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Home My WebLink About00-00723 ~ ~ -"-,.- ,I , -~ '"^",---- SHERIFF'S RETURN - REGULAR CASE NO: 2000-00723 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK ET AL VS MCCOURT COLLEEN A KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCCOURT COLLEEN A the DEFENDANT , at 0018:32 HOURS, on the 23rd day of February, 2000 at 237 WOOD ST ( CAMP HILL, PA 17011 by handing to COLLEEN MCCOURT a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: , ~1?t?~~~~ R. Thomas Kline Sworn and Subscribed to before 02/25/2000 JAFFE~y:"'E~~~ ~ Depub Sheriff me this ;J,J .......JL-.day of ~ ;;L1)'lrO A.D. ~/U- Q, f1,.~~~, ~,~ '. P othonotary . t;:;,;',~Uf{,_ ~" ~ Ca_ \ JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE LD. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, P A 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. V. COLLEEN A. MCCOURT CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 AFFIDAVIT OF SERVICE BRIAN H. SMITH, ESQUIRE, being duly sworn according to law, deposes and says that on q/7- ~oo, he did send by regular mail, postage prepaid, a true and correct copy ofthe Notice of Sheriff's Sale of Real Property regarding the above-captioned matter to: The Bank of New York as Trustee Pursuant to the Terms of that Certain Pooling and Servicing Agreement Dated as of November I, 1998, Related to Metropolitan Asset Funding, Inc. II, Mortgage Pass-Through Certificates, Series 1998- B c/o MetWest Mortgage Services, Inc. 601 W. First Avenue Spokane, WA 99201-5013 A true and correct copy of each Certifi Cumberland County Domestic Relations Dept. 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, Pa 17013-3387 of Mailing is attached hereto. BRIAN H. SMITH, ESQUIRE Attorney for Plaintiff Sworn to and suQ,ije,ribed before me this25" day o~()(JO..".,." hL /~ww- / Notary Public ':';;c<;S",:>~~___ NOTARIAL SEAL ----,- STEPHANIE Ii. 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" 0 3 g.~. ::; 0 () 0 ~i~ ,. 0 <l w " L 00 ,~~ ~I " I----L-I ~ 1---1 ..., ..... -7( i li~<'~""'" - .;..,~...;"~. ,.. ~- ,_. , , liimIIilIlIIIl~~l1ti1J1lf~lJIJI.Wf1ll\1. ~ ,'-~_ '0"- ~"'"=,~, ".~ ~ (') c: -oS:: mCD --.,..rr! 2::::(:' -c (f)rP" ;:$ :~- ~t5 ::t>(~ ZC'i >, c 2:: ::t , , t:"' ..,... CJ c:J "" 0'1 " N ~ :7:: >O;;:.""7j :,:~,'f~ 6;:: ..-1....) f'~ c:5rn g -< --.J " :.J!!: ~, . .. . J '~;: '. 1 ~;. l . ,. STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ______________________________________________________________________________Ilecorderof Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which h_n___________ Bank of New York Tr ____________________________________________________________________________________ ~ thegr.antee 7th the same having been sold to said grantee on the _______________n_________nn____n__h____n_ day of March 2001 ____n___h____n______________n_hh__ A. D., ; n___' under and by virtue of a wriL______n_____ Execution . 11 th _ __________ _______________________h n _n ___ ___ _ISSUed on the h_ ___ __ n_ _______ nn __ __ n__ ___h__ Sept day of _____________________n___ A. D., 2000 _____, out of the Court of Cornman Pleas of said County as of Civil 2000 ______________________________.,.__ ___ ____________ _________ _________ ________ _ _____ _ Term, : 723 Bank of New Tr Number __________n__' at the suit of _________________n___n___n_n__n________n__h______n_____ Colleen A McCourt ________ _________n_________ ___ n __ against_n __ _ __n_____ __________n n __ __ ________________ _n ~ 241 160 dnly recorded in Sheriff's Deed Book No. __n________, Page _nn_______. / IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office th~ .dJL'!!::n_ day of --~-,------~,A.-'d A,,~)I_02~L ~-61_~-,;.;;,. Recorder of ~ds. Cumberland County, Ca~isle. PA My Commis~OIl EKpires tl1e First Monday of Jan. 2002 1" ~ . The Bank of New York et al -Vs- Colleen A. McCourt In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-723 Civil Dawn 1. Kell Deputy Sheriff who being duly sworn according to law, says on October 12, 2000 at 7:32 o'clock P.M. EDST, she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the wihtin named defendant to wit: Colleen McCourt, by making known unto Patrick McCourt, husband at 237 Wood Street, Camp Hill Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. William Diehl Deputy Sheriff, who being duly sworn according to law, says on October 9, 2000 at 3:00 o'clock P.M. EDST, he posted a copy of real Estate Writ Notice Poster and Description on the property of Colleen McCourt located at 237 Wood Street, Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant to wit: Colleen McCourt by regular mail to her last known address 23 7 Wood Street, Camp Hill, P A. This letter was mailed under the date of October 13,2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7,2001 at 10:00 o'clock A.M., E.S.T. and sold the same for the sum of$1.00 to Attorney Leon Haller for The Bank of New York As Trustee. It being the highest bid and the best price received for the same The Bank of New York As Trustee, of601 West First Avenue Spokane, WA, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $770.80 it being costs. Sheriff s Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deeds 30.00 15.11 15.00 15.00 30.00 10.00 .50 1.00 18.60 .69 15.00 20.00 20.00 288.65 216.60 23.15 25.00 26.50 770.80paid by attorney 3-14-01 " Sworn and subscribed to before me This cS'!!:' day of Cfr:P 2001 A.D'~:r (). ~1A.9f( Pr 0 otary ~~ri-t:P~ R. Thomas Kline, Sheriff ~~~~;~~ep~dt: u;; tjl>. &pl ~. J.rU C)e..- , 1) '> /7 J.-J,' 95'5 Il to. 0 fuP' "ISf . [)(.... j ,-", oJ.' --," ~''''''~" ~ ~ ~- ~""'''''\liIIlf"~"''~' ..~ -~ lr..'"I'lI'JOI,U~'1 '"'~ .- "",. W,. r{ . " JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE 1.0. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff 1HE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO 1HE TERMS OF 1HAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE PASS- TIIROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Trustee c/o MetWest Mortgage Services, Inc., Plaintiff in the above action, sets forth as of the date that the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 237 Wood Street Camp Hill, PA 17011 (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") '''''"~ ~ Joo~o '~"""""",:.lli<"'"'''''''' ""'- ~ ~ . J~" . ; ::ig- < 1. Name and address ofOwner(s) or Reputed Owner(s): Colleen A. McCourt 237 Wood Street Camp Hill, PA 17011 2. Name and address ofDefendant(s) in the judgment: Colleen A. McCourt 237 Wood Street Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. , Name and address of the last recorded holder of every mortgage of record: The Bank of New York as Trustee Pursuant to the Terms of that Certain Pooling and Servicing Agreement Dated as of November 1, 1998, Related to Metropolitan Asset Funding, Inc. n, Mortgage Pass-Through Certificates, Series 1998-B c/o MetWest Mortgage Services, Inc. 601 W. First Avenue Spokane, WA 99201-5013 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Dept. 13 N. Hanover Street Carlisle, P A 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, Pa 17013-3387 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: N/A 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 1/.(cf) Bro!SMITIl, !'.SQUIRE Attorney for Plaintiff "-- ~" "~"'"'~-'-.,'=.' ...J..-._"" ~. lQ,\c . ' DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, 'Situate in the Township of Hampden, Cumberland County, and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the North side of Wood Street Eighty five (85) feet West of the Western line of Holly Drive; thence along the Northern line of Wood Street, South Eighty-three (83) degrees Fifty six (56) minutes West Eighty five (85) feet to a point Forty five (45) feet West of the line dividing Lots Nos. 157 and 158; thence in a line paralleling the last mentioned dividing line North Six (06) degrees Four (04) minutes West One Hundred (100) feet to a point; thence North Eighty three (83) degrees Fifty six (56) minutes East Eighty-five (85) feetto a point Forty (40) feet East of the line paralleling the last mentioned dividing line South six (06) degrees Four (04) minutes East One hundred (100) feet to the place of beginning. BEING the Western Forty (40) feet of Lot No. 157 and the Eastern Forty five (45) feet of Lot No. 158 in the Plan of Lots of the Hollywood Development Company, Inc. which said Plan of Lots is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 9, page 17. Parcel # 10-20-1850-037 - _.1 i!.O;, , , .. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland NO, 2000-723 CIVIL)f9: Term CIVIL ACTION - LAW COUNTY: To satisfy the debt, interest and costs due 'IlE Bmk of N;:w York, as trostre p.JrSJaIlt to th:> terns of tlE:t oerta:in Rol.irg am servi.cirg ~ d:rt:ro as of N:Jvmber 1, 1':l':l!l, ReJatej to u"LLOJPUtan Cl.S!tt 1:I.lI:r::l1.rg, lrI::., II, M:rtqaqe rA"..rinJgh oerI'if,,...,,res, series 1998--B c/o ~ J\t:n:Qaoe Services, In::. PLAINTIFF(S) from Cblleen A. M:i'.a.n:t; 237 W:xrl S\:reet, Carrp Hill, Fa 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See leqal descri pl'i nn (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of . '. r ~; : " .. GARNISHEE(S) as follows: , ' , ' and to notny the garnishee(s) that: (a) arl attachment has been issued; (b) the garnishee(s) islare 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 subjeclto attachment is found in the possession of anyone other thana named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. % L.L. .50<:: Due Prothy $1. 00 Other Costs REQUESTING PARTY: Name Brian H. Smith, Esq. Address: 7848 Old York Road, , Suite 200 Elkins Park, Pa 19027 Attorney for; Plaintiff Telephone: (215) 635-7200 Supreme Court ID No. n~n?7 Curtis R. Long, , ' Prothonotary, Civil Division by {kMAd.u{jJ~fJJ&h ~ Date: September 11, 2000 ~;,l:~.',"",,"~' ',~k. ~ fI " -1_1IIliIWHli~IDliO.. \ l-~._.......~-'-",h'"" ~ , - ' . .' , REAl ESTArE SALE No. ~ i .- -------'- un ~ I (.J..Pi> the sheriff levied upon the defendant::. interest in the real property situated in ~ t. ~^h<7~ Cumberland County, Pa.. known and numbered as:o.37 vddJ ~~ and more f"lscr!bed on exhibit "An flled with this writ and by this reference incorporated herein. 'laIrr..J,?:I:..k1r~ BY,y~ - ' '" i ~_:' i ! ! ',1 :J c\ , Ii Z j d3S J 1 f~:~;--lJ~~. " ., \c', ,J ..'" ~ ! -.' <', ',~ -" ,,,,," .. ~. '- l' e> I:lV\I CViJ c::::::J ~ &VV '" ----; "~i<l.il ""' ._~ ~.~" ...........-- ~~ I W'li;k' JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE J.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF mAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., IT, MORTGAGE PASS- TIIROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT TillS FIRM IS A DEBT COLLECTOR Al'TEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Colleen A. McCourt Your house at 237 Wood Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on December 6, 2000, at 10:00 a.m., in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $139,229.1 0 obtained by The Bank of New York as Trustee c/o MetWest Mortgage Services, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the amount of the judgment plus costs, the back payments, late charges costs and reasonable attorneys fees due. To find out how much you must pay, you may call Brian H. Smith, Esquire at (215) 635-7200. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. k_ I e_ - L "~ ".r,'_ ~......, ""-'" ~ ~ - , . YOl) 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Brian H. Smith, Esquire, at: (215) 635-7200. 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 BrianH. Smith, Esquire, at (215) 635-7200. 4. If the amount due from the buyer is not paid to the Sherif!; 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 on January 5, 2001. 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 January 5, 2001. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE TillS 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 COURT ADMINISTRATOR 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Very truly yours, JAFFE, FRIEDMAN, SCHUMAN, s~ NEMEROFF & APPLEBAUM, P.C. Brian H. Smith BHS:srm - .~ . ' , . DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, Situate in the Township of Hampden, Cumberland County, and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the North side of Wood Street Eighty five (85) feet West of the Western line of Holly Drive; thence along the Northern line of Wood Street, South Eighty-three (83) degrees Fifty six (56) minutes West Eighty five (85) feet to a point Forty five (45) feet West of the line dividing Lots Nos. 157 and 158; thence in a line paralleling the last mentioned dividing line North Six (06) degrees Four (04) minutes West One Hundred (100) feet to a point; thence North Eighty three (83) degrees Fifty six (56) minutes East Eighty-five (85) feet to a point Forty (40) feet East of the line paralleling the last mentioned dividing line South six (06) degrees Four (04) minutes East One hundred (100) feet to the place of beginning. BEING the Western Forty (40) feet of Lot No. 157 and the Eastern Forty five (45) feet of Lot No. 158 in the Plan of Lots of the Hollywood Development Company, Inc. which said Plan of Lots is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 9, page 17. Parcel # 10-20-1850-037 .- " ,,', H '1 ;1 ! i II I, 'j ,. , , I " I' ~ THE THE PATRIOT NEWS SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office ao_d place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of Th e Patriot,News and The Sundav 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 established 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 31 st day of October and the 7th and 14th day(s) of November 2000. 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 tirne, place and character of publication are true; and That he has personal knowledge of the facts afoJesaid 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 :::',~:~:~:."' " ~.~ '" .. fu'~'::::""~r="=:'~~"~mmm COpy Sworn to and subscribed before m 1st day of ece er 2000 A.D. S ALE #38 Notarial Seal Terry L. Russell, Notary Public Harrisburg, Dauphin County My Commission Expires June 6, 2002 Member, Pennsylvania Association ot Notaries -- RtAC-~jrTA1E""-~Al.~-NO:-38- ~-_. --0__- __ _ Wnt No.200Q-00723 II Civil Term The Bank of New York, As Trustee Pursuant I To Th" ,e Tenns Of That Certain Pooling and - ~roI_lc\ng Agreement Dated As Of r _~Novem~r 1, 199B Related To Metropolitan . ,:__~lFuncljng, Inc., II, Mortgage " . . Pass-Through Certificates, Series 1998--8 ~:,',~:' ~o M;:::,rt.;~it~ec:u:ceSJ rn~ ~~:.~!\Y:,e,ri.n Smnh ..-cc c- ,,-: OESCRt IONi ~lJ.JJ>~:CCt)lrA!N piec, or pace,! of land. ~ffi Eie ~~in~5 and improvements thereon ' "- erei:lea, Slftlate 111 the Township of Hampden,. Cumberla!ld County. and State of I Pennsylvama bounded and described as follows,to-wit; BEGINNING at a ~nt on the North side 01 I _ ~~:"S~~t E!&~:y,!2.~5) Jeef We~t of ~e r My commission- ~xpires J~ne 6, _ 200"2 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 215.10 1.50 216.60 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... 1iI1._I~W' ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : 55. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esqnire, 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 ofthe said Cumberland Law Journal on the following dates, V1Z: OCTOBER 27, NOVEMBER 3,10,2000 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 true. -"-,,--_., - REAL ESTATE SA,U!: NO. 38 I Roger M. Morgenthal, Editor Writ No. 2000-00723 Civil The Bank of New York, As Trustee Pursuant To The TenUS of That Certam Pool1ng and SeIVicing i Agreement Dated as of November 1, 1998 Related to Metropolitan Asset Funding. Inc.. II, Mortgage Pass-Through Certificates, Series 1998-B% Metwest Mortgage SeIVices, InC. vs. Colleen A. McCourt Atly.:Brlan H. Sm1th DESCRIPTION ALL THAT CERTAIN piece or arcel of land. with the bOOdlngs ' ~~<:mmt~.ther.eOJLen;.c;k<1.., SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 NOTARl l S~AL LOIS E. SNYDER, Notary Pu~1ic Cailitl. Boro. Cumberland Caunly. PA My Commillion Expi... !.\arCh S. 2(l()1 . ,-I -~~'" . . BRIAN H. SMITH, ESQUIRE J.D. NO. 65627 JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.c. 7848 Old York Road, Suite 200 Elkins Park, l' A 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF TIIAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1,1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., IT, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 1998-B clo METWEST MORTGAGE SERVICES, INC. 601 W. First Avenue P.O. Box 113200 Spokane, WA 99210-5013 CUMBERLAND COUNTY COURT OF COMMON PLEAS I NO. ..2000 -?.:)J (70l'l '7f;, v. COLLEEN A. MCCOURT 237 Wood Street Camp Hill, l' A 17011 NOTICE Yau have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOUSHOUJLD TAKE THIS PAPER TO YOlJRLAWYERAT ONCE. IF YOU DO NOTHA VE 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, pA 17013 (717) 249-3166 1-800-990-9108 ~~ ~~=" . ~ " I. U:\DATA\HOME\JGEFTMAN\MEf.MOR\MCCOUR1\COMPLAlN. 1/18/00 BRIAN H. SMITH, ESQUIRE I.D. NO. 65627 JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 TIlE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE PASS-THROUGH CERTIFICATES , SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. 601 W. First Avenue P.O. Box 113400 Spokane, WA 99210 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMONPIEAS NO. v. COLLEEN A MCCOURT 237 Wood Street Camp Hill, PA 17011 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffis The Bank of New York, as Trustee pursuant to the terms of that certain Pooling and Servicing Agreement dated as of November 1, 1998, related to Metropolitan Asset Funding, Inc., II, Mortgage Pass- Through Certificates, Series 1998-B, c/o MetWest Mortgage Services, Inc., having a place of business at 601 W. First Avenue, P.O. Box 113400, Spokane, WA 99210. 2. Defendlllllt is Colleen A. McCourt, who is an adult individual presently residing at 237 Wood Street, Camp Hill, PA 17011. 3. On or about July 31, 1998, said Defendant made, executed and delivered a Mortgage upon the premises, 237 Wood Street, Camp Hill, PA 17011 more particularly described in Exhibit "A," which is attached hereto and incorporated by reference herein as though fully set forth at length, to Columbia National Jrncorporated, which Mortgage is recorded in the Office of the Recorder of Deeds '-.:f-c,; ~,... "0.' -ik, U:\DATA\HOME\JGEFTMAN\MET.MOR\MCCOURTlCOMPLAIN. 1/6/00 of the County of Cumberland in Mortgage Book No. 1473, Page No. 275, and the terms of which are incorporated by reference herein as though fully set forth at length. 4. The Mortgage was last assigned to Plaintiff by written assignment, which is recorded in the Office of the Recorder of Deeds for the County of Cumberland in Assignment of Mortgage Book No. 615, Page No. 1027, and the terms of which said assignment are incorporated by reference as though fully set forth at length. 5. A description of the land and premises subject to the said Mortgage is set forth in Exhibit "A" attached hereto and incorporated by reference herein as though fully set forth at length. 6. The monthly payment on account of amortization of the principal of the Note secured by said Mortgage, interest on the Note secured by said Mortgage and other items set forth in said Mortgage, such as fire insurance and mortgage insurance due on June 1, 1999, and on the first of each month thereafter, are due and have not been paid. 7. As a result of Defendant's nonpayment, the said Mortgage is in default and the entire principal of said Note and all interest due thereon, together with late charges, mortgage insurance premium, attorney's commission for collection, and other items as set forth in said Mortgage and Note, are now due and payable. A true and correct copy of said Note is attached hereto as Exhibit "B," the terms of which are incorporated by reference herein as though fully set forth at length. 8. On October 18, 1999, a letter wa,s sent to Defendant, advising of Plaintiff's intent to foreclose within thirty (30) days pursuant to 41 P.S. Section 403. A true and correct copy of said letter is attached hereto as Exhibit "C." 9. On or about October 18, 1999, notice under the Homeowners Emergency Mortgage Assistance Act, Act 91 of 1983, was given to Defendant. A true and correct copy is set forth as Exhibit "D." 10. The following amounts are now due and payable: 2 "~~ ,~ .~- "'" "-< '~'-'ID,- H:\DATA\HOME\1GEFTMAN\MET.MOR\MCCOURT\COMPLAIN 212100 Principal of Mortgage Debt Due and Unpaid 111,868.95 Late Charge to 1/31/00 at $43.25/mo. 346.00 Interest from 5/1/99 to 1/31/00 at $26.05/diem 7,189.80 Attorney's Commission for Collection 5,593.45 Information Search & Cost of Suit 550.00 NSF Fees 40.00 Speed Pay Fees 20.00 Appraisal 100.00 Escrow/Deficit - June 1, 1999 to August 1, 1999 MontWy Escrow Amount: $258.47 775.41 Escrow/Deficit - September 1, 1999 to January 31, 2000 MontWy Escrow Amount: $262.14 1.310.70 Amount Due $127.794.31 WHEREFORE, Plaintiff demands judgment for the amount due of $127,794.31, plus per diem interest at $26.05, late charges at the rate of $43.25 per month, escrow deficits at $262.14 per month and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage, and for the foreclosure and sale of the subject premises. JAFFE, FRIEDMAN, SCHUMAN, SC10LLA, NEMEROFF & APPLEBAUM, P.C. BY: ~ BRIAN H. SMITH, ESQUIRE Attorney for Plaintiff 3 oj" -. -. ~I. '.,;.~ VERIFICATION I, LUKE RAYNOR, hereby state that I am a duly authorized agent for the Plaintiff in this action and verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.s4904, relating to unsworn falsification to authorities. LV DATE: 2/( too U:\DATA\HOME\TGEFTMAN\MET.MOR\MCCOUR1\VERlF -I . ~ L ~ --~".~,~ - .. .. -:-. ';,:~ti!;:\;~1f;::;;~:~~,;~,:;'~\~i~,l:.ii'~~~!1?~;i!.~~~:;1~;!~'B:~t~b~F~'7i~~\~~~J~1~~~]~~:~,~I~1r~~~~llg~:~~l~l~]~'" DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, Situate in the Township of Hampden, Cumberland County, and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the North side of Wood Street Eighty five (85) feet West of the Western line of Holly Drive; thence along the Northern line of Wood Street, South Eighty-three (83) degrees Fifty six (56) minutes West Eighty five (85) feet to a point Forty five (45) feet West of the line dividing Lots Nos. 157 and 158; thence in a line paralleling the last mentioned dividing line North Six (06) degrees Four (04) minutes West One Hundred (100) feet to a point; thence North Eighty three (83) degrees Fifty six (56) minutes East Eighty-five (85) feet to a point Forty (40) feet East of the line paralleling the last mentioned dividing line South six \06) degrees Four (04) minutes East One hundred (100) feet to the place of beginning. ", .. .....-,...... :'::':.It BEING the Western Forty (40) feet of Lot No. 157 and the Eastern Forty five (45) feet of Lot No. 158 in the Plan of Lots of the Hollywood Development Company, Inc. which said Plan of Lots is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 9, page 17. Parcel # 10-20-1850-03 7 ;;::,;;:;:':~~ ):;':;~\,ii:; :;.:~: ,j>;~.~ 1 l , > , ... --.: ; : . P.:. ."... '., ,.: . .. " .:".,_ . .. ___' .;.~ '.;. ,;':, :~:';:t ,;::i~ -h :~;.;:;i:~;~:~::i;::i'~~~:'.~;:~;~'~:''-:~i.::f:t~ ~:,;'~::' .':' .', . . . .. ..;::,E II! <#./ G',/:;~(~i;;-~;:~{~~-";~f;\{,'&'~~';";,;:,~",,;;,,;~,:'~'ic::c:,,:;j:":.;i;;; - .~ -- ( ....... I 03581635 NOTE July 31, 1998 [Date] Camp Hill [Cily] 237 Wood Street Camp Hill, PA 17011 [Property Address) Pennsylvania (S","] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 112,500.00 "principal"), plus interest, to the order of the Lender. The Lender is columbia National (this amount is called Incorporated I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder. . . 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 8.500 %'. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the 1st day of each month beginning on September 1 1998 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I ,may owe under this Note. My monthly payments will be applied to interest before principal. If, on Augus t 1, 2028 . , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date. " I will make my monthly payments at P.O. Box 3050, Columbia, MD 21045-6050 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 865.03 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a "prepayment." When I make a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a fu1l prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that tbe interest or other loan charges co1lected or to ~e co1lected in connection with this loan exceed the permitted limits, then: (i) any such loan charge sha1l be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I oWe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAll..URE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments . If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days. after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the fu1l amount of each monthly payment on the date it is due, I will be in default. MUL TI5T ATE FIXED RATE NOTE. Single Family. FNMA/FHLMC Uniform Instrument .- -SR 19105).04 Form 3200 12/83' ~ Amended 5/91 VMP MORTGAGE FORMS. f8001521-7291 ~.gB' ot 2 Inhlal,,: Cm E Y/I/L:? 17/# // 111111I111111 IIIU111111I11 11111111 ~- .0_"" . .-~ <-- (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, .the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or mailed to me. (D) No Waiver by Note Holder . Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder wlll still have the right to do so if I am in default at a (ater time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it .or by mail~g it by first class mail to me at the Property Address above or at a different address if I give the NOle Holder a nottce of my'dtfferent address. ' Any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one personsigtlS this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that anyone of us may be required to pay all of the amounts owed under this Note. , 9. WAIVERS land any other perSOn who has obligations under this Note waive the rights of presentment and nOlice of dishonor. "Presentment" means the right to requite the Note Holder to demand payment of amounts due. "Notice of dishonor" means the right to require the No.te Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust or SeCurity Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as' follows: Transfer of the Property or a Beneficiallnterest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person), without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender 'exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument., If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies pennilted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND'SEAL(S) OF THE UNDERSIGNED. (;1.&P'?A1.U ,4lr ('~TJ A r (Seal) Colleen A. McCourt .Borrower SSN:168-52-1940 SSN: (Seal) .Borrower (Seal) (Seal) ~Borrower -Borrower SSN: SSN: . .:!-:. " [Sign Original Only] .' 1..i.:CIIDr-5R 19"061,_04": IH" '.' -: -~ " 'I. . wmtOI:IT AECOURSE PAY TO THE (llIIDI!P . Metropolitan. ~ ,_~1tl", <>>.,100. ~NA_1NCO~ ' BY: ~~~~ /1vi),0 - - ~~ lS JAFFE.. FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM A PROFESSIONAL CORPORATION GARY JAFFE" PETER S, FRIEDMAN*+ ANTHONY J. SCIOLLA. JR. KERRY SCOTT SCHUMAN' DAVID A, APPLEBAUM. ROBERT H. NEMEROFF EUGENE M. SCHLOSS. JR. JILL EVANTASH SCHUMAN*+ DANIEL D, MCCAFFERY* BARBARA M. WERTHEIMER' JEFFREY R. HOFFMANN. . BRIAN H, SMITH THOMAS A. NELSON, 1Il* . !UTORNEYSATlAW . SUITE 200 7848 OLD YORK ROAD ELKINS PARK. PA 19027 (215) 635.7200 TELECOPY (215) 635.7212 EMAIL JFSSNA.LAW@CWIXMAIL.COM NEW JERSEY OFFICE 4390 U:S. ROUTE I NORTH PRINCETON. NJ 08540 (6091279.9797 OF COUNSEL RICHARD J. MOLISH ARTHUR SILVERMAN STANFORD S. HUNN OUR FILE NO. ll3? 034 "ALSO ADMITTED TO PRACTICE IN NJ . Ll M IN TAXATION -ALSO Al1MITTEnro rRA<...'TICE IN FL October 18, 1999 CERTIFIED MAIL RETURN RECEIPT REQUESTED AND REGULAR MAIL Ms. Colleen A. McCourt 237 Wood Street Camp Hill, PA 17011 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by MetWest Mortgage Services, Inc. (hereafter we, us or ours) on your property located at 237 Wood St., Camp Hill, PA 17011, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1.123..50 for the months of June 1999 through Au~t 1999 and $1.127.17 for the months ofS~tember 1999 through October 1999. Late charges have also accrued to this date in the amount of $344.50. NSF Charges have accrued in the amount 0[$40.00. Speed Pay has accrued in the amount of $20.00. The total amount now required to cure this default, or in other words, get caught up. in your payments, as of the date of thls letter, is $6,029.34. '" -You-may-curethis default within THIRTY (30) DAYS of the date of this letter bv paying to us the, I amount of $6.029.34. plus any additional monthly pavrnents and late charge which may fall due during this period. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. Iffu]] payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a law suit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriffto payoff the mortgage debt. If we refer your case to Out attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00.. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty-day period. vou will not be ~)(;/ /#/ /- /1 L // October 18,1999 Page 2 JAFFE, FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF I< APPLEBAUM A PROFESSIONAL CORPORATION required to pay attorney'" fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the ri~t to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments. plus anv late or other charges then due. as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs Sale could be held would be approximately March 2000. A notice of the date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may frod out at any time exactly what the required payment wi]] be by calling us at the following number: (215) 635-7200. This payment must be in cash, cashier's check, certified check or money order, and made payable to us at the address stated above. You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff s Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HA VB 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. YOU MAY HA VB THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 PRIORTO OR AT THE SALE (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES YOUHA VErnIS RIGHT TO HA VB THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default. the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. ?!iy yours, /.i1~ RRY S. SCHUMAN KSS:gb cc: MetWest Mortgage Services, Inc. (#1352004) U:\DA TA\HOME\JGEFTMAN\MET.MOR\MCCQURT\ACT6 ~_.~M_ JAFFE.. FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM A PROFESSIONAL CORPORATION GARY JAFFE" PETER S, FRIEDMAN*+ ANTHONY J. SCIOLLA, JR. KERRY SCOTI SCHUMAN* DAVID A. APPLEBAUM. ROBERT H. NEMEROFF EUGENE M. SCHLOSS. JR, JILL EVANTASH SCHUMAN*+ DANIEL D. McCAFFERY* BARBARA M. WERTHEIMER' JEFFREY R. HOFFMANN. . BRIAN H. SMITH THOMAS A. NELSON, Ill" <It AITORNEYSATlAW <It SUITE 200 7848 OLD YORK ROAD ELKINS PARK, PA 19027 (215) 635.7200 TELECOPY (215) 635.7212 EMAIL JFSSNA.LAW@CWIXMAIL.COM .ALSO AnM1TfEt1T0 PRAl."TICE IN NJ ,LLMINTAXATION ACT 91 NOTICE .ALSO Al'JMITIEDTO PRAl.,ICE IN FL IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. Date: October 18, 1999 Re: Customer(s): Colleen A. McCourt Account No.: 1352004 Address: 237 Wood Street, Camp Hill, P A 17011 TO: Ms. Colleen A. McCourt 237 Wood Street Camp Hill, PA 17011 FROM: MetWest Mortgage Services, Inc. c/o Kerry S. Schuman, Esquire 7848 Old York Road, Suite 200 Elkins Park, P A 19027 ;" . -"'~ flc:!li' NEW JERSEY OffiCE 4390 U:S. ROUTE 1 NORTH PRINCETON, NJ 08540 (609) 279.9797 OF COUNSEL RICHARD J. MOLISH ARTHUR SILVERMAN STANFORD S, HUNN OUR FILE NO. 932 034 J You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet the eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. E X rf I g / T ''lJ // ~~, ,--" - .---' I;~~" JAFFE, FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM Under the Act, you are entitled to a temp6fl'&Y'~bm~~I:'I'8~e on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting , with a representative of this lender, or with a designated consumer credit counseling agency." The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage forectosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Kerry S. Schuman, Esquire 7848 Old York Road, Suite 200 Elkins Park, PA 19027 Telephone: (215) 635-7200 The names, addresses and telephone numbers of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $6,029.34. That sum includes the following: June 1999 - August 1999 payments @ $1,123.50/month September 1999 - October 1999 payments @ $1,127.17/month Late Charges NSF Charges Speed Pay Total 3,370.50 2,254.34 344.50 40.00 20.00 $6,029.34 If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available. funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your 2 ',- ~~ ~ _'-'-' J '" JAFFE, FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM application. During that additional time, 'l:f<'l~Cl'sffi'!j''i'M5l5@'edings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call (717) 780-1869. In addition, you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to FOreclose Mortgage". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. ~frulY yours, 7~ Kerry S. Schuman KSS:gb Enclosure (Counseling Agency List) U:\DATA\HOME\JGEFrMAN\MET.MOR\MCCOURi\ACT91 cc: MetWest Mortgage Services, Inc. (#1352004) CERTIFIED MAIL RETURN RECEIPT REQUESTED AND REGULAR MAIL 3 _~c , ,'''' ,- ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA/S HOMEOWNER'S .EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. If you need more information call the Pennsylvania Housing Finance Agency at 1 (800) 342-2397 La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en du casa. Si no comprandeel__G_Of,l..t.~n;i.Jio de esta notificacion obtenga uns traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. .=-~ . ~ ~ 1736 , ~. ,,",&;;'i! STATEMENTS OF POLICY Commission on Economics Opportunity of Luzerne Count)' 163 Amber Lane .' Wilkes-Barre, PA 18702 (570).826-0510 or (800) 822-035~ FAX (570) 82~-1665-Call Before Faxing (717) 455-4994 Hazelton FAX (717) 455.5631-Call Before Faxing (717) 836-4090 Tunkhannock cces of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 ' FAX (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-975L_,. FAX (717)234-2227 Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX (814) 453-5749 John F. Kennedy Center, Inc 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227' Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX (215) 765-1427 CCCS of Delaware' Valley , 1515 Market Street-Suite 1325 Philadelphia, PA 19107 (215) 563-5665 FAX (215) 864-2666 Media Fellowship House 302 S. Jackson Street Media, PA 19063 (610) 565-0846 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street . Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981.5310 :; CUMBERLAND COUNTY Financial Counseling Services of Franklin ' 31 West 3rd Street ' Waynesbora, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 DAUPHIN COUNTY Urban League of Metropolitan Harrisburg 2107 North 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 , . " , DELAWARE COUNTY Northwest Counseling Sen.lce 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 FAX (215) 324-8753 RACE 167 W. Allegheny Ave, 2nd Floor Philadelphia, PA 19140 (215) 426-8025 FAX (215) 426-9122 Community Housing Counselor, Inc. P. O. Box 244 Kennett Square, PA 19348 (610) 444-3682 ' FAX (610) 444-8243 PENNSYLVANIA BULl.ETIN, VOL 29, NO. 14, APRIL 3, 1999 ii~- "= ,T ""'".J_\!Iiii.l.1II.!l:IuMIi ~ ~.llbI.'WIliIl - ",-~~~~". . , " -'- .,' ~';..~ 10 (0 ~ ~ "'-). () ~t ~ ~; '-l1't ...a (5 ...c) ( ~ =~~~i.-.....~....."" ~~ ~~.j 2":t,__~ U)"";..- r." <:;-.~ r;-.~ ~~3 >'~;;; :-J -, (') ~:~ o c; -" r:l 'c;:; i 0.. '--1'1 ;:1 ~~~,t] :, ~:~ :.n (,) " < cl'- " . ,-,"1 =< G ~ , " ...... ~~IJ~)IIiUl(~!k. j [1 i'i " i:! JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE LD. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, P A 19027 (215) 635-7200 Attomey for Plaintiff " , THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 V. COLLEEN A. MCCOURT ORDER TO ENTER JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in the above-noted matter in the amount of ONE HUNDRED THIRTY NINE THOUSAND TWO HUNDRED TWENfYNINE and 10/100 ($139,229.10) DOLLARS in favor of the Plaintiff and against the Defendant, Defendant having failed to respond to the Complaint in Mortgage Foreclosure within the statutory period. ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages as follows: Principal of Mortgage Debt Due and Unpaid Late Charges to 12/6/00 @ $43.25/mo. Interest to 12/6/00 @ $26.05/diem Attorney's Commission for Collection Information Search NSF Charges Speed Pay Fees Appraisal Escrow/Deficit - 6/1/99 to 8/1/99 @ $258.47/mo. Escrow/Deficit - 9/1/99 to 1/31/00 @ $262.14/mo. Escrow/Deficit - 2/1/00 to 12/6/00 @ $262.14/mo. $111,868.95 821.75 15,265.30 5,593.45 550.00 40.00 20.00 100.00 775.41 1,310.70 2.883.54 Total "f)RJAN"" S";;', ESQUIRE Attorney for Plaintiff $139,229.10 I HEREBY ASSESS DAMAGES AS ABOVE Pro Prothy IIiIIiItIIioo l_ <" ." ~"~~l~d&IIil' ~tuY."'-~ -~ ~ --'........ >...~ ~.. - (j C .,;: ~\{ U)<, -'.... ....;:.- 1;'\._.) <... [~... r-- Z-";-~'; >C :<S -< r~ C' ,n '~\ r::J r'O 0) .,;:" "--, <."'--, :<': " . " _b. , "'.-,,^! JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE !.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attomey for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- : TIIROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 V. COLLEEN A. MCCOURT CERTIFICATION OF NOTICE I hereby 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 attomey of record, if any, on July 20, 2000, after the default occurred and at least ten (10) days prior to the date of filing this Praecipe. A copy of said notice is attached hereto as Exhibit "A." ~-- BRIAN H. SMITH, ESQUIRE Attorney for Plaintiff ~~ii , ~ '" bo."",~ "U~.~ ,.,- '~-"~~~~""""""~ "d1l1iiilii~. "~..~ ~ ~ - - ~.' '-liIi~ (") c:> C) c e, , , "," r./) U c:::' ;'1 I'll IT -.u ~z ~T ZC S2~~.:' r;: L ~'O;-. ::> c- W;''''' () )> S -'-:1 :':::1 :.') '~ _C-.-' -< .t::-. -< .~ " ,---' I' --',j JAFFE, FRIEDMAN SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM A PROFESSIONAL CORPORATION GARY]AFFE* PETER S. FRIEDMAN*. ANTHONY J, SCIOLLA, JR. KERRY SCOTT SCHUMAN'" DAVID A. APPLEBAUM. ROBERT H, NEMEROFF DANIEL D, MCCAFFERY'" JON D, FOX EUGENE M. SCHLOSS, JR. JILL EVANTASH SCHUMAN"'. JEFFREY R. HOFFMANN.. BRIAN H, SMITH THOMAS A, NELSON, 1II* MARLON R, GROEN* '" ATTORNEYSATlAW '" NEW JERSEY OFFICE 9 TANNER STREET HADDONFIELD. NJ 08033 (856) 795-0351 SUITE 200 7848 OLD YORK ROAD ELKINS PARK, PA 19027 (215) 635.7200 TELECOPY (215) 635.7212 EMAIL JFSSNA.LAW@PRODIGY.NET OF COUNSEL RICHARD J. MOLlSH ARTHUR SILVERMAN OUR FILE NO. 9 3'2d'C't :':';~~~~~~~;~PRACT'CE'NNJ NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT -ALSO ADMITTED TO PRACTICE IN FL DATE: July 20, 2000 TO: Ms. Colleen A. McCourt 237 Wood Street Camp Hill, PA 17011 RE: The Bank of New York, as Trustee Pursuant to the Terms of that Certain Pooling and Servicing Agreement dated as of November 1, 1998, Related to Metropolitan Asset Funding, Inc. II, Mortgage Pass-Through Certificates, Series 1998-B, c/o MetWest Mortgage Services, Inc. V. Colleen A. McCourt; c.P. Cumberland County; No. 2000-00723 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARlNG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 1-800-990-9108 JAFFE, FRIEDMAN, SCHUMAN, SCh~A, JPLEBAUM & NEMEROFF, P.C. gC~1 ,/;L - KEftR'fS.SCHUMAN,ESQUIRE cc: MetWest Mortgage Services, Inc. (#1352004) .~ w . 1_' ,~~u, ;o:g!, o o UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL V ANlA INRE: CYRIL PATRICK MCCOURT, JR. COLLEEN ANN MCCOURT Debtors CHAPTER 13 Bankruptcy No. 1-00-01124 FILED Harrisburg, PA TIME _A.M, , P.M. BANK. OF NEW YORK clo METWEST MORTGAGE SERVICES Movant 1IOl~11; 7 2000 ORDER Clerk, U.S. Bankruptcy Court Per D u Clerk AND NOW, this/~ay of * 2000, at Harrisburg, upon failure of Debtor to file an answer or otherwise plead or appear (or after hearing held and consideration of all evidence, arguments and briefs of Counsel), it is ORDERED and DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 US.C. Section 362, is modified to allow Bank of New York clo Metwest Mortgage Services to continue with foreclosure on, and conduct execution process (through, among other remedies, but not limited to, Sheriffs Sale) regarding, premises known as: 237 Wood Street Camp Hill, PA 17011 ICI;Rqbert J,WqodSlde ROBERT J. WOODSIDE CHIEF BANKRUPTCY JUDGE CC: Movant's Counsel: Brian H. Smith, Esquire 7848 Old York Road Suite 200 Elkins Park, PA 19027 Debtors: Cyril Patrick McCourt, Jr., Pro Se Colleen Ann McCourt, Pro Se 237 Wood Street Camp Hill, PA 17011 Trustee: Charles J. DeHart, III, Esquire P.O. Box 410 Hummelstown, P A 17036 - ,J~ " ~ i:>.. ~, JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P,C. BRIAN H. SMITH, ESQUIRE !.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, P A 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAlN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT AFFIDAVIT OF NON-MILITARY SERVICE BRIAN H. SMITH, ESQUIRE, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above-entitled matter; that he is authorized to make this Affidavit on behalf of the Plaintiffs; and that the above-named Defendant is over 18 years of age; the address of Defendant is 237 Wood Street, Camp Hill, PA 17011, and the occupation of Defendant is unknown to Plaintiff; and Defendant is not in the Military Service of the United States, nor any State or Territory thereof, or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. rJ BRIAN H. SMITH, ESQUIRE Attorney for Plaintiff Sworn to and sup,~cribed before me this ,,'tf([ay oy~ 2000. :J4~ Il~ / Notary Public NOTARIAL SEAL . STEPHANIE F\. DUBROW. Notary Public City of Ph!ladelphia, Phila. County My Commiss.inr. Ex!":::>s March 12, 2001 "~ ~ ... .~ "~,." . :~ JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE I.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT CERTIFICATION OF ADDRESSES I hereby certify that the true and correct address of the Plaintiff is: 601 W. First Avenue Spokane, WA99201-5013 I hereby certify that the true and correct address of the Defendant is: 23 7 Wood Street Camp Hill, P A 17011 L 13RIAN H. SMITH, ESQUIRE Attorney for Plaintiff iiR~- &.. ~~& '.. - 4~lllillil~li~'J.;;dIH~nWllh~:IiIriik.Jilij__ljJ' ~,,-,_..-," ..~ ~~-~"" ~Q~~ ~~~. ~ I.,,}J , "'S\ ("',. ~ .....) :t ~ w .~ (t- C :J-. ""'\'-- . r ......... oi ......r V\i t ,~~ ..~,~ h" (') ~; -ot6- nlrYl ~~:,: rS( <- ~8 /' =< "~=C~_ '1 ;"-;::-, L) ;'"j) i-q U :..0 . . ~C; .-:', _- "I ~ );:;:-:;: ~~~ rr; s-J :<: .t::-- ~ " ,--' 8ii:lJ~i.r!t" . \ JAFFE,FRlEDNL\N,SCH~,SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE I.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., IT, MORTGAGE PASS- : TIIROUGHCERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $139,229.10 Interest $ $ (Costs to be added) JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA, NEMEROFF & APPLEBAUM, P.C. BY: rJL- BRIA1'rH. SMITH, ESQUIRE 7848 Old York Road, Suite 200 Elkins Park, Pa. 19027 (215)635-7200 lI!j_i~~__ -~ "'~-~~~_ ':~""~m,~_~~~'-' "'=~'-~liitlil..~" ,_~~.J.<... ~~= ~ ~ o <::; :~ -1.1(;:] nlfT~ ~~' C:::C~" ,~ ZC:- 5>~~ 2; -< ~" ,~ o (j') "'1 "':J (,~ j ._;, T,'" 'D ~ - ( ";: I ~ I ~ ~ " ti I,; ,'q p- t'! 1.1 . j , ) I I I , I 1 I )1 1 - ~ ~~. =--, -, ~~ ~ -- -,~" """.."""~,~- . >+'~'- '. WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 The Bank of New York. as Trustee Pursuant to the :IN THE COURT OF COMMON PLEAS OF Terms of that Certain Pooling and Servicing :CUMBERLAND COUNTY, PENNSYLVANIA Agreement Dated as of November 1. 1998. Related: to Metropolitan Asset Funding. Inc.. IT. Mortgage Pass-Through Certificates. Series 1998-B c/o MetWest Mortgage Services. Inc. vs. Colleen A. McCourt No. 2000-00723 WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of Cumberland TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically described property below): 237 Wood Street Camp Hill, PA 17011 (See legal description attached) Amount Due Interest from $ 139.229.10 $ Total $ Plus costs $ as endorsed. Dated Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy ill1iiMIjjj!ll!l!~iJ!IMIilii;;Ull"'lI,"J,"',<l,j,J";,iililili<i",.id;.,"""-w.."",~~",,,,",,,",,,Iil!"'lIflliJl-:ltli!ij.lh~I!'>[jI~,,~.il;~N~lijji1ln'U.lill,"._~~lljlililililiHS..iliNil~IiilliliI~llK-'~lillill'!""'" "1 ~.'~..""""""'~~iiI~!I.'Illid'l "-"l"'" No., 2000-00723 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P'ENNSYL VANIA The Bank of New York as Tru~tee Pur~uant to the Terms of that Certain Pooling and Servicing Agreement Dated as of November 1, 1998, Related to Metropolitan Asset Funding, Inc., II, Mortgage Pass-Through Certificates, Series 1998-B, c/o MetWest Mortgage Services, Inc. vs. Colleen A. McCourt WRIT OF EXECUTION ~ORTGAGEFORECLOSURE) Costs Real Debt Int. from Costs Prothy. Pd. Sheriff $ 139.229.10 JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 (215) 635-7212 FAX .~, Attorney or Plaintiff Kerry S. Schuman, Esquire Address of Defendant (s) 237 Wood Street Camp Hill, PA 17011 Where papers may be served / 'li 1',1 I I! Ii II I, [i I I I Ii II II 'I I I , , , II ~ 4'" ~ ,- ~... .1 l1Uti~.- . . DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, Situate in the Township of Hampden, Cumberland County, and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the North side of Wood Street Eighty five (85) feet West of the Western line of Holly Drive; thence along the Northern line of Wood Street, South Eighty-three (83) degrees Fifty six (56) minutes West Eighty five (85) feet to a point Forty five (45) feet West of the line dividing Lots Nos. 157 and 158; thence in a line paralleling the last mentioned dividing line North Six (06) degrees Four (04) minutes West One Hundred (100) feet to a point; thence North Eighty three (83) degrees Fifty six (56) minutes East Eighty-five (85) feet to a point Forty (40) feet East of the line paralleling the last mentioned dividing line South six (06) degrees Four (04) minutes East One hundred (100) feet to the place of beginning. BEING the Western Forty (40) feet of Lot No. 157 and the Eastern Forty five (45) feet of Lot No. 158 in the Plan of Lots of the Hollywood Development Company, Inc. which said Plan of Lots is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 9, page 17. Parcel # 10-20-1850-037 iillilim'''''-"~~~lI!_~ji,~RlI~~~~-\m~~ilfN"\f''''' . "~:.i.._~"""" ~'J .. t~ , ......... ~ci - ~ ~ $ Ft> ~ . ~ k ;'1 ~. ~~~"I'- ~ -:--1 ~ ~'\ ~ ~~ -..", ~ ~ ~ \0-, ~ o c ~,- (.:)[_[3 nor".' Z " 7_. ZC' (I)> ---,<-' c.-~c~, 1€fJ L, =< ~~ ~ I c::: o U, '''''1 -'0 ~~< "\) ::J~ 'u~- :.:> ()'l ~~s --< " . ~ ,~ . " , 'J, .... JAFFE,FRIED~,SC~,SCIOLLA NEMEROFF & APPLEBAUM, P.C, BRIAN H. SMITH, ESQUIRE !.D. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF TfIAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- : THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 V. COLLEEN A. MCCOURT AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York as Trustee c/o MetWest Mortgage Services, Inc., Plaintiff in the above action, sets forth as of the date that the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 237 Wood Street Camp Hill, PA 17011 (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") .~...J oJ ~""~'-"!J , '"... 1. Name and address ofOwner(s) or Reputed Owner(s): Colleen A. McCourt 23 7 Wood Street Camp Hill, PA 17011 2. Name and address ofDefendant(s) in the judgment: Colleen A. McCourt 237 Wood Street Camp Hill, P A 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: The Bank of New York as Trustee Pursuant to the Terms of that Certain Pooling and Servicing Agreement Dated as ofNovembcr 1, 1998, Related to Metropolitan Asset Funding, Inc. II, Mortgage Pass-Through Certificates, Series 1998-B c/o MetWest Mortgage Services, Inc. 601 W. First Avenue Spokane, W A 99201-5013 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Dept. 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, Pa 17013-3387 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: N/A 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. l-' BJ H. SMITH, ESQUIRE Attorney for Plaintiff ,({;/o{) , DATE ,... ~~-"'ij:,;o'If,,,...-W"'v'" ~'I!l!.!iliI;lIlli~>0:8.!j;~~_~~~ ~ ~~ "-lIWlrw.....".""~j~'u<\iliiw- : o r- I:~~ IT)r:--' ~~~~,' r'::'::t: ~. ..;::;: '-- ~:::;~ c: J;E .2: =< 1111 1:r~~ Es' :,0 '--"1 "TJ :~~~ :._) (J/ 5:J -< 1 -.-' 0 . ~I ,-,""--" lll!I~ I > . '" . ~ JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.C. BRIAN H. SMITH, ESQUIRE LD. NO. 65627 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff TIIE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO TIIE TERMS OF TlIAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INe. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 v. COLLEEN A. MCCOURT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, 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. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Colleen A. McCourt Your house at 237 Wood Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on December 6, 2000, at 10:00 a.m., in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $ 139,229. 10 obtained by The Bank of New York as Trustee clo MetWest Mortgage Services, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the amount of the judgment plus costs, the back payments, late charges costs and reasonable attorneys fees due. To find out how much you must pay, you may call Brian H. Smith, Esquire at (215) 635-7200. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "- 1&..- ~'"_' , . ~ ''" .. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the bid price by calling Brian H. Smith, Esquire, at: (215) 635-7200. 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 ifthis has happened, you may call Brian H. Smith, Esquire, at (215) 635-7200. 4. Ifthe amount due from the buyer is not paid to the Sheriff, you will remain the owner ofthe 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 maybe entitled to a share of the money which was paid for your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff on January 5, 2001. 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 January 5, 2001. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE TillS 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 COURT ADMINISTRATOR 4th Floor Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 Very truly yours, JAFFE, FRIEDMAN, SCHUMAN, s~ NEMEROFF & APPLEBAUM. P.e. Brian H. Smith BHS:srm " -. ~ .' .1 ~,~. '''''''~:1~. . DESCRIPTION ALL THAT CERTAIN piece or parcel of land, with the buildings and improvements thereon erected, Situate in the Township of Hampden, Cumberland County, and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the North side of Wood Street Eighty five (85) feet West of the Western line of Holly Drive; thence along the Northern line of Wood Street, South Eighty-three (83) degrees Fifty six (56) minutes West Eighty five (85) feet to a point Forty five (45) feet West of the line dividing Lots Nos. 157 and 158; thence in a line paralleling the last mentioned dividing line North Six (06) degrees Four (04) minutes West One Hundred (100) feet to a point; thence North Eighty three (83) degrees Fifty six (56) minutes East Eighty-five (85) feet to a point Forty (40) feet East of the line paralleling the last mentioned dividing line South six (06) degrees Four (04) minutes East One hundred (100) feet to the place of beginning. BEING the Western Forty (40) feet of Lot No. 157 and the Eastern Forty five (45) feet of Lot No. 158 in the Plan of Lots of the Hollywood Development Company, Inc. which said Plan of Lots is recorded in the Cumberland Comity Recorder of Deeds Office in Plan Book 9, page 17. Parcel # 10-20-1850-037 lldIl!tliOlHlil~ti,l!:~t~~'~~.kl!il;"~~J~i_,diillii~~- -'-" iJ,..u."h~lL o c <: -of;j rnL" ZJ_ zr' uJ~ -( r: ~c-, ~CI J>c ~ -<. S? ~, U) ,<1 --0 . - OJ I , il I I " ~ '--,1 ,_.~ z::; ..~ :x ;~?, ~~!\ ~~ ~iJ -( :..:> (J'1 J .- ~ -- . ., , . . , '''",.j; COUNTY OF CUMBERLAND SHERIFF'S OFFICE REAL ESTATE DEPARTMENT TIIE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO TIlE TERMS OF mAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES 1998-B clo METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 V. COLLEEN A. MCCOURT CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certifY that I am the Attorney of record for the Plaintiff in this Action against Real Property and further certifY this Property is: _ F.H.A. - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit X That the Plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including but not limited to: (a) Service of notice on Defendant(s). (b) Expiration of30 days since the service of notice. (c) Defendant(s) failure to request or appear at meeting with Mortgagee or Consumer Credit Counseling Agency. Defendant(s) failure to file application with the Homeowners Emergency Assistance Program. (d) I further agree to indemnifY and hold harmless the Sheriff of Cumberland for any false statement given herein. iR-. BRIAN H. SMITH, ESQUIRE Attorney for Plaintiff Attorney LD. #65627 JAFFE, FRIEDMAN, SCHUMAN, SCIOLLA NEMEROFF & APPLEBAUM, P.c. 7848 Old York Road, Suite 200 Elkins Park, Pa. 19027 (215) 635-7200 liilililllll!~lol_~~il'i~lWilll~llW~~:i;I!_~~;r--' l', ."j~~u~iJ{I'''" ~~- 0 CJ c: c ~::: t/"') - -0':'--'- '" rn h~~ -0 Z:T' Z r-' ~~~?:, ~C:~', ~ _"0- " <;c: ,,"-,~., >(:= '-.,r~ ~' ~" :0 (" -< -<. n BRIAN H. SMITH, ESQUIRE I.D. NO. 65627 FRIEDMAN, SCHUMAN, NEMEROFF APPLEBAUM & McCAFFERY, P.C. 7848 Old York Road, Suite 200 Elkins Park, PA 19027 (215) 635-7200 Attorney for Plaintiff THE BANK OF NEW YORK, AS TRUSTEE PURSUANT TO THE TERMS OF THAT CERTAIN POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1998, RELATED TO METROPOLITAN ASSET FUNDING, INC., II, MORTGAGE PASS-THROUGH CERTIFICATES,: SERIES 1998-B c/o METWEST MORTGAGE SERVICES, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-00723 V. COLLEEN A. MCCOURT PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Kindly mark the judgment in the above-captioned matter satisfied. Respectfully submitted, By: FRIEDMAN, SCHUMAN, APPLEBAUM, NEMEROFF & MCCAFFERY, P.C. ~ Brian H. Smith, Esquire Attorney for Plaintiff {P:\ WDOX\CLIENTS\000932\00034\00059927 .DOC; I} 1'-..,) = (.:::;:) <.::t'" o .1 -~ fl;-n .F: -om ~ CJ c:-J :),1 ~".1 1;.,_) g~~ -~,;;::.. ::0 -< I --.J U --,<!,-,.. -~,...... N .. N u;