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Home My WebLink About01-06452 !.\lIj~.' --~,. I 1 -"~. ~ ~ - I, '~ , ~ ,_. ..I I . '.~ ~, "~;iti;w", SHERIFF'S RETURN - REGULAR CASE NO: 2001-06452 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS BREHM DORIS V RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BREHM DORIS V the DEFENDANT , at 2054:00 HOURS, on the 16th day of November, 2001 at 100 B STREET PLAINFIELD, PA 17081 DORIS V BREHM (JOHNSON) by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.90 .00 10.00 .00 31.90 So Answers: ~~~<~ R. Thomas Kline 11/19/2001 FEDERMAN & Sworn and Subscribed to before By: h. tz...- me t lS oli.. day of ~ :2hOf A.D. q'r'~ Q 'n".Il'p'd~ Prothonotary' ~,::,1.;I('~ ., .'~*,~~;i\!iitFIii!t~k""h~~~k);':;;''''' 'ct'[,;r-,~,~~'",;; ,7<:',',"'J),}""":,,,,,, ro-.-~'" f-.d,",,' ,_',.i-'-"'_;"'~'-'N",,',;JW;;,',,;i!lJo,,;.&je>L;\:'''\.0ii!illIil:!lii1ll,w.~~Jf'']DJ:tknil('~r ,. ~,~~'" "~,~~..,~"', '" ,~"'" - ~~ , __, c_,. ,'.","', ~, ''''"~'~''~~''~' .,-- =- < ^ "--""",, '~'-'Jt~l!tlyr"i '"\i~"tl!LM ES itS ~, III " ilifL "J rJ~1;i,1:ii;;:{~t;'8 / STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, ____________________________________________________________________________~rderof Deeds in and for said County and State do 'hereby certiry that the Sherirrs Deed in which __________ Salomon Brothers Mtg Securities VIr Inc Tr _____________________ ____________ ___________________________ is the grantee 5th the sa~e having been sold to said grantee on the ______________-C.______""-_______ day or 02 ___________!~_r:=_____________ A. D., r ----J under and by virtue of a writ_____________ 8th ______issued on the _______________ 02 ____..., out of the Court of Cornman Pleas of said County'as of 01 Execution January day of _________________________ A. D., Civil --~_..-----~~;~-----------------~llS F~~go- Bk Minnesota NA-~bre~Jr~esE-lfl( Minnisota Numhcr __________,&t th,'rfu~f -or"ar~-IIrr;rJj:f'Jrs::tttg-.frt-,e...,4-lri.~\!~-I'i'f--"T=~~'1!: Backed eertificatD~r~~rve~r~R~ -lB-b p66l~ng berv agree ___________________________________against____________________________________________________ ~ duly recorded in Sherirrs Deed Book No. __}_~L___.., Page ____~622 _ IN TESTIMONY WHEREOF, I have hereunto ~ set m1Jand and seal of said oWce this ~____ day of -r;ft;--- ~~- --_ Li_ r Deeds CumI>tlIInd CountY, CIr\IIlt, PA My loll e,q,.,.1lllI fftl MIlndlW ol.lln.llIlIlI - . ~.......L""~llllllllli<l J'---'~.~~-.""- '. -'~if"'<' ""'I:iJ>''-'--''f~\'~~:i Wells Fargo Bank Minnesota, N.A., Successor by merger to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc. Asset Backed Certificates, Series 1997-IB6 Under pooling and servicing aggreement dated As of November 1, 1997 VS Doris V. Brehm In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6452 Civil Term Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on March 04, 2002 at 5:16 o'clock pm, EST, 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: Doris V. Brehm, by making known unto Doris V. Brehm (nlk/a Doris V. Johnson t1rrough marriage) personally, at 304 Walnut Lane, Carlisle, Cumberland County, Pennsylvania, its contents and at tl1e same time handing to her personally the said true and correct copy ofthe same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2002 at 8:45 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in tl1e above entitled action, upon tl1e property of Doris V. Brehm located at 100 B Street, Plainfield, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served tl1e above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Doris V. Brehm, by regular mail to her last known address of 304 Walnut Lane, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to tl1e Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says tl1at after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5, 2002 at 10:00 o'clock A.M.. He sold the same for the sum of $1.00 to Attorney Frank Federman for Wells Fargo Bank Minnesota, NA successor by merger to Norwest Bank Minnesota,N .A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Asset Backed Certificates, Series 1 997-IB-6 Under Pooling & Servicing Agreement Dated as of November 1, 1997. It being the highest bid and best price received for tl1e same, Norwest Bank Minnesota, N.A., as Trustee of Salomon BrotI1ers Mortgage Securities VII, Inc., Asset Backed Certificates, Series 1997-IB-6 Under Pooling & Servicing Agreement Dated as of November 1,1997 of505 South Main Street, 6th Floor, Orange, CA 92868-4509, being the buyer in tl1is execution, paid Sheriff R. Thomas Kline tl1e sum of$1,086.69, it being costs. .'",! ~ - ~~~- Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed ~, ' $30.00 21.73 15.00 15.00 30.00 10.00 .50 1.00 8.28 2.41 15.00 20.00 493.25 366.55 25.20 . '~ ll~. LL :',;,! ,~-, .~'~".', !tic .i;~_' "hf.<~ii 25.00 29.50 $1108.42 paid by attorney 06/19/2002 Sworn and subscribed to before me ThiS~daYOf~ 2002, A.D.~, (). I'vt.jp,. , ,~ r honotary So Answers: -r'R~ ~-~#~ R. Thomas Kline, Sheriff BY~(lc1.J ~iG Real Estate Deputy ~ ~. ;;0 .!iI?' \ ",-"I) . 101'-\ J'L..3 ;J..f }/.1 l0>>' .._~ . I - ill' ,.,~-' ~,". .'.' - ". i "'''~~''""":,.,t,,x ... ' WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK .' CUMBERLAND COUNTY MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECUlRITES"VII, INC. COURT OF COMMON PLEAS ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING CIVIL DIVISION AGREEMENT DATED AS OF NOVEMBER 1, 1997 NO. 01-6452 Plaiutiff, v. DORIS V. BREHM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) WELLS FARGO BANK MINNESOTA. NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA. N.A.. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII. INC. ASSET BACKED CERTIFICATES. SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER I. 1997, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed tl1e following information concerning the real property located at .100 B STREET. PLAINFIELD. PA 17081. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DORIS V. BREHM 100 B STREET PLAINFIELD,PA 17081 . 2. Name and address of Defendant(s) in the judgment: DORIS V. BREHM 100 B STREET PLAINFIELD,PA 17081 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: ~'?;I - I ,~_ , '^ 11iIliiiIIil' ."""'-"''-T- "...' ~"""~n''',r~~''''',>\' ." . Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. FRONT STREET HARRISBURG, PA 17105 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DONALD R. BREHM 100 B STREET PLAINFIELD,PA 17081 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by tile sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) T enantlOccupant 100 B STREET PLAINFIELD, PA 17081 . Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify tilat tile statements made in t1ris 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 :::~:::~ :~o~s S~ 49~ rel.ting re =J:T iriti" DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '9 l> ." _~I. ~' _,I . ~ ' , .. -~",'j~ :I""m!i-:&'i',:<$,~"c'" \ " WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST .BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 CUMBERLAND COUNTY No. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). December 24,2001 TO: DORIS V. BREHM 100 B STREET PLAINFIELD, PA 17081 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at .100 B STREET. PLAINFIELD. PA 17081. is scheduled to be sold at the Sheriff's Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of58.149.18 obtained by WELLS FARGO BANK MINNESOTA. NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA. N.A.. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII. INC. ASSET .BACKED CERTIFICATES. SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1. 1997 (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the SEPTEMBER 4,2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE . To prevent this Sheriff's Sale, you must take immediate actiou: 1. The sale will be cancelled if you pay to fue mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) I 'j, ~~~ I - ,I ~~ -< -- '- kll 'Ii&. - ,.. ~ '!",,~.',utl-."--'-d~"""'Y' .. ,. yOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2 I 5) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Iffue amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving fuat money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . ~. ,'I' "'0 .., I,J:..' '--0 ilrI'u - .L%'~,'~';o",,,~~,' , " ALL THAT CERTAIN house and lot of g.mind situate in West Pennsboro Township, Cumberland County; Pennsylvania, bounded and described in accordance with lot layout of Gilbert Q. Crosley as recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, P.ennsylvania, in Plan Book 11, Page 46, and survey made by Thomas A. Neff, Registered Surveyor, on May 17, 1966. BEGINNING at a spike in the centerline of a 33 feet wide unnamed public street extending Northwardly from Pennsylvania Route No. 641 where tl1e same intersects the centerline of said unnamed 33 feet wide public street running Eastwardly therefrom; thence from said spike at the place of BEGINNING, Soutl1 65 degrees 45 minutes East, a distance of 95 feet to a point; tl1ence along the Western line of Lot No. 20 now or formerly of Thomas Lebo, Soutl1 24 degrees 15 minutes West, a distance of 126 feet to a point on the Northern line of Lot No. 17 now or formerly of Thomas Lebo; thence along the Northern line of a portion of Lot No. 17 now or formerly of Thomas Lebo and the Northern line of all of Lot No. 18 nowoI' formerly of Christine Kluck, North 83 degrees 25 minutes West, a distance of 99.70 feet to a spike in the centerline of said 33 feet wide unnanled public street extending Northwardly from Pennsylvania Route No. 641; tl1ence along the centerline of said 33 feet wide unnamed public street, North 24 degrees 15 minutes East, a distance of 156.25 feet to a spike at tl1e place of BEGINNING. CONTAINING all of Lot No. 19 as shown on said Plan of Lots recorded as aforesaid and having thereon erected a one-story brick cased ranch-type dwelling with other improvements. BEING No. 100 "B" Street a/k/a Lot 19, Plan Book 11-46. TAX MAP NUMBER: 18-1392 PARCEL NUMBER: 013 TITLE TO SAID PREMISES IS VESTED IN Doris V. Brehm, married person by reason of the following: . hi h Richard A Lindsey and Patricia M. Lindsey, husband and wife by BEING tl1e same premIses w c '. f C bId' Deed Book "J" Deed dated 11/29/1971 and recorded _1_1_ m tl1e County 0 . um er an musband and Volume 24 Page 1058 conveyed unto Donald R. Brehm, Jr. and Dons V.Brehm, h. _ wife. . . D ald R B hm Jr married person by Deed' dated AND ALSO BEING the same premIses which on . re .'. ., 30 P 1086 10/6/1995 and recorded 11/8/1995 in the County of Cumberland m Record Book 1 age conveyed unto Doris V. Brehm, married person. "- ~ - .....~. -~~~ ..1, ~ " "~I","- ' ~< .~~ .., 'ru:;l<:~~a!6t",,",,"';';,","'M't'. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEAL TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO~ (11_1;4"7 CIVIL lllX TERM CIVIL ACTION - LAW - TO THE SHERIFF OF C>llI1berJe'T1d________..._COUNTY To sallsly the debt. inlerest and costs due Wal;LJ>.Fm:gg. Bank Minnesota, NA Successor ~y, MerQer To NOIwest Bank Minnesota, N.A., As Trustee of Salanon Brothers Mortg<;!g~ beCUIl.L...,-,e. .II, Inc..-Asoct Bac]{cd CortifiGal;es. Serieo;; ~7,._JBfi_JJnder Poolinq & Servwmq ~ PC~N1TFF(S) fMlfie~nt~,,~e6 As of November 1, 1997. From.-Doris. 'L._Brehm 100 "B"_~treet,_Rlain.i'.~e~d, Pa. 17081 DEFENDANT(S} (1) You are directed 10 levy upon Ihe property of Ihe delendant(s) and to sell See.~flttfl"hed description of property (2) You are also directed 10 atlach the property 01 the defendant(s) nOllevied upon in the possession of GARNISHEE(S) as follows: and 10 nolOy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 delendant(s) not levied upon an subject to attachment isfournl In the possession of anyone other than a named garnishee. you are directed to notify himlherthat he/she has been added as a garnishee anclis enjoined as above slaled~ Amount Due $"R,14g.1R Interest from 12/24/01 to 6/5/02 Interest 1;:1,558.28 Atty's Comm % L.L. (per diem-9.56) Due Prothy Other Costs $0.50 $1 00 Atty Paid Plaintiff Paid $ 103.90 Date: ,1flnllfl1:Y 8. 2002 Curtis R. Long Prothonotary. Civil Division by ._~O )y" #0:, , Deputy REOUESTlNG PARTY: Name Fr.:mk Federman, Esgt,i ,^p .~->_.-.- ~ Address Opp Ppnn Center At Suburban s:t:1!:t::!o.on. 1617 John F. Kennedy Boulevard, SU:Lte 1400 .-l'h:i:lau."lJ!hia-;--Pa~&~-l-814 - . Attorney for: --'f'ib~L1!tiff Telephone: .---{21" l"h1-7000 Supreme Court 10 No. 12248 1 ~:"',';"!h';''i" "i;,t'J';;"l;0fi~8!IIi~~i";&'iHI@I~ilIl~di:~~;"S'fu~>;,"""~;'j';I"~M"d"'i~i('Ai9iil'iN,",~iI&~~@!'d!gnr~T ~, I.: if' !!ftt1': REAL EST ATE SALE No. \5 On February 7, 2002, the sherifflevied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, known and numbered as 100 B Street, Plainfield, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 7,2002 By: -Jt)~~ Real Estate Deputy t~ ~ CC...::3 ~ CTiiIJ VIH't,\1),SHN3d ., -'. : . ,c.") ZO. \':c\ OS I: B lt1f ." ,., I ,II" " ,;tlfiftO li~t~~W,;' 3lil JO 3Pl.m ,~,'^ ,"~,J=~_~".~,,=, ,~.~ ".,~,~';',~ ,.y.~__ ," > ,- ~, . .- ,,",-"'~'~.~ .~. ,.=,'," ._~ < ,,-' 1--, "~ ' '~'~ ", ~" "".'h'lJ:j' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.l784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthllll, Esquire, Editor oftl1e Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says tl1at 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 tl1e said County, and that the printed notice or publication attached hereto is exactly the same as was printed in tl1e regular editions and issues of the said Cumberland Law Journal on tl1e following dates, viz: APRIL 26, MAY 3,10,2002 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 tl1e aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~ir iJJI)A Roge~ . Morgenthal, Editor -- SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 LOISE.SNYD~= =Elqli18S MardI 5, 2005 My . Of J 1IEAL ESTATE SALE NO. lIS of-r.;o't No. i 7 - r;-~;:-~or f~rmerly ol~- Thomas Lebo and the Northern line - of all of Lot No. 18 nOW or ronnerly of Christine Kluck. North 83 de~ grees 25 minutes West. a distance of 99.70 feet to a spike in the centerline of said 33 feet wide un- named public street extending Northwardly from Pennsylvania Route No. 641; thence along the centerline of said 33 feet wide un- named puhlic street. North 24 de grees 15 minutes East. a distance of 156.25 feet to a spike at the place of BEGINNING. CONTAINING all of Lot No. 19 as shown on said Plan of Lots re- corded as aforesaid and having thereon erected a one -story brick cased ranch-type dwelling with other improvements. BEING No. 100 "B" Street a/k/a Lot la. P1LU~ Bc.ok 11~16. TAX MAP NUMBER: 18~1392 PARCEL NUMBER: 013. TITLE TO SAID PREM1SES IS VES1"ED IN Doris V. Brehm. mar- ried person by reason of the follow- ing: BEING the same premises which Richard A. Llndsey and Patricia M. Lindsey. husband and \Vife by Deed dated 11/29/ 1971 and recorded --1 _I_in the County of cwnberland in Deed Book "J" Volume 24 page 1058 conveyed unto Donald R. Brehm. Jr. and Doris V. Brehm. husband and wife. AND ALSO BEING Ule same prem- ises which Donald R. Brehm. Jr.. married person by Deed dated 101 6/1995 and recorded 11/8/1995 in the County of cumberland in Record nook 130 Page 10B6 con- veyed unto Doris V. Brehm, mar- ried person. Writ No. 2001-6452 Civil Wells Fargo Bank Minnesota. N.A Successor by Merger to Nonvest Bank Minnesota. N.A. as Trustee of Salomon Brothers Mortgage Securities VII. Inc. Asset Backed Certificates. Series 1997-.ID6 Under pooling & Servicing Agreement Dated as of November 1. 