. By: KML LAiieUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 .Xlyk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK 57 F Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County No. 2014-2838 CERTIFICATE OF SERVICE Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Danita J. Lisk this mail, postage prepaid. DANITA J. LISK 57 F Street Carlisle, PA 17013 day of September 2014, by first class By: /72a44.x.e, KML Law Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 fr NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK 57 F Street Carlisle, PA 17013 ORDER IN THE COURT OF COMMON PLEAS OF Cumberland COI rn er) z r" 2014-2838 AND NOW, this 7 day of Orciav2014, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, Danita J. Lisk, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, Danita J. Lisk, by posting a copy of the Notice upon the premises 57 F Street, Carlisle, PA, 17013, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 57 F Street, Carlisle, PA, 17013, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Danita J. Lisk, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. Service is complete upon mailing. Distribution list: ..--"17chael T. McKeever, Esquire, Suite 5000 — BN Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 DANITA J. LISK, 57y Street Carlisle, PA 17013 et)7 fiat BY T CO T: KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff NATIONS TAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK Mortgagor(s) and Record Ow ne r(s) 57 F Street Carlisle, PA 17013 OF 7- 1 F.- TOFFICF 1NdMiCi NOV I] 10: 25 CUMBFF,' 129484FC CF: 05/09/2014 SD: 12/03/2014 $122,477.27 Plaintiff Defendant(s) THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 2014-2838 Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ) Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). ) Certified mail by Sheriffs Office. ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) ofrecord. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (X) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). (X) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, BY: Andrew Hauck Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA NATIONSTAR MORTGAGE LLC; et seq. Plaintiff (Petitioner) V. DANITA J. LISK; et al. Defendant (Respondent) CASE and/or DOCKET No.: 2014-2838 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint 0 Summons 0 Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served DANITA J. LISK the above process on the 16 day of October, 2014, at 1:31 o'clock, PM, at 57 F STREET CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: J[J By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: I) 2) 3) Commonwealth/State of f4 ) SS: County of Jas Before me, the undersigned notary public, this day, personally, appeared fetvtn C 4'5 e duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. to me known, who being Subscribed and sworn to before me (Signature of Affiant) this t7 day of File Number:129484FC Case ID #:4121498 C0Mfv1,ONWC,n1.TN Ot: PENNSYLVANIA NOTARIAL SEAL Eric M. Afflorbach, Notary PubltC Washington Township, Berks County My Commion txpirea November 19, 2017 Notary Public Name and Address of Sende �OLOBECK �TE50OO U| l)1 MARKET STREET 'HILADELPHIA, PA 9106'1532 Check type of mail or service: . Ooertifieu ORecorded Delivery (Ime,national) O000 O Registered------ Omy*e�onrmnn��" Onommn��xxmon*�mm, O Express Mail O Signature Confirmation O Insured Postage Members 5000 Louise Mechanicsburg, Affix Stamp Here (If issued asaailing �m�mn additional Postmark and Date of Rece Fee 1st Federal Drive, , PA es pt Handling Charge Credit 17055 Actual Value if Registered Union Insured Value • '' ��' �£ L. �,''-^' � ~ '''•` Due Sender if COD V�.P[xST7*SE>> re � ~�rm« ��i' ZIP ��F�� ^/r`v,vn ' ` Vu ~0801391829AUG DC Fee 19106 �� SC Fee SH Fee PITNEY RD Fee BovmES RR Fee Article Number Mdressee (Name, Street, Coy, State, & ZIP Code) 1' DOMESTIC RELATIONS OF CUMBERLAND COUNTY POBox 32O Carlisle, PA 17013 — PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement HeohhmndVVo!hanoB|dg -Room �--'��--''-----�' 432 TENANTS/OCOU 57 F Street Carlisle, ----�'� PA 17013 TS «�� ,��- 26. 8*�� 2014 3. Harrisburg, 4. ` :le . /` . ` `'� `' �� •' � �, ^ . 7. 8. Total Number of Pieces Listed by Sende Total Number of Pieces Received at PostiO ice i � Po aster, Per Name ^�_� � \ See PrhacyA�S��men¢onRwva�e PGFonn3��7,Fobmu�2�Vu(Pog��p �omp��byTyp�wh�x|n�or��ipo|mPen 129484FC Cumberland County Sale 1�%e[12/O3/2014 DAN|TAJ.L|SK Name and Address of Sender CML LAW GROUP, P.C. SUITE 5000 '01 MARKET STREET P HILADELEHIA, PA 'HILA 532 Check type of mail or service; ❑ Certified ❑Recorded Delivery (International) ❑ COD 11 Registered El Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail E Signature Confirmation ❑ Insured Addressee (Name, Street, City, State, & ZIP Code) Postage Affix Stamp (If issued as certificate of or for additional of this bill) Postmark and Date of Receipt Fee Here a mailing, copies H. CFee Article Number • ? ' f.- ' Km-- i ' N.- Ly - t. ',c :. -i •*• . 0001391829 U.S. POSTAGE»» +� ,�3� ��► Z91°6 021ri $ n PITNEY c" BoWES 2014 i °^ RR 1. LISK, DANITA J. 57 F Street Carlisle, PA 17013miltimmur 00 OCT. .30° 14. 2, 5. .ti �a„ ,:x 6. 7. 8. Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post office Postmaster, Per (Nam .;;/ -c-'vi • employee) ^` r See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) Corfsplete by Typewriter, Ink, or Ball Point Pen 129484FC Cumberland County Sale X12/03/2014 DANITA J. LISK Print Your Documents b• • PS USPS Manifest Mailing System Page 1 of 3 Page 1 Mailer's Name & Address KML Law Group 701 Market Street Suite 5000 Philadelphia, PA 19106 Permit Number 123 MAC Ver. Number ConnectShip Progistics 6.5 Sequence Number 2618-2 Class of Mail Mixed Article #1 Piece ID Addressee Name Delivery Address ES Type Postage ES Pee Insurance Duel .Amount Sender Total Charge 71901088206000009311 9171999991703513282214- 9171999991703513282221 SUN, XIAOYI 7 Oakdale Avenue Wellesley. MA 02482 0.480 ERR 1.35 C 3.30 WILLIAMS, LINDA 0.480 558 East Clarkson Avenue ERR 1.35 Philadelphia, PA 19120 C 3.30 LUSK. DANITA J. 0.480 57 F Street ERR 1.35 Carlisle, PA 17013 C 3.30 917199999170351 NAMAU: DIANE J. 0.480 282238 POSox 233 ERR 1,35 Cheltenham, PA 19012 C • 3.30 9171999991703513282245 9171999991703 TONGOR, DAVID Z. 0.480 7327 Lawndale Avenue ERR 1.35 Philadelphia, PA 19111 P 3.30 TONGOR, DAVID 2. 0.480 282252 1344 Passmore Street ERR 1.35 Philadelphia. PA 19111 C 3.30 91719999917035.13282269 9171999991703513282276 9171999991703513282283 917 999170 9171999991703513282320 OEMURO, RICHARD W. 0.480 406 Hellerman Street ERR 1.35 Philadelphia. PA 19111 C 8.30 MAO. YAN 0.480 26 Wentworth Ddve ' ERR 1.35- BeA:eley Heights. NJ 07922 C 3.30 MAO. YAN 0.480 150 Snyder Avenue ERR ,Berkeley Heights. NJ 07922 C SUN, XIAOYI 0.480 Jc Wentworth Drrve ERR 1.35 Berkeley Heights, NJ 07922 C 3.30 HUTCHINSON, JOY IN, 0.480 2429 Valentine Avenue, ERR 1,35 Apartment 25, C 330 Bronx, NY10458. HUTCHINSON, JOY M. 9171999991703513282337 3230 Gunther Avenue Apartment 2 Bronx, NY 10489 0.480 ERR 1.35 C 3.30 5.13. 5.13 5.13 5.13. 5.13. 5.13 5.13 5.13 5.13 5.13 5.13 Page Totals 12 Cumulative Totals 12 http: //pbpc/sendsuite%201ive/projects/image. aspx?pd=1 5.76 5.76 55.80 55.80 61.56 61.56 10/15/2014 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DANITA J. LISK Mortgagor(s) and Record Owner(s) 57 F Street Carlisle, PA 17013 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2014-2838 AFFIDAVIT PURSUANT TO RULE 3129 NATIONSTAR MORTGAGE LLC, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 57 F Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): DANITA J. LISK 57 F Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DANITA J. LISK 57 F Street Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: Members 1st Federal Credit Union 5000 Louise Drive, Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 57 F Street Carlisle, PA 17013 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. DATED: November 13, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant