HomeMy WebLinkAbout99-03558
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Axel A. Shield, 11, Esquire
I.D. No. 17440
Stephen M. Hladik, Esquire
I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
Telephone: 610.640-1200
Fax: 610-640.9865
The Bank of New York as Co-Trustee
under the Pooling and Servicing Agreement
dated as of July 31, 1998, Series 1998-13,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff,
V.
NO: i( i - _3SSJ) (? C iAi,?__
CIVIL ACTION
Chester L. Brenizer,
Defendants.
MORTGAGE FORECLOSURE
COMPLAINT - CIVIL ACTION
NOTICE TO DEFEND
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 ajudgment may be entered against you by the court without
further notice for any money claimed in the complaint or for any other claim of 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo all partir de la
fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con
un abogado y entregar a la cone en forma escrita sus defensas o sus objecciones a las demandas en
contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede
continuer la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir
a favor del demandante y requiere que usted cumpla con todas [as provisiones de esta demanda.
Usted puede perder dinero o sus edades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA
0 LLAME FOR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTANCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Axel A. Shield, II, Esquire
I.D. No. 17440
Stephen M. Madik, Esquire
I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
Telephone: 610-640.1200
Fax: 610-640-9865
The Bank of New York as Co-Trustee
under the Pooling and Servicing Agreement
dated as of July 31, 1998, Series 1998-B,
Plaintiff,
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO:
CIVIL ACTION
Chester L. Brenizer,
Defendants.
MORTGAGEFORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff The Bank of New York as Co-Trustee under the Pooling and Servicing Agreement
dated as of July 31, 1998, Series 1998-B, brings this action in mortgage foreclosure upon the
following cause of action:
1. Plaintiff, The Bank of New York as Co-Trustee under the Pooling and Servicing
Agreement dated as of July 31, 1998, Series 1998-B ("Plaintiff'), is a corporation with a principal
place of business c/o The Money Store, 4111 South Darlington, Suite 800, Tulsa, Oklahoma 74135.
2. The last known address of Chester L. Brenizer, Defendant, is: 1819 Heishman
Gardens Drive, Carlisle, Pennsylvania 17013.
3. Chester L. Brenizer executed a mortgage with TMS Mortgage Inc., d/b/a The Money
Store, on June 18, 1998 (the "Mortgage"), in the amount of $36,000.00, which Mortgage was
F:\DOCS\1513\134.8RE\PLEADING\CWL.DOC
recorded with the Recorder of Deeds of Cumberland County on June 24, 1998 in Mortgage Book
1462, Page 757. The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked
as Exhibit "A" and is incorporated herein by reference as though fully set forth at length.
4. TMS Mortgage Inc., d/b/a The Money Store, assigned all right, title and interest in
the Mortgage to The Bank of New York as Co-Trustee under the Pooling and Servicing Agreement
dated as of July 31, 1998, Series 1998-B, which assignment was recorded in the Recorder of Deeds
Office for the County of Cumberland on April 15, 1999, in Mortgage Book 609 at Page 1016.
5. Plaintiffis, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original mortgagee, or is the present holder of the Mortgage by virtue of
the above-described assignments.
6. Each Mortgagor named in paragraph 3 above executed a note as evidence of the debt
secured by the Mortgage (the "Note"). A true and correct copy of the Note is attached hereto and
marked as Exhibit "B" and is incorporated herein by reference as though fully set forth at length.
7. The real property which is subject to the Mortgage is generally known as 1819
Heishman Gardens Drive, Township of Middleton, Cumberland County, Pennsylvania 17013 (the
"Mortgaged Premises"). The legal description of the Mortgaged Premises is attached hereto and
marked as Exhibit "C" and is incorporated herein by reference as though fully set forth at length.
8. The interest of the Defendant is as Mortgagor, Real Owner or both.
9. If the Defendant above-named is deceased, this action shall proceed against the
deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or
executors through his/her estate.
2
10. The Mortgage is in default because the monthly payment of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of December 1, 1998 and
have not been paid, and upon failure to make such payments when due, the whole of the principal,
together with the charges specifically itemized below are immediately due and payable.
11. The following amounts are due as of May 14, 1999:
Principal of Mortgage debt due and unpaid ..................... $35,969.67
Interest due and owing as of May 14, 1999
at 10.25%, $10.24 per diem .................................. 1,986.82
Late Charges of $16.13 per month
assessed on the 16th day after payment is due ....................... 96.78
Corporate advance .......................................... 100.00
Current NSF Charges ......................................... 30.00
Deferred NSF Charges ........................................ 30.00
Attorneys' fees .......................................... 800.00
TOTAL ......................................... $39"013.27
12. Interest accrues at a per diem rate of $10.24 and late charges accrue at a monthly rate
of $16.13 assessed on the 16th day payment is past due for each date after May 14, 1999 that the debt
remains unpaid, and Plaintiff may incur additional attorneys' fees and costs as well as other expenses,
costs and charges collectable under the Note and Mortgage.
13. The original principal balance of the Mortgage did not exceed Fifty Thousand Dollars
($50,000.00). Notice of Intention to Foreclose pursuant to 41 P.S. § 403 was mailed to each
individual Defendant via regular mail and certified mail, return receipt requested, on April 13, 1999.
3
A true and correct copy of said notice is attached hereto and marked as Exhibit "D" and is
incorporated herein by reference as though fully set forth at length.
14. Notice pursuant to the Homeowner's Emergency Mortgage Assistance Act of 1983,
35 P.S. § 1680.402c, et sea., was sent to each individual Mortgagor by first-class mail on. A true
and correct copy of said notice is attached hereto and marked as Exhibit "E" and is incorporated
herein by reference as though fully set forth at length.
WHEREFORE, Plaintiff demands judgment against Defendant Chester L. Brenizer, for
foreclosure and sale of the Mortgaged Premises in the amounts due as set forth in paragraph 11,
namely $39,013.27, plus the following amounts accruing after May 14, 1999, to the date ofjudgment:
(i) interest at a per diem rate of $10.24; (ii) late charges of $16.13 per month, assessed on 16th day
payment is past due; and (iii) additional attorneys' fees hereafter incurred and costs of suit.
Date: _('f - 3 , el S
CAPLAN & LUBER, LLP
By:
Axel . Shield, II, Esquire
40 Darby Road
Paoli, PA 19301
610-640-1200
Attorneys for Plaintiff
UNLESS YOU NOTIFY US IN WRITING WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS
LETTER THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT
IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT
AND MAIL IT TO YOU. ALSO UPON YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE
WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF
DIFFERENT FROM THE CURRENT CREDITOR THIS COMMUNICATION IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
//:,, :: au41o3 ?
RECORD AND RETURN TO:.
PROFESSIONALABSTRAQT
ASSURANCE C.oRP.',? °.i:L>t1U Citft•i 'r
4800 STREET ROAD'
TREVOSE, PA 'gap JUIl "L`+ : R(?`'1Q+` ?' 'z 11341
Parcel Number: 'y "e?,? ?•;? ?;??? .}
i_ ._ ; t•1'r* r?,:. °
29-17-1585-235
After recording return to:
The Money Store/Packaging
P.O. Box 160128
Sacramento, CA 95816.0128
0081023558
MORTGAGE
THIS MORTGAGE ("Security Instrument") is made this Eighteenth Day of June, 1998
between the Mortgagor. Chester L. BreniZer
(herein "Borrower"), and the Mortgagee, TMS Mortgage Inc. , dba The Money Store
which is organized and existing under the laws of New Jersey
and whose address is 4660 Trindle Road Suite 1002.
Shiremanstown, PA 17011 (herein *Under').
WHEREAS, Borrower is indebted to render in the principal sum of Thi rty-Six thousand and 00/100
Dollars (U.S. s 36,000.00 ) together with interest, which indebtedness is evidenced
by Borrower's note dated June 18, 1998 (the "Note"), providing for monthly
installments of principal and interest, with the balance of the indebtedness, if not sooner paid, due and payable on
July 1, 2028
TO SECURE to Lender the repayment of the indebtedness evidenced by the Note, with interest thereon; extensions
and renewals of the Note; the payment of all other sutras, with interest thereon, advanced in accordance with this Security
Instrument to protect the security of this Security instrument; and the performance of the covenants and agreements of
Borrower contained in this Mortgage. Borrower does hereby mortgage, grant and convey to Lender, the following described
property located in Cumberland County. Pennsylvania: .
(SEE EXHIBIT 'A' ATTACHED)
PdvvL a9 -- 1-1- 115 85 - X35
being the same property commonly imown as: 1819 Hei shman Gardens Dri ve, Carl i sl e, PA 17013
,. ("Property Address").
PENNSYLVANIA MORTGAGE'isrcal Original - Record
M002-IPA r.a• ai
C''???•???' ? I IIII IIIIII?I IIII IIIII?IIBI111111V011111111111111111111111111
00810235SSRMG - 60
9ood462?Ad X757
ausrnrE•itrirMAnotuu J
TOGETHER with all the improvements now or hereafter%ereeted.odahT!,propeny; and all easements, rights,
appurtenances and tents, all of which shall be deemed to be and re"m'ain p'arr;.oflthe,praperty covered by this Security
Instrument. All of the foregoing, together with such property (or •the•Ieasehoid-ennte.,iftthis Security Instrument is on a
leasehold) are called 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 warrants
and covenants that Borrower will defend generally the title to the Property against all claims and demands, subject to
encumbrances of record. Borrower further warrants, represents and covenants as follows:
1. Payment of Principal and Interest. Borrower shall promptly pay when due the principal and interest Indebtedness
and all other charges evidenced by the Note.
2. Funds for Taxes and Insurance. If required by Lender, and subject to applicable law, Borrower shall pay to Lender
on the day monthly payments are due under the Note, until the Note is paid in full, a sum ('Funds") for: (a) yearly taxes and
assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or
ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly food insurance premiums,
if any; and (e) yearly mortgage insurance premiums, if any. These Items are called "Escrow Items." Lender may, at any
lime, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan
may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1974, as amended from
time to time, 12 U.S.C. Section 2601 el seq. ("RESPA"), unless another law that applies to the Funds 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 future 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 entity
(including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Foods to pay
the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow
account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender
to make such a charge. However. Lender may require Borrower to pay a one-time charge for an Independent real estate tax
reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement
is made or 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 Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for
which each 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
Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by
Lender at any time is not sufficient to pay the Escrow items when due, Lender may so notify Borrower is writing, and, in
such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the
deficiency in no more than twelve monthly payments, at Lender's sole discretion.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any
Funds held by Lender. If, under Paragraph 18, Lender shall acquire or sell the Property, Lender, prior to the acquisition or
sale of the Property, shall apply any Funds held by Lender at, the time of acquisition or sale w a credit against thr, sums
secured by this Security Instrument.
3. Application of Payments. All payments of principal and interest received by Lender shall be applied as provided in
the Note. If Borrower owes Lender any late charges, or other fees or charges ("nther charges"), they will be payable upon
demand of Lender. Unless prohibited by law, the application of payments may be affected by the imposition of other charges.
Therefore, payments of other charges, whether paid to Lender in addition to the monthly payment or separately, will be
applied in a manner at the absolute discretion of the Lender. Borrower agrees that Lender may apply any payment received
under Paragraphs I and 2, either first to amounts payable under Paragraph 1, or first to amounts payable under Paragraph 2.
PENNSYLVANIA MORTGAGE ,stunt Original
M002.2PA
Record poox1462PAGE .758
P.a. 2 e, 1
0081023558
I
4. Prior Mortgages and Deeds of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under
any mortgage, deed of trust or other security agreement with a lien which has priority over this Security Instrument, if any,
including Borrower's covenants to make payments when due. Borrower shall pay or came to be paid all taxes, assessments and
other charges, fines and impositions attributable to the Property which may attain a priority over this Security Instrument, and
leasehold payments or ground rents, if any.
5. lnsurance.'9orrower shall keep the improvements now existing of hereafter erxtedon the Properly insured against
loss by fire, hazards included within the term "extended coverage," flood and my other hazards as Lender may require, from
time to time, and in such amount and for such periods as Lender may require.
The insurance carrier providing the insurance shall be chosen by Borrower subject to approval by Lender; provided
that such approval shall not be unreasonably withheld. If the Borrower falls to maintain the coverage described above, Lender
may, at its option, obtain coverage to protect its rights on the Property In accordance with Paragraph 8. All insurance policies
and renewals thereof shall be in a form acceptable to Lender and shall include a standird mortgage clause in favor of and in a
form acceptable to Lender. Lender shall have the right to hold the policies and renewals thereof, subject to the terms of any
mortgage, deed of trust or other security agreement with a lien which has priority over this Security Instrument. If any
insurance proceeds are made payable to Borrower, Borrower shall promptly pay such amounts to Lender, including, without
limitation, the endorsement to Lender of any proceeds made by check or other draft.
Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair
of the Property damaged. if the restoration or repair is economically feasible and Lender's security is not lessened. If the
restoration or repair Is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be
applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower.
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 I and 2 or change the amounts of the payments. If
under Paragraph 18 the Property is acquired by Lender. Borrower's right to any insurance policies and proceeds resulting
from damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security
Instrument immediately prior to the acquisition.
The provisions of this Paragraph 5 concerning the payment, disbursement or application of insurance proceeds shall
apply to any insurance proceeds covering the Property whether or not (1) Lender is a named insured, (ii) the polity, contains a
mortgage clause, or (iii) Lander has required Borrower io maintain the insurance. Borrower authorizes and directs any insurer
to list Lender as a loss payee on any payment of insurance proceeds upon Lender's notice to insurer of Lender's interest in the
insurance proceeds. ,
in the event of loss,. Borrower shall give prompt notice to•the insurance carrier and Lender. Lender may make proof
of loss if not made promptly by Borrower.
If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date
notice is mailed by Leader to Borrower that the insurance carrier offers to settle a claim for insurance benefits. Leader is
authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to
the sums secured by this Security Instrument.
6. Preservation and Maintenance of Property: Leaseholds; Condominiums; Planned Unit Developments. Borrower
shall keep the Property in good repair and shall, not commit nor permit waste or impairment or deterioration of the Property.
Borrower shall not do anything affecting the Property that is in violation of any law, ordinance or government regulation
applicable to a residential property, and Borrower shall comply with the provisions of any lease if this Security Instrument is
on a leasehold. If this Security Instrument is on a unit in a condominium or a planned unit development, Borrower shall
perform all of Borrower's obligations under the declaration or covenants creating or governing the condominium or planned
unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents.
Unless Lender and Borrower otherwise agree in writing, all awards, payments or judgments, including interest
thereon, for any injury to or decrease in the value of the Property received by Borrower will be used to restore the Pmpcrty or
applied to the payment of sums secured by this Security Instrument, whether or not then due, with any excess paid
to Borrower. 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 amounts of the payments.
Borrower agrees, that in the event an award, payment or judgment, includes compensation for both injury or, decrease in the
value of the Property and compensation for any othei injury or loss, the total amount of such award, payment or judgment
PENNSYLVANIA MORTGAGE 497001 Original - Record 0081023558
M002.3PA r•a• 0.17
eooK 1462 fac( .759
shall be deemed compensation with respect to the Property and Borrower hereby consents to Lender's intervention into any
proceedings regarding the Property.
7. Loan Application Proem. Borrower shall be in default under this Security Instrument, if Borrower, during the loan
application process, gave materially false or inaccurate information or statements to Lender (or' felled to provide Lender with
any material Information directly hearing an Lender's decision to extend credit to Borrower), in connection with the loan
evidenced by the Note.
S. Protection or Lender's Rights In the Property. If Borrower fails to perform the covenants and agreements contained
in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as
a proceeding in bankruptcy, probate, for condemnation, forfeiture, or to enforce laws or regulations), then Lender may do and
pay for whatever is necessary to protect the value of the Property and Lender's rights lit the Property. Lender's actions may
include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying
reasonable attorneys' fees and entering on the Property to make repairs or abate nuisances. Although Lender may take action
under this Paragraph 8, Lender does not have to do so. The right of Lender to protmt Lender's rights in the Property shall
include the right to obtain at Borrower's expense, property inspections, credit reports, appraisals, opinions of value or other
expert opinions or reports, unless prohibited by law.
. . Any amounts disbursed by Lender under this Paragrophi8 shall become addliional-debt of Borrower, secured by this
Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the
date of disbursement at the Note rate and shall be payable, with interest, upon demand of Lender. The Borrower's obligation
to pay the amounts advanced by Lender under this Paragraph 8 shall continue in full force and effect after the entry of any
judgment in mortgage foreclosure or a judgment on the Note.
9. Mortgage Insurance. If Lender required mortgage insurance as a condition of matting the loan secured by this
Security Instrument, Borrower shall pay the premiums required to maintain the insurance In effect until such time as the
requirement for the insurance terminates in accordance with Borrower's and Lender's written agreement or applicable law.
10. Inspection. Lender may make or cause to be made reasonable entries upon and inspections of the Property, provided
that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor as related to Lender's
interest in the Property.
if. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any
condemnation or other taking of the Property, or pan thereof, or for conveyance in lieu of condemnation, are hereby assigned
and shall be paid to Lender, subject to the terns of any mortgage, deed of trust or other security agreement with a lien which
has priority over this Security Instrument.
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 otherwise 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 the taking. Any balance shall be 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 less than the amount of the sums secured
immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable 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 for damages, Borrower fails to respond to Lender within 30 days after the daze 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
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 I and 2 or change the amount of such'payments.
B001(i162PACE %760
PENNSYLVANIA MORTGAGE 197091 Original - Record
M002-4PA P.v.. e.7 0081023558
r, ..r.../. i;;:: ,..
12. Borrower Not Released; Forbeanmce By Lender Not a Waiver; Acceptance of Partial Payment. Extension of the
time for payment or modification of amortization of the sums secured by, this Security Instrument granted by Lender to
Borrower or any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original
Borrower .and Borrower's successors in Interest. Lender shall not be required to commmce proceedings against such successor
or may.mfuse to, extend time for payment or otherwisemodify amortization of the sums secured by this Security Instrument-by
reason of any demand madeby•the original Borrower and;Borrower's successors in interest. Anyiforbearance by fender on
one or more occasions in exercising any right or remedy hereunder, or otherwise afforded by applicable law,,shall not b6 a
waiver of or preclude the later exercise of that or any other right or remedy.
Lender may accept partial payments from Borrower, without waiving or forbearing any of its rights under this
Security Instrument or under the Note even if such payments are notated as a payment in full, or with a notation of similar
meaning.
13. Successors and Assigns Bound; Joint and Several Liability; Signers. The covenants and agreements herein
contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower,
subject to the provisions of Paragraph 17 hereof. All covenants and agreements of Borrower shall be joint and several. Any
Borrower who signs'this Security Instrument, but does not execute the Note: (a) is signing this Security Instrument only to
mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Security Instrument, (b)
Is not personally liable on the Note or under this Security Instrument, and (e) agrees that Lender and any other Borrower may
agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note
without that Borrower's consent.
14. Notice. Except for any notice required under applicable law to be given in another rawer: (a) any notice to
Borrower provided for in this Security instrument shall be given by delivering it or by mailing such notice by first class mail
addressed to the Property Address or to such other address as Borrower may designate by notice to Lender as provided herein,
and (b) any notice to Lender shall be given by first class mail to Lender's address stated herein or to such other address as
Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Security Instrument shall be
deemed to have been given to Borrower or Lender when given in the manner designated herein.
15. Governing Law; Sevessnbility. The state and local laws applicable to this Security Instrument shall be the laws of the
jurisdiction in which the Property is located. The foregoing sentence shall not limit the applicability , of-federal law to this
Security Imtmment. 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, and to this end, the provisions of this Security Instrument and the Note are declared to be severable.
As used herein, "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law or
limited herein.
16. Borrower's Copy. Borrower shall be famished a copy of the Note and of this Security Instrument at the time of
execution or after recordation hereof.
17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it
is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person)
without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all Burns secured by
this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of
the date of this Security Instrument.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period
of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by
this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any
remedies permitted by this Security Instrument without Nrther notice or demand on Borrower.
is. Acceleration; Remedies. Except as provided iii Paragraph l7 hereof, upon Borrower's breach of any wvcnant or
agreement of Borrower in this Security Instrument, including the covenants to pay when due any sums secured by this Security
Instrument, Lender prior to acceleration shall give notice to Bonower as provided in Paragraph 14 hereof specifying: (1) the
PENNSYLVANat MORTGAGE most Original Record
M002-SPA Pq. 5 nr) 0081023558
Bolik 11462 PACE , 762,
breach; (2) the action required to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to
Borrower, by which such breach must be cured; and (4) that failure to cure such breach on or before the date specified in the
notice may result in acceleration of the sums secured by this Security Instrument or foreclosure by judicial proceeding.
The notice shall further inform Borrower of the right to reinstate this Security Instrument after acceleration and the
right to bring a court action or to assert in the judicial procieding the nonexistence of a default or any other defense of
Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, lender, at
Lender's option may declare all of the sums secured by this Security Instrument to be immediately due and payable without
further demand and may foreclose this Security Instrument by judicial precceding and any other remedies permitted by
applicable law. Lender shall be entitled to collect all expenses of foreclosure, including, but not limited to, reasonable
attorneys' fees, court costs, and costs of documentary evidence, abstracts and title reports, even if the breach is cured prior to
the completion of any foreclosure.
Borrower agrees that the interest rate payable after judgment is entered on the Note, or in an action of mortgage
foreclosure, shall be the rate payable from time to time under the Note.
19. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums secured by this Security
Instrument due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this
Security Instrument discontinued up to one hour prior to sale of the Property If: (a) Borrower pays Lender all sums which
would be then due under this Security Instrument and the Note had no acceleration occurred; (b) Borrower cures all breaches
of any other covenants or agreements of Borrower contained in this Security Instrument; (c) Borrower pays all reasonable
attorneys' fees, trustees' fees and court costs; and (d) Borrower takes such action as Lender may reasonably require to assure
that the lien of this Security Instrument, Lender's interest in the Property and Borrower's obligation to pay the sums secured
by this Security Instrument shall continue unimpaired. Upon such payment and cure by Borrower, this Security Instrument and
the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. This right to reinstate
shall not apply, however, in the case of acceleration pursuant to Paragraph 17.
20. Assignment of Rents; Appointment or Receiver. As additional security hereunder, Borrower hereby assigns to
Leader the rents of the Property,' provided that Burrower shall, prior to acceleration under Paragraph 18 hereof or
abandonment of the Property, have the right to collect and retain such rents as they become due and payable.
Upon acceleration under Paragraph 1S hereof or abandonment of the Property, Lender, in person, by agent or by
judicially appointed receiver, shall be entitled to enter upon, take possession of and manage the Property and to collect the
rents of the Property including those past due. All rents collected by Lender or the receiver shall be applied first to payment of
the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premium on
receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Security Instrument. Lender and the
receiver shall be liable to account only for those rents actually received.
21. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any
Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the
Property 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 for normal
residential uses and for niaintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by
any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or
Environmental law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or
?t 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 uddd in this Paragraph 21, "Hazardous Substances" are those substances defined as toxic of hizardous substances
by Environmental law and the following substances: gasoline, kerosene, other flammable or toxic peiroleiim'products.toxie
pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactivc.ii2erials. As'used
in this Paragraph 21, "Environmental Law" means federal laws and laws of the jurisdiction where the Prop1. ny i's;located:that'.
:.
relate to health, safety or environmental protection. - '• •:-:°? ?, :'`';'?'=' <'-
Bood462 PAGE .762
PENNSYLVANIA MORTGAGE 19709[ OrS9rina2 - Record
Mooz-avA P., 6 of 7 0081023558
22. Release. Upon payment of all sums secured by this Security Instrument, Lender shall release the Security Instrument,
Borrower shall pay any release fees and costs of recordation unless applicable law provides otherwise.
23. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire
title•to the Property, this Security Instrutment shall be a purchase money mortgage.
Adjustable Rate Mortgage 'Loan Rider attached hereto and incorporated herett by' this
reference.
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.
L.
at Law
TIMOTHY M.
Certlntate of Residence
-Borrower
(Seal)
(Seal)
(Seal)
-Borrower
(Seal)
-H.Mwer
1, John Maurer , do hereby certify that the correct address of.
the within-named Lender is 4660 Trindle,,Road Suite 1002, Shiremanstown,, PA 17011
Wiirteas my hand this " 18th' day of J e 1998
L, nA a?-
John Maurer Agent of Lender
COMMONWEALTH OF PENNSYLVANIA. Cumberla County as:
On this, the 18th day of June
personally appeared Chester L. Brenizer
1998 , before me, the undersigned officer,
known to me (or satisfactorily proven) to be the
person(s) whose name(s) is subscribed to the within instrument and acknowledged that he
executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official sea].
My Commission Expires:
Tide of Officer
ItMerfdl seat
Koran L. Burcb.' Notary Public Hempaen Cumberland Coumy
My Canmisaion Expires Nov. 24• 2001
Member. PentnrNgnia Association of Notaries
PENNSYLVANIA MORTGAGE ia>osi Original - Record
Moot-TPA P.a. r.. r
PoxU62?Act 5763
0081023558
-ALL THAT CERTAIN TRACT OF LANDS, SITUATE IN NORTH MIDDLETON TOWNSHIP,
CUMBERLANfl COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH
SURVEY OF CARL D. BERT, REGISTERED SURVEYOR, DATED NOVEMBER 4, 1983, AS
FOLLOWS:
BEGINNING AT A POINT ON THE NORTH SIDE OF HEISHMAN GARDENS DRIVE, TOWNSHIP
ROAD T-716 SAID POINT BEING THE DIVIDING LINES BETWEEN LOTS NOS. 1819 AND
1819A ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE BY SAID DIVIDING
LINE AND THROUGH THE CENTER OF A PARTY WALL DIVIDING THE DWELLING HOUSE
HEREIN CONVEYED FROM THE DWELLING HOUSE KNOWN AS 1819A HEISHMAN GARDENS
DRIVE, NORTH 37 DEGREES 55 MINUTES 22 SECONDS EAST 119.26 FEET TO A POINT
IN LINE OF LAND NOW OR FORMERLY OF WILLIAM M. CROFT; THENCE BY LAND NOW OR
FORMERLY OF WILLIAM M. CROFT, NORTH 83 DEGREES 28 MINUTES 40 SECONDS WEST
57.63 FEET TO A POINT AT THE NORTHEAST CORNER OF LOT NO. 1817A ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE BY SAID LOT NO. 1817A SOUTH 32
DEGREES 02 MINUTES 47 SECONDS WEST 107.51 FEET TO A POINT ON THE NORTHERN
SIDE OF HEISHMAN GARDENS DRIVE; THENCE BY HEISHMAN GARDENS DRIVE SOUTH 76
DEGREES 57 MINUTES 58 SECONDS EAST 42.09 FEET TO A POINT, THE PLACE OF
BEGINNING.
Boox1462WE 064
0081023558
ADJUSTABLE RATE NOTE
(LIBoR 6 Month Libor Index-Rate Caps)
THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND
MY MONTHLY PAYMENT. THIS NOTE LI19TS THE AMOUNT MY INTEREST RATE CAN
CHANGE AT ANY ONE TM AND THE MINIMUM AND-THE MAXIM RATE I MUST PAY.
June 18. 1998
Date
1819 Heishman Gardens Drive, Carlisle, PA 17013
Property Address
BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay Thi rty S i x Thousand and 00/100
Dollars (U.S. $ 36,000.00 >
(this amount will be called 'principal"), plus interest, to the order of the Lender. The Lender is TMS Mortgage Inc. ,
dba The Money Store
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note and who is entitled to receive
payments under this Note will be called the "Note Holder."
2. INTEREST
I will pay interest at an annual rate of 10.250 X
Interest will be charged on unpaid principal beginning on Jul y 1, 1998 , and will
continue until the full amount of principal has been paid. The interest rate I will pay may change in accordance with Section 4
of this Note.
Interest shall continue to accrue at the interest rate required by this Section 2 and Section 4 of this Note after the maturity
or default of this loan.
3. PAYMENTS
(A) Amount of My Initial Monthly Payments
I will pay principal and interest by making payments each month ("monthly payments"). My initial monthly payment
will be in the sum of U.S. $ 322.60 This amount may change.
(B) 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
must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance
with Section 4 of this Note.
(C) Time, Place and Application of Payments
I will snake my monthly payments on the Fi rst day of each month beginning on August 1, 1998
I will make monthly payments every month until I have paid all of the principal and interest and any other fees or
charges, described below, that I may owe under this Note. If, on July 1. 2028
any sum still remains unpaid, I will pay what I owe in full on that date. All monthly payments received by Note Holder shall
be applied first to accrued interest and the remainder, if any, to the principal.
If I owe the Note Holder any late charges, or other fees or charges ("other charges"), they will be payable upon demand
of the Noce Holder, Unless prohibited by law, the application of payments may be affected by the imposition of other charges.
Therefore, payments of other charges, whether paid to the Note Holder in addition to the monthly payment or separately, will
be applied in a manner at the absolute discretion of the Note Holder, subject to applicable law.
I will make my monthly payments at P.O. Box 1058, Newark, NJ 07101.1058
or at a different address if required by the Note Holder.
PENNSYLVANIA ADJUSTABLE PATE NOTE Islon Original - File
MODS-1 PA Pee. t ., 4
--
A45TATE?INfEpNAnntUt
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The interest rate 1 will pay may change on the 1St day of July. 2000 and on the 1St
day of every 6th month(s) 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 interest rate will be based on an Index. The "Index" is the average of
interbank offered rates for 6 Month Libor U.S. dollar-denominated deposits in the London market based on quotations of
major banks, as published by The Wall Street Journal. The most recent Index figure available as of the 20th day of the calendar
month immediately preceding each Change Date is called the "Current Index."
If the Index is no longer available, or is no longer published by The Wall Street Journal, the Note Holder will choose a
new index or source of index that is based upon comparable information. The Note Holder will give me notice of this choice.
(C) Calculation of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by adding F1 ve and 1 /2
percentage points ( 5.500 %) to the Current Index. The Note Holder will then round the
result of this addition up to the nearest one-eighth of one percentage point (0.125%). Subject to the limits stated in Section
4(D) below, this rounded amount will be my new interest rate until the next Change Date.
The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid
principal that I am expected to owe at the Change Dare in full on the Maturity Date at my new interest rate in substantially equal
payments. The result of this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Changes
The interest rate I am required to pay at the first Change Date will not be greater than 13.250 % or less
than 10.250 %. Thereafter, my interest rate will never be increased or decreased on any single Change Date by
more than One percentage point(s) ( 1.000 %) from the rate of
interest I have been paying for the preceding Six and 00/100 month(s). My interest rate will never be greater than
16.250 %, or less than 10.250 %.
(E) Effective Date of Changes
My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment
beginning on the first monthly payment date after the Change 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 monthly
payment before the effective date of any payment change. The notice will include information required by law to be given me
and also the title and telephone number of a person who will answer any question I may have regarding the notice.
5. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any of my monthly payments by the end of 15 calendar
days after the date it is due, I will promptly pay a late charge to the Note Holder. The amount of the charge will be
5.00 % of my full monthly payment. I will pay this late charge only once on any late monthly payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all
the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or
trailed to me.
(D) No Waiver by Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in frill as described
above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to
be paid back for all of its costs and expenses to the extent not prohibited by applicable law. Those expenses include, for
example, reasonable attorneys' fees, foreclosure fees and court costs.
PENNSYLVANIA ADJUSTABLE RATE NOTE o7o2: Original - File
M006dPA Pete 2 of 4 0081023558
(F) Check CoBMion Charges
if 1 present the Note Holder with a check, negotiable order of withdrawal, share draft or other instrument in payment
that is returned or dishonored for any reason, I will pay a check collection charge to the Note Holder. The amount of the
charge will not be greater than U.S. $ 15.00
6. TICS NOTE SECURED BY A SECURITY INSTRUMENT
In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the
'Security lnstmment"), on real property (the "Property") described in the Security Instrument and dated the same daze as this
Note, protects the Note Holder from possible losses which might result if 1 do not keep the promises which I make in this Note.
The Security Instrument describes how and under what conditions I may also be required to make immediate payment in full of
all amounts I owe under this Note. I agree to these conditions. Some of these conditions are 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 Is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower
is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate
payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by
Lender if exercise is prohibited by federal law as of the date of this Security Instrument.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower
must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration
of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or
demand on Borrower.
7. BORROWER'S PAYMENTS BEFORE THEY ARE DUE
Subject to the application of payments described in Section 3(C), 1 have the right to make payments of principal at any
time before they are due. A prepayment of all of the unpaid principal is known as a "full prepayment." A prepayment of only
part of the unpaid principal is known as a "partial prepayment."
If I make a partial prepayment equal to one or more of my monthly payments, my due date may be advanced no more
than one month. If I make any other partial prepayment, I must still make each later payment as it becomes due and in the same
amount.
I may make a full or partial prepayment at any time. However, if within the first 60 months from the
date of this loan I male any prepayment(s) within any 12-month period whose total amount exceeds 20% of the original
principal amount of this loan, I will pay a prepayment charge equal to sit months' interest on the amount by which the total of
my prepayment(s) within that 12-month period exceeds 20% of the original principal amount of this loan.
8. BORROWER'S WAIVERS
I waive my rights to require the Note Holder to do certain things. Those things are: (A) to demand payment of amounts
due (known as "presentment"); (B) to give notice that amounts due have not been paid (known as "notice of dishonor"); (C) to
obtain an official certification of nonpayment (known as "protest"). Anyone else who agrees to keep the promises made in this
Note, or who agrees to make payments to the Note Holder if 1 fail to keep my promises under this Note, or who signs this Note
to transfer it to someone else, also waives these rights. These persons are known as "guarantors," "sureties" and "endorsers."
9. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail addressed to me at the Property Address described in the Security Instrument. A
notice will be delivered or mailed to me at a different address if I give the Note Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the
Note Holder at the address stated in Section 3(C). A notice will be mailed to the Note Holder at a different address if I am
given a notice of that different address.
10. RESPONSIBILITY OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each of us is fully and personally obligated to pay the full amount owed and to
keep all of the promises made in this Note. Any guarantor, surety, or endorser of this Note (as described in Section 8 above) is
also obligated to do these things. The Note Holder may enforce its rights under this Note against each of us individually or
against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. Any
PENNSYLVANIA ADJUSTABLE RATE NOTE (57021 Original - File
MOOS•3PA Paa s 0 4 0081023558
person who takes over my rights or obligations under this Note will have all of my rights and must keep all of my promises
made in this Note. Any person who takes over the rights or obligations of a guarantor, surety, or endorser of this Note (as
described in Section 8 above) is also obligated to keep all of the promises made in this Note. This Note is intended by lender
and me as a complete and exclusive statement of its terms, there being no conditions to the enforceability of this Note. This
Note may not be supplemented or modified except in a writing signed by me and the Note Holder. This Note benefits Lender,
its successors and assigns, and binds me and my heirs, personal representatives and assigns.
11. APPLICABLELAW
This Note shall be governed by the laws of the State of Pennsylvania. If a law which applies to this loan and sets
maximum loan charges is finally interpreted so that the interest and other charges collected or to be collected in connection with
this loan exceed the permitted limits, then: (A) any such interest or other charge shall be reduced by the amount necessary to
reduce the interest or other charge to the permitted limit; and (B) any sums already collected from me which exceeded permitted
limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this
Note or by taking a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment.
12. BORROWER'S COPY
I hereby acknowledge receipt of a filled-in copy of this Note.
-Bo=wer
Arty at Law TIMOTHY M. ANSTINE
Pay to the order of:
TMS Mor gagf Inc., dba The Money Store
By 1! ?t t• ij 6--
B 6h Manager John Maurer
t`
PENNSYLVANIA ADJUSTABLE RATE NOTE 197023 Original - File
M00E•4PA
•Bormwer
Page 4 of 4
(Seal)
(Seal)
-Bomwer
(Sign Original Note Only)
0081023558
DESCRIPTION
ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in
North Middleton Township, Cumberland County, Pennsylvania, bounded and described in
accordance with survey of Carl D. Bert, Registered Surveyor, dated November 4, 1983, as follows:
BEGINNING at a point on the North side of Heishman Gardens Drive, Township Road T-716 said
point being the dividing line between Lot Nos. 1819 and 1819A on the hereinafter mentioned plan
of lots; thence by said dividing line and through the center of a party wall dividing the dwelling
house herein conveyed from the dwelling house known as 1819A Heishman Gardens Drive, North
37° 55' 22" East 119.26 feet to a point in line of land now or formerly of William M. Croft; thence
by land now or formerly of William M. Croft, North 83° 28' 40" West 57.63 feet to a point at the
Northeast corner of Lot No. 1817A on the hereinafter mentioned plan of lots; thence by said Lot
No. 1817A South 32102' 47" West 107.51 feet to a point on the Northern side of Heishman
Gardens Drive; thence by Heishman Gardens Drive South 76° 57' 58" East 42.09 feet to a point, the
place of beginning.
BEING Lot No. 1819 on the Plan of Lots known as Heishman Gardens as recorded in the Office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 19, page 43.
HAVING thereon erected a dwelling being the western half of a duplex and being known as 1819
Heishman Gardens Drive.
Tax Parcel # 29-17-1585-235
EFXO M
UNLESS YOU NOTIFY US IN WRITING WITHIN THIRTY (30) DAYS AFTER RECEIPT
OF THIS LETTER THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL
ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE
WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON
YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU
WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM
THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
April 13, 1999
CERTIFIED MAIL
RECEIPT REQUESTED AND
REGULAR FIRST CLASS MAIL
To: Chester L. Brenizer
1819 Heishman Gardens Drive, Carlisle, PA 17013
Re: Mortgage Loan Number: 81023558
Mortgage Premises: 1819 Heishman Gardens Drive, Carlisle, PA 17103
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The mortgage held by The Bank of New York as Co-Trustee under the Pooling and
Servicing Agreement dated as of July 31, 1998, Series 1998-B (hereinafter we, us or ours)
on your property located at 1819 Heishman Gardens Drive, Cariisle, PA IS IN DEFAULT
because you have not made the monthly payments of principal and interest of $322.60 for
the months of December, 1998 through April, 1999 totaling $1,613.00 Late charges (and
other charges) have also accrued to this date in the amount of $154.52. The total amount
now required to cure this default, or in other words, get caught up in your payments,
through the date of this letter is $1,767.52.
You may cure this default within thirty (30) days of the date of this letter, by paying
to us the above amount of $1,767.52, plus any additional monthly payments and late
charge which may fall due during the period. Such payment must be made either by cash,
cashier's check, certified check or money order, and made payable to The Bank of New
York as Co-Trustee under the Pooling and Servicing Agreement dated as of July 31, 1998,
Series 1998-B c/o The Money Store.
If you do not cure the default within thirty (30) days, we intend to exercise our right
to accelerate the mortgage payments. This means that whatever is owing on the original
amount borrowed will be considered due immediately and you may lose the chance to pay
off the original mortgage in monthly installments. If full payment of the amount of default
ALL•STAW UIIENUMML
is not made within thirty days, we also 4truct our attorneys to start a lawsuit to
foreclose on your mortgaged propertyprtgage is foreclosed, your mortgaged
property will be sold by the sheriff to pajortgage debt.
If we refer your case to our atto ou cure the default before they begin
legal proceedings against you, you will o pay the reasonable attorneys' fees,
actually incurred. Any attorneys' fees to whatever you owe us, which may
also include our reasonable costs. If yo efault within the thirty-day period, you
will not be required to pay attorney's fie
We may also sue you personally laid principal balance and all other sums
due under the mortgage. If you have nol default within the thirty-day period, and
foreclosure proceedings have begun, yor right to cure the default and prevent the
sale at any time up to one hour before I's foreclosure sale. You may do so by
paying the total amount of the unpaid mcnent plus any late or other charges then
due, as well as the reasonable attorneyd costs connected with the foreclosure
sale (and perform any other requiremerthe mortgage). It is estimated that the
earliest date that such a sheriffs sale cold would be approximately October 12,
1999. A notice of the date of the sheriff ibe sent to you before the sale.
Of course, the amount needed to Default will increase the longer you wait.
You may find out at any time exactly whaired palment will be by calling us at the
following number: 918-280-2700. This plust ben cash, cashier's check, certified
check or money order and made payabli the adress stated above
Your should realize that a sheriffll end vur ownership of the mortgaged
property and your right to remain in it. ontinuito live in the property after the
sheriffs sale, a lawsuit could be started lou.
You have additional rights to help ,0 intest in the property. YOU HAVE
THE RIGHT TO SELL THE PROPEROBTA MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORFONEY=ROM ANOTHER LENDING
INSTITUTION TO PAY OFF THIS DEBI MAY ,VE THE RIGHT TO SELL OR
TRANSFER THE PROPERTY SUBJEiTHE IRTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME TRTGAQEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CH NO AIRNEYS' FEES AND COSTS
ARE PAID PRIOR TO OR AT THE SA OTHER REQUIREMENTS
UNDER THE MORTGAGE ARE SATISJTHAT?'
ONTAIS TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGH T EXIS'OU HAVE THE RIGHT TO
HAVE THIS DEFAULT CURED BY ANYQ PARTYING ON YOUR BEHALF.
If you cure the default, the mortgau berestoe same position as if no
default had occurred. However, you are tled to thi o cure your default more
than three times in any calendar year.
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
MAY BE ABLE TO HELP YOU.
READ THE FOLLOWING NOTICE TO FIND OUT
HOW THE PROGRAM WORKS.
If you need more information call the Pennsylvania
Housing Finance Agency at 1 (800) 342-2397
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA
TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN
PRESTAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE
SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
GILOCFIIUVN BBEV.ETTER6 Ml NOT
EXHIBIT
0
AU-STATE- NTEBNATIOM
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
Date: April 13, 1999
RE: Account No.: 81023558
TO: Chester L. Brenizer
1819 Heishman Garden Drive, Carlisle, PA 17103
PROPERTY: 1819 Heishman Gardens Drive, Carlisle, PA 17013.
FROM: Axel A. Shield, II, Esquire
Attorneys for The Bank of New York as Co- Trustee under the Pooling and
Sevicing Agreement dated as of July 31, 1998, Series 1998-B c/o The Money
Store.
You may be eligible for financial assistance that will prevent foreclosure on
your mortgage if you comply with the provisions of the Homeowners' Emergency
Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency
temporary assistance if your default has been caused by circumstances beyond your
control, you have a reasonable prospect of resuming your mortgage payments, and
if you meet other eligibility requirements established by the Pennsylvania Housing
Finance Agency. Please read all of this Notice. It contains an explanation of your
rights.
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 a representative of this lender, or with a designated
consumer credit counseling agency. The purpose of this meeting is to attempt to work out
a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the
next (30) days.
F.U=S%1513V3I BE ETTEESMC[91.NOT
If you attend a face-to-face meeting with this lender, or with a consumer credit
counseling agency identified in this notice, no further proceeding in mortgage foreclosure
may take place for thirty (30) days after the date of this meeting. The name, address and
telephone number of our representative is:
Kelly Deal, Litigation Officer
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Tel No.: 918-280-2700
Fax No.: 918-280-2719
The names and addresses of designated consumer credit counseling agencies are shown
on the attached sheet. It is only necessary to schedule one face-to-face meeting. You
should advise this lender immediately of your intentions.
Your mortgage is in default because you have failed to pay promptly installments
of principal and interest, as required, for a period of at least sixty (60) days. The total
amount of the delinquency is $1,767.52. That sum includes the following:
Principal and Interest @ $322.60 per month for 5 months $1,613..00
Current Late Charge $ 64.52
Current NSF Due $ 30.00
Deferred NSF Charge $ 30.00
Total Fees $ 30.00
TOTAL
$1,767.52
If you have tried and are unable to resolve this problem at or after your face-to-face
meeting, you have the right to apply for financial assistance from the Homeowners'
Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file
a completed Homeowners' Emergency Assistance Application with one of the designated
consumer credit counseling agencies listed on the attachment. As application for
assistance may only be obtained from a consumer credit counseling agency. The
consumer credit counseling agency will assist you in filling out your application and will
submit your completed application to the Pennsylvania Housing Finance Agency. Your
application must be filed or postmarked, within thirty (30) days of your face-to-face
meeting.
PDOW 1511115/ BPEILETTERSUM L NOT
It Is extremely Important that you file your application promptly. If you do not
do so, or If you do not follow the other time periods set forth In this letter,
foreclosure may proceed against your home Immediately.
Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act.
It is extremely important that your application is accurate and complete in every
respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that additional time, no foreclosure
proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street,
Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800
or 1-800-342-2397 (toll free number). Persons with impaired hearing can call (717) 780-
1869.
In addition you may receive another notice from this lender under Act 6 of 1974.
That notice is called a "Notice of Intention to Foreclose". You must read both notices,
since they both explain rights that you now have under Pennsylvania law. However, if you
choose to exercise your rights described in this notice, you cannot be foreclosed upon
while you are receiving that assistance.
Very truly yours,
CA N 85 UBLER, L
By: Q // ^i ?) /?
wo
Axel A Shield, II, Esquire
UNLESS YOU NOTIFY US IN WRITING WITHIN THIRTY (30) DAYS AFTER RECEIPT
OF THIS LETTER THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL
ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE
WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON
YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU
WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM
THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
F %DMS11 5 1 9115 4 BEEU.ETTEE5MCT91 NOT 4
Consumer Credit Counseling Agency
Notification To:
Date:
Name of Mortgagee
Address
In accordance with the Pennsylvania Homeowners' Emergency Mortgage
Assistance Program (Act 91 of 1983), we have been approached for mortgage counseling
assistance by:
Name of Applicant
ress
Telephone Number
Mortgage Loan Number
Address of property on which mortgage is in default,
if different from above.
F\DOCAI51A134 RRELLETTERSAR91 NOT
The counseling agency met with the above named applicant on
Date who have indicated that they are more than sixty days delinquent on their
mortgage payments and have received notification of intention to foreclose from
Name and Address of Mortgagee
In accordance with the Homeowners' Emergency Mortgage Assistance Program,
this is to inform you that :
1. If the delinquency cannot be resolved within the 30 day forbearance period
as provided by law, the applicant listed above may apply to the Pennsylvania Housing
Finance Agency for Mortgage Payment Assistance.
2. By a copy of this Notice, we are notifying all other mortgagees, if any, which
the applicant has indicated as also having a mortgage on the property identified above.
3. It is our understanding that the 30 day forbearance period in which we are
now in ends on
4. No legal action to enforce the mortgage may occur during this forbearance
period, unless procedural time limits were not met by the homeowner.
Name of Counseling Agency:
Signer and Title
Telephone Number
F`DOCS ??11H.BRELLETTER CT91.NOT
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
ADAMS COUNTY
American Red Cross-Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
FAX 4 (717) 637-3294
Blair County Economic Opportunity
Council
5433 Industrial Avenue
Altoona, PA 16601
(814) 946-3851
FAX m (814) 946-5451
A&=n Housing, Inc.
Number Two Gateway Canter
9th Ficor
Pittsburah, PA 15222
(412) 391-1956
Community Action Southwest
22 West High Street
Waynesburg, PA 15370
(412) 852-2893
Consumer Credit Counseling Service
of Western Pennsvivania. Inc.
309 Smithfield Street
Pittsburgh, PA 15222
(412) 471-7584
Consumer Credit Counselino Service
of Western Pennsylvania. Inc.
500-02 3rd Avenue
Past Office Eox 278
Ouncansviile, PA
(814) 696-3546
F9D0C=r.CXMUCFGPE=A C'91rgr
Consumer Credit Counseling Service of
Western Pennsylvania, Inc.
2000 Unglestown Road
H2msbura, PA 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
ALLEGHENY COUNTY
Housing Opportunities. Inc.
133 Seventh Street
Mci(eesocrt, PA 15132
(412)65'4-1590
FAX m (412) 1564-0872
Man-Valley Unemployed Committee
120 E. 9th Avenue
Homestead, PA 15120
(412) 462-9962
Urban League of Pittsburgh. Inc.
building For Ecuai Opportunity
One Smithfield Street
Pittsburgh, PA 15712-11"
(412) 261-1120
FAX-, (412) 251-6207
ARMSTRONG COUNTY
Indiana County Community Action
Prpgrm
827 Water Street. Eox 187
Indiana. PA 15701
(412) 465-726=5 7
FAX T (412) 465-:118
BEAVER COUNTY
Action Housing, Inc. Housing Opportunities of Beaver
Number Two Gateway Center County, Inc.
9th Ficor 334 Insurance Street
Pittsburgh, PA 15231 Beaver, PA 1009
(412) 391-1966 (412) 728.7511
Consumer Credit Counseling Service Mon-Valley Unemployed Committee
of Wester Pennsylvania. Inc. 120 E. 9th Avenue
524 Franklin Avenue Homestead, PA 15120
Franklin Center (412) 762.9962
Aliquippa, PA 15001
BEDFORD COUNTY
Eedford-Fulton Housing Services Tableland Services. Inc.
R.D. 1, Box 1-84 131 North Center Avenue
EvererL PA 15537 Somerset. FA 15501
(814) 623-9129 (814) A5.9528
FAX T (814) 1=3 3c'9O
Consumer Coedit Counselinc Services We_therization Of`c3
of Western Pennsvivania. Inc. 917 Mifflin Street
500-02 3rd Avenue Huntingdon, PA SBc52
Pcst Office Box 278
Ouncansviile. PA
(814) 696-3546
Kevstone Ecanamic Deve!ooment
Corocration
1954 Mary Grace Lane
.:ohnstown. PA 15501
(81A) 535 556
FAX;: (814) 539-1688
BERKS COUNTY
Eudae*- Caunselinc Canter E_anomic Opportunity Cabinet or
247 North Fifth Street Schuylkill County
Re=dina, PA 19601 118 Norweigian Street
(215j 375-7866 Pattsviile, PA 17901
FAX T (215) 376-5 5515 (717) 622-.995
FAX ;. (717) 622-0429
Consumer Credit Counseling Service
of Lehigh Valley
3671 Crescent Court
East Whitehall, PA 18052
(610) 821-4011 or 1 (800) 220-2733
(717) and (814) ONLY
fax T (215) 821-0137
Sedfard-Fulton Housino_ Services
R.D. 1, Box 384
Everett, PA 15537
(814) 623-9129
FAX (814) 623-7187
Blair County Economic Opportunity
Council
5433 Industrial Avenue
Altoona. PA 16601
(814) 946-3651
FAX :(814)946-5451
Consumer Credit Counselino Service
of Western Pennsvvvania. Inc.
500-02 3rd Avenue
Post Office box 278
Ouncansviiie, PA
(814) 696-3546
Consumer Credit Counseline Service
of Northeastern Pennsylvania
Human Services Euiidino_
! 41 Wyoming Avenue
Box 168
Scranton, PA 18501
(717) 342-1072 or 1 (800) 922-9537
FAX # (717) 342-8040
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or 1 (800) 922-9537
FAX m (717) 821-1785
La Case Del Puebla
815 W. Baltimore Pike
Kennett Square, PA 19348
(215) 444-3731
FAX *(21a)444-3178
BLAIR COUNTY
Keystone Economic Development
Corporation
1954 Mary Grace Lane
Johnstown, PA 15901
(814) 535-6556
FAX m (814) 539-16a8
Weatheraation Office
917 Mifflin Street
Huminadon,PA 16652
BRADFORD COUNTY
His Maiestv FeilowshiD Church
207 Penn Ave.
P.O. Box 104
Athens. PA 16810 (Wed.-Fri.)
(717) 888-0024
17 Crofton Street
Weilsboro, PA 16901
(717)724-5252
"Z0C=-CiUB=X0F =GA 0.712 ar
The Trehab Center of Northeastern
Pennsylvania
7 Lake Avenue
Box 339
Montrose, PA 18801
(717) 278-3338 or 1 (800) 982-4045
FAX # -717) 278-1889
185 E:mira Street
P.O. Sax 218
Troy, PA 16947
(717) 297-2101
German Street
P.O- Sox 389
Oushore, PA 18614
(717) 928-9668
Acorn Housing Corporation
846 North Eroad Street
Fhiiade!priia. PA 19130
(215) 765-1221
FAX # (215) 765-1427
AM Credit Counseling Institute
144 East Dekaib Pike, Suite 100
King of Prussia. PA 19406
(610) 2254-9922
Sucks Ccunry Housing Grcuo, Inc.
140 East Richardson Avenue
Langhorne. PA 19047
(216) 7517310
FAX # (215) 750-d318
Hiscanic Association of Ccntrccprs
8 Enterprises
2921-27 North 5th Street
Philadelphia. Pa 19133
(215) 426-8026
FAX # (215) 426-3027
602Y22 Chruch Street
P.O. Box 97
Homesdale, FA 18431
(717) 258-4967
103 Warren Street
P.O. Box 709
Tunkhanncck, PA 18667
(717) 836-0840
BUCKS COUNTY
Consumer Credit Counseling_ Service
or Delaware Valley
1211 Chestnut Street. Suite .100
Phiiade!onia. PA 19107
(2 i5j So -666
FAX # (215) 864-2666
Consumer Credit Counseling_ Service
of Lehich Valley
3671 Crescenr Court
East Whitehall, PA 18062
(610) 821-401', or 1 (800) 220-2733
(717) and (814) ONLY
FAX # (215) 821-0137
F:1D0C TrT -FUgL. CT0n=p C,,9i Nor
BUTLER COUNTY
Action Housing Inc.
Number Two Gateway Center
9th Floor
Pittsburgh, PA 15272
(412) 391-1956
Consumer Credit Counseling Service
of Wester Pennsylvania, Inc.
YMCA Building
339 North Washington Street
Butler, PA 16001
Bedford-Fulton Housing Services
R.D. 1, BOX 384
Everett. PA 15537
(814) 623-9129
FAX m (814) 623-7187
Consumer Credit Counseling Service
of Western Pennsylvania. Inc.
500-02 3rd Avenue
Post Office Box 278
Dunce nsviile, PA
(814) 696-3546
Indiana County Community Action
Program
827 Water Street, Box 187
Indiana, PA 15701
(412)465-2657
FAX 1 (412) 465-5118
Housing Opportunities, Inc.
133 Seventh Street
McKeesport, PA 15132
(412) 664-1580
FAX T (412) 664-0873
Mon-Valley Unemployed Committee
120 E. 9th Avenue
Homestead, PA 15120
(412) 462-9962
CAM13RIA COUNTY
Keystone Economic Oeve!oement
Corporation
1954 Mary Grace Lane
Johnstown, PA 1,5901
(814) 5C5?556
FAX m (814) 539-1688
Tableland Services Inc.
131 North Center Avenue
Somerset PA 15501
(814) 445-9628
FAX ,: (814) 443-3690
CAMERON COUNTY
Norther IerCommunity Action
Corp.
135 W. Fourth Street
Emporium, PA 15834
(814) 485-1161
FAX ;(814)486-3370
Consumer Credit Counseling Se,
6i Westem Pennsylvania. Inc.
500-02 3rd Avenue
Post Office Box 278
Ouncansville, PA
(814) 696-3546
MOC=r-cn ucroncLownenixor
CARBON COUNTY
Economic Opportunity Cabinet Consumer Credit Counseling Service
of Schuylkill County of Lehigh Valley
118 Norweigian Street 3671 Crescent Court
Pottsville, PA 17901 East Whitehall, PA 18052
(717) 622-1995 (610) 821-4011 or 1 (800) 220-2733
FAX -1 (717) 622-0429 (717) and (814) ONLY
FAX -1 (215) 821-0137
Consumer Credit Counselino Service Commission an Economics Opportunity
of Northeastern Pennsylvania of Luzeme County
Human Services building 211-213 South Main Street
541 Wyamina Avenue Wilkes-Barre, AP 18701
Eox 168 (717) 825-051Oar 1 (800) 822-0359
Scanton, PA 18501 FAX-1(717) 829-;6666
(717) 342-1072 or 1 (800) 922-9537 Cail before faxing
FAX -1 (717) 342-3040 (717) 836090 7unkhanncc!c
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or 1 (800) 922-9557
FAX -1 (717) 821-1785
CENTRE COUNTY
Consumer Credit Caunselino Service Lycamina-Clintan Counties
of Western Pennsylvania Inc. Commission For Community
500-02 3rd Avenue Action (S cP)
Past Office Eox 278 2138 Lincoln Street
Duncansviile. PA P.O. Sax 1228
(814) 696-3546 Williamsport, PA 177 03
(r 17) 326-0587
FAX # (717) 322-2197
CHESTER COUNTY
Acorn Housing Corporation La Cas Del Pueblo
846 North Eroad Street 815 W. Ealtimore Pike
Philadelphia. PA 19130 Kernel Square, PA 19348
(215) 765-1221 (610) 44'3751
FAX -1 (215) 765-1427 FAX (610) 444-3178
AM Credit Counseling Institute Media Fellowship house
144 Esst Dekalb Pike. Suite 100 302 S. Jackson street
Ming of Prussia. PA 19406 Media, PA 19063
(6 i0) 354-99Z (610) 565-0846
F:`no==L• MUCFOREG' 65\ = NGT
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-78666
FAX : (610) 376.6575
Consumer Credit Counseling Service
of Delaware Valley
1211 Chestnut street, Suite 400
Philadelphia, PA 19107
(215) 563-5665
FAX # (215) 864-2666
Hispanic Asscciadan of ContraCars
& Enterprises
2921-27 North 5th Street
Philadelphia, PA 19133
(215) 426-8025
FAX # (215) 4264027
Consumer Credit Counseiina Se vice
of Western Pennsvlvania. Inc.
YMCA Euildina
339 North Washinatcn Street
Euder, FA 16001
(412) 282-7812
Keystone Economic Development
Corporation
1954 Mary C-rce Lane
Johnstown, PA 15901
(814) 535-6556
FAX # (814) 539-1688
Indiana County Community Action
Proaram
827 Water Street Box 187
Indiana. PA 15701
(412) 465-2657
FAX # (412) 465-5118
Philadelphia Council for Community
Advancement
100 North 17th Street
Suite 600
Philadelphia, PA 19103
(215) 67-7803
FAX #(215)963-9941
Tabor Community Service, Inc.
439 E. King Street
Lancaster, PA 17602
(717) 397-5182 or 1 (800) 788-5062
(Homeowners only)
FAX # (717) 399-4127
CLARION COUNTY
CLEaRFiELD COUNTY
Consumer Credit Counselina Se vice
of Western Pennsylvania, Inc.
500-02 3rd Avenue
Post Office Box 278
Ouncansviile, PA
(814)696-3546
rmaoc=-C veuesane¢o?e.vil=
CUNTON COUNTY
Lycoming-Clinton Counties
Commission For Community
Action (STEP)
2138 Uncoln Street
P.O. Box 1328
Williamsport. PA 177703
(717) 326-0587
FAX : (<17) 322-2197
COLUMBIA COUNTY
Consumer Credit Counse!ino Service Commission an E-znamics Opportunity
of Northeastern Pennsylvania of Lu<eme County
Human Services Building 211-213 South Main Street
541 Wyoming Avenue Wilkes-8arre, PA 18701
Box 168 (717) 826-0510 or 1 (800) 822-0359
Scranton, PA 18501 FAX-, (717) 822-1665
(717) 342-1072 or 1 (800) 922-9537 Cal before faxina
FAX m (717) 342-3040 (717) 455-4994 Haze!tan
FAX T (717) ASE-5631
Call before faxing
(717) 830=090 Tunkhanncc!:
31 W. Market Street
Wickes-Barre, PA 18702
(717) 821-0837 or 1 (800) 927--_537
FAX : (717) 821-1785
CRAWFORD COUNTY
Backer T. Washinamn Carver Jann F. Kennedy Center, Inc.
1720 Holland Street 2021 Esst20th Street
Elie. PA 16503 Erie. PA 16510
(814) 45?-S744 (814) 8984400
FAX # (814) 453-5744 FAX # (814) 898-1243
Greater Erie Community Acton Shenanao Valley Urban Le=cue. Inc.
Committee 601 Indiana Avenue
18 West 9th Street Fsrre!I, PA 16121
Erie, PA 16501 (412) 981-5310
(814) 469-1581
FAX (814) 456-0161
CUMBERLAND COUNTY
Consumer Credit Counseling Service
of Western Pennsylvania, Inc.
2000 Unglestown Road
Harrisburg, PA 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Consumer Credit Counseling Service
of Western Pennsylvania. Inc.
2000 Unglestown Road
Harrisbrug, PA 17102
(717) 541-1757
A.ccm Housing Corporation
846 North Broad Street
Philadelphia. PA 19130
(215) 765-1221
FAX m (215) 765-1427
AM Credit Counseling Institute
144 East Dekalb Pike, Suite 100
fling of Prussia. PA 19406
(610) 34-9922
Consumer Credit Counseling_ Service
of Delaware Vallev
1211 Chestnut street. Suite 400
Philadelphia. PA 19107
(215)563-5665
FAX # (215) 864266666
Urban League of Metropolitan
Harrisburg
25 N. Front Street
Harrisburg, PA 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX 9 (717) 243x948
DAUPHIN COUNTY
Urban League of Metropolitan
Harrisburg
25 N. Front Street
Hamsbura, PA 1710.
(717) 2345925
FAX m (717) 232-985
OE? AWARE COUNT'
La Cas Del Pueblo
815 W. Baltimore Pike
Kennett Square. PA .°348
(610)444-3731
FAX # (610) 44a 3178
Media Fellowship house
302 S. Jackson s-.reet
Media, PA 19063
(610) 565-0846
Philadelphia Council for Community
Advancement
100 North 17th Street
Suite 600
Philadelphia, PA 19103
(215) 567-7803
FAX m (215) 96-3-9-04-1
rM0=-cvueucs6nea.0snCMs Cr
Hispanic Asacciatlon of Contractors
8 Eiterprises
2921-27 North 5th Street
Philadelphia, PA 19133
(215)426-8025
FAX -1(215)426-8027
Northern Tier Community Action
Corp.
135 W. Fourth Street
Emporium, PA 15834
(814)486-1161
FAX -1 (814) 486-3370
Soaker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 898-0400
FAX -1(814)453-5749
John F. Kennedy Center, Inc.
2024, Esst 20th Street
Erie, PA 16510
(814) 898-0400
FAX -1 (814) 8989-1243
Action Housina Inc.
Number 7wa Gateway Center
9th Fiaar
Ritsburah, PA 152-
(412) 391-1956
Communitv Action Southwest
22 'Nest Hiah Street
Wavnesbura, PA 15370
(Ali) 852-2893
EIJC COUNTY
Jahn F. Kennedy Center, Inc.