1997 VS. Doris V. Brehm Atty.: Frank Federman ALL THAT CERTAIN house and lot of ground situate in West Penns- boro Township. Cumberland Coun- ty. Pennsylvania, bounded and de- scribed in accordance with lot layout of Gilbert g. Crosley as recorded in the Office of the Recorder or Dc~ds in and for Cumberland County at Carlisle, Pennsylvania. in Plan Book 11. Page 46. and survey made by Thomas A. Neff. Registered Survey- or. on May 17. 1966. BEGINNING at a spike in the centerline of a 33 feet wide unnamed public street eJr...'tending Northwardly from Pennsylvania Route No. 641 where the same intersects the cen- terline of said unnamed 33 feet wide public street running Eastwardly therefrom: thence from said spike at the place of BEGINNING. South 65 degrees 45 minutes East. a dis- tance of 95 feet to a point; thence along the Western line of Lot No. 20 noW or formerly of Thomas Lebo. South 24 degrees 15 minutes West. a distance of 126 feet to a point on the Northern line of Lot No. 17 noW or formerly of Thomas Lebo; thence along the Nortllem line of a portion. , ~' ~,~ - I~.:""tl!/'. ~ '.~~~" '~~~_~"""",",' " '~ '. '.~"'M - =~.~;""",;,,,,ti,,,;,-~'"'o 1\ 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State> aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That. the printed notice or pUblication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duiy recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #15 , CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 t , Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 364.80 1.75 366.55 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ,tii .h,.. ;]:,;,:,.':'"2_,"-''',,, . " - ~'~m..~:~,gi;~l!'__~~";"""''''~m~~~'ili!~~~~I.!".~ .. i' \ _,_,~"",,,,,,,~_,~ r,_~~,'";.,,,\, 1'< "ec._' ,,<",^, ',"',,""__'"".~<" ^~ , ~ ~ , ,~"' ~, ~ - ~." it!1J .,~r -~ -~ " , ,,'. '0 ".'..1 , ~-;;:~tAL-ESTATE SALE "0.15'-- ------. "wrlt No. 2001'6452 ~- -' .,- Clvnrenn . i-Gk~e Fe'110 Bank ~ _~_ n 56 NA: Successor ~ ~ .n.."M~rj'..1O - llOrWilifaan 1I1nnesota, '~~"':'"N}.. u' _of ~ ~ ,~_-..,SI.lo~()t :~era ....... .. ,."lIQi1lPge Sa' !IiiO VlI,lnc. = :...,.., o;.'AtHtBacr~~cates, ;-- T 80ritalS 17.lB6 Undar ':..JO,9.lll)gJ. ~Icll)g w. ,.Ajireeme" Dated aa of ~.,.~~~ ~!lIherl,l997 .......___ \'S .~ - ~ IlOila v: Brehm ~."'t>IIY:Flallk Fedennan EJ).liliCJlJHjJ>>'L..... _ .. . -.aTTJl!~'f CERT~ hQuse and lot of ground ~re:::IifWeSl Pcnnsbol<iTawnship, Cumberland ~~~j'lvanja, bo~ded and described in ~~'!!b)a,llayout ofGllbCrt Q. CiosleJ' - ~j!1th~ Ofllce o((be ReoorderofDeed.'l ~, for Cumberlaml County at Carlisle, . 3ijf'larua, in Plan Book .1 t, Page 46. and' -- b,,}'. Thomas A. Neff. Registered J.J'y 11, 1966. .... . Gat,Dspik,ein tlJt'centeJ'Jineofa33 wide -unmimoo Public. street extemfrng Ctrtbwa'rdrfJrom" Pen;isylvania route No. 641 '~l1ie'SafueinterSectsthecenterlineofsaid " .eJL33 r~ wide public street running X ~TLtteace from said spike at iit';'OUlNNlNG; SouJh 65 degr<<s .\5 o t.e Ii 41~~ 'of 95 feet t6 a polnt~ ::::::_ ,_ ',.llJlJ-'.!he,""Westelll flIle o[1ot No. 20 now - ~"or - - nJ or1jiOTnll! lenD. SOuth 24 degrees 15 Bi.. "." ~ ~S. tan..ce Ofl. 26._..reet to a point on _w-orthem line ofLof No, 17 now or formerly ---'- .bo; th~n~~ aIo~ the Northern line , otfof Lot N'o. 11 now ~df formerly of - :. 'liOO an~'i'he Nl;'tt)ieni TIne of all of Lot -.-. __fO~erlJ,qf~Ch~~eK1uck,North. mmull;s West, a dIStance of 99.70 - ~,'iiiffie~rlineofsaid33feet_ ,..' ~-e<!_ -p~E!iC _ street ,extending . ,_Y (rom Pe!ll1Si'lv3;!11a_~u1:eNo, 0iIT;-- --The centerline of sma 33 feet wide - public street, "North 24' degrees 15 . , aistimc'e of 136.23 feet to a spike G. . _ aUcifLotNo.19asshownonsaid ~~).s,afOreSa1dandhaving ~1lerq;teQ:aJJI1e?jO;Q'brickcas<<lranch:!ype_ ~withotherfmproVements, - - -" 1::mm~-CfNo. lOO "Bn Street aMa Lot Ig, Plan ~k.ll,46. ~l;O.J8-1392 ",:P.I~<'l'rl;'lJf1>'" ..... ~1t'~ r;=SI~~ves= ~sth~ - !1ffl8,itk~.same :yremises wbich Richard A, ~ ~y and PatriCI8, ~ Lindsey. husband and :cmr~ byDo,j datoJ 11;",11971 and reimiled .-1- . ~.::. i1i the ~.'O~.,i*' }~~ c..t(1be._!!.~d in DeeJ Book - ;ff' ~ ~~ reSt oom~d unto Donald Il:~m 1,t}Il po~s y.. ~re~!':1,~.u~band. and: ~" . "Ci BEmCriile same pre~ises w1lfch ,: R. BreJm:. Jr.. married perron, by Deed 10/6/1995 and recorded 111811995 in <he o . umoofran& in Record Book lJ(J p.~ ~ .~~ed untof Th:l~s V" Brehm. mamed ' :;-.~-'"' -, , I"" I."~,: ~~~. - " - .' '~ "~-_~;L'''' _,~,;,v . '~ o'~'o'*"".0'g~ .. , FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES Vii, INC. ASSET BACKED CERTIFICATES, SERIES 1997-lb6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997. 505 SOUTH MAIN STREET, 6th FLOOR ORANGE, CA 92868-4509 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 01 - l...4~~ C't.)~L)-E:A.r1 v. CUMBERLAND COUNTY DORIS V. BREHM 100 B. STREET PLAINFIELD, PA 17081 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THlS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVlOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attomey and filing in writing with the court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 0007156078CEM !l ~~., ,', ,-I IF TillS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TillS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. ~ _, - ,L '~ ""c' ;,.,' W' LdIl:l,'1 - ~ ~ c' '" ,~ - 1. Plaintiff is WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES Vii, INC. ASSET BACKED CERTIFICATES, SERIES 1997-Ib6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1,1997 505 SOUTH MAIN STREET SUITE 6000 ORANGE, CA 92868-4509 2. The name(s) and last known addressees) of the Defendant(s) are: DORIS V. BREHM 100 B. STREET PLAINFIELD, PA 17081 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On MAY 8,1997 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to LONG BEACH MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1381, Page 462. PLAINTIFF is now the legal owner ofthe mortgage and is in the process of formalizing an assigmnent of same. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due MARCH 1, 2001 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit" A." ,,; '~_'$.;&;i~i- - . - ", I.....: ;. 0" "^<"'-~ 6. The following amounts are due on the mortgage: Principal Balance Interest FEBRUARY 1,2001 through NOVEMBER 1,2001 (Per Diem $12.88) Attorney's Fees Cumulative Late Charges MAY 8,1997 to NOVEMBER I, 2001 Cost of Suit and Title Search Subtotal $47,399.87 3,529.12 1,000.00 201.44 550.00 $52,680.43 Escrow Credit Deficit Subtotal 0.00 4.773.23 $4.773.23 TOTAL $57,453.66 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on tile date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has tenninated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAlNIFF demands an in rem Judgment against the Defendant(s) in the sum of $57,453.66, together with interest from NOVEMBER 1, 2001 at the rate of$12.88 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. -f-~}~ Isl Frank Fedennan FRANK FEDERMAN, ESQUlRE Attorney for Plaintiff " <6.1 ~! ,I' 0' ~ ~ ~ '.' 'I ,"",~-b" :,c":,'-i-L;.',,,.;. ..~~,'. Amt:riqut::-it Murtgage Company ,05 South Main 51.. SLllle (,000 Orange. CA 92X6X-4,{)'i May 2. 200 I S80/Clemelt; Duris V. Bn:hm 100 B Slreet Plainfield I'A 170XI ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Loan Account No: Property Address: Original Lender: Currenl Lender/Servicer: STATF.MF.NTS OF POLICY 0007156078 100 B Street. Plainfield P A 17081 Ameriquest Mortgage Company Ameriques! Mortgage Company TInS FIRM IS ^ DEBT COLLECTOR ATIEMP11NG TO COlLECT A DEBT. TInS NOTICE IS SENT lOYOU IN AN ATIEMPI'TO COlLECT 1HE INDEBTEDNESS.REFERRED TO HEREIN AND ANYINFOQMATION OJrrAINED FROM YOU WIlL BEUSED FOR lHAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY 1HIS CORRESl'ONDENCE IS NOT ANDSHOUU> NOT BE CONSffi.UED TO BE AN ATIEMPI' TO COlLECT A DEBT, Bur ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. This is an official notice that the mort e on our home is in default, and the lender intends to orec ose. I Ie m orma on a . u e ua re 0 e au t IS rovl mea ac es. to To see if HEMAPean hel~oll must MEET WITH A CONSUMER CREDIT COUNSEllNG Ac...'ENCY WUHIN 30 DA OF "JIll!; DATE 01<' "HIS NU'IlC& Take this Notice with you when you meet with the Counselm2 A2ency. The uame address and. hone uumher of Consumer Credit Counselin OlIn ate IS a e en 0 IS 0 ce. ou ave an elon usm. Dance en 0 roo a ersons WI 1m encies servin our OU ma e enns Ivania r cann can This Notice contains important legal information. If you have any questions, representatives at the Cousumer Credit Counseling Agency may he able to help explain it. You may also want to contact an attorney in your area. The locaI bar association may he able to help YOll find a lawyer. LA NOTlFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTTNUAR VTVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION TNMEDITAMENTE 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 SALVAR SU CASA DE LA PERDJDA DEL DERECHO A REDIMIR SU HlPOTECA. EXHIBIT A 'f,\ "" ~ ~ '~L -,.",. ,="',-.,',' hlill~:i!h4*,'k' 580 HOMEOWNER'S EMERGENCY MORTGAGE A.";SISTANCE PROGRAM YOU MAYBE EUGIBLE FUR FINANCIAL ASSISTANCE WHICH CAN SA VI<; YUUR HOME I-RUM I<UIlliCWSUIlli AND HELP YOU MAKE FUI1JRE MORTGAGE PAYMENTS IF YOU COMPLY WITII llIE PROVISIONS OF llIE HOMEOWNER'S EMERGENCY MORTGAGE AS.<;;ISTANCE ACT OF 1983 (TIlE "ACf'~, YOU MAY BE EUGIBLE FUR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HA<;; BEEN CAUSED BY CIRClJIVt<iTANCES BEYOND YOUR CONIROL, IF YOU HAVE A RFASONABlE PROSPFL, OF BEING ABlE lD PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEEf OTIIER EUGIBILIlY REQUIREMENTS FSfABUSHED BY TIlE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECWSURE - Under the Act, YOll are entitled to a temporary stay 01 loreclosure on your mortgage lor thlrly (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face me~~i with one of the consumer credit counseli~. agcncics listcd at the cnd of this NoticcJlllS M NG MUST OCCUR WITIIIN llIE NEXT 1HI1UY ~O) DAYS. IF YOU DO NOT APPLY I-OR EMERGENCY MORIGAGE ASStSIANCE YOU US!" BRING YOUR MORIGAUE UP 10 DAlE. HIE PARI 01- HilS NOtiCE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORIUAUE UP 10 DAlE. CONSUMER CREDIT COUNSEliNG AGENCIES - If YOU meet with one of the consumer credit counselm a 'encles listed at .the end. ot thIS notIce, the lender ma NOT take action a amst you or t. Ir.ty ays a er t e ate 0 t IS meetmg. e names, a resses an te ep one numbers 01 cteslgnatecl consumer crectlt counsetmg agencIes lor the county m whIch the property IS located are set lorth at the enct ot thIS Notice. It IS only necessary to schedule one tace-to-face meetmg. AdVIse your lender ImmedIately of your intentions. APPUCATION FOR MORfGAGEASSISTANCE - Your mortgage is in a default for thc rcasons set torth later 111 thiS Notice (see tollowmg pages for specific mformation about the nature of 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 Assistance Program. To do so, you must till out, sib'll and file a completed Homeowner's~mergency ASSistance Program ApI'Iication with one of the designated consumer credit counseling agencies listed at the eno of tillS J.'!oticl!. Only. consu~e~ credIt counseling agen,cies have applications. for the program and they WIll assIst you m submlttmg a complete applicatIOn to the; Pennsylvallla Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPUCATION PROMPTLY. IF YOU FAIL lD 00 SO OR IF YOU 00 NOT FOLLOW THE OTlIER TIME PERIODS SEf FORTII IN TInS LEITER, FOREClDSURE MAY PROCEED AGAINST YOUR HOME IMMEDIAlELY AND YOUR APPUCATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACI10N - 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 tias sixty (60) days to make a decision after it receives your applicatio.n. During that time, no foreclosure pro~eedings ~1l be .pursued against you if y~u have .met t.he tIme requirements set forth above. You WIll be notIfied dIrectly by the Pennsylvallla Housmg Fmance Agency of its decision on your application. N01E: IF YOU ARE CURRENILY PROH'CIED BY 1HE FlUNG OF A PEllTION IN BANKRUPTCY, TIlE FOlLOWING PARr OF TIllS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOUlD NOT BE CONSIDERED AS AN ATIEMPT 10 COlLECT llIE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mlrtgage Assistance.) EXHIBIT A '''R "~ ~~" , ~ ' ,,', ,," . w" "0' 1ilL~~_;i.;.~, 580 May 2, 2001 Loan Number: 00071 5607X HOW TO CURE YOUR MORTGAGE DEFAUI.T (Flring it un to date). A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followillg alTHHlllls are past tJue: .... OJ/OI/OI thru 05/02/01 Monthly Payment' plus late charges or other fees: $2713.91 Total Amount to Cure Default: $2713.91 B. YOU HAVE FAILED TO TAKE 11IE FOlLOWING AcnONS (Do nol use if not aoolicahle): NlA HOW TO CURE THE DEFAULT - You may cure the del"ult within THIRTY (30) DAYS of the date of this notice BY J'AYING lllE"JUJALAMOUNT PAST DUE TO THE LENDER, WHlCHIS $2713.91 PLUS PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TIIIRTY (30) DAY PERIOD. Payments must be made either by ca,h. cashier's check, certitled check or money order made payable and sent to: Ameriquest Mortgage Company 505 South Main St., Suile 6000 Orange, CA 92868-4509 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if nol applica!>le.) N/A. IF YOU DO NOT 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 riehts to accelerate the mortgage debt. This means that the entire outstandmg balance 01 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 TH IRTY (30) DAYS, the Iendcr also intends to instruct its attorney to start Icgal action to foreclose upon your mortgage property. IF THE MORlGAGE IS FORFCLOSED UPON - The mortgage property will bc sold by the Sheriff to pay all the mortgage debt. It the lender reters your case to its attorneys, but you cure the delinquency betore the hmder begins legal proceedings against you. YOll will still be required to pay the reasonablt: attorney's fees lhal were actually incurred, up Lo $50.00. However, if legal proceedings arc started again" 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 10 the amount to the lender, which may alsn include other reasonable cnsts. If you cure the default within the THIRlY (30) DAY period, you will not be required to pay attorney's tees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all otber sums due under the mortgage. RlGHf TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE - If you have not cured the dcfault wIthm the THIRTY (30) DAY penod and loreelosure proeeedmgs have begun, vou still have the right to cure the default and revent the sale at an time u to one hour before the Sheriffs Sale. You ma do so b a in the total amount t en ast due. Ius an latc or other char cs then due, reasonable attorne 's ees an costs connecte Wit t e orec osure sa e an an ot leI' costs connecte Wit t e. en s. e as s eCI Ie m wntm teen e:r an er ormm J an ot er re Ulrements un er t e mort a e. urll~g your au ID e manner se 0 ID IS DO Ice WI res ore your mo gage 0 e same post on as If you had never defaulted. EXHIBiT A JO',c "-' I; L' , ...., " X~, " " "~~,,,,,,, 580 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sherllt's Sale ot the mortgaged property could be held would be aRproximately SIX (6)MONTHS from the dateofthis Notice.A nolice of the actual date of the Sheriffs Sale will be sent to you before the sale. 0 t course, the amount needed to cure the detault wlll mcrease the longer you walt. You may tind out at any time exactly what the required payment or action will be by contacting the lender. HOW m CONTACf TIlE LENDER: Ameriquest Mortgage Coml1a.ny 505 South Main St., Suite 6000 Orange, CA 928684509 Phone Number 800-430..5262 x 5812 Fax Number 714-242-1903 EFFECT OF SHERIFFS SALE - You should realize that a Sheriff's Sale will end your ownership of the mortRageo property ana your right to occupy it. I f you continue to live in the property after the Sheriff's Sale, a la>>,sui[ to remove you and your furnishmgs and other belongings could be started by the lender at any time. ASSUMP110N OF MORfGAGE - You mayor X may not sell or transfer your home to a buyer or transteree who WIll assume the mortgage debt, provided that all the outstanding payments, ch,arges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of tlie mortgage are satisfied. . YOU MAY ALSO HAVE TIlE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO I1AVETHIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSlTlON AS IF NO DEFAULT HAD OCCURREDlT!F YOU CURE THE DEFAULT. (HOWEVER'rYOU DO NOT HAVE THIS RIGHT TO CuRE YOUR DEFAULT MORE THAN THREE IMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED Very truly yours, Ameriquest Mortgage Company Cc: Ameriquest Mortgage Company Attn: Collections Department . loan Number: 0007156078 Mailed by 1st Oass Mail and by Certified Mail EXHIBIT A "'ij .... "L ~I h , " ~'~~, .,.- .~I!l:~Jtig~~. 580 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSEUNG AGENCIES (REV. 8/00) .cUI\1BJ:Rl.:\~12 CQuNIY cccs ur Wc:slc:rn Pennsylvania, Inc. 2000 LingleSlown Road Harrisburg, PA 17102 (717) 541-1757 fAX# (717) 541-4670 Finam:j<.iJ Cuunst:ling St:rvil.:t:s ur FnmJ...lin 31 W cst 3 rd Street Waynesboro, PA 17268 (717) 762-32H5 Urbi:ln Lt:agut: of Mt:tropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Stred Harrishurg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle 51. Oellysburg, P A 17325 (717) 334-1518 FAX (717) 334-H326 EXHIBIT A :.w- . - , ~." ,,~ ~" 'oC" .. ,"~:;" - '"oI;~,"~ ." ~~'-"-"------~"-~""',..-.- -""""""'"'-<-"'--~_..^--" "-ALL THAT' CllRTAI'N h'~use' 'lI.;~r-i~t-';;f-'ql"OUnd situate in West Pennsbol"o Township, CUmberland County, PennsYlvania, bounded and described in accordance with lot layout of Gilbert Q. Crosley as recorded in the Office of the Recorder ot Deeds in and for Cumberland County at carlisle, PennsYlvania, in Plan Book 11, Page 46, and survey made by Thomas A. Neff, Registel"ed Surveyor, on May 17, 1966. \00 i &t-ee:e..J-- *"j ',',,~ ~"",,-,"'_......l . , VRR TFTr A TTON , "~ ,I' ~', ~I "'~--~,",,, n.: " ^~'-liilij~~,; Lucy Herrada hereby states that,,*/she is Foreclosure Coordinator Of Litton Loan Servicing LP mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best ofhislher knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: II f &/0/ .1 ~ ""i1ri'~~\1,-;.t:}"''Mili;\\;illl~~kti'l;jJ(i!*-W.::;'>Ii~\';\~ir:C;;,ji1iif;!'*''''':;~>B,;,!;;<~,/,-,,"',r"""':-~'jJ>',>i,.t';i,+.;'b!~i,"j,~-;&~m'f~liiIifiJj~~:id~"':..~;MW.$1!ll> , .. II (.J -l: ~ 0 C) ~ 1- & c:: ~ ~ ~ ,,;:;: ::.:: :',;:1 ~ffi 0 <: ri~:D B 8 D- r 8 ..... Z('- -c- {"II ""- \;' Q~ w ~~6 ....... ~o :S j ~ I J:> -0 9~ zO ::t: ~ ~Vl -0 W >c:: r:- om ~ ~ ~ .:::> ~ (X) :n -< '<. "' ~''-'tI1IIl ...... ,I' 'J, 0, , " ""iIlIiiiili" 'Jll.~~JI.,,~,,__ , ,. , FEDERMAN AND PHELAN BY: FRANKFEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 - ONE PENN CENTER PHll.,ADELPHIA, PA 19103 215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS BANK MINNESOTA, NA, ET. AL. vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS CNlL DNISION DORIS V. BREHM NO. 01-6452 VERTFTrATTON I hereby certify that a true and correct copy of tl1e Notice of Sheriffs Sale in tl1e above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s) DORIS V. BREHM on 3/19/02 as evidenced by the attached receipts, in accordance with the Order of Court dated, 3/13/02. The undersigned understands tl1at this statement is made subject to the penalties of 18 P A. C.S. s4904 relating to unsworn falsificaton to authorities. ~~ f;L FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF DATE: March 20,2002 ~j ,', ~ , ~I>l ~~ - <>~!N '7' ,;;,;, <<i:'\ .", ~ .'$1 . ':>, Ill) Q.' ~-~ /' ~ .. l! ~ . .. ~ ~ ~ ~ " " < ~ u I:: 0 1J: ~ '" " = '" n '" $ <of ~ ~ '. u Z ~ .. .. < en 0; l' ~ "" :i'" or :it ~:it .. n'" !! = 0:= < = a:5 .. .. u [;!gc[;!!;;c ~< ~ ~ " :;.. " CC_....;l=-~....;l Z u - < '>(~ .g::~ < U .! . >ot:>E-ot: :;: ="" . CIlCCZCllCllZ == ~ " .:(,,=:;: 0: u ~ E .. .." n Oq""og"" Q .S Z Qa..a..Q_a.. .. ~:a .. ,.... t ~ ~ u -.Q .~ IS-I< . 1: = . . <z: . . " ~ ~ ... = ~ u ~ . ~" = u u = ::; E ~ u "en .". Z<. Iil_ Ii I. G9t9909 '<J ,of- .=:' c;.t.3 \!'Hld ~::O S' I :: 1'<f J.I:! l0.6lli~1I1 :. l ~ ,:j}~:5- ;\, '~ ~/9Vtsu!~:;l'Jx~'''~ . ~ ~~~.Jl ~ ~ ~ ~ ~ ~ ~~ ~ . lo(O;,l =~O..c~ E ~ ~~ :; "Cl"ClOoE ~;~~Bl ;,I ",'-V;c ]c~.~= if Ere ~ ~ L. ::::I ==:a.2 C:;~~Cc. g"ClB~O~ ;~....~:~ =.c ~ ;,1'- L. E.!.-'E~~ ~o.g:::c8 .: if: ~ ~ '0 "Cl C t"l.o'!. ~ C g.~ ~:; ;;: ~.:~~E~ t; 0 g,,~"O.s ;,Iao~t'E ~;::g=t:= "Cl ~ =- ~.Q 10. -;.=~:E~.E =~.~~SN o t ~ g,,:; ~ t L. C ....Q"Cl '5~E~~; t;\"- 1:l E Nr) ~ ~.: ;,I~;: .~ ': c "g.; ~ ;,1- 0.__= .E~~E~a; ~ ~.E: e ~g:: .... =- "'._ Cl."; oca=o= c'_r.lS'_c .S! C;,l =:: - E 10. ;,I E ~ 5.;-=~.;::: 1:.E E ~':::E "Cl e :::I r.,I e ... = = ~ 5 ::::I;:: ..:: e"Cl t IS tl ;,I'~ == ::::I.~ E ..c = = ... as 0 E-oe~~eQ .. = .;: -~ u ~ 0: . . ~ E . ~ ~ ~ .. "- $ $ ~ >. . . E- ~ .. ~ E .... ~ ~ ~ u ~ ~= .- . "0 'C~ ~ t~ ""~ E n =" Z ~ > '. -;'ii ~ ~ u . ~ ,..0: ~ ~ " = u .en . >. ~.Q ~" .. u E 1J: 0-- ... .. on '" ... .. '" ~ ::: ... z-:; ~ - ~ l! t . .- ,.... ,,"'"'-, tlIlii1l2!;%'~;~>'< ' !~TI! d>,,,,'o ,,- -""" . # ...- ~~ ~"-l I, _ ~~ " [ ~~~ J~~ 7160 3901 9844 7042 8261 TO: DORIS V. BREHM P.O. BOX 100 PLAINFIE):-D, PA 17081 I SENDER: KMD REFERENCF:SALESBREHM PS Form 3800 June 2000 RETURN Postage RECEIPT . SERVICE Certified Fee Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail ,I No Insurance Coverage Provided 00 Not Use for International Mail 7160 3901 9844 7042 8278 TO: DORIS V. BREHM 100 B STREET PLAINFIELD, P A 17081 I SENDER: KMD REFERENCE: SALES BREHM PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for International Mall .34 2.10 1.90 ..~ ~ 'tt~;"";K-"-~'}'" .34 2.10 -.' ,- :, - -. ~~?-k~.~~~~;t.~~~~f%,,~1l~'0M'N,_j,!'1"i<"~:';""''-\'TI~~i-,,,'"",)~"~"O,~,,"---l,{';-I.d,<](,I~4.~"li!iilit_:lt!rJill:i.&l_~""'- ~-~",;.,~*... ..1."" - -~~-~ . _. .0 " 0 c. c: 1'.,]1 ;:'0'" ""D Ci:~ ---", rn r":; ~ r.....) "c_ U.> Cl -<: ,:; ....... 1> _/--~ )> S:;) ", -,~, .1="" 5:"] -~ r;s BI/ ,L ].. r. L \lUlril:mU..lmlll\...,"~.Lg{l..LWI.I\.I.U .....,,!...,,"'''''.... ..11 III.~UL. "-~~-- " ~_, ,"._~'d'?_,_, ."" '";',-,,, ", ,_ ,,~'" ,"=,- ~~ ~," ,~\tlU;<""- ~ fl.illl1i-..,l<iji~_~"",~~. o_~~ -.........~.L r 1- ." .~- --liiljfiuiJJ'~-w.,.'''''''"''''ut~~~~ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MAR 1 2 Z002) ~ ~" .. 0'- COURT OF COMMON PLEAS CNIL DNISION WELLS FARGO BANK MINNESOTA, NA CUMBERLAND COUNTY SUCCESSOR BY MERGER TO NORWEST BANKMNNESOTA, N.A., AS TRUSTEE OF No.: 01-6452 SALOMON BROTHERS MORTGAGE SECURITES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1,1997 vs. DORIS V. BREHM ORDER AND NOW, this , 3 ~ay of ~ ~ , 2002, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), DORIS V. BREHM, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service ofthe aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of service. ;jJ L 6f( f( RAS 3-Jy-02 ~QJK ~Je(<rnO-j J. \. .. . ~. . I~~'"". .~ ,"" ". -.'" , 02 E~~~ i"3 r" 2~ 39 C' ..I.... ... .1-' ,.... , "\ _ _---; . _ ' ^' , ' . ,,,1 ' I' i ~ "\" \.' Uld,-,._llW 'c '!l.,) .,j.../'o.,n'\; 1 ~ PENNSYD//\N1A "~~?"""",,.,.,,:? ;"nl..J!!WTr~ O?_ "., J.'~,~4lvI.~ '~''1,elI~!l)~~~1llJII'W11llII _",,'!l~~"''fq:P-'j =~","' '~ ~ ~ -~,~ ~~~"""'-"= ~ "~I ,~'" " ]{ ->~: r < M J . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CNIL DNISION WELLS FARGO BANK MINNESOTA, NA CUMBERLAND COUNTY SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON No.: 01-6452 BROTHERS MORTGAGE SECURITES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-ffi6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1,1997 vs. DORIS V. BREHM MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service ofthe Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rille of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results there from is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. 1rr--L ~~ FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF " ' .~ c~ """""" r '~~.'.,,",_O -, - ,. ~"~~~ ~ ^ . ~ ........." ,I - " J~ '-'-'-.. ' "" ^ ':Awi'1ii~ 11~~'j,'1(' r' . liEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK No.: 01-6452 MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 VS. DORIS V, BREHM MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Mfidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom oflnfonnation Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: 1-~ -0~, FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ~};-;d " ,....~ ~<ol"~:llI'-" ' '"'~ ~~~.~ ~~.~ I '''. ~~""" ,,', '- :&. ~...';;o'IWi"~,)":" # ~ .. VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. J~ ~u1v~ FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ....."'b ,-~ '~'" __",....-. . . . ~ " . I -' ~" - ...,-- .i""t'~--'lfli@lit!:lci~ ..- ., FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, P A 19103-1814 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION WELLS FARGO BANK MINNESOTA, NA CUMBERLAND COUNTY SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF No.: 01-6452 SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-ffi6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 vs. DORIS V. BREHM CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy ofthe Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on February 28, 2002. DORIS V. BREHM 100 B STREET PLAINFIELD, PA 17081 ?-~ 1-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: February 28, 2002 ! - " AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 No. 01-6..\52 jpv CUMBERIOOAND COUNTY ACCT. #0007156078 Type of Action - Notice of Sherifrs Sale DORIS V. BREHM Sale Date: JUNE 5, 2002 DEFENDANT(S) SERVE DORIS V. BRElli"\ol AT 100 B STREET PLAINFIELD, PA 17081 SERVED Served and made kno\VO to _ "_Defendant, on the at ,o'clock_.m, at of Pennsylvania. in the manner described below: Defendant personally served. Adult family member with whom Defendanl(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk ofp!ace oflodging in which Defendant(s) reside(s). J1gent or person in charge ofDefendant(s)'s office or usual place of business. an officetof said Defendant(s)'s company. day.of .200~ Qther: Description: Height_ Weight_ Race Sex Age_ Other I, . a competent adult, being duly sworn according to law, depose and state that I personally haoded a true and correct copy of the Notice of Sheriffs S~le in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. . Sworn to and subscribed before me this _ day of .200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. ,EXH\B\T~'~~ r On the / ;2Jh day of ~}Ju;:}r.l NOT SERVED a.;;!O . ,200;6 at C.J' o'clock~m, Defendant NOT FOUNQ hecau,e: _ 1-40ved _ Unknown L No Answer Vacant other:~JC"v4f~-:; M'tl.., N. e\l.'J....~c.... "'-&- ;\Jf~'-I' \;\llt1') . *ej:..e- I b\lf- -\",~",.. 'l"" -\vltP'\'\'''\t.<e.. '"" ,l,;, Sworn to and subscriqed I . \ before me this..L1..... JJuay N~" ')1..1% ","__sa' ~ . l 1/'.< f IN < It "- S'~ rfCGc ~ of T3;JViJ.t<.f ,200ji._ (V-DVe. c.J<\- \ I-> c~. .;;20('(. Nota~ \y\.~~y: Attornev'tdr Plaintiff Frank Federman, Esqnire - l.D. No. 12248 1 NOTARW.SEAL ,\ ElIZABEnl M. JOHANSSON, NeIlly PubIo Gr8eneT~~~ My CommIIIIon DtG. 1'," / Iri#d.- ~: oofc~ ~. /5/0:J. . 7;/') J~. .(" :3 . iI8/0:)" 1/ ,'/tJ f'''' 4~ 111~/cJ '. J.: 5 ~ f"'" 5"', Ilj~)6J.. 8'.1'5' aW\ (5 - "" , j-., ,<L;__~ "'-' "I ",,,,' ..,;, " e., =~'~."'.w '-, .'-~"M,~*,ki,"'" ..' , ~ro PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 01-6452 Attorney Firm: TRACK STARS Case Number: Subject: DORIS V BREHM AKA.: None Last Known Address: 100 B STREET PLAINFIELD, PA 17081 Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2, On 01/24/2002, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATlON- A. SOCIAL SECURITY NUMBER: B. EMPLOYMENT SEARCH: Unable to locate a good employer for Doris. EXHIB1T"B" C. INQUIRY OF CREDITORS: The creditors indicated that Doris is using 100 B Street, Plainfield, Pa. 17081 with no valid home phone number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Doris Brehm. INQUIRY OF NEIGHBORS - Unable to locate. any neighbors to confirm where Doris V Brehm is living. INQUIRY OF POST OFFICE- A. NATIONAL ADDRESS UPDATE: As of January 16, 2002 the National Change of Address (NCOA) has no change for Doris from PO Box 100, Plainfield, Pa. 17081. We were unable to verify 100 B Street, Plainfield, Pa. 17081 with the post office. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: Unable to obtain drivers licensing information. OTHER INQUIRIES - A. DEATH RECORDS: As of January 16, 2002 the Social Security Administration has no death record on file for Doris V Brehm under her social security number. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None Found .EV8'~'" "~" Ik. "i'~jliUill j! ,,_ ~v ,- ---, -'"._~,' ~'. "I ,', , L , "~ ;_,c;,. ~ -:J- - ,-~ --, -'" ~~'tIIri&"',", . ~. ~ . C. COUNTY VOTER REGISTRATION: The Voters Registration Office has no listing for Doris. OTHER SEARCHES. Unable to locate any tax records for Doris Brehm at 100.B Street, Plainfield, Pa. 17081. ADDITIONAL INFORMATION ON SUBJECT. A. DATE OF BIRTH: Unable to verify date of birth. ~.;:; C - ::> AFFIANT " NOTARY SEAL" Kristine M. Scott, Notary Public SI. Louis County, State of Missouri My Commission Expires 9/2/2002 ,..';..,,..,,,~J"J"'>""""_, Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 'rE"". ., .' ~ ,. '",;, " . t~__~;'i':.,~ 'J;, ';, ;:,~ l:XHIB1T_ttB" "'$ :{~~~:b'il!lt~'rL~i~i!t~~~~;i"~,tlici,fuw;j$:~~U' :<.,,'~ ~~,~,i.,h"_c'ili-'''''''j,~":i*",,_,,,j.,~,';;'''d<''fuNI~;GdfilM-($iii~~"lliilii~~lRc~~~~~..wJirn' llii""" "~~-....." . ,,,. -~._,~" ~_. >.," ."" "<~~, c' ~~.. . ,,",_^, ,~, '^ _"",^""'"'$ " ""'~"'" _.' ,C"',' '_',,'''''. ,~, ,. ~=-- . .,~ .,,, ,~ -~^ ,'-^,~ () C <"'" -oeD S2c-H 7r ((;):> - " r::c) j; .., <.,~~, '- .J ::=C" Pc Z -~i -< " Il!Ll~! ..:,. I ...... C) f""-.I ~lf.: ~,,"~ ,~ \_) ~;l '-71 i--:;-:O (~3 , '~'-'::::-() ~- , , '~q .=.::;:,in ::=::: 55 -< :;:~:J , _J :!;':: ~';o..,. -:..,..) ()O ~ .$I~ ~ ~~~, .~I /Y ~,' . c ,I_~ _~'. '" .-.-,-", "' '.W '>J<I8i;V,l I.'EDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PffiLADELPffiA, PA 19103-1814 (215) 563-7000 WELLS FARGO BANK MINNESOTA; NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 505 SOUTH MAIN STREET, 6TH FLOOR ORANGE, CA 92868-4509 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DORIS V. BREHM, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 11/1/01 to 12/24/01 TOTAL $57,453.66 $695.52 $58,149.18 I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. I~EZ;~QUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE:(}wU'l 'iI.l~:L PR~1~T~Y !MAli,.. ,~. "lrl ~, ~ . " ~ _c'__"'__"d'<_' '*-' '<,~<---,,.'~',. c">_ ","" ,,~ ,","0.- "" "-. _ (,-,"" . ,.It' 02 JI1)! '"8 AN 10: 29 ~=,~ _ J, I~ "1~ ~l!ifr:r~)\~..,,-,lL_ ' '~~ii~~JI!1'f~:>1"" ,,_ TIni~~ CU!vI8Enu,lvu COUNty PENNSYLVANIA ~ '-l\ <:r- '1 ~ ~ ~ (). :>- .. "I <> ~ K ~ ..... ...... ; '~ l ~J 2 ~ - !,IIJi!l!j~_~"w~m-~"'H0~~~;'-;'''[,''''''';' ~, LliM~ ,0,.", ,.;_",,"_>';-' .. ~. - -~". ~' ","'--~ ~"1 '-'""~"-",""'"<_.\'~-".-~,''c>-"",;w''~''' '" II'. _.. _...."-...........'~> -~ .~ -. ~- I 'gll!!iiliillid - ~, - . '. '^ --'-' '';;''-~ai!I'I~H~1-. #' (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGEn. TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INe. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 505 SOUTH MAIN STREET, 6TH FLOOR CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on q'''''''r r- 2001.. By: q~. 0 /1", let. ) UIY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." ~:::; ...~I-"."~"",,,"''''" - ilI'~" ,~ , FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES vn, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 505 SOUTH MAIN STREET, 6TH FLOOR Plaintiff, v. DORIS V. BREHM Defendant(s). ~J". ",",I_~ ~ ',' ~~~-~"~r:l"-"~ !i;j!~~,"",~~H^(' ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6452 VERIFICATION OF NON-MILITARY SERVICE FRANK. FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DORIS V. BREHM is over 18 years of age and resides at, 100 B STREET, PLAINFIELD, PA 17081 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ j-;;~~ FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff .'Ii ",~, "~,,,"~ ~ ~,~,-' ~ '" 1,,<, J ~~ , -"," o~" J :, ,,~- -~:il<i;it"",> ., PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 No. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $58,149.18 ~ Interest from 12/24/01 to 6/5/02 (per diem -9.56) $1,558.28 and Costs TOTAL $59,707.46 -;J--:;.-aJ- ::j-~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. -'1:1 r~;~6D" J(F/CE OF +: .:,:, " "JTN,Y 02 ,fAN -8 Mf 10: 29 CUMBEriU,NO COUNTY PENNSYLv'/Wi/1 ?;.:: 01 :::- l,~ N t- ': .r~~.. .C;;S; """"'-~ tL :,'- ':- __,,:::> ,.. , .----- '--,~ ---.1 ',," ,7>- - ' CO -.., ~-r"(.O t..~_'+': ''-.-)Z ....L.." , ,,""'I:Z -,' - .JJW CL~' =2 bJa.. r- J ~ '. '-~ ", .:.:J C' a 0 " '!f~~~"wrjL~~i'Jkd:}'iij~,)'AO+:[.-,,\l~,.,p-"a;9;;'H\~ i;f;,.,""".u,;',,,,,,;,'"~' ,-, i;: .'; ',"," -~. . ''''b;,;ki3.1_~1iIlrlt.@l~~M-'';~~~~:~'"''~ '''''"J"'''-'< ... ~ .~ lID" ("l 0=", ("l.... ~ "Ij ":I ":Itol"''''~~~ ~~ ~ ~. ~ I::Ig:;:ltol~ ("ltol ;:::>-3 " 0.- p,.. >-3("l :;:::(''It"' 0== ..., J tol ~~9~o;:::~~ (1) toltol en ("l ~~ .... ~~("l~;:::~"'~ ?Z("l ~":I >~~a~~~~ (1) .... ;:::tol 1::1 ~g ..., 0 o "Ij '" tol "'o=c;':l (1) 0 - 0 1::I:;:l -g 0= Iw ::\.0 o~~:$~So<o ~:;:l ~ ("l>-3 -0", ~:;:l",ro>~o= 00 (I >-3 '-< ~ ~ '" ~ <: tol.... >-3~ ~ 8 Gl S' ~~ :< <: o~~~=:-::;:l ~~ ~ ~("l ..., 0= ~.... . tol >c;':l:;::: >-30 '" tol "0 .. >-3 ~ '" >:;:l~ tol;::: '-< >-3 - ~ 0 Gl ;::: ...."''''>:;:l ~~ cr"~ '" (1) ":I S" CS'~ = 0=>~~;:::"'>-3S! ":I~ ri t"' - :; tol tolo :1 ~ ai 3-~ ;::: ~c;':l~>-30~O~ ~~ ~~ ....GlO=O=~(j~'" ~":I ("l ~ tolC\>c;':l"'OO ~~ :;l (j t;;;:::~("l>>-3:;:l>-3 tol >-3 ::itol ~c;':l~~? t"' .... <:> ~I::I 0 ~toll::ltolo"'~ >'" ~ ~o ":I :;:l ~>-3 ....~ > > .... .... 0 00 .... ~% ~ '- ~ ~ ~ w ~ ~. '- ~ ~ c (" d :.., ~ -$ ~ ~ w .. . .,- -- J::) ~ ~ It- ~ . . c Cl ~2. \'k ~ ~ ~r~ ">- ,'.~'~ '~"_~"~d"~"""=' _'e.~,J"..,"~" ^". <,,',^, _ .'__'>"'__ ,~, -" >'-' ^ ,~ () 0 u~ ~',;, , . "- mL, :=:9 r"-' , ~ii'" 2-+' t3~ r ,. ,. ." -<~~. m r:l--; .....;.'_,.,1 <"'.J "l>C J."";;" ,)~ :TJ 2::' ~" 'i-C) ;:::;~C) PC: 0 C) iT, Z -~ W -,.; ~ :iJ -< "' .- ~ ~~~" ._~~~" '..."'" ~ ~ ~ """"_ I i',~ I........ IT a;~~!f,~_ "'wt~~~~I",'~;!:""h"':h\!"~' ,. ALL THAT CERTAIN house and lot of ground situate in West Pennsboro Township, Cumberland County; Pennsylvania, bounded and described in accordance with lot layout of Gilbert Q. Crosley as recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, P.ennsylvania, in Plan Book 11, Page 46, and survey made by Thomas A. Neff, Registered Surveyor, on May 17, 1966. BEGINNING at a spike in the centerline of a 33 feet wide nnn~med public street extending Northwardly from Pennsylvania Route No. 641 where the same intersects the centerline of said unnamed 33 feet wide public street running Eastwardly therefrom; thence from said spike at the place of BEGINNING, South 65 degrees 45 minutes East, a distance of 95 feet to a point; thence along the Western line of Lot No. 20 now or formerly of Thomas Lebo, South 24 degrees 15 minutes West, a distance of 126 feet to a point on the Nort!:Iern line of Lot No. 17 now or formerly of Thomas Lebo; thence along the Northern line of a portion of Lot No. 17 now or formerly of Thomas Lebo and the Northern line of all of Lot No. 18 now oJ" formerly of Christine Kluck, North 83 degrees 25 minutes West, a distance of 99.70 feet to a spike in the centerline of said 33 feet wide unnamed public street extending Northwardly from Pennsylvania Route No. 641; thence along the centerline of said 33 feet wide unnamed public street, North 24 degrees 15 minutes East, a distance of 156.25 feet to a spike at the place of BEGINNING. CONTAINING all of Lot No. 19 as shown on said Plan of Lots recorded as aforesaid and having thereon erected a one-story brick cased ranch-type dwelling with other improvements. BEING No. 100 "B" Street alkJa Lot 19, Plan Book 11-46. TAX MAP NUMBER: 18-1392 PARCEL NUMBER: 013 ~~ TITLE TO SAID PREMISES IS VESTED IN Doris V. Brehm, married person by reason of the following: . hich Richard A Lindsey and Patricia M. Lindsey, husband and wife by BDEINed~~ ~~;9r~~~s:dWtecorded /' / in the County of Cumberland in Deed Book ''In e - -R B hm J d D ris V Brehm husband and Volume 24 Page 1058 conveyed unto Donald . re ,r. an 0 . " . . wife. AND ALSO BEING the same premises which Donald R. Brehm, Jr., married person by Deed dated 10/6/1995 and recorded 11/8/1995 in the County of Cumberland in Record Book 130 Page 1086 conveyed unto Doris V. Brehm, married person. - ,.'~- ~ ~~- ". ~ - I, J.ililC' --~ ~', "-' 'ilio:!~r!iirblW"','iJ"Il>(~," , FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SffiTE 1400 PHILADELPHIA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997- 1B6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. '?-~r~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ;';':* ~la~~~mRwj;i~f!!1i~i(llifi11lof;lil1,ii"~j~,~};,-;:,i01w,,',~,I",";'..,^ "..~.,~',,3.'~'" o.,,~, '" .~ ~ " _n ~ J~~~, U!ln ._, """,.;}" ;'V~~,';AMii~"1ml~~!il;io.t.'i~lm~YllJ~,b.M.1it;i:iiHl:if.Jl.~~D,,,fj""MiiNs,::i1J:~;j~tOO;mu<"~ Q '-- ;z- .......-_'>. vtJ'] mp- 2-/,; zr::: co..' -<2~: ~c ):>~ z\..~' 5>Q Z :< .. .. ~t!!il JIili%i'~ ... a ", ~ ~~ J;; z I co "'" ~ '2 w , . .~ -~....~.~- ~~. ~ ~ -l, I, ,~.- - I Ii. ._~ - ,- ,," -'" " lll'."""@";;';WoHlkd"" '. ., " WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES vn, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO BANK MINNESOTA. NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA. N.A.. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII. INC. ASSET BACKED CERTIFICATES. SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1.1997, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .100 B STREET. PLAINFIELD. P A 17081 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DORIS V. BREHM 100 B STREET PLAINFIELD,PA 17081 2. Name and address ofDefendant(s) in the judgment: DORIS V. BREHM 100 B STREET PLAINFIELD, P A 17081 3. Name and last known address of every judgment creditorwhose judgment is a record lien on the real property to be sold: '!ii; ,- ~"'~," 1.'::Nlfllllil. . i -'"""~"ilf-'"~l~"- "' "iIIIl~,iI'",~~~o ", Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. FRONT STREET HARRISBURG, P A 17105 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DONALD R. BREHM 100 B STREET PLAINFIELD,PA 17081 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 100 B STREET PLAINFIELD, P A 17081 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the ::~:::8 :~o~.S. Soc .9W reillMg ro -1:T lloritire DATE FRANK. FEDERMAN, ESQ'lJIRE Attorney for Plaintiff 'J;j ~~~ia!~~t~fliii.~~imlh!,w:r::~tU:x"p$i",[,l'-d""''' "," ~ -.~ n~'_,' ~"~ ,",~~~, <h ,~~ " ,~~,y, '~'~',,,,,," "Y2'.A" ,,-y,<i,;;;'n,' . ~" .c' ~, oj"",,' 'Y.""1V~i:ti1.~~J:l&\\!,~~~li$C~~,jjJ~~~l!f_~ll'"' ./,J... ..' ~" , w 0 C:-,) ~c, c: I'J ":..~:: ~ , ,- -Ocr: :;;n>ro rn rii Z::c .,,'"- z"" (j) );0. CO -<2~' ~G ;J::r~ ~Q .};:_:,; 5U S7 -,",.i ,c C Z 0:-1 -J ,:.,,) ::0 ~, -< ~.. ~~ -~"--- ;of -.....'"'. ~_ _ ~~ i '~",~ , -_I_~ , .'" '-'~"'r"J '"" - -w~ '~ ."'Ai,,,c';\n~C",, WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURlTES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997- IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 CUMBERLAND COUNTY No. 01-6452 Plaintiff, v. DORIS V. BREHM Defendant(s). December 24,2001 TO: DORIS V. BREHM 100 B STREET PLAINFIELD, PA 17081 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFOR/vIA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 100 B STREET, PLAINFIELD, PA 17081, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 58,149.18 obtained by WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MNNESOTA, N.A" AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the SEPTEMBER 4,2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE . To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may . call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) "~' ~ " .~I ~J ", "" '~1 o~ ~1f;T!l;~'~.''\rj~,'1>" ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . .l?j' J,-,c~ ~.,~ I ~,:,';I_, . '"'. '~"""'""""'~"~';*:;';-.\';j""",,, . ALL THAT CERTAIN house and lot of ground situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with lot layout of Gilbert Q. Crosley as recorded in the Office of the Recorder of Deeds in .and for Cumberland County at Carlisle, P.ennsylvania, in Plan Book 11, Page 46, and survey made by Thomas A. Neff, Registered Surveyor, on May 17, 1966. BEGINNING at a spike in the centerline of a 33 feet wide unnamed public street extending Northwardly from Pennsylvania Route No. 641 where the same intersects the centerline of said llnn~med 33 feet wide public street running Eastwardly therefrom; thence from said spike at the place of BEGINNING, South 65 degrees 45 minutes East, a distance of 95 feet to a point; thence along the Western line of Lot No. 20 now or formerly of Thomas Lebo, South 24 degrees 15 minutes West, a distance of 126 feet to a point on the Northern line of Lot No. 17 now or formerly of Thomas Lebo; thence along the Northern line of a portion of Lot No. 17 now or formerly of Thomas Lebo and the Northern line of all of Lot No. 18 now 01' formerly of Christine Kluck, North 83 degrees 25 minutes West, a distance of 99.70 feet to a spike in the centerline of said 33 feet wide unnamed public street extending Northwardly from Pennsylvania Route No. 641; thence along the centerline of said 33 feet wide unnamed public street, North 24 degrees 15 minutes East, a distance of 156.25 feet to a spike at the place of BEGINNING, CONTAINING all of Lot No. 19 as shown on said Plan of Lots recorded as aforesaid and having thereon erected a one-story brick cased ranch-type dwelling with other improvements. BEING No. 100 "Bn Street alkla Lot 19, Plan Book 11-46. TAX MAP NUMBER: 18-1392 PARCEL NUMBER: 013 TITLE TO SAID PREMISES IS VESTED IN Doris V. Brehm, married person by reason of the following: . hi h Richard A Lindsey and Patricia M. Lindsey, husband and wife by BEING the same preIDlses w c. f C bId' D ed Book "J" Deed dated 11/29/1971 and recorded --1_/_ in the County 0 . um er an ~us:and and Volume 24 Page 1058 conveyed unto Donald R. Brehm, Jr. and Dons V. Brehm, . . wife. . . ald R B hm J married person' by Deed'dated AND ALSO BEING the same preIDlses which Don . re .' r., . 86 10/6/1995 and recorded 11/8/1995 in the County of Cumberland in Record Book 130 Page 10 conveyed unto Doris V. Brehm, married person. k ~!:i':rii''-'ll~tj1;,,! kc;;,"; """'''!!lIfW,i'UI:iilli1ilit~ij.ji'letJiliitl';''4:!1'+'''''''''' ;"oJ c;rh ~J~lLn'"T',,,",,,,,,,~c ,,"",.~,_ {",', _ . ,~o;, r,. ,~>~.~'" '_,'r', .,"'~:'" ",", 'c. '<",,,,,,,,;-~,,,,; C<';7--,"".ci"..Qj-J"'i!j,'!;')~ilii<:f~U~Wlill.lIli~iIioIl'&; ~ilil~W",'iiWiiHlll!iJiriL~",~,i~Q\.~\.liti'~~- ~~'i' , ") .'~ ..~" - "_',', ",,",,. ~~ .', ~,Y w, '~"_ ~"" M " . ."'.._ _.~~ -n"R~ IIIlO~' . 0 D 0 c: f-V <;- "T1 '"T)(J~ <- IT -.' ",. _ ! rT'~ ..~'~'" "1 2:::) ""'- t~-~ ZC , (f) -'-. 0- -<.::;. .' -- <C~' ~.. ~::::.:<) ~. '. ZG --.-i_.. ~~~l ;~:; >8 D i~~,i , S -~ W "r--: ,-< ,.. f" :D -< EJ &1-/ '", , ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MINNESOTA, NA, AS TRUSTEE OF SALOMON BROTHERS MOfHGAGE SECURITIES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMEBER 1,1997 ) CIVIL ACTION ) vs. DORIS V. BREHM ) ) CIVIL DIVISION NO. 01-6452 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) S5: I, FRANK FEDERMAN, ESQUIRE attorney for WELLS FARGO BANK MINNESOTA, NA SUCCESSOR BY MERGER TO NORWEST BANK MINNESOTA, NA, AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. ASSET BACKED CERTIFICATES, SERIES 1997-IB6 UNDER POOLING & SERVICING AGREEMENT DATED AS OF NOVEMEBER 1,1997 hereby verify that on 12/28/01,3/1/02, & 3/19/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 12/28/01, 3/19/02, 2/28/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: Mav 6. 2002 F:tN~li~~D~Mr~t~8uIRE Attorney for Plaintiff --,~'-,"',~- .. 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J: MAR 19'02;; tit!.. :: I cO::: 0.- --- -.;) ': PBMETE:'I -If. ,_~ fI. 6068360 . .. . ~ .. ~ I / ~/'. ~ '~I ~~,~ ~ "';. ~~@ ,. .~ , . 7160 3901 9844 7042 8261 TO: DORIS V, BREHM P.O. BOX 100 PLAINFIELD, P A 17081 SENDER: KMD REFERENCE: SALES BREHM PS Form 3800 June 2000 RETURN Postage RECeiPT Certified Fee SERVICE Retum Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for International Mail .34 2.10 7160 3901 9844 7042 8278 TO: DORIS V. BREHM 100 B STREET PLAINFIELD, P A 17081 SENDER: KMD REFERENCE: SALES BREHM PS Form 3800 June 2000 RETURN postage RECEIPT Certified Fee SERVICE Retum Receipt Fee Restricted Delivery Total postage & Fees US Postal Service Receipt for Certified Mail No Insurance Covera{l8 Provided OQ Not Use for International Mall' .34 2.10 1. 0 PO " '/B~!j 7160 3901 9844 6532 5551 TO: DORIS V. BREHM 100 B STREET PLAINFIELD, PA 17081 , SENDER: JPG REFERENCE: BREHM,DORIS PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Retum Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use lor International Mail ~ "' POST 7160 3901 9844 7038 8428 ,.---- -------------------:---,.-.-,~.- TO: DORIS V BREHM - PO BOX 100 PLAINFIELD, PA 17081 SENDER: TEAM 5 REFERENCE: BREHM, D PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee"'~ Restricted Deliva' '. .,~:.. Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for Inteliational Mail ..-.-..__...--~.---_..--_..--_.--..---_.._--~- ---~_...--_.---_.---_..__...--_..----_._..-_.-- ;fut''j'' JfM~~,@.J)@11il~"'~;'>t"1tl!btL~i~~iJ'J"-),.." '"".,. 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