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HomeMy WebLinkAbout02-5141FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. 505 SOUTH MAIN STREET, 6TH FLOOR ORANGE, CA 92868 LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 Plaintiff TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED VVILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice arc 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 arc warned that if you fail to do so the case may proceed without you and a judgment may bc entered against you by the court without further notice for any money claimed in thc Complaint or for any other claim or relief requested by thc Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 0019109552 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. 505 SOUTH MAIN STREET, 6TH FLOOR ORANGE, CA 92868 The name(s) and last known address(es) of the Defendant(s) are: LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 12/23/00 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1660, Page 192. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 05/01/02 through 10/01/02 (Per Diem $25.30) Attorney's Fees Cumulative Late Charges 12/23/00 to 10/01/02 Cost of Suit and Title Search Subtotal $89,739.47 3,896.20 1,000.00 192.80 550.00 $95,378.47 Escrow Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $95,378.47 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This acfon does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an _in rem Judgment against the Defendant(s) in the sum of $95,378.47, together with interest from 10/01/02 at the rate of $25.30 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: //~raneis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff Borough of Cktp Hill, County 4f ~amberland I~d State of Penntylvan~o, bounded and dencribed a~ re,zeus, to ~he dzstince or one hundred e'~ghty (i8Q) rent B~asured :fl pa eusLerZy dzrec- ton Avenues; thence in a Southerly d~rectzon a~ang the eastern liwe, ~ong ~o~ No. 4? oo sm~d Plan. one hundred t~ent~-~zyff and one-hundredths (~2~.62) ~eet, more or less, to ~ po~n~ on the northerly n~nety (90) feet to a Point; thence ~n a northerly dzrectzon o~ong the ~tne oF Eot Ho. St, on saxd P~aa, one hun~'red t~entT-r~¥e and s~xt~-t~o one-hun° CoXuBbXa Avenue; thence tn a ~e~ter~y dxrect~on o3=n~ Co~umbxa 4venue Havtng a ;roatage o~ n~nety (90) ~eet an the south s~de o~ Columbia Ave- ten (10) foot alley. VERIFICATION ROSE LARA hereby states that she is Foreclosure Specialist of AMERIQUEST MORTGAGE COMPANY, mortgage servicing agent for Plaintiff in this matter, that she is authorized, to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to ~he best of 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. ROSE LARA ~ SHERIFF'S RETURN - CASE NO: 2002-05141 P COMMONWEALTH OF PENNSYLVANIA: cOUNTY OF CUMBERLAND BANKERS TRUST CO OF NY VS STEPP LINDA A REGULAR DAVID MCKINNEY ' Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon STEPP LINDA A Sheriff or Deputy Sheriff of who being duly sworn according to law, the DEFENDANT , at 1812:00 HOURS, at 2809 COLUMBIA AVENUE on the 5th day of November 2002 CAMP HILL, PA 17011 LINDA STEPP by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this [? day of 'l~~ ~ ~o ~L- A.D. ~P~othonotary So Answers: R. Thomas Kline 11/06/2002 FEDERMAN & PHELAN Deph~'y Sh ' ~/ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. 505 SOUTH MAIN STREET, 6TH FLOOR ORANGE, CA 92868 Plaintiff, V. LINDA A. STEPP CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 CIVIL Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against LINDA A. STEPP, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of thc mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 10/2/02 to 12/9/02 TOTAL $95,378.47 $1745.70 $97,124.17 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~RANK FED]~, E~(~U~,~ - Attorney for Phintiff DAMAGES ARE HEREBY ASSESSED AS INDICA~D. DATE: l,"~l,2r'-O.,),- / b~ PRO PROTHY FEI3ERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kermedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 56~-7000 BANKERS TRUS']? CoMPaNY OF NEW YORK, AS TRUST A_DMINISTRATOR OF ACE SECURITIES; CORP HOME EQUITY LOAN TRUST SERIES 2001- AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. Plaintiff VS. LIN-DA A. STEDP Defendant(s)' Attomey for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-5141 TO: LINDA A, STEPP 2809 CO'!JUMBIA AVENUE CAMP HI~L, PA 17011 DATE OF NOTI~?E: NOVE~BER 26, 2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NCTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, B_ND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVEO A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT A/VD SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICR You are in default because you have failed 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 ~%udgment may be entered against you without a hearing and you ma~ lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or ~annot afford one, go to or telephone the following office to find out where you can get legal help: ~ CUMBERLAND COUNTY ') ~ CUMBERLAND COUNTY BAR ASSOCIATION : 2 L~ERTY AVENUE · CARLISLE, PA 17013 (717) 249-3166 ~r~nk Federman, Esqfi~re Attorney for Plaintiff ' FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHII,ADELPHIA, PA 19103-1814 (215) 563-7000 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THI~ POOLING & SERVICLNG AGREEMENT DATED AS OF APRIL 1, 2001. 