2021 Esst20th Street
Erie. PA 16510
(814) 698-0400
FAX-, (814) 898-12x3
ERIE COUNTY
Greater Erie Community Action
18 West 9th Street
Erie. PA 16501
(81 a) AS9=581
FAX -1 (814) ASS-0161
FAYE: t E COUNTY
Committee
Favette Ccunty Communitv Action
Aaencf, Inc.
137 North Beeson Avenue
Uniontown. PA 15401
(412) 437-0050 E-t 38 or
1 (800) d27-,NFO
FAX -1 (412) 437-4418
Tab!e!and Services Inc.
131 North Canter Avenue
Somerset. PA 15501
(814) A45-3628
FAX -1 (61A) 943-3690
F^DOCVT.C1ptl9LLC1FdpEGOSIACDINRr 10
Consumer Credit Counseling Service
of Western Pennsylvania, Inc.
1 North Gate Square
2 Garden Center Drive
Greensburg, PA 16601
Warren-Forrest Counties Economic
Opportunity Council
204 Liberty Street
Post Office Box 547
Warren, PA 16365
(814) 726-2400
FAX : (814) 723-0510
Financial Services Unlimited
117 West 3rd street
Waynesboro, PA 17268
(7177) 762-3285
YWCA of Carlisle
301 G Street
Carlisle. AP 17013
(717) 243-3818
FAX T (717) 245-3948
Bedford-Futon Housing Services
R.D. 1, Sax 384
Everett: PA 15=37
(814) 623-9129
FAX (814) 623-7187
Financial Services Unlimited
117 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Action Housing, Inc.
Number Two Gateway Center
9th Fcor
Pittsburgh, PA 157"
Mon-Valley Unemployed Committee
120 E 9th Avenue
Homestead, PA 15120
(412) 462-9962
FOREST COUNTY
FRANKLIN COUNTY
Consumer Credit Counse!!nc service
of Westem Pennsyivania, Inc.
912 South George Street
York, PA 17403
Americen Red Cross - Hanover Chacter
529 Ca, iisle Street
Hanover. PA 17321
(717)637-376'0
FAX m (717) 637-3294
FULTON COUNTY
Consumer Credit Ccunse!inc Service
of Western Pennsvivania. Inc.
912 South George Street
York, PA 17403
GREENE COUNTY
Community Action Southwestern
22 West High Street
Waynesburg, PA 15370
(412) 852-2893
FAX 2(412)627-7712
r:no¢u-rrnmucsanE¢osucyi,r6r 11
Man-Valley Unemployed Committee Consumer Credit Counseling Service
120 E. 4th Avenue of Western Pennsylvania, Inc.
Homestead, PA 15120 1 North Cate Square
(412) 462-9962 2 Garden Center Drive
Greensburg, PA 15601
HUNTINGDON COUNTY
Bedford-Fulton Housing Services Weatherization Office
R.D. 1, Box 364 917 Mifflin Street
Everett, PA 15x37 Huntingdon, PA 16662
(814) 623-?129 (814) 643-2243
FAX : (814) 623-7187
Consumer Credit Counselina Service Indiana County Community Action
of Western Pennsylvania, Inc. Proaram
500-02 3rd Avenue 827 Water Street. Eax 187
Post Office Eax 278 Indiana PA 15701
Duncansviile, PA (412) 465-2657
(814) 696-3546 FAX m (412) 465-5118
Consumer Credit Counseling Service Keystone Eccnomic Development
of West em Pennsylvania. Inc. Corporation
1 North Cate Souare 1954 Mary Gmca Lane
2 Garden Canter Drive JohnstaNn, PA 15501
Greensburg, PA 1-65011 (814) 535-6555
FAX m (814) 539-160'8
JEFFcRSON COUNTY
Jahn F. Kennedy Canter, Inc. Indiana Counrv Community Acdon
2021 Esst20th Street Prcaram
Erie. PA 16510 827 Water Street. Eox 187
(814) 898-0400 Indiana. PA 15701
FAX -1 (814) 898-1243 (412) 465-2657
FAX m (412) 465-5118
Consumer Credit Caunse!ina Service
Pr Western Pennsylvania. Inc.
YMCA Buiidina
339 North Washington Street
Eutler, PA 16001
(412) 282-7812
VMOCSlTT{,pgguCXCMCLOS CTINOT 12
JUANITA COUNTY
Consumer Credit Counseling Service Weatherization Office
of Westem Pennsylvania, Inc. 917 Mifflin Street
500-02 3rd Avenue Huntingdon, PA 16a52
Post Office Box 278 (814 643-2343
Duncansville, PA
(814) 696-3545
LACKAWANNA COUNTY
Consumer Credit Counseling Service Consumer Credit Counseling Service
of Northeastern Pennsylvania, Inc. of Northeastern Pennsylvania, Inc.
Human Services Building 31 W. Market Street
541 Wyoming Avenue Wilkes-Sarre, PA 18702
Box 168 (717) 821-0837 or (800) 922-9537
Saanton, PA 18501 FAX (717) 821-1785
(7177) 342-1072 or (800) 922-9537
FAX (717) 342-9040
LANCASTER COUNTY
La Casa Del Pueblo Consumer Credit Caunselino Service
815W. Baltimore Pike of Western Pennsvivania. Inc.
Kennert Square. PA 19348 912 South Gearae Street
(215) 444-3731 York, PA 17403
FAX(215)444-3178
Consumer Credit Counseling Service Tabor Community Services. Inc.
of Lehigh Valley 439 E. Kinc
Street
3671 Crescent Court _
Lancaster, PA 17602
East Whitehall, PA 18052 (717) 397-5182 or (600) 788-5062
(Homeowners only)
FAX (717) 399-4127
LAWRENCE COUNTY
Consumer Credit Counseling Service Shenaao Valley Urban League. Inc.
Of Wes' am Pennsylvania. Inc, 601 Indiana Avenue
1st Federal Plaza. Suite 406 Farrell. PA 161121
North MiII Street (412) 981-5310
New Caste, PA 16101
r?aoass;.cvveucsgneensucs?rar )?
LEBANON COUNTY
Economic Opportunity Cabinet Tabor Community Services, Inc.
of Schuylkiil County 439 E fling Street
118 Norweigian Street Lancaster, PA 17602
Pottsville, PA 17901 (717) 397-5182 or (800) 788-55062
(717) 622-1996 (Homeowners only)
FAX (717) 622-0429 FAX (717) 399-4127
LEHIGH COUNTY
Consumer Credit Counsefina_ Service Economic Opportunity Cabinet of
of Lehich Valley Schuylkill County
3671 Crescent Court Esst 118 Norweigien Street
Whitehall, PA 1805 Pottsville. PA 17901
(215) 821-4011 or (800) 720-2733 (717) 622-1995
(717) and (814) ONLY FAX (717) 672-0d29
FAX (215) 821-0137
LUZERNE COUNTY
Commission an Economics Opportunity Consumer Credit Caunseiina Service
Of Lu<eme Counrv of normesstern Pennsylvania
211 _1' South Main sueet Hunan Resources Euiidina
Wickes-Barre. PA 18701 541 Wyoming Avenue
(717) 826-0510 or (800) 822-035? Eox 16B
FAX (717) 829-1665 Sc smon, PA 18501
(cail before faxing) Scranton, PA 16501
(717) 455-49_94 Hazeftgn (717) 242-1072 or (800) 9%?-2537
FAX (717) 45E-5631 FAX (717) 242 8040
(call before faxing)
(717) 836-4090 Tunkhanncc:<
21 AN. Marker Street
Wilkes-bane. PA. 18702
(717) 621-0837 or (800) 9 =537
FAX (717) 821-1785
Economic Opportunity Cabinet of
Schuylkill County
1 18 Nprweiaian Street
Pottsville. P.417901
(717) 622-1995
FAX 9717) 622-0d29
Vnocwr.C g UCTC9 CLCMC91N9r 14
LYCOMING COUNTY
Consumer Credit Counseling Service Lycoming-Clinton Counties
of Northeastern Pennsylvania Commission for Community Action
Human Services Building (STEP)
541 Wyoming Avenue 2138 Uncoin Street
Box 168 P.O. Box 1328
Scranton, PA 18501 Williamsport, PA 177703
(717) 342-1072 or (800) 922-9537 (7177) 326-0587
FAX (717) 342-8040 FAX (717) 322-2197
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 922-9537
FAX (717) 821-1785
MCKEAN COUNTY
John F. Kennedy Center, Inc. Narthem Tier Community Ac:icn Carp.
2021 Esst 20th Street 135 W. Fourth Street
Erie, PA 16510 Emporium, PA 16834
(814) 898-0400 (814) 486-1161
FAX (814) 898-1243 FAX (814) 486-3370
MONTGOMERY COUNTY
Acom Housing Corporation Eudoet Caunsei!na Center
846 North Broad Street 247 North Firth Street
Philadelphia, PA 19130 Re=ading, PA 19801
(215) 765-1221 (215) 375-7866-
FAX (215) 765-1427 FAX (215) 376.6675
AM Credit Counseling Institute Cammunitv Action
144 Esst Deka!b Pike, Suite 100 Deve!ooment Ccmmissