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Home My WebLink About01-2100 FX , MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID# 60068 Suite 2226, Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 NORWEST BANK MINNESOTA, NATIONAL COURT OF COMMON PLEAS ASSOCIATION, AS TRUSTEE FOR THE AMRESCO CHESTER COUNTY RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 19982, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1,1998 CIO WENDOVER FINANCIAL SERVICES 725 N. REGIONAL ROAD GREENSBORO, NC 27409 Plaintiff Ys. No.: d/- ,;(/00 C()~l 'r~ DEBRA DEE REED 119 YORKSHIRE DRIVE MECHANICSBURG, P A 17055 CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT Defendant( s) ::1~,~" '. ^_ ,- -~ " < . " ,~~d, 'I 'f- " ............,...., NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgement may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, COURT ADMINISTRATOR 4111 FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 1-717-240-6200 i%.. ***************************************************************************** NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ***************************************************************************** 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notifY our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgement will be mailed to you by our offices. i"~", Jl) ~ 0,_" "T,r_~'," .. ,"~" ,I"":; . e .. MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID# 60068 Suite 2226, Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE I, 1998 C/O WENDOVER FINANCIAL SERVICES 725 N. REGIONAL ROAD GREENSBORO, NC 27409 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, No.: DEBRA DEE REED 119 YORKSHIRE DRIVE MECHANICSBURG, P A 17055 Defendant( s) CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT I. Norwest Bank Minnesota, National Association, as Tgrustee for the Amresco Residential Securities Mortgage Loan Trust 1998-2, under the pooling and servicing agreement dated as of June I, 1998 c/o Wendover Financial Services (hereinafter referred to as "Plaintiff') is a mortgage corporation, conducting business under the laws of the Commonwealth of Pennsylvania and brings this action to foreclose in the Mortgage executed between Debra Dee Reed, mortgagor hereinafter referred to as "Defendant" and WMC Mortgage Corp, Said Mortgage is dated November 19, 1997 and was recorded in the Office of the Recorder of Deeds and Mortgages in Cumberland County, Pennsylvania on December 10, 1997 in Mortgage Book ;"-::..",.., , '-<c,' ~ 1""1 -. "' "I , , ' ~, 1421, page 276. A copy of the Mortgage is attached hereto and made a part hereof as Exhibit "A". 2, Said Mortgage was subsequently assigned as follows: a. to Norwest Bank, Minnesota, NA, as Trustee for Amresco Residential Securities Mortgage Loan Trust 1998-2, under the pooling and servicing agreement, recorded on May 30, 2000 in Book 645, page 240, Said Plaintiff is the proper party plaintiff herein by way of assignment. 3, The Mortgage secures Defendant's Note dated November 19,1997 in the amount of $78,000.00 payable to Plaintiff, with an adjustable interest rate. A copy of said Note is attached hereto and made a part hereof as Exhibit "B", 4, The land subject to the mortgage is: 119 Yorkshire Drive, Mechanicsburg, PA 17055 A copy of the legal description is attached hereto and incorporated by reference. 5, The Defendant(s), Debra Dee Reed is the Real Owners of the land subject to the mortgage. The Defendant( s) mailing address is 119 Yorkshire Drive, Mechanicsburg, P A 17055. 6. The Mortgage is now in default due to the failure of the Defendants to make payments as they became due and owing, The following amounts are due: Principal Balance Interest Calculated to Apri15, 2001 Late Charges Property Inspection Fees Appraisal NSF Charges Attorney Fees (5% of Principal Balance) Total 'f'-.~ ~__~,' ~-~" ., -- 'f','_ i" - "", -f' 'I '0,' " $ 77,168.50 $ 12,084.35 $ 293.64 $ 31.00 $ 100.00 $ 20.00 $ 3,858.43 $ 93,555.92 plus interest from 04/06/01 at $28.54 per day, costs of suit and attorney fees. 7. In accordance with the provision of the Act of January 30,1974, P.L. 13 No, 6, Section 403 (41 P,S, 403), a Notice of Intention to Foreclose Mortgage is not required in said proceeding as the bona fide consideration is in excess of $50,000.00. A Notice of Homeowners' Emergency Mortgage Assistance was sent to the defendant by regular and certified mail on November 16, 2000. A copy of said notice is attached hereto and made a part hereof as Exhibit "COO, The Defendant has not cured the default. WHEREFORE, Plaintiff requests the court enter Judgment in Mortgage Foreclosure for the sale of the mortgage property in Plaintiff s favor and against the Defendant, in the sum of $93,555.92 together with interest from 04/6/2001 at $28,54 per day, costs of suit and attorney fees, MATTLEMAN, WEINROTH & MILLER BY: Sharon Oras Morgan, Es #60068 00-55264 ~~r"1-'"~^''''--'''' _,' _~T ';'" ", . ~ -I ," , " '"" " VERIFICATION I, (!h ris Pi f/s , state that I am the Vice President of Wendover Financial Services Corporation, servicing agent for Horvest Bank Minnesota. et a1. . Plaintiff herein; that I am acquainted with the facts set forth in the foregoing Complaint; that the same are true and correct to the best of my knowledge, infonnation and belief; that this statement is made subject to the penalties of 18 Pa.C.S. section 4904 relating to the unsworn falsification to authorities. {~io ~ Vice President PAGE,02 I-'I"""_~ - r " ". " When Reco~ded, Mail TO: WMC MORTGAGE CORP. (EQUITY SERVICES) 6320 CANOGA AVE,7TH FL, TR-790 *720 WOODLAND HILLS, CA 91367 Parcel Number: [Space Above This Line For Recording Data) MORTGAGE THIS MORTGAGE ("Security Instrument") is given on NOVEMBER 19, 1997 DEBRA DEE REED, A MARRIED WOMAN, AS HER SOLE AND SEPARATE PROPERTY . The mortgagor is ("Borrower"). This Security Instrument is given tlWMC MORTGAGE CORP. which is organized and existing under the laws of CALIFORNIA address is P.O. BOX 54089 LOS ANGELES, CA 90054 SEVENTY EIGHT THOUSAND AND NO/lOa , and whose ("Lender"). Borrower owes Lender the principal sum OJ Dollars (U.S. $ 78,000.00 ) This debt is evidenced by Borrower's note dated the'same date as this Security Instrument ("Note"), which provides fo: monthly payments, with the full debt, if not paid earlier, due and payable ODECEMBER 1, 2027 This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals extensions and modifications of lhe NOle; (b) the payment of all olher sums, with interest, advanced under paragraph 7 te protect the security of this Security Instrument; and (c) the performance of Borrower's covenantS and agreements under thi Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the followinl described property localed in CUMBERLAND County, Pennsylvania LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF AND KNOWN AS EXHIBIT "A". which has the address of 119 YORKSHIRE DRIVE, MECHANtCS8URG Pennsylvania 17055 [Zip Code) ("PrOperty Address"); PENNSYL V ANIA.Single Familv.FNMA/FHLMC .- UNIFORM INSTRUMENT Form 3039 9/90 _ .6RIPAI"4,Q,.o, Amended 5/91 · vMPMORTaAGEFORMS"8001521-729~ (') Page 1 of 6 Initials: l.) 1'-- [Streer,Ci~ 11111111111111111111111111 ~llJ ;', ',~,~''''-'\''' =-je'~~~"T""~ ~. ~".." , , TOGETHER WITH all the improvements now or hereafter erected on the property,' and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property. " BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrant! and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limite( variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due thl principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. Funds for Taxes and Insurance. Subject to applicable Iliw or to a written waiver by Lender, Borrower shall pay t( Lender on tbe day montbly payments are due under the Note, until the Note is paid in full, a sum ("Funds") for: (a) yearly taxe: and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold paymen~ or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums if any; (e) yearly mortgage insurance premiums, 'if any; and (I) any sums payable by Borrower to Lender, in accordance wit! the provisions of paragraph 8, in lieu of tbe payment of mortgage insurance premiums. These items are called "Escrow Items,' Lender may, at any time, collect and hold Funds in an amount not to exceed the maximUm amount a lender for a federall~ related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act 0 1974 as amended from time to time, 12 U.S.C. Section 2601 et seq. ("RESPA"), unless another law that applies to the Fund sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of futur, Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entil: (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay th Escrow Items, Lender may not charge Borrower for bolding and applying the Funds, annually analyzing the escrow account, 0 verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make suc: a charge. However, Lender may require Borrower to pay a one-time charge for an independent real estate taX reporting servic used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made 0 applicable law requires interest to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrowel without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which eac: debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrowe for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at an time is not sufficient to pay the Escrow IteQlS when due, Lender may so notify BOrrower in writing, and, in such case Borrowe shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more tha twelve monlhly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower an Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender. prior to the acquisition or sa! of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured b this Security Instrument. ' 3. Application of Payments. Unless applicable iaw provides otherwise, all payments received by Lender under paragrapt 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph; third, to interest due; fourth, to principal due; and last, to any late charges due under the Note. 4. Charges; Liens. Borrower shall pay all taXes, assessments, charges, fines and impositions attributable to the Propert which may attain priority over this Security Instrument, and leasehold paymems or ground rents, if any. Borrower shall pa these obligations in the manner provided in paragraph 2, or if not paid in that manner,Borrower shall pay them on time directl to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraplIf Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees j writing to the payment of the obligation secured by the lien in a manner acceptable 10 Lender; (b) contests in good faith the Iif by, or defends against enforcement, of the lien in, legal proceedings which in the Lender's opinion operate to prevent tl enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien' this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority ov, this Security Instrumem, Lender may give Borrower a nOlice identifying the lien. Borrower shall satisfy the lien or take one, more of the actions set fonh above within 10 days of the giving of notice. CO!: -6RIPAI19"0I,OI .. Page20tS Form 3039 9/!Inlli.tJ:~ IOO89S7 ""'N':''''~~'~'F'lffl'''''' n" 1- I 5. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erecte~ on ~l Property insured against loss by fire, hazards included within the term "extended c?ve~ge". and any other hazards, tnclu~lD~ floods or flooding, for which Lender requires insurance. This insurance shall be mamtatned 10 the amounts and for the penou that Lender requires. The insurance carrier providing the insurance shall be cbosen by Borrower subject to Lender's approva which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender' option, obtain coverage to protect Lender's rights in the Property in accordance with paragrapb 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lende shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts 0 paid premiums and renewal notices. In the event of loss, Borrower shall give prompi notice to the insurance carrier and Lendel Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of th Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration c repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the SUII secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons th Property, or does not answer within 30 days a notice from Lender that the insurance carrier bas offered to settle a claim, the Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay SUII secured by this Security Instrument, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to, principal shall not extend ( postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. : under paragrapb 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting fro! damage to the Property prior to tbe acquisition shall pass to Lender to the extent of the sums secured by lbis Security InStrumel immediately prior to the acquisition. 6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leasehold: Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after lbe execution ( lbis Security Instrument and shall continue to occupy lbe Property as Borrower's principal residence for at least one year aftl the date of occupancy, unless Lender olberwise agrees in writing, which consent shall not be unreasonably withheld, or unle: extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair It Property, allow the Property to deteriorate, or commit waste on lbe Propeny. Borrower shall be in default if any forfeituJ action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of It Property or otherwise materially impair the lien creacedby lbis Security Instrument or Lender's security interest. Borrower ml cure such a default and reinstate, as provided in paragraph 18, by causing the actiOn or proceeding to be dismissed with a rulit that, in Lender's good faith detennination, precludes forfeiture of the Borrower's interest in the Property or other materi impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or faill to provide Lender with any material infonnation) in connection with the loan evidenced by lbe Note, including, but not Iimiu to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security InStrument is on leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, tl leasehold and the fee title shall not merge unless Lender agrees to the merger in writing, 7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contained this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do 1II pay for whatever is necessary to prolect the value of the Property and Lender's rights in the Property. Lender's actions tru include paying any sums secured by a lien which has priority over this Security Instrument, appearing in conn, payil reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may talce action under this paragra] 7, Lender does not bave to do so. Any amounts disbursed by Lender under lbis paragraph 7 shalt become additional debt of Borrower secured by tl: Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from ( date of disbursement at the Note rale and shall be payable, wilb interest, upon notice from Lender to Borrower requestil payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Secun Instrument, Borrower shall pay the premiums required to maimain the mortgage insurance in effect. If, for any reason, t mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required obtain coverage substantially equivalent to the mongage insurance previously in effect, at a cost substantially equivalent to t COSt to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. substantially equivalent mortgage insurance coverage is DOe available, Borrower shall pay to Lender each month a sum equal one-twelfth of lbe yearly mongage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased be in effect. Lender will accept, use and relain these payments as a loss reserve in lieu of mongage insurance. Loss resee Form'3039 9/ rnitial$l~ tMRC3.cj' G-6RIPAI19410I,Ol .. Page 3 a'6 1'!"~-'!11~n'I""."~~"""o'-~ .~,-;W-llll<'lrlfl!ll"f!I~ . F ~ r payments may no longer be required, at the oplion of Lender, if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and ~Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condemnation. The proceeds of any award or claim for damages, direct or conSequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of COndOl1Ula,ion, are hereby assigned aiId shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security InstrUment, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the' fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this . Security Instrument immediately before the taking, unless Borrower and Lender othetwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the fOllowing fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before me taking. Any balance shall be paid to Borrower. In the event of a partial taking of me Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless appli~le law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim {or damages, Borrower (ails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. Unless Lender and 'Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security instrUment; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Securily Instrument or the Note without that Borrower's consent. 13. Loan Cbarges. If the loan secured by this Security Instrument is' subject to a law which sets maximum loan' charges, and that law is fmally interpreted so that the interest or other loan charges collected or to be collected in connection willi the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the penuitted limit; and (b) any sums already collected from Borrower which exceeded permiued limits will be refunded to Borrower, Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a rel\ind reduces principal, the reduction will be treated as a ,partial prepayment without any prepayment charge under the Note. 14. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. IS. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declarec to be severable. 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. Form 3039 9/9C 'nitla'$:~k UVlllO<C;7-; ~.6RCPA) 194101.01 Page 4 of 6 !9fiiXl7 '0 ~,-- , ! ] , 17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of ~e Property or any interes.t in it is sold or transfened (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 imm~diate p~Yn:ent in. ~1l of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender If exercIse IS prohlblled 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 th~ 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 10 the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without funher notice or demand on Borrower. 18. Borrowers RI~ht to Reinstate. If Borrower meetS certain conditions. Borrower shall have the right to have enfo~cement of this Secunty Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such oth:r pe~od ~ applIcable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contaIned m thIS Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Insrrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in the Propeny and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 17. . 19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above and applicable law. Tbe notice will state the name and address of the new Loan Servicer and the address to which payments should be made. Tbe notice will also contain any other infonnation required by applicable law. 20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Subslances on or in the Property. Bomiwer shall not do, nor allow anyone else 10 do, anything affecliJig the Propeny that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. ' Borrower shall promptly give Lender written notice of any investigation, claim, de1l1lll1d, lawsuit or other action by any governmental or regulatory agency or private party involving the Propeny and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any govemniental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary. Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. . As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by EnVIronmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, lI1aIerials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located thai relate to health, safery or environmental protection. " , , NON-UNIFOIU1 COVENANTS. Borrower and Lender further covenant and agree as fonows: 21. Acceleration; Remedies. Lender shllll give notice to Borrower prior to acceleration following Borrower's breach 01 any covenant or agreement in this Security, Instrument (but not prior to acceleration under Paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure ,to cure the default as specified mal result In acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of thl Property. Lender shall further infonn Borrower of the right to reinstate after acceleration and the right to assert in thl foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. Il th~ default is not cured as specified, Lender, at Its option, may require Immediate payment In full of all sums secured b) this Security Instnunent without further demand and may foreclose this Security Instrument by judicial proceeding, ~ende!" shall be entitled to collect all expenses Incurred in pursuing the remedies provided in this paragraph 21, mcludmg, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable Jaw . ' 22. ReJense. Upon payment of all sums secured by this Security Instrument, this Security InstrUmcntand the estatl c~nveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy tbis Security Instrumen: WIthout charge to Borrower. Borrower shall pay any recordation costs. 23. Wl;'ivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceeding~ to enforce thIS Security Instrument, and hereby waives the benefit of any present orfurure laws providing for stay of execution extension of time, exemption from attachment, levy and sale, and homestead exemption. 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to th. commencement of bidding at a sheriff s sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire tid. to the Propeny, this Security Instrument shall be a purchase money mongage. . 26. Il.1terest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Not' or In an aCllon of mongage foreclosure shall be the rate payable from time to time under the Note. . .6RIPAI..4'OI,Ol .. PageS of G FO:,:.:k( tnnoQ.(..,,, ij:!'''PP" ~",".~ , " '~-,~. - ~~I ~,~, 27. Riders to tbis Security Instrument. If one or more riders are ,executed by Borrower and recorded together with this Security InsllUment, ihe covelUllllS and agreemeDls of each such rider shall be incOlporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a pan of this Security Instrument. . [Check applicable bax(es)] [Jg Adjustable Rate Rider o Graduated Payment Rider o Balloon Rider DVARider o Condominium Rider o Planned Unit Development Rider o Rate Improvement Rider o Other(s) [specify] o 1-4 Family Rider o Biweekly Payment Rider o Second Home Rider BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. WitneSSes: ~c-- ~J. ~.9J-d D RA DEE REED (Seal) -Borrower ~ ~o ~Pl n1 f0t::h : (Seal) .Borrower (Seal) -Borrower (Seal) -Borrower Certificate of Residence If Ltj,4.,.. [; ;ll.Ua.rnbYL:l-i t ';v ~J"~'cl.ii t,..!;4~'y ~'" w.~ l,.UfftCL address of the within-named Mortgagee is P.o, 50'1 54-0SQ) Lo$. r::}Vl~tLs. C.A Qoo6Lf \qtl1 dayof Noue~nL . ~1. _ ~~Qtfmlr(f1 Agent of Mortgagee Witness my hand this COMMONWEALTH OF PENNSYLVANIA, On this, the I qlh day of tJoveW-beY personally appeared 'te.bR 'bee Meed County ss: ./991 , before me, the undersigned officer, known to me (or satisfactorily proven) tlJ be the person whose name 2> subscribed to the within instrument and acknowledged that .she execuled the same for the purposes herein contained. IN WITNESS WHEREOF. I hereunto set my hand and official seal. My Commissilln Expires: .. Notarial Seal I Lisa E, Talamontl, Notary Public : Swatara Twp,. Dauphin County 7\ L..~~ Commission expires No~. 13.2000 J.J rrrrJ +-it...bl/r ..-. "" '.,1. r'P,M5Vf4Jarlla AsSOC'lltlOR at No~lli of OfflCer (f .. ..6R(PA) {94101.01 ,. Page6of6 Form 3039 9/9( 10089575 ..r.1'>...,..... n~",,~ -;""-~~ ,,'"R'la; .,; ~I"~~ " ....." '" --.. ') . '. \ ADJUSTABLE RATE NOTE (L180R Index - Rate Caps) ~ , ...~, ..... ~~;. ..J ., __.;~~.~ f~.:::':-M~>': .~.~ .....~. THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOllNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE I MUST PAY. NOVEMBER 19, 1997 IDate) HARRISBURG (City] PENNSYLVANIA IStale) 119 YORKSHIRE DRIVE MECHANICSBURG, PA 17055 [Property Address) 1. BORROWER'S PROMISE TO PAY , , In return for a loan that I have received, I promise to pay U.S. $ 78,000; 00 (this amount is calle . 'principal' '), plus interest, to the order of the Lender. The Lender is , WMC MORTGAGE CORP. I unaerstand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitle 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 yearl rate of 10.7400 %. The interest rate I will pay may change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and SeCtion 4 of this Note is the rate I will pay both before and after an default described in Section 7(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments eveI)' month. I will make my monthly payments on the first day of each month beginning on JANUARY 1 ,1998 , I will make these payments eveI)' month until I have paid all of the principal and interest and any other charges described belo~ that I may owe under this Note. My monthly payments will be applied to interest before principal. If, 01 DECEMBER 1 , 20 27 , I still owe amounts under this Note, J will pay those amounts in full on tha date, which is called the "Maturity Date." ' I will make my monthly payments at P.O. BOX 54089 LOS ANGELES, CA. 90054-0089 or at a different place if required by the Note Holder. (B) Amount of My Initial Monthly Payments Each of my initial monthly payments will be in the amount of U.S. $ 727.53 change. . This amount lOa) (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I mus pay. The Note Holder will determine illY new interest rate and the changed amount of my monthly payment in accordance witl Section 4 of this Note. 4. INTEREST RATE AND MONTHLY PAYMENT CHANGES (A) Change Dates The interest rate I will pay may change on the first day of DECEMBER ,1999, and on that day evel) sixth month thereafter. Each date on which my interest rate could change is called a "Change Date." (B) The Index Beginning with the first Change Date, my interesl rate will be based on an Index. The "Index" is the average of interbank offered rates for six-month U.S. dollar-denominated deposits in the London market ("LIBOR'), as published in The Wall Slree, Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month ir which the Change Date occurs is called the "Current Index." If thp Tnnpy ;li! nn InnopT' !.:nt!:\i1!:1hlp th". Nntj:lo Unlri"... ",ill ,.hnnC'/IO !I n.,:o\11 inn.,:oy t},<:rot i" h.."...1"1 nnnn ,.n".,n..,...hlQ ;n.f"",",,,tinn '~,,,,;jjjffi....,..,.,"-~~,," ,W; ~'''''':''~_'" ,~,~ ~~ ~ ~'I 'T~-~ r-"", . ~~'I-' , , -' " .'" ") . ' "') The N"te Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpa: principal thai I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substnntially equ payments. TJ Ie result of this calculation will be the new amount of my monthly payment. (D) LiDlits on Interest Rate Changes The inll'rest rate I am required to pay at the first Change Date will not be greater than 13 . 740 0 or less than 10 . 7400 %. Thereafter, my interest rate will never be increased or decreased on any sing Change Date by more than one percentage point (1.0%) from the rate of interest I have been paying for the preceding si months. My interest rate will never be greaterthan 17.2400 % or less than 10.7400 %. (E) Err. ,ctive Date of Changes , ' . '- My ne\! intcrest ratc will become effective on each Change Date. I will pay the amount of my new monthly paymel beginning on the first monthly payment date after the Chang~ Date until the amount of my monthly payment changes again. , (F) Notice of Changes The Note Holder will deliver or mail to me a notice of any changes in ,my interest" rate and the amount of my monthl payment before the effective date of any change. The notice will include information required by law to be given me and als the title and telephone number of a person who will answer any question I may have regarding the notice. s. 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 "prepayment. " When I make a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The 'Note Holder will use a: of my prepayments to reduce the amount of principal that I owe under this Note. If I make' a partial prepayment, there will b no changes in the due dates of my monthly payments unless the Note Holder agrees in writing to ~ose changes. My parti! prepayment may reduce the amount of my monthly payments after the first Change Date following my partial prepayment However, any reduction due to my partial prepayment may be offset by an interest rate increase. 6. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest 'or othe loan charges COllected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charg, , shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (Ii) any sums already collected fron me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing th, principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treatel as a partial prepayment. ' 7. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charges 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 5.0000 % of my overdue payment of principal and interest. I will pay this late charge promptl: but only onCI: on each late payment. (B) Delault If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) NoHce 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 ! ccrtain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest I hat I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered OJ mailed to me. (D) No Waivcr by Note Holdcr Even iI', 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 will still have the right to do so if I am in default at a later time. (E) Pa)ment 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 attornevs' fees. ~"<~~_"'%l,." ~_..'~~!f!/fIiIIIiIIIl'""~1 ." , .. ~~ ,...., i 10. WAIVERS I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonc "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" mea the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to tl Note Holder under this Note, a Mortgage. Deed of Trust or Security Deed (the "Security Instrument"), dated the same date ,this Note, protects the Note Holder from possible losses which might result if I do not keep the promises that I make in th Note, That Security Instrument describes how and under what conditions I may be required to make immediate payment in ft of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) witho' Lender's prior written consent, Lender may, at its option, 'require immediate payment in full of all sums secured by th Security Instrument.- However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the da of this Security Instrument. LCnder also shall not exercise this option if: (a) Borrower causes to be submitted to Lend, information required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (I Lender reasonably determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach, any covenant or agreement in this Security Instrument is acceptable to Lender. To the extent permitted by applicable law, Lender may charge a reasonable fee as a condition to Lender's consent :0 t1 loan assumption. Lender may also require the transferee to sign an assumption agreement that is acceptable to Lender 1I11 j th; obligates the transferee to keep all the promises and agreements made in the Note and in this Security Instrument. Borrower wi continue to be obligated under the Note and this Security Instrument unless Lender releases Borrower in writing. If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of acceleratior:. Tb ,notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrowl must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this periol Lender may invoke any remedies penr.itted by this Security 'Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. ~1J1wCJ\.~u.,~~ ~ ftQ DEBRA DEE REED . (Se,") ';'Borrower (Seal pBllrrOWt (Seal) pBorrower _ (Seal pBnrrowc [Sign 0, iginal Only. ";~, ~ . ,... [--, , " JOHN c. MILLER. ID NATALEG.SAVASTA+ STEVEN H. FINKELSTEIN. DELIA A. CLARK; PAULD, AARONSON 'MICHAEL J. MILSTEAD -+ HELENE B. RAUSH ERIC L. METH SHARON ORAS MORGAN ADAM R. ELGAR1* ELISE N. LAZARUS MICHAEL J. KENNEDY LYNNMBOWLBY. PINA S. WBRTZBERGER MELANIE J. THOMPSONlp DANC.PELLETIER-+ MATTLEMAN, WEINROTH & MILLER A PROFESSIONAL CORPORATION COUNSELLORS AT LAW OF COUNSEL GEORGE J. WEINROTH HERMAN MATfLEMAN' DOLORES M, BOJAZI JOHN G. MlJLFORThp GERALD J. PROFFl'ITe PLEASE REPLY To: PHlLADELPIllA OURFlLENo.: 29I/55264 MEMBERS OF THE NJ &: PA BARS + NJ&:FLBARS . PABARONLY -+ NJBARONLY e PA&DEBARS ; NJ,PA&DEBARS . NJ&:NYBARS lp DEBARONLY November 16, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM' FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose, Soecific information about the nature of the default is orovided in the attached oaaes The HOMEOWNER's MORTGAGE ASSISTANCE PROGRAM (HEMAP) mliV be able to helD to save your home, This Notice exolains how the oroaram works To see if HEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with YOU when YOU meet with the Counselina Aaencv The name. address and ohone number of Consumer Credit Counselina Aaencies servina your County are listed at the end of this Notice, If YOU have any auestions. YOU may call the Pennsvlvania Housina Finance Aaencvtoll free at 1-800-342-2397, (Persons with imoaired hearina can call (717) 780-1869. This Notice contains important legal information. If you have any questions, 401 RoUTE 70 EAsT CHERRy HILL. NEW lERsEyQ8034 TEL: (856) 429-5507 FAX: (856)429-9036 LAND TrrLIi BUILDING SUIT!! 2226 BROAD &: CHESTNUT STREETS PHn.ADELPHlA, PENNSY:LVANIA 19110 TBL:(21S)923-2225 FAX: (21S) 567-4151 200CONTINIiNTALDIUVB.SUlTIl21I NEWARK.,DliLAwARI!19713 TEL: (302)731-8349 FAX: (302) 731-8753 1135 BROAD STREET, SUIT!! 207 CLiFTON,NBwIIiRsIiY07013 TiU.: (973) 365-6140 FAX: (973) 365-6143 I,." yr- ~,.,..,.."., ,~" ,~.~, -,' r-'c- , ", J November 16,2000 Page 2 representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an 'attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMORTANCIA, PUES AFECTA SU DERECHO -A CONTINUAR VIVIEN DO EN SI CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE DALVAR SU CAsA DE LA PERDOD DEL DERECHO A REDMIR SU HIPOTECA HOMEOWNERS' NAME: Debra Dee Reed MAILING ADDRESS: 119 Yorkshire Drive Mechanicsburg, PA 17055 LOAN ACCT, NO,: 2210276 ORIGINAL LENDER: Amresco Residential Mortgage Corporation CURRENT LENDERlSERVICER: Norwest Bank Minnesota National Association, as Trustee for the Amresco Residential Mortgage Loan 1998-2, under the Pooling and Servicing Agreement dated as of June 1, 1998 c/o Wendover Financial Services. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAUL T"/ EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, ' ~P!"I~~~F ":~I ~ r . ~, ',," November 1S, 2000 Page 3 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the .Iender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desianated consumer counselina aaencies for the county in which the orooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise .your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature or your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency.Mortgage Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end ofthis Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility' criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (SO) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. Ypu will be notified directly by the Pennsylvania housing Finance Agency of its decision on your application. . NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF PI. PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT IBrina it UD to date\. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 119 Yorkshire Drive Mechanicsburg, PA 17055 '!r~~~ "-~ -__~ ~ I I -,. " , . . November 16,2000 Page 4 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: March 1, 2000 to November 1, 2000 at $852.08 per month Late Charges - $204.72 TOTAL AMOUNT PAST DUE: $7,873.44 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of this date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $7,873.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY(30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made oavable and sent' to: Norwest Bank Minnesota National Association. as Trustee for the Amresco Residential Mortaaae Loan 1998-2. under the Poolinaand Servicina Aareement dated as of June 1. 1998 clo Wendover Financial Services. P.O. Box 70808 Charlotte. NC 28272-0808 IF YOU DO NT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the leAder begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred,' up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any Attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and J,~J!lJ ~"",," F~~"""""""" ~"' ~~ ~-r- - "'eO" . " . " - ~ --,~"""- I~=._~.. November 16,2000 Page 5 by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -It is estimated that the earliest date that .such a Sheriff's Sale of the mortgaged property could be held would be approximately FIVE (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Norwest Bank Minnesota National Association, as Trustee for the Amresco Residential Mortgage Loan 1998-2, under the Pooling and Servicing Agreement dated as of June 1, 1998 c/o Wendover Financial Services. Address: P.O. Box 70808 Charlotte, NC 28272-0808 Phone Number: 1-800-436-1022 Contact PerSon: Foreclosure Representative EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff' Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor .!l1ay not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to ir at the sale and that the other requirements of the mortgage are satisfied. Please contact: Norwest Bank Minnesota National Association, as Trustee for the Amresco Residential Mortgage Loan 1998-2, under the Pooling and Servicing Agreement dated as of June 1, 1998 c/o Wendover Financial Services. P.O. Box 70808 Charlotte, NC 28272-0808 1-800-436-1 022 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) ,,\!+_ J. " '_~" ~ ",.",Jl.,. ~ , ~.'I" ""","" ~M ~~,. :JI:f~ November 16, 2000 Page 6 TO ASSERT THE NONEXISTENCE elF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT INCLUDED. = '-ii-~ filli'f '-""'''I ~ - *" <(;~ I ~ r ,~ ~ , ~ "-"",,,,~'''I''''' ".~" .~ - y" -. -,~ .='. ~'-';..'_"M~" _~'"_'". . ~.~- ~- "". ,"-- 7'( (J ~ 'G<l. () IS (") ,- ./:: C -',1 ~ h 0 s: ~ 'iJ 8 .. "1 8 ......... [,-'C;O & 0 d ::fr;c I C? , 0 (f.~ ,.0 a ~ 1 .:;~-: tv ~VJ -.0 '-C:. . ~ .,:- ~ :.~' , .. / , ~g --< .,. =< . "l'f!'!I1Ilt1;lll\,<._ ^~ = ""~ -~C''''~'~J-~Q', .1,......!~~ICifi\}im~'Ifl<":."'-'*,j,~'lfWF,~!",mji,,:,J,"'WiH~...,g'J!IWl~~~~~Ef.I(\:_~"%~~Ij!.~\1\!~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-02100 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA VS REED DEBRA DEE KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REED DEBRA DEE the DEFENDANT , at 0015:40 HOURS, on the 16th day of April , 2001 at 119 YORKSHIRE DRIVE MECHANICSBURG, PA 17055 by handing to DEBRA DEE REED 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 So Answers: 18.00 6.82 .00 10.00 .00 34.82 ~~~~~~/ R. Thomas Kli e 04/17/2001 MATTLEMAN, WEINROTH & MILLER Sworn and Subscribed to before By: ~4I me this day of '~'~"'" ,." , ~' , ". ~, w '~',; ,-,,-^- " MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney I.D. No,: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1,1998 C/O WENDOVERFINANCIAL SERVICES Plaintiff vs, DEBRA DEE REED Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 01-2100 PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Default Judgment in favor of Plaintiff, NorwesfBank Minnesota et ai, and against the Defendant, Debra Dee Reed, for failure to Answer the Complaint in Civil Action Mortgage Foreclosure, Service was made on the Defendant, Debra Dee Reed, on April 16, 2001 via B&R Services for Professionals, '_'_0 r' ~. - h,_,._ r ~,_, .' Assess Damages as follows: Principal Balance Interest calculated to November 12, 2002 Late Charges Escrow Advances Property Inspection Appraisal Costs NSF Charges Property Preservation Other Fees Insurance TOTAL AMOUNT OF ruDGMENT f'-" ',.' ".'_' ';'''-'~i,. , - $ 77,168.50 $ 27,875,08 $ 795.33 $ 2,320.00 $ 220,00 $ 545.50 $ 20.00 $ 170.50 $ 20.75 $ 1,850.00 $ 110,985,66 MATTLEMAN, WEINROTH & MILLER BY x&Al ~A~~ SHARON ORAS MORG , ES . ATTORNEYLD, NO,: 60068 . - OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary TO: DEBRA DEE REED NORWEST BANK MINNESOTA, NATIONAL COURT OF COMMON PLEAS ASSOCIATION, AS TRUSTEE FOR THE AMRESCO CUMBERLAND COUNTY RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 1998 C/O WEND OVER FINANCIAL SERVICES Plaintiff vs. NO,: 01-2100 DEBRA DEE REED Defendant NOTICE PURSUANT TO RULE 236 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTION CONCERNING THIS NOTICE, PLEASE CALL: 291/55264 SHARON ORAS MORGAN, ESQUIRE #60068 MATTLEMAN, WEINROTH & MILLER (215) 923-2225 NOTICE PURSUANT TO FAIR rrn COLLECTION PRACnr F,--i.rr"'"' THIS COMMUNICAT,'(v/\llc; 'I;~,~.r;/ r '~T . ,1_- II Jl\t; r', I' i- '< COLLECTOR THIS I, U.: I ',"'"/ ' " . ,'}"',' "", . ,r. j ,....,'.. !~ l I 'I" ,- I COLLECT A DEBT ANC'AN',( i;n:-':'~f4 OBTAINED Will BE urcr, [' :i: ... ,. ~ .. U IVI\ lrw.1 PURPOSE. ~-',,!, . "___', _''n_ " ,",' ,_ r ", - ~ , MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney I.D, No,: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, P A 1911 0 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 COURT OF COMMON PLEAS CUMBERLAND COUNTY NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1,1998 C/OWENDOVERFINANCIAL SERVICES Plaintiff vs. NO,: 01-2100 DEBRA DEE REED AFFIDAVIT OF ADDRESS COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, being duly sworn according to law, upon my oath, depose and say: 1. I certifY that the Plaintiff's address is 2601 South Bayshore Drive, 4th Floor, Miami, FL 33133, 2. I certifY that the Defendant's address is as follows: 119 Yorkshire Road, Mechanicsburg, PA 17055, 3. I certifY that the foregoing information is true and correct to the best of my knowledge, information and belief ;;;;,~\ - ., ,. '. 'H <. ~ .. ~_\ I',. 'r "',-~ , Sworn and Subscribed to before me this to -#I day of~QJ!nJ>>r ,2002, 91 ~ /4.", 'T/M;ihu-, JU!llnlATltlIllTCllNER A NOTARY PUBLIC Of NEW JERSEY MY CO'MMl$S10Nm'IRES 6/2512006 !~"~.'- -.." , 'T""~ " -T ,--~ 1- MATTLEMAN WEINROTH & MILLER ~A~. SHARON ORAS MORG , ESQUIRE ATTORNEYI.D. NO.: 60068 ~w ~,,,,,it;l~" ~J*HjT!H '>~!~;~, ;,;; f;:;l Y~.~;Z:tt w.:m,I\:1-1 ;:",<,:\'1 v'_:,:, ':(i;~ ~ V~, . .....! 1,"< ,., I,,, ~j,:;;:;\i::;\lf ,Jrt1X3 ;-,U;~;::-',l:.~, .1 .0' -=:<,~~;$'f,~)'iI""RI!'!!il'W~'Q!~'I"i'-"'~f!)It'<i;>:>w.t1lW'^~~.m:!iIllW,@p-r~~~~~N;fYiI~~~~ MATTLEMAN, WEINROTH & Mll..LER BY: SHARON ORAS MORGAN, ESQUIRE Attorney LD. No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1,1998 C/O WENDOVERFINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs, NO.: 01-2100 DEBRA DEE REED AFFIDAVIT OF NON MILITARY SERVICE COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: I, That the Defendant is not in the Military Services of the United States of America or any other Country within the provision of the Soldiers' and Sailors' Civil Relief Act of Congress, as amended; and 2. That the Defendant( s) are at least 21 years of age and reside at 119 Yorkshire Road, Mechanicsburg, PA 17055. The Affiant has ascertained the foregoing information by personal inquiry and knowledge and makes this Affidavit with the authority, 1:8'"",_"""",,,, .1I!Il !-I Sworn,and Subscribed to before me this /0-1'1 day of ~<, 2002. ~':~~ . "., "., ",' ',., -, 'J' -,,", .."..,' '" .,. JtlD1THANN HITCHNER A NOTAR1 PUBUC9F NEW JERSEY MY COMMISSION EXPIRES 6/25/2006 !t'~!l" , ' . '-'d--" .,.'. -"" :""''''r ,.. '" MATTLEMAN WEINROTH & MILLER ~~ SHARON ORAS MORGAN, QUIRE ATTORNEYID. NO.: 60068 ~-. ., ' MATTLEMAN, WEINROTH & Mll.LER BY: SHARON ORAS MORGAN, ESQUIRE Attorney LD, No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff File No,: 291/55264 COURT OF COMMON PLEAS CUMBERLAND COUNTY NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 1998 C/O WEND OVER FINANCIAL SERVICES Plaintiff vs. NO,: 01-2100 DEBRA DEE REED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, Attorney at Law, being duly swom according to law, upon my oath, depose and say: 1. I am a member of the firm of Mattie man, Weinroth & Miller, attorneys for Plaintiff in the above entitled cause of action. 2, Notice, Rule 237.1 was forwarded to the Defendant's place of residence by regular mail on November 12, 2002 and has not been returned to this office, therefore it is assumed that same has been delivered to Defendant. ~~:, ,'C - ,_ _,".__. "'_~' - _,".~., ,r _. .~ Sworn and Subscribed to before me this I 0'1'1 day of ~"bU, 2002. ~fF:.~ Jilllmt AttTfIftTCHtlER · A NOTARY PUsy\C ot~EWiERSEY MY 'COMMISSION~PIRES 6/25/2006 \1l." - > , ","~ ~ ~, J. , MATTLEMAN WEINROTH & MILLER . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: Debra Dee Reed 119 Yorkshire Road Mechanicsburg, PA 17055 Date of Notice: November 12, 2002 NORWEST BANK MINNESOTA, NATIONAL COURT OF COMMON PLEAS ASSOCIATION, AS TRUSTEE FOR THE AMRESCO CUMBERLAND COUNTY RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1,1998 C/O WENDOVERFlNANCIAL SERVICES plaintiff vs. NO.: 01-2100 DEBRA DEE REED NOTICE, RULE 237.1 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 hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 NOTICE PJlRSU~NUO FAIR DEBT (717) 249-3166 COLLECTIO~ PRACTICES ACT. Mattleman, Weinroth & Miller THIS~COMMUNICATION IS FROM A DEBT Land Title Building - Suite 2226 COLLECTOR. THIS IS AN ATTEMPT TO Broad & Chestnut Streets COLLECT A DEBT AND ANY INFORMATION Philadelphia, PA 19110 OBTAINED WILL BE USED FOR THAT (215)}23- PURPOSE. 291/55264 Esquire #60068 '~"!I':w. ._~ ~ ..c.,_ ~~.., ,""< .,- "--., ,,"~ . "" ~Gf "c ~,' ".<~ ,~,_.,;;=,,, _^ .J " ...""""~ ,- , ' ,"~m ,_,_,_.,.~" ~ __~ ~, .N~'~"'~<_~~'" ~." 0 t::~ ., C t"-j ,~ "~!'l C N () s: '''' -IoQ. ;:gg': 1 #=- ~ :-C 2:,\.' C) .. ~ C:;-~ . ~ C'''- -c, - ~~ r' ....... - 0 -l,:] Lv <-::~: r--., ~- '-' IN ~C.. ,-- 9.) ~ -r:J --'~~ ~ ~ ....-:- ':.,.q ~~ (} r- :;! (Jl :< - ~ ~ ~ '(' t-f . l_rlT_ll:'1ml~~1IllII ~_",~~,,4~~!~w,1l'~-?"_?r!""1,'.',;;r,"'t'1I'!1':"ff~~~;\f-,!!,'-'I]"~~q!<i~~Jlli-;i~!I.~~~~ ('. ...... . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS CUMBERLAND COUNTY NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 01,1998 C/O WENDOVER FINANCIAL SERVICES Plaintiff vs. NO.: 01-2100 DEBRA DEE REED Defendant PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above referenced matter: Amount Due Interest from 12/17/02 to 12/10/03 Total (Costs to be added) $ 110,985.66 $ 10.103.16 $ 121,088.82 / Sharon Oras M gan, Esquire Attorney ill Number: 46450 MATTLEMAN, WEINROTH & MILLER Attorneys for Plaintiff Mortgage Foreclosure 'i",,_ " . '<, \<" "".""'""~"~"",' ~_"., ,~" ... IN ~ aY<JRr OF ~ PLEAS OF Cl.MlERLAND COUNl'Y. PENNSYLVANIA CIVIL DIVISION Caption: NORWEST BANK MINNESOTA, et al File No. Arrount Due 2001-2100 VS. Interest Atty's COnn! .' Costs 11 n QR~ 5h 10,103.16 DEBRA DEE REED TO THE PRCY!'HONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as arrehded.; and for real property pursuant to Act 6 of 1974 as arrended. PRAEX:IPE FOR EXECUTION tssue writ of execution in the above rratter to the Sheriff of -CllMBRRLAND County, for debt, interest and costs upon the following described property of the defendant(s) DEBRA DEE REED ~ ,..,<',~' ~f" '_0..: __" PRAEX:IPE FOR ATl'ACI-MENl' EXEnlTION ISsue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, ,directing attachment qgainst the above-named garnishee(s) for the following property (if real estate, supply six copies of the description;' supply four copies of lengthy personalty list) 119 ygP.KSHIU RQUl MECHANICSBURG, PA 17055 and all other property of the defendant ( s) in the possession, custody or control of the said garnishee(s). DATE: (Indicate) Index this writ against ,the garnishee(s) asa lis pendens real estate of the defendant(s) ~/q/l)) , I I I , " t d~oribOO ~i:':~ ~ Print Narre: SHARON ORAS MORGAN against Address: 100 ~OIT'1'H RROAn ~'1' PHIL~EhPHI~,. FA 18118 Attorney for: NORWEST BANK MINNESOTA. et a1 Telephone: ?1'-9?3-2225 Suprerre Court ID No.: '<ill'"'''" 'j:r ~ n", f-'f"" " ~ ~ -{- &f ~ , I I ! I: Ii " II \ , rw - -~~ ~R ~ {. ....... ..... , ::-.. ~ ~~ ~ 2 ~ 5' _ ~ ~ 1" f "'0 r- ().J 4::' ~ ~ --t; '->\ ~ ~ . , '0' 0 ~ lei 0 ~ ~ ---... \) ~ , ~ ,. . \~ 0 0 8 c (....:; ~ c.") -u l~,J ,." 92~_ "'"0: ;-~ . 2:1 ,,"; ~Z;~;.' <::> c (S '-' ~ ~~ ,-, ~ C' .':5 -n .....>i.. (") C) -'7 $ C' Cl :~rn z w ~ -,.1 -< '0 :J:I -< <. i'l'I ,~.~_ ~ ~!~ ~~~II'lI~W~W~i!'J.""@~W'iW1;~I~'fi'q,W',1lWl'_"!~'lJ',,'~f;j"r~_~~1Ii!~"ilW'm\~~~ ..... WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NOOI-2100 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORWEST BANK MINNESOTA NATIONAL ASSOCIATION AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 01, 1998C/O WENDOVER FINANCAIL SERVICES Plaintiff (s) From DEBRA DEE REED (1) You are directed to levy upon the property ofthe 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 ofthe 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 hirn/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $110,985.66 L.L.$ 0.50 Interest FROM 12/17/02 TO 12/10/03 $10,103.16 . Arty's Comm % Due Prothy $1.00 Arty Paid $106.82 Plaintiff Paid Date: SEPTEMBER 10, 2003 Other Costs (Seal) CURTIS R. LONG Prothonotary By: ~rB- O. ~/, .I Deputy REQUESTING PARTY: Narne SHARON ORASMORGAN ESQUllffi Address: BROAD & CHESTNUT STREET PHlLADELPIDA, PA 19110 Attorney for: PLAINTIFF Telephone: (215) 923-2225 Supreme Court ill No, 46450 "~lffi~_ ~, [,""""'"I, ~, r "0 MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney LD. No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 1998 C/O WENDOVER FINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.:01-2100 DEBRA DEE REED Defendants NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at119 Yorkshire Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on December 10,2003 at !0:00am in Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013 to enforce the Court Judgment of $ HO,985.66 obtained by Norwest Bank Minnestoa, et al. NOTICE OF OWNER'S RIGHTS YOU MAYBE 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 Sharon Oras Morgan, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Sharon Oras Morgan at (215) 923-2225. '-~-"-"~-"' , 'I " - ~. ' . ,.-.." , e? ,r-, . 2. You may be able to stop the Sale by filing a petition asking the Court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Sharon Oras Morgan at (215) 923-2225. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out ifthis has happened you may call Sharon Oras Morgan at (215) 923-2225. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of Distribution ofthe money bid for your house will be filed by the Sheriff on January 10, 2004. 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 ten (10) days after. 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 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. Lawyer Referral Service Lehigh County Bar Association Old Courthouse, Room 304 Fifth and Allentown Streets Allentown, PA 18105 (610) 433-7094 '~,,,Ji'l-__,", "~_.,,, ".0 _ '"" ",.",_,_, <- " 1 ~ , ~ " -" " F _, , "~~~~'" ~-'-,.."","""..,. ~-",~- . ,..." (') 0 (:1 c 'W "TI ~ c./') ~-'~ -u en 1'''1 ":"2::! cp 1" "-0 '-\-, r"'- 4_ I::I:; ~:. 1- .~ (/:1 r::;I 1:~) """" \- J-' ::~ =~:~~ :f-\ ;~ , 0 ;; t' 5 '-"', n" L~ :=j -"'1 !'..',) ~"'"1 -c;;. , 0 :< ~"",""'J!Ii$~1Ii'!Ph\~;~~i~WW,">i'~tl(f;'i!I~r~~!I"ffii''';W~$l;~1i''Clgj'''lj!!",~..,.,em~~~~\~#"M~ < MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney J.D. No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 1998 C/O WENDOVER FINANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.:01-2100 DEBRA DEE REED Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Norwest Bank Minnesota, et al, Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 119 Yorkshire Road, Mechanicsburg, P A 17055: 1. Name and address ofOwner(s) or Reputed Owner(s): Debra Dee Reed 119 Yorkshire Road Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the Judgment: Debra Dee Reed 119 Yorkshire Road Mechanicsburg, P A 17055 '~a,~". , -!'" '" ,.J ,= ,'r.' __ _~ - - r- - - ,-' _ _ 7 ,." '" 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Norwest Bank Minnesota (Plaintiff herein) 2601 South Bayshore Drive 4th Floor Miami, F1 33133 Domestic Relation Court 13 North Hanover Rd Carlisle, Pa 17013 PP&L 827 Hassman Rd Allentown, Pa 18194 Lower Allen Township 120 Limeklin Rd New Cmnberland, Pa 17070 Lower Allen Township 1993 Hummel Ave Camp Hill, Pa 17011 Lower Allen Township 120 Limeklin Rd New Cmnberland, Pa 17070 4. Name and address of the last recorded holder of every mortgage of record: Norwest Bank Minnesota (Plaintiff herein) 2601 South Bayshore Drive 4th Floor Miami, F133133 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property ~d whose interest may be affected by the sale: Occupant 0 119 Yorkshire Road Mechanicsburg, P A 17055 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant 119 Yorkshire Road Mechanicsburg, PA 17055 '~"'! """'"',_,_"'._ .0'7"'.,., -, r' ". . . ~ I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ARON ORAS MILLER, ESQUI ATTORNEY J.D. NO.: 60068 BEATRICE HEALEY NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES MAY 20.2008 :.\:.,-~~-.,,_.,..,.-~ -~ .", -.-.- .',r=-_B,_ '-WL' ., ~ ~tJ " . ."., ,~'"'~~, - ~Wl!,o~.~ .-, _ 'W' ,",e_ - ~_"~';~ ,.~".~~c '" " ^ ~-~, '" ~~-, >'" ~-~.- o c: <'" "Tlr: if- r-.-'., :.<:' ---....:...,.- 1~~; :':~ - a (.0 o ., .::r-J :'r~';11 -""'1 . ,~, i,::::'J ~-2 (J ~-J~~ ~~fn ~.O ""< :/) -" -0 C~ :;:::>:> :~;i: C) :.J \(..) - ~ i!PIlIJ.I;_""""",~'tll.'_fll~ffl"MJ~W;~~'!W''ifmW'!l'~~'lffl!#IIN''W-~~$!\'l1'!<1l'''f'1'.WI~~,,""~~W!I;'I!~~- MATTLEMAN, WEINROTH & MILLER BY: Sharon Oras Morgan, Esquire Attorney LD. No.: 60068 Suite 2226 Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 01,1998 C/O WENDOVER FINANCIAL SERVICES FILE NO.: 291/55264 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.:01-2100 DEBRA DEE REED Defendant AFFIDAVIT PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, offull age, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the firm of Mattleman, Weinroth & Miller, attorneys for the Plaintiff in the above entitled cause of action. 2. On, September 10,2003 a copy of the Notice of Sheriffs Sale of Real Property was served on all interested parties by registered mail. A copy of the registered mail receipt is attached hereto and made a part hereof as Exhibit "A". 'f?1 0 . ,. """ ,~.-s_,_~" . 'F ~"', t" 3. Copy of the Notice of Sheriffs Sale of Real Property was served on the Defendant, Debra Dee Reed via the Cumberland County Sheriffs Department. A copy of the Return of Service is attached hereto and made a part hereof as Exhibit "B". 4. A Notice ofIntention to Foreclose MortgagelNotice of Homeowner' s Emergency Mortgage Assistance was sent to the Defendant(s) by regular and certified mail on November 16, 2000 . The Defendant has not cured the default. A copy ofthe Act Notice is attached hereto and made a part of hereof as Exhibit "C". Mattleman, Weinroth & Miller "~4 Sharon Oras Morg , Esquire Atty LD. No. #60068 Sworn and Subscribed to before me this:fl:ll Day of~ ,2003. ~~~- JUDITH ANN HITCHNER A NOTARYPUBl:ICOfNEW JERSEY MY COMMISSION EXPIRES 6/25/2006 ;;.'"To_ ~_. -' _ r"-',--"_"_ '1- , . ;;; il'" =l:? 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O.!!2 il--.J i/j G d };. \( ~, ~ <t ~ ~ (" ~~ ~ I ;5)104: Norwest Bank Minnesota, National Association, as Trustee for the Amresco Residential Securities Mortgage Loan Trust 1998-2, Under the Pooling and Servicing Agreement Dated as of June 1, 1998 c/o WendoverFinancial Services VS Debra Dee Reed In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2100 Civil Term David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on September 16, 2003 at 5: 1 0 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: Debra Dee Reed, by making known unto Debra Reed, personally, at 119 Yorkshire Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy ofthe same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 3:21 o'clock P.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 Debra Dee Reed located at 119 Yorkshire Road, Mechanicsburg, 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 Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Debra Dee Reed, by regular mail to her last known address of 119 Yorkshire Road, Mechanicsburg, PA 17055. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriff's Office. This _ day of ~~~..<~ R. Thomas Kline, Sheriff ( i ~/ ,-' I' , . , ,{-;__;- BY'o-) C(l..cY-<7{IVlIX'vl Real Estate Deputy Sworn and subscribed to before me 2003, A.D. Prothonotary ?"[ffi, " r."" \F>'-- '.-'-', -,~_ ""r'~ 10lrn C. MIllER. 111 NATALEG. SAVASTA. STEVENH. FINKELSTEIN. DELIA A. CLARK _ PAllL D. AARONSON . MICHAELJ. MILSTEAD + HELENEB. MUSH ERIC L. METH SHARON ORAS MORGAN ADAMR. ELGART' ELISE N. LAZARUS MICHAELJ. KENNEDY LYNN MBOWLBYofo PINA S. WERTZBE.RGER. MELANIE 1. TIlOMPSONrp DANC. PELLETJER+ MATTLEMAN, WEINROTH & MILLER A PROFESSIONAL CORPORATION COUNSELLORS AT LAW OF COUNSEL GEORGE 1. WElNR.OTH IlERMANMATrLEMAN' DOLORES M. BOIAZl JOHN G. MULFORDtp GERALD 1. PROFFITI't PLEAsEREPLvTo: PHlLADELP!llA OURF1LENo.: 291/55264 MEMBERS OF THE Nl &. pADARS . NI&:FLBARS . PABARONLY + NIBARONLY . PA&DEBARS ;. NI,PA&DEBARS .. N1.1; NYBARS ., DE BAR ONLY November 16, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortcace on vour home is in default. and the lender intends to foreclose. SDecific information about the nature of the default'is Drovided in the attached Daces The HOMEOWNER's MORTGAGE ASSISTANCE PROGRAM IHEMAP) mBv be able to helD to save vour home. This Notice exolains how the Drocram works To see if HEMAP can helD. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselinc Acencv The name. address and Dhone number of Consumer Credit Counselinc Acencies servinc vour Countv are listed at the end of this Notice. If you have any cuestions. vou may call the Pennsvlvania Housinc Finance Acencvtoll free at 1-800-342-2397 .IPersoris with imDaired hearinc can call (717) 780-1869. This Notice contains important legal information. If you have any questions, 401 RouTE 70 EAsT CHERRy Ha.L, NEw IBRSEr 08034 TEL:(8S6)429-SS07 FAX: (BS6) 429-9036 lANDl'mEBun.otNG SUItE2226 BROAD &: CHESTNUT STREETS PHn:.ADBLPHIA, PENNSYLVANJA 19l10 TIiL: (2IS) 923-222S FAX:(21S)S67-4IS1 200CoNTINENTALDRIvE. SurrE2l I NEWARK. DELAWARE 19713 TEL: (302)731-8349 FAX:(302)731-87S3 113S BROADSTREET.SUlTE207 CUFroN, NEw .JllllSEV 07013 Tm.:(973)36S-6140 FAX:(973)36S-6143 ,Jr~,v" ~_ r ~" r ~',~~""" November 16,2000 Page 3 CONSUMER CREDIT COUNSELING AGENCIES- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the ,lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desicnated consumer counselinc acencies for the county in which the Drooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face~to-face meeting. Advise .your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature or your defauit.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed atthe end ofthis Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FilE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED ,AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility' criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. Ypu will be notified directly by the Pennsylvania housing Finance Agency of its deciSion on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT IBrina it UD to date). NA lURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 119 Yorkshire Drive Mechanicsburg, PA 17055 :.-,b ". -, "~_~, .-, '- --, ~ November 16,2000 Page 4 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: March 1, 2000 to November 1, 2000 at $852.08 per month Late Charges - $204.72 TOTAL AMOUNT PAST DUE: $7,873.44 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of this date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $7,873.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made Davable and sent'to: Norwest Bank Minnesota National Association. as Trustee for the Amresco Residential Mortaaae Loan 1998-2. under the Poolina and Servicina Aareement dated as of June 1. 1998 clo Wendover Financial Services. P.O. Box 70808 Charlotte. NC 28272-0808 IF YOU DO NT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any Attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default within the THIRTY (30) DAY period and foreClosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then dUe, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and ;">'; __ r I "~ .<,-.~ ,-,. November 16, 2000 Page 5 by performing any other requirements under the 'mortgage. Curing your default in the manner set forth in this noticewill restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that .such a Sheriff's Sale of the mortgaged property could be held would be approximately FIVE (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Norwest Bank Minnesota National Association, as Trustee for the Amresco Residential Mortgage Loan 1998-2, under the Pooling and Servicing Agreement dated as of June 1, 1998 c/o Wendover Financial Services. Address: P.O. Box 70808 Charlotte, NC 28272-0808 Phone Number: 1-800-436-1 022 Contact PerSon: Foreclosure Representative EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff' Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may orl11ay not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to ir at the sale and that the other requirements of the mortgage are satisfied. Please contact: Norwest Bank Minnesota National Association, as Trustee for the Amresco Residential Mortgage Loan 1998-2, under the. Pooling and Servicing Agreement dated as of June 1, 1998 c/o Wendover Financial Services. P.O. Box 70808 Charlotte, NC 28272-0808 1-800-436-1022 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) ;{ ..~ --,- - ,.< ~"~- - ,-, - I November 16,2000 Page 6 TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW c J GENCIIjf SER~ING YOUR i WvG1-UW r1( ~haron Oras Morgan, E uire l'ii1attleman, Weinroth & Miller COUNTY IS CONSUMER CREDIT INCLUDED. M\,t~~,= . ' - ,~" , -. -" L_., -_.'" , -, - ~, "] t~ l,.,.~m~ -~--- ~ ~- -~~ .. '"~" ~ ~o 8 ""tJi:::' ,-i'; \"[, -1!J; ! ,20J OJ' ;:::;;;;- . r' '.fO' <:~c: Y;E .~ -.., ~< ~.... .. ;r.;... ::r 9 ,",) 0'\ . c Co.:> t:::) (1'"1 <- , <.0 Q .,., f:!~:-n ,.,~ ',:3[:4 r):Y .. ('- '~f:! ..;{ --- J:I ;),~. ? 6 ~ .:0 -< ....!"'~,~,~~~,~~~ q~li'J!'lI'~W!IilI~:JlI!I_,~1'\'i\!l!;;'!i~~Ji''''~I''''',Ii,...It'[n~!>_"""T-''pllwJt-O!'cW~_~;rJ~ll{l'~ffi~"<II~Iffi'~~~~ , 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 Sheriff's Deed in which Norwest Bank Minnesota N A tr for Amresco Residential see Mtg Ln Trust is the grantee the same having been sold to said grantee on the 10th day ofDec A.D., 2003, under and by virtue ofa writ Execution issued on the lOth day offum!, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 2100, at the suit ofNorwest Bk Minnesota N A tr for Amresco Res Sec Mtg Loan Tr 1998-2 against Debra Dee Reed is duly recorded in Sheriffs Deed Book No. 261, Page 1576. IN TESTIMONY WHEREOF, I have hereunto set my hand --tft:;-" and seal of said office this JlJ day of /L". (f- , A.D2004 - Recorder of Deeds I'lecorder 01 , CUmbeI10nd County. Carlisle. PA My commIsSion ExpiIM the FIrst Monday of JaIl. 2C06 (~.",...,-~--" -'=~ "" ,. , -1 " , Norwest Bank Minnesota, National Association, as Trustee for the Amresco Residential Securities Mortgage Loan Trust 1998-2, Under the Pooling and Servicing Agreement Dated as of June 1, 1998 c/o Wendover Financial Services VS Debra Dee Reed In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2100 Civil Term David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on September 16, 2003 at 5: 1 0 0' 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: Debra Dee Reed, by making known unto Debra Reed, personally, at 119 Yorkshire Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 3:21 o'clock P.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 Debra Dee Reed located at 119 Yorkshire Road, Mechanicsburg, 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 Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Debra Dee Reed, by regular mail to her last known address of 119 Yorkshire Road, Mechanicsburg, P A 17055. 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, Penn~ylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of$I,OO to Attorney Sharon Morgan for Norwest Bank Minnesota, National Association, ~s Trustee for the Amresco Residential Securities Mortgage Loan Trust. It being the highest bid and best price received for the same, Norwest Bank Minnesota, National Association, as Trustee for the Amresco Residential Securities Mortgage Loan Trust of P.O. Box 70808, Charlotte, NC 28272, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$713.05, it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library $30.00 13.98 15.00 15.00 30.00 10.00 .50 ')"-l~ ,_ u~."",,,.d,""'1",,,, .-- . ~. p T. ~_ [___~ , Prothonotary Mileage Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 1.00 15.18 15.00 20.00 246.80 207.19 28.90 25.00 39.50 $ 713.05 s~om and subscribed to before me , So Answers: ~ ThIs ;.I.l",,","aYOfY~"1'''t ~~~ ~ Q c R. Thomas Kline, Sheriff 2001/ A.D. ~~v - ~, ~ J~ (" .11 P othonotary BY ~ Real Estate eputy ~"'''f''''f7'''''"_'''"'_'''.I'.''j,'~_~^ T ' "r""'~"1! ~ ~ 3boV V \,60 ~~ ck.-- '13'11 '7 ~ 1'fC.7J 7 .~ --~----= ~,-'" , MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney LD. No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plaintiff File No.: 291/55264 COURT OF COMMON PLEAS CUMBERLAND COUNTY NORWEST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 1998 C/O WENDOVER FINANCIAL SERVICES Plaintiff vs. NO.:01-2100 DEBRA DEE REED Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND Norwest Bank Minnesota, et al, Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 119 Yorkshire Road, Mechanicsburg, PA 17055: 1. Name and address ofOwner(s) or Reputed Owner(s): Debra Dee Reed 119 Yorkshire Road Mechanicsburg, P A 17055 2. Name and address ofDefendant(s) in the Judgment: Debra Dee Reed 119 Yorkshire Road Mechanicsburg, P A 17055 O"'1i~-j,~0I1>;" ~, ,. "'~ ~""! . , . - 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Norwest Bank Minnesota (plaintiff herein) 2601 South Bayshore Drive 4th Floor Miami, F133133 Domestic Relation Court 13 North Hanover Rd Carlisle, Pa 17013 PP&L 827 Hassman Rd Allentown, Pa 18194 Lower Allen Township 120 Limeklin Rd New Cumberland, Pa 17070 Lower Allen Township 1993 Hwnmel Ave Cam]} Hill, Pa 17011 Lower Allen Township 120 Limeklin Rd New Cumberland, Pa 17070 4. Name and address of the last recorded holder of every mortgage of record: Norwest Bank Minnesota (plaintiff herein) 2601 South Bayshore Drive 4th Floor Miami, FI 33133 5. Name and address of every other person who has any record lien on the property: None known. 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: , Occupant 0 119 Yorkshire Road Mechanicsburg, PAl 7055 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant 119 Yorkshire Road Mechanicsburg, P A 17055 or;~~~ ,- ~~ r l,~ '1 =~ I verifY that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made , subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BEATRICE HEALEY NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES MAY 20, 2008 ;:c,~"",," "' ,_ _, , J_"~""'F"'~ ~ ~, -~ r e-., ,-' '1 ON ORAS MILLER, ESQU ATTORNEY J.D. NO.: 60068 ~= ~~ ~ '~ MATTLEMAN, WEINROTH & MILLER' BY: SHARON ORAS MORGAN, ESQUIRE Attorney I.D. No.: 60068 Land Title Building - Suite 2226 Broad & Chestnut Streets Philadelphia, PA 19110 (215) 923 -2225 Attorneys for Plaintiff File No.: 291/55264 NORWEST BANK MINNESOTA, NATIONAL 'ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDERTHEPOOLmGANDSER~CmG AGREEMENT DATED AS OF JUNE 1, 1998 C/O WEND OVER FmANCIAL SERVICES COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.:01-2100 DEBRA DEE REED Defendants NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) atl19 Yorkshire Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on December 10,2003 at 10:00am in Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013 to enforce the Court Judgment of $ 110,985.66 obtained by Norwest Bank Minnestoa, et al. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: L The Sale will be canceled if you pay to Sharon Oras Morgan, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you ,must pay, you may call Sharon Oras Morgan at (215) 923-2225. .-".T","'",Y~;wo;",". ~~ .- , - 2. You may be able to stop the Sale by filing.a petition asking the Court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. . 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. lfthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Sharon Oras Morgan at (215) 923-2225. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To frod out if this has happened you may call Sharon Oras Morgan at (215) 923-2225. 4. lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of Distribution of the money bid for your house will be filed by the Sheriff on January 10, 2004. 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 ten (10) days after. 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 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. Lawyer Referral Service Lehigh County Bar Association Old Courthouse, Room 304 Fifth and Allentown Streets Allentown,PA 18105 (610) 433-7094 ',,-, ., -~ t "~ ,,~, - -. " ALL THAT CERTAIN piece or parc:1 of land situate in Lower Allen Township, Cumberland' County, Pennsylvania, being bounded and described as follows, to wit: BEGINNING at a point on the Easter y side of Yorkshire Drive (50 feet wide) at the dividing line between Lots Nos. 10 and 11, Block,:: on the hereinafter mentioned Plan of Lots; thence ~long the dividing line between Lots Nos. 10 a1 d 11 on said Plan North 45 degrees 22 minutes East the distance of 110 feet to a point in line )f Lot no. 16; thence along the Westerly line of Lots Nos. 16 and 17 South 44 degrees 38 minutes I ast the distance of 75 feet to a point at the dividing line between Lots Nos. 9 and 10 on said F Ian; thence along said dividing line South 45 degrees 22 minutes West the distance of 110 feet to a point on the Easterly side of Yorkshire Drive; tI:.ence along said Drive North 44 degrees 38 minutes West the distance of 75 feet to a point, the t,lace of Beginning. BEING Lot No. 10, Block E on Plan ~o. 7 of Windsor Park, also known as Orchard Cres!: Manor, as recorded in Plan Book 19, Page 44 BEING known as 119 Yorkshire Drivt. Tax Parcel #13-24-0793-071 - REAL ESTATE SALE Nel. S3 ,-, r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOOI-2100 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due NORWEST BANK MINNESOTA NATIONAL ASSOCIATION AS TRUSTEE FOR THE AMRESCO RESIDENTIAL SECURITIES MORTGAGE LOAN TRUST 1998-2 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 01, 1998C/O WENDOVER FINANCAIL SERVICES Plaintiff (s) From DEBRA DEE REED (I) You are directed to levy upon the property ofthe 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 gamishee(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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $110,985.66 L.L.$ 0.50 Interest FROM 12/17/02 TO 12/10/03 $10,103.16 Atty's Comm % Due Prothy $1.00 Atty Paid $106.82 Plaintiff Paid Date: SEPTEMBER 10, 2003 Other Costs CURTIS R. LONG (Seal) Prothonotary By: 9ut/U- 0 ~ Deputy REQUESTING PARTY: Name SHARON ORAS MORGAN ESQUllffi Address: BROAD & CHESTNUT STREET PIDLADELPIDA, PA 19110 Attorney for: PLAINTIFF Telephone: (215) 923-2225 Supreme Court ID No. 46450 ,"~if.lJli1il~nrD.~ ~. 0.1', .. --~ ,.", Real Estate Sale # 53 On September 12,2003 the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA known and numbered as 119 Yorkshire Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 12,2003 By: J wi fAXA. -rI-I/l Real is;a~l D:~ \ ~ ~ ~ 'V I N'V ^ l), S fIN.3 d ::? -1 ':~' [ ".~ ~~l \,f ~ EO, Wd 60 8 "c13S JUilI,n,0~, ,:i':'i"i8JOHOO :JIdI;,*,.3I:lS 3111 JO 3JIJJO ~,,_~, A """",.",~,,,,,,,~I"M1,,~~'<J'ilI~fSl;t$~!'ln'l1"!'!W_'PW<?'.'!"blf''''<<"':''+'''''i,,,-q,,,_.'C,N,",,"'<.' ~., ,"t":r,",,:o~""""1',.~"~"ef'<'";''"'i>I''~'''''/''_''_~losqiJ!'!'i~~fl;Wi1lll'~1~~l!Jii \. ..... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to iaw, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws at the-Commonwealth of Pennsyivania, 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....IbiL 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,oand September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is secureiy 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 personai 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. Sworn t NO My commission expires June 6, 2006 PUBLICATION COPY SALE#53 d subscribed before NOlanal Seal Terry L. Russell, Nolary Public City Of Hamsburg, Dauphin County My Commission Expires June 6, 2006 Member. Pennsylvania Association Of Notaries ':C:;:-:I'lEAL,l':STATIOSALl':'Nti. 53-- !. ,...., W.rit No. 2001-2100 "'" Civil Term NorW:est Bank MinnesQta, National Association, as , :rrL#S~~ for the Amresco !.,::::.... . Residential Securities Mortg~ge Loan Trust 1998-2, .". Under The Pooling and '. ,', .Servlc;:,Jng Ag~ment Dated . ,',- ..~,"ofJunfi'1,1998 ' ': ',(;/0 Weridover Financial SelVices ,.. ,'.., vs ' , 'Debr. Dee Reed , AftY: Sharon Morgan '.",. ,DESCRIPTION ,:':'::'::::tl,;LL T!M.T:'CB-RTAlN piece o~ parcel of Jan9 -_'I [:::~t~TC~:Ylf::r;:~y~ Allen Tp~nshJ:p; ,Cutpperkrid .. (::::::::I~iy;:: :,p~p..ci'~y'{van1a,' . beilil~", bounded ..!lnd t':,::"::~~~1#d ~l91\9W~, l1? WIt: ' ",:' ',.'.. ' -:: ':::'::',:::::,aEP~NNn{.q.aJ: a pom!, on fu.e Easterly. Slqe of:,,' ~,::'"..:',YOt:KshireDn\~(50feet'wide)at'thedlvlding.line,': P bl' h ' R . .. C ,J;,(weenLot,Nos,IO,and II,BlookEnn',(po. U IS er S ecelpt for AdvertiSing ost '::::I:l~e1~rJ.li;ntioncdPlanofLots;theDt'e~l~,ilg,::o. publisher of The Patriot-News and The Sunday Patriot-News newspapers of general ,thedlvldmg,h~e1JetweenLotsNos.JOapd]!-on '. .. . . '.. , said Plan NQl'ih 45 degret.'li 22 rilinUtes East the jge receipt of the aforesaid notice and publication costs and certifies that the same have "distance..of lio feet to a point in line ofL6t No. 16; thence along the Westerly line of Lots Nos. L6 and 17 SotI,~.1 44 ~~grees 38 minuteS East the distance of 15'feel to a point at the dividing line belweenLotS_Nos.9:ind 10 ori said Plan; thence aiong said"dividing line South 45 degrees 22 , ":nlinutesWe.';t theuistance.of 110 feet to a point {iri,"tlie'Easreny side oiYorks.hire Drj\le; thenc~ along said Dri~ North 44 degrees 38 minutes \Vestthe distance of 75 feet to a point. tneplace ofBEGINNJNG. BEING I.pt No. 10, Block E on, Plan .No. 7 of Windsor Park. also known as Orchard Crest i rvtanor, asreeoroed in Plan Book 19, Page_44. , BEINGknOWnilS J19YorhhireDnve;. 1l\X PARCEL NO,: IJ.24-D793.07L 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 Total $ 207.19 By.................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor ofthe 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, placr character of publication are true. --- SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER. 2003 AL SEAL LOIS E. SNYDER, Notary Public , Carlisle Boro, Cumberland County My Commission Expires Man:h 5, 2005 ol;~"""'"",,=""!"'__llll\!!I!il "..., I;' ",~ T"" ."1"'0='"'-'_' -'--I' "~--- R!IML ESt'Am SAlLE NO. 53 Writ No, 2001-2100 Civil Norwest Bank Minnesota, National Association. as Trustee for the Amresco Residential Securities Mortgage Loan Trust 1998-2. Under the Pooling and Servicing Agree~ient Dated as of June 1. 1998 c/o Wendover Financial Services 'vs. Debra Dee' Reed Atty.: Sharon Morgan ALL THAT CERTAIN ptece or parcel of land situate in Lower Allen Township. Cumberland County. Pennsylvania. being bounded and described as follows. to wit: BEGINNING at a point on th,e Easterly side of Yorkshire Drive (50 feet wide) at the dividing line be- tween Lots Nos. 10 and II. Block E on the hereinafter mentioned Plan of Lots: thence along the dividing line between Lots Nos. 10 and 11 on said Plan North 45 degrees 22 minutes East the distance of 1-10 feet to a point in line of Lot no. 16; thence along the Westerly line 'of Lots Nos, 16 and 17 South 44 de. grees 38 minutes East the distance of 75 feet to a point at the dividing line between Lots Nos. 9 and 10 on said Plan; thence al0ng said divid- ing line South 45 degrees 22 min- utes West the distance of 110 feet to a point on the Easterly side of Yorkshire Drive; thence along said Drive North 44' degrees 38 minutes West the distance of 75 feet to .a point, the place of Beginning. BEING Lot No. 10. Block E on Plan No. 7 of Windsor Park. also known as Orchard Crest Manor, as recorded in Plan Book 19. Page 44. I BEING known as 119 Yorkshire Drive. Tax Parcel #13-24-0793-071.