505 SOUTH MAIN STREET, 6TH FLOOR Vo LINDA A. STEPP Plaintiff, ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 CIVIL Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant LINDA A. STEPP is over 18 years of age and resides at, 2809 COLUMBIA AVENUE, CAMP HILL, PA 17011 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Attorney for Plaintiff OF ExeCUTION ' (,MORTGAGE FoRECLOS~JR~') pRAECIPg FOR. WRIT p.R.C.P. 3180-3183 OF NEV¢ yORK, : BANKERS TRUST COMPAI~ : AS TRUST ADMiNISTRATOR OF ACE : sEcURITIES CORP ltOME EQUITY LOAN TRUST SERIES 2001-AQ1 AssET BACKED pASS- cERTIFIcATES UNDER TBlg : TBRoUGH sERVICING AGREEMENT DATED :: pOOLING & : AS OF APRIL 1, 2001. Plaintiff, No. 07.-5141 CIVIL LINDA A. STEPP Defendant(s)- TO TIlE DIRECTOR OF TIlE OFFICE OF TIlE pROTIIONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 12/9/02 to IUNE 11, 2003 (per diem -$15.97) TOTAL $ 97,124.17 v/ $ 2,938.48 and Costs 100,062.65 One penn Center at Suburban StaUon 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. certaln Pieces or Parce Col/~lty of C~erla~ a ~EG~G at a pOint on ~f one hundr~ eighty alon~ said aTM ....... ~ a ten ,~-. -~=~ f12~ ~-~ ~oc ~o a. ~= ia a ........ oc No. S1 on (125,62) feet, more or 1( ~', o~e h~d~' =~ence in = ~= in an ea~- ~' to a , co a · th~ce ~n a westerly dir(~- . Point on -= Y'flve ~,~ fly ~re-~. lreCtloa Having a frontage of nih,(90) feet on the south side of -~ uae Place of extending back an even T~ P~C~ ~22-0533, P~ 2~8 P~SES BEING ~O~ ~ HILL, PA 17011 TrTLE TO SAID Executrix et' thc Last Will an<~ L~cla A 8re- - ' · ' ~ recorded FEDERMAN and PItELAN, LLP By: FRANK FEDERMAN Identification No. 121248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHII,ADELPHIA, PA 19103-1814 (215) 563-7000 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. Plaintiff, V. LINDA A. STEPP Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 CIVIL .CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~RMAN, ESQUIRE F Attorney for Plaintiff BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. Plaintiff, V. LINDA A. STEPP Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) BANKERS TRUST COMPANY OF NEW YORK~ AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1~ 2001, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 2809 COLUMBIA AVENUE~ CAMP HI1,L~ PA 17011. 1. Name and ad&ess of Owner(s) or reputed Owner(s): Name Last Known Ad&ess (if ad&ess cannot be reasonably ascertained, please indicate) LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 2. Name and ad&ess of Defendant(s) in the judgment: Same as above 3. Name and last known ad&ess of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Ad&ess (if ad&ess cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Nanle CITIFINANCIAL, INC Last Known Address (if address cannot be reasonably ascertained, please indicate) 3401 HARTZDALE DR., SUITE 126 CAMP HILL, PA 17011 5. Name and address of every other person who Name None 6. Name and address of every other person who interest may be affected by the sale. has any record lien on the property: Last Known Address (if address cannot be reasonably ascertained, please indicate) has any record interest in the property and whose Sallie COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTN: JOHN MURPHY Last Known Address (if address cannot be reasonably ascertained, please indicate) 6TM FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 THIRTEENTH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 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: Nalne Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 2809 COLUMBIA AVENUE · CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. November 27, 2002 ~~~ Ar~. ~F)~/V~ DATE ~RANK FEDEI~kMAN, ESQUIRE Attorney for Plaintiff BANKERS TRUST COMPANY OF NEW YORK, : AS TRUST ADMINISTRATOR OF ACE : SECURITIES CORP HOME EQUITY LOAN : TRUST SERIES 2001-AQ1 ASSET BACKED PASS- : THROUGH CERTIFICATES UNDER THE : POOLING & SERVICING AGREEMENT DATED : AS OF APRIL 1, 2001. : Plaintiff, : V, LINDA A. STEPP Defendant(s). TO: LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-5141 CIVIL November 27, 2002 **THIS FIRbI IS ,4 DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOTAND SHOULD NOTBE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 2809 COLUMBIA AVENUE~ CAMP HILL, PA 17011, is scheduled to be sold at the Sheriff's Sale on JUNE 11, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97,124.17 obtained by BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1~ 2001 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. 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 notice on page two on how to obtain an attorney.)  sold to t~c b~ghest -^t stoPPed, your property will be f t~e Sheriffs Sale is ~. sale i~he bid price was grossly 1. ~ . -'~b" ca~g Co~ ~o se~ as~re ~e find out the p~ce ora ~ o efi~to~ t~e -- - maybe able t ~ _ o[ ~ou~ p~°peay' due ~a the sale. To 2. xou ~ -~ the vata~ the She~f the ~l ~ount inaaequate comp~eu ~ · ba er pa~s ~ ~e sate will ~ . .,on ~a~ eau k, - - find ou[ [f this h~ happeneu, 2~ is not pMfl to the S~ff' you will remora the o~er of · ~e sal .. · (hll mo~t due }s padto:the Sherbet p,ope~ as ff . ---<in ,n t,e p,op~Y ~1~;, ma~ brng ,egat p~oceedmgs toe ~. ~. ~ ~;.,~ a ced to the uu~~- ~d the ~nenu ~, .... d ' · ,~ naid for yo~ house. A schedule o~ you. u ma be entitled to a shoe 6. Yo_. ~_~ · for our hous~ ~'" ;~;,,e ,elf within 30 days of the sale. dis~bution of me mo,,e~ b~d Y ~at money. T~e mney will be paid om in accordmce schedule will state who will be receiving the propos~ d~bmion is ~ong) ~e filed with the schedule ~less exceptions (reasons why ~s days a~er the ~stfibution is filed. Sheriff wi~n ten 00) 7. You may also have other fi~ts ~d defenses, or ~s of geeing your home back, if you i~ediately a~er ~e sale~iS pAPER ~O yOUR LA~R AT ONCE. IF YOU DO NOT THE oF~CE LIST] yOU s~oULD ~A~ A LA~ER OR c~NOT ~FO~ ONE, GO TO o~ELEPHONE BELOW ~O ~ND OU~ WHE~ yOU C~ GET LE~ HELP. CUMBEreD COUNTY As~EY CUMBEreD COUNTY B~ ASSOC~TION 2 LIBERTY cUMBEreD cOUNT~URTHOUSE c~iSLE' pA'013 (7~ 249-3~ (soo) 990-9t ~PERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 Sher/ffthe full amount due in the sale. To find out if this has happened, you may call (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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriffgives 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 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 distribution is wrong) are flied with the Sheriff within ten (10) days after the distribution is flied. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~r.r. THOSE three certain pieces or parcels of land situate ~ t. he Borough of Camp Hill, County of Cumberland and S~&te of Pennsylvpn{a, known as L~s Nos. %8, 49 and 50 on the Plan of Lots known as South Earlington, said plan being reorded in the Office of the_ Recorder of Deeds in and for said County of Cuafu~rland in ~anBook 1, Page 8, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the aouther~ boundary line of Coltubia Avenue at the distance of one hundred eighty (180) feet measured in an easterly drection along Columbia Avenue from ~he southeast corner of Columbia and Princeton~venues; thence in a southerly direction along the eastern boundary line, alongLot No. 47 on said Plan, one hundred twenty-five and sixty-two one hundredths (125.62) aet, more or less, to a point on the northerly line of a ten (10) foot alley; the;e in an easterly direction along said alley ninety (90) feet to a point; thence in a ~rtherly direction along the line of Lot No. 51 on said Plan, one hundred twenty-five at sixty-two one-hundredths (125.62) feet, more or less, to a point on the southerly lie of Columbia Avenue; thence in a westerly direction along Columbia Avenue ninetl(90) feet to the place of Beginning. Having a frontage of ninety {90) feet on the south side of'olumbia Avenue and extending back an even width to said ten (10) foot alley. TAX PARCEL {22--0533, PARCEL 218 PREHISES BEING KIqOI~IN AS: 2809 COLUHBIA AVEI~U~ CA14P HII.L, PA 17011 TITLE TO SAID PREMISES IS VESTED IN Linda A. Stcpp by Dee~from Linda A. Stcpp, Executrix of thc Last Will and Testament of 'Nila M. St~pp, cl~ceascd d~t 7/26/1989 and recorded 7/26/1989 in R~cord Book 34-B, Page 733. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5141 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANKERS TRUST CO OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001- AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF 4/1/01 Plaintiff (s) From LINDA A. STEPP, 2809 COLUMBIA AVE., CAMP HILL PA 17011. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 2809 COLUMBIA AVE., CAMP HILL PA 17011.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirrdher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $97,124..17 Interest 12/9/02 TO 6/11/03 ~ $15.97//per diem Atty's Comm % Arty Paid $115.35 Plaintiff Paid Date: DECEMBER 13, 2002 (Seal) REQUESTING PARTY: Name FRANK FEDE1RMAN, ESQ. L.L. $.50 $2,938.48 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: ~J Dduty d Address: ONE PENN CENTER ~ SUBURBAN STATION 1617 JFK BLVD., SUITE 1400 HILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No 12248 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER TI:gE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. Plaintiff, LINDA A. STEPP Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) BANKERS TRUST COMPANY OF NEW YORI~ AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1~ 2001, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 2809 COLUMBIA AVENUE~ CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA A. STEPP 2809 COLU31BIA AVENUE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nanle None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name CITIFINANCIAL, INC Last Known. Address (if address cannot be reasonably ascertained, please indicate) 3401 HARTZDALE DR., SUITE 126 CAMP HILL, PA 17011 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Nalne COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTN: JOHN MURPHY Last Known Address (if address cannot be reasonably ascertained, please indicate) 6~a FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER BOROUGH OF CAMP HILL P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 THIRTEENTH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 2145 WALNUT STREET CAMP HILL, PA 17011 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Nanle Tenant/Occupant Domestic Relations of Cumberland County Last Known Address (if address cannot be reasonably ascertained, please indicate) 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania PO Box 2675 Department of Welfare Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. DATE FRANK FEDERMAN, ESQU]ILE Attorney for Plaintiff AFFIDAVIT OF SERVICE PLAINTIFF BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED pASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1, 2001. DEFE~OAYr(S) LINDA A. STEPP SERVE LINDA A. STEPP AT 2809 COLUMBIA AVENUE CAMP IHLL, PA 17011 CUMBERLAND COUNTY KMD No. 02-$141 CIVIL ACCT. #0019109552 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 11, 2003 SERVED Served and made known to L~ ~~'t~-h3~° ~ Defendant, onthe ~C'~lN' dayofx~'~l~u~\1200~_ at '-'~} [~-1_ o'clock~.m.,at ~h/)~t~_~. 2(~[I_L~.~(~ _~1~-,Q~-p¢ I~ ,Comonwea,~ nnsylvania, in the manner described below: Defendant personally served. '~Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __Manager/Clerk of place of lodging in which Defendant(s) reside(s). .Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age/~. ~ Height Weight ~ Race ~ Sex '~ Other I,~, ~x~[Ch{D~k© (f~~_. a competent adult, being duly sworn according to law, depose and state that I personally handed a tree and corr'e~t copy~f the-'~Notice of Sheriff's Sale. in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. ~ -- Notada/Seal / ~_. ?/~r~ I /"~ e,-~*,-o-a--hscribed LlndaJ'Jumper'N°tadPu~)~ic / before me this po clay of. i.LW~' ,2003. - ' · ' '~..~-, ~'~ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the __ __ day of ., 200__, at o'clock __.m., Defendant NOT FOUND because: Moved Unknown ~ No Answer 1st Attempt: [~)./~l /(3 Z~. Time: \c~, ' ~ [ Vacant 2"a attempt: \ /~ C):~_ Time:--~ 3rd Attempt: / / Time: · Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001 Plaintiff, Vo No. 02-5141 LINDA A. STEPP Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest fi.om 12/13/02 to 12/10/03 (per diem -$15.97) TOTAL $97,124.17 $5,797.11 and Costs $102,921.28 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. DESCRIPTION ALL THOSE three certain pieces or parcels of laud situate in thc Borough of Camp Hill, County of C-'ombcrland m~d State of Pennsylvania, known as Lots No,~. 48, 49 and 50 on the Plan of Lots known as South Earlington said Plan boing recorded in the Office of thc Recorder of Deeds in and for said County of Cumberland in Plan Book 1, page 8 and more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern boundary linc of Columbia Avenue at the distance of one hunch'cci eighty (180) feet m~asured in an Easterly direction along Columbia Avenue from thc Southeast comer of Columbia auct Princeton Avenues; thence in a Southerly direction along the Eastern boundary linc, along Lot No. 47 on said Plan, om: hundred twenty-five and sixty-two one-hundredths (125.62) feet, more or less, to a point on the Northerly line of a ten (10) foot alley; thence in an Ea.aterly direction along said alley ninety (90) feet to a point; thence in a Northerly direction along the Line of Lot No. 51, on said Plan, one hundr~ twenty-five and sixty-two one-hundredths (125.62) feet, more or less, to a point on the Southerly line of Columbia Avenue; thence in a Westerly direction along Columbia Avenue ninety (90) feet to the place of I:~glnnlng. HAVING a frontage of, ninety (90) feet on the South side of Columbia Avenue and extending back an even width to said ten (10) foot 'alley. Tax Parcel g22-0533, Parcel 218 TITLE TO SAID PREM[SF, S IS VESTED IN Linda A. Stepp by Deed from Linda A. Stopp, E~xeeutrix of the Last Will and Testan-~nt of Nils M. Stcpp, deceased dated 7/26/1989 and recorded 7/26/1989 in Record Book 34-B, Page 733. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO02 - 5141 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001, Plaintiff (s) From LINDA A. STEPP (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garmshee and is enjoined as above stated. Amount Due $97,124.17 L.L. Interest FROM 12/13/02 TO 12/10/03 (PER DIEM - $15.97) - $5,797.11 AND COSTS Atty's Comm % DueProthy $1.00 Atty Paid $926.33 Other Costs Plaintiff Paid Date: AUGUST 4, 2003 (Seal) CURTIS R. LONG By: ~ n-.-~t . Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 119103-1814 (215) 563-7000 BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001 Plaintiff, LINDA A. STEPP Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 02-5141 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN THE MATTER OF: LINDA A STEPP BANKERS TRUST COMPANY OF NEW YORK, as Trust Admonostrator of ACE Securities Corp Home Equity Loan Trust Series 2001-AQ1 UNDA A STEPP MARKIAN R SLOBODIAN, TRUSTEE Debtor(s) Case Number: 1-03-02655 Movant(s) Chapter: 7 vs. Document No.: 5 Description of Respondent(s) Motion(s): Relief from Stay ORDER IT IS ORDERED that service of this Order and the above-referenced Motion shall be made on the debtor, debtor's counsel, trustee and in Chapter 11 cases upon the U.S. Trustee and the individuals identified in F.R.B.P. 4001 (a)(1) and B.P.O. 4001 by the moving party and certification of service filed with this Court within five (5) days from the date hereof. IT IS FURTHER ORDERED that responses to such Motion must be served upon the moving party and a copy filed with this Court, within fifteen (15) days from the date of this Order. If no Response is filed, relief may be granted. If responses are filed, a final hearing on said Motion and Responses will be held: DATE: JULY 15, 2003 PLACE: TIME: 9:00 AM DATE: June 9, 2003 Bankruptcy Courtroom Third Floor, Federal Building Third and Walnut Streets Harrisburg, Pennsylvania /s/MARY D. FRANCE Bankruptcy Judge BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS- THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001 Plaintiff, LINDA A. STEPP Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5141 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EOUITY LOAN TRUST SERIES 2001-AO1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001, Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 2809 COLUMBIA AVENUE, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: NaiTle CITIFINANCIAL, INC. Last Known Address (if address cannot be reasonably ascertained, please indicate) 3401 HARTZDALE DR., SUITE 126 CAMP HILL, PA 17011 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTN: JOHN MURPHY DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER Last Known Address (if address cannot be reasonably ascertained, please indicate) 6Ta FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 13TM FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 BOROUGH OF CAMP HILL 2145 WALNUT STREET CAMP HILL, PA 17011 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 Tenant/Occupant Last Known Address (if address cannot be reasonably ascertained, please indicate) 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania PO Box 2675 Department of Welfare Harrisburg, PA 17105 I verify that the statements made in tlfis 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. Sec. 4904 relating to unsworn falsification to authorities. August 1, 2003 r'~/<, r'~ ~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff BANKERS TRUST COMPANY OF NEW YORK, : AS TRUST ADMINISTRATOR OF ACE : SECURITIES CORP HOME EQUITY LOAN : TRUST SERIES 2001-AQ1 ASSET BACKED PASS- : THROUGH CERTIFICATES UNDER THE : POOLING AND SERVICING AGREEMENT : DATED AS OF APRIL 1, 2001 : Plaintiff, : LINDA A. STEPP Defendant(s). TO: LINDA A. STEPP 2809 COLUMBIA AVENUE CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-5141 August 1, 2003 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. B UT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 2809 COLUMBIA AVENUE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriff's Sale on DECEMBER 10, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97,124.17 obtained by BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OVqNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 notice on page two 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. 1. 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 (215) 563-7000. 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 (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 the 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 Sheriffwithin 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THOSE three certain pieces or parcels of ]and sit:,~te in thc Borough of Camp Hill, County of C-ha-nbcrland and State of Pennsylvania, Imown as Lots No.~. ,¢8, 49 and .50 on the Plan of Lo~s known as South Earlillgton said Plan boing r~'corded in the Office of thc Recorder of Dezxls in and for said County of Cumberland in Plan Book 1, page 8 and more particularly bounded Paid described as follows, to wit: BEOINNING at a point on the Southern boundary line of Columbia Avenue at the distance of one hundred eighty (180) feet m~.asured in an Easterly direction along Columbia Avenue from the Southeast ex~rner of Col~rmhia and Princeton Avenues; thence in a Southerly direction along the Eastern boundary line, along Lot No. 47 on said Plan, one hundred twenty-five and sixty-two one-hundredths (125.62) feet, more or leas, to a point on the Northerly line of a ten (10) foot alley; thence in an Easterly dir~lion along said alley nip. cry (90) feet to a point; thealce in a Northerly direction along the line of Lot No. 51, on said Plan, one hundred twenty-five and sixty-two one-hundredths (125.62) feet, more or less, to a point on the Southerly line of Columbia Avenue; thence in a Westerly direction along Columbia Avenue ninety (90) feet to the place of bCginning. HAVING a frontage of, ninety (90) feet on the South side of'Columbia Avenue and extending back an even width to said ten (10) foot alley. Tax Parcel//22-0533, Parcel 218 TITLE TO SAID PREMISES IS VESTED IN Linda A. Stepp by Deed from Linda A. Stepp, Executrix of the l.ast Will and Testament of Nila M. Stepp, deceased dated 7/26/1989 and recorded 7/26/t989 in Record Book 34-B, Page 733. PLAINTIFF AFFIDAVIT OF SERVICE BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES cORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-TItROUGH CERTIFICATES UNDER T[i~ POOLING AND SERVICING AGREEMENT DATED AS OF APRIL 1, 2001 cUMBERLAND cOUNTY K/VID No. 02-5141 ACCT. #0019109552 Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 10, 2003 DEFENDANT(S) LINDA A. STEPP SERVE LINDA A. STEPP AT 2809 COLUMBIA AVENUE cAMP roLL, PA 17011 ~, SERVED ~- ~ ~ 'q -- - 200''~ of Pennsylvania, in the manner described below: ~ Defendant personally served. . . -' s ' Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant(s)'s residence who refused to give name or relationship. -- Manager/Clerk of place of lodging in which Defendant(s) reside(s). -- in char e of Defendant(s)'s office or usual place of business. _Agent or person g an officer of said Defendant(s) s company. Other: Description: Age ~-"/-_~5" Hei ht / ? ~ight/'~/~//~,ace ~AJ Sex ~._~__ Other I, ~ Z, ~/~:~/-'~, a competent adult, being duly sworn according to law, depose and state that I personally handed a ~½ of the Notice of Sheriff s Sale m the manner as set forth hereto, issued tn the captioned case on the date and at the address indicated t~'bove. Sworn to and sub, cried before me this _~2 _ day Notary: //~/A.~n.A~.~ ~ ;~:L~A~T-3 TIMES INDICATE DATES & TIMES OF SERVI .... , ,, ,. ~ ,, ~ NOT SERVED ..... ~ o'clock .m., Defendant NOT FOUND because: - , , ~,, '~: ,5C.,~, ,200 ,at ofl~$e~ ~' ..'~Y.of 2'_~.~' ~ Moved _ U~o~ ~ No Answer 1st Attempt: / / Time: _ : 3rd Attempt: / / Time: : Vacant 2na Attempt:: / / Time: Sworn to and subscribed before me this ~ day of_ ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CO1LP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGP~EMENT DATED AS OF APRIL 1, 2001. VS. LINDA A. STEPP CIVIL ACTION CIVIL DIVISION NO. 02-5141 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for BANKERS TRUST COMPANY OF NEW YORK, AS TRUST ADMINISTRATOR OF ACE SECURITIES CORP HOME EQUITY LOAN TRUST SERIES 2001-AQ1 ASSET BACKED PASS-THROUGH CERTIFICATES UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF APRIL 1~ 2001. hereby verify that on August 4, 2003 tree and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 12, 2003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the SherifFs Deed in which Ace Securities Cot0 Home Erluitv Loan Trust tr is the grantee the same having been sold to said grantee on the 10th day of Dec A.D., 2003, under and by virtue of a writ Execution issued on the 4th day of Aug, A.D., 2003, out o£the Court of Common Pleas of said County as of Civil Term, 2002 Number 5141, at the suit of Ace Securities Corp Home Equity Loan Trust Tr against Linda A Stepp is duly recorded in Sheriff's Deed Book No. 261, Page 3342. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /? d~- day of /) Bankers Trust Company of New York Et al VS Linda A. Stepp In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2002-5141 Civil Term Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on September 09, 2003 at 6:16 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Linda A. Stepp, by making known unto Linda Stepp, personally, at 2809 Columbia Ave., Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 11:25 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Linda A. Stepp located at 2809 Columbia Ave., Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Linda A. Stepp, by regular mail to her last known address of 2809 Columbia Ave., Camp Hill, PA 17011. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Peunsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $45,000.00 to Attorney Frank Federman for U.S. Bank National Association as Trustee of Ace Securities Corp. Home Equity Loan Trust, Asset-Backed Pass-Through Certificates, Series 2001-AQ1. It being the highest bid and best price received for the same, U.S. Bank National Association as Trustee of Ace Securities Corp. Home Equity Loan Trust, Asset-Backed Pass-Through Certificates, Series 2001-AQ1 of 505 South Main Street, 6th Floor, Orange, CA 92868, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $6,000.00. Sherif?s Costs: Docketing $30.00 Poundage 900.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 19.32 Levy 15.00 Surcharge 20.00 Law Journal 316.55 Patriot News 244.54 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriff's Deed 40.50 $ 1,710.81 Sworn and subscribed to before me So Answers: This ,~3~<day of ._~~ ~-~ t, R. Thomas Klinro Sheriff 2004, A.D. ~ ~_~ '~rdthonotary BY Real EstateuDeputy ~ 3t~.o° SCHEDULE OF DISTRIBUTION SALE NO. 28 Date Filed: January 9, 2004 Writ No. 2002-5141 Civil Term Bankers Trust Company of New York, as Trust Administrator of Ace Securities Corp Home Equity Loan Trust Series 2001~AQ1 Asset Backed Pass Through Certificates Under the Pooling and Servicing Agreement Dated as of April 1, 2001 VS Linda A. Stepp 2809 Columbia Avenue Camp Hill, PA 17011 Sale Date: Buyer: Bid Price: December 10, 2003 Bankers Trust Company of New York, as Trust Administrator of Ace Securities Corp Home Equity Loan Trust Series 2001-AQ1 Asset Backed Pass Through Certificates Under the Pooling and Servicing Agreement Dated as of April 1,2001 $45,000.00 Real Debt: $97,124.17 Interest: 5,797.11 Attorney Costs: 926.33 Total: $103,847.61 DISTRIBUTION: Receipts: Cash on account (08/11/03): $1,500.00 Cash on account (12/10/03): 4,500.00 Credit Writ No. 2002-5141: 39,000.00 Total Receipts: $45,000.00 Disbursements: Sheriffs Costs Legal Search Camp Hill Borough Lien No. 03-2879 Cumberland County Tax Claim Bureau Attorney Federman Credit Writ No. 2002-5141 $ 1,710.81 600.00 338.72 1781.81 1,568.66 39,000.00 Total Disbursements: Balance for distribution: ($45,000.00) 0.00 So Answers: R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 28 Held Wednesday, December 10, 2003 Date: December 10, 2003 TAXES: Receipts for all taxes for the years 2000 to 2002 inclusive. Taxes for the current year 2003. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below, JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , , and recorded , in Cumberland County Deed Book , Page RECITAL: Being the same premises which Linda A. Stepp, Executrix of the Estate of Nila M. Stepp, by deed dated July 26, 1989 and recorded July 26, 1989 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book "B," Volume 34, Page 733, granted and conveyed to Linda A. Stepp. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Columbia Avenue and in the roadbed of a 10 foot wide unnamed alley. Conditions, easements and restrictions as shown on or set forth on the Plan of Lots for South Earlington, recorded in Plan Book 1 page 8. Mortgage in the amount of $90,400.00 given by Linda A Stepp to Ameriquest Mortgage Company dated December 23, 2000 and recorded December 27, 2000 in Mortgage Book 1660, Page 192. Said mortgage was assigned to Banker's Trust Company of New York as Trust Administrator by instrument recorded November 25, 2002 in Miscellaneous Record Book 692, Page 260. Complaint in mortgage foreclosure filed by Banker's Trust Company of New York, as Plaintiff against Linda A Stepp as Defendants in the Office of the Prothonotary of Cumberland County on on October 24, 2002, to File No. 2002-5141. Judgment entered in the amount of $97,124.17. 8. Mortgage in the amount of $15,314.00 given by Linda A. Stepp to CitiFinanciai, Inc., dated April 18, 2002 and recorded April 22, 2002, in Mortgage Book 1756, Page 862. Municipal lien filed by Borough of Camp Hill as Plaintiff against Linda A. Stepp as Defendant in the Office of the Prothonotary of Cumberland County on June 18, 2003 to File No. 2003-2879 in the amount of $338.72. 10. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff's sale. 11. Satisfactory evidence to be produced that advertisement of the sale of subject premises was sufficient despite the absence of reference to any improvements on the premises. 12. Real estate taxes accruing on and after January 1, 2004 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. until countersigned by an authorized signatory. REAL ESTATE SALE NO. 28 Writ No. 2002-5141 Civil Bankers Trast Company of New York, as Trust Administrator of Ace Securities Corp. Home Equity Loan Trast Series 2001- AQ i Asset Backed Pass-Through Certificates Under the Pooling amd Servicing Agreement Dated as of April 1, 2001 vs. Linda A. Stepp Atty.: Framk Federman DESCRiPTION ALL THOSE three certain pieces or p~rcels of land situate in the Bor- ough of Camp Hill, County of Cum- borland and State of Pennsylvania, known as Lots Nos. 48, 49 and 50 on the Plan of Lots known as South Earlington said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in Plan Book I, page 8 a.nd more pm-tlcularly bounded and described as follows, to wit: BEGINNING at a point on the Southern boundary line of Colum- bia Avenue at the distance of one hundred eighty (180) feet measured in a.n Easterly direction along Co- lumbia Avenue from the Southeast comer of Columbia and Princeton Avenues; thence in a Southerly di- rection along the Eastern boundm-y line, along Lot No. 47 on said Plan, one hundred twenty-fiv~.-/-nd sixty-~vo one-hundredths (125.62) feet. more or less, to a point on the Northerly line of a ten [10) foot al- ley: thence in an Easterly direction along said alley ninety [90) feet to a point; thence in a Northerly direc- tion along the line of Lot No, 5i, on said PIa~, one hundred twenty-five and sixty-two one-hundredths (125- .62) feet, more or less, to a point on the Southerly line of Columbia Av- enue; thence in a Westerly direc- tion along Columbia Avenue ninety (90) feet to the place of begirmmg. HAVING a frontage of mnety (90) feet on the South side of Columbia Avenue and extending back an even width to said ten (10) foot alley. Tax Parcel #22-0533, Parcel 218. TITLE TO SAID PREMISES IS VESTED IN Linda A. Stepp by Deed from Linda A. Stepp, Executrix of the Last Will and Testament of Nila M. Stepp, deceased dated 7/26/ 1989 and recorded 7/26/1989 in Record Book 34-B, Page 733. Advance Costs: Assessed Valuation: Real Debt: Interest Attorney writ costs Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge Law Journal Patriot News Share of bills Distribution of proceeds Sheriff's deed Current Taxes REAL ESTATE SALE #28 ATTORNEY Frank Federman $1,500.00 99,190.00 Writ No. 2002-5141 Civil Term Bankers Trust Company of New York et al VS Linda A. Stepp 2809 Columbia Ave. Camp Hill, PA 17011 $97,124.17 5,797.11 926.33 30.00 c/o0,09 15.00 15.00 30.00 10.00 1.00 19.32 15.00 20.00 316.55 244.54 28.90 25.00 40.50 1,766.81 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to taw, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and Tt~e Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were estabfished March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. as L~s N~s. 48~ ~; IOlan of l~s CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishJng the notice or publication attached hereto on the above stated dates Total $ 244.54 Publisher's Receipt for Advertising Cost ~., publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general ge receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. REAL ESTATE SALI~ NO. '~8 Writ No. 2002-5141 Civil Bankers Trust Company of New York, as Trust Administrator of Ace Securities Corp. Home Equity Loan Trust Series 2001- AQ1 Asset Backed Pass-Tarough Certificates Under the Pooling a-nd Servicing Agreement Dated as of April 1. 2001 VS. Linda A. Stepp Atty.: Frank Federman DESCRIPTION ALL THOSE three certain pieces or parcels of/and situate in the Bor - ough of Camp Hill, County of Cum- berland and State of Permsylvania. lmown as Lots Nos. 48, 49 and 50 on the plan of Lots knov, m as South Earlington said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in plan Book 1, page 8 axed more particularly bounded described as follows, to wit: BEGINNING at a point on the Southern boundary line of Colum- bia Avenue at the distmqce of one hundred eighty (1801 feet measured in an Easterly direction along Co- lumbia Avenue from the Southeast --~eum sm3--rw~6~6~e~dredths .62) feet. more or less. to a point on the Southerly line of Columbia Av- enue: thence in a Westerly direc- tion along Columbia Avenue ninety (90J feet to the place of beginning. HAVING a frontage of ninety (90) feet on the South side of Columbia Avenue and eXtending back an even width to said ten [10) foot alley. Tax Pared #22-0533, Parcel 218. TITLE TO SAID PREMISES IS VESTED IN Linda A. Stepp by Deed (~h Marie Coyne, E~itor SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER. 2003 berlamd and State of Peralsy[vama. known as Lots Nos. 48, 49 and 50 on the Plan of Lots knoval as South Earlington said Plan being recorded in the Office of the Recorder of Deeds in and for said County or' Cumberland in Plan Book 1, page 8 and more particniarly bounded arid described as follows, to wit: BEGINNING at a point on the Southern boundary lilxe of Colum- b~a Avenue at the distamce of one hundred eighty f180) lbet measured in ax Easterly direction along Co- lumbia Avenue from the Southeast corner of Columbia and Princeton Avenues; thence in a Southerly di- rection alot~g the Easteva boundary line. along Lot No. 47 on said Plan, one hundred twenty-five and sixty-two one-hundredths (125.621 Northerly line of a ten [101 foot al~ ley: thence in an Easterly direction along said alley ninety (901 feet to a point; thence in a Northerly dlrec- tion along the line of Lot No. 51. on said Plan. one hundred ~venty-?~ve and sixey-two one-hundredths/12fi- .621 feet, more or less, to a point on the Southerly line of Columbia Aw enue; thence in a Westerly direc- tion along Calumbia Avenue ninety {90} feet to the place of beginning. HAVING a frontage of ninety /bet on the South side of Columbia Avenue and extending back an even width to said ten {10) foot alley. Tax parcel #22-0533, parcel 218. TITLE TO SAID PREMISES IS VESTED IN Ltnda A. Stepp by Deed from Linda A. Stepp, Executrix of the Last Will and Testament of Nila M. Stepp, deceased dated 7/26/ 1989 and recorded 7/26/1989 in Record Book 34-B. Page 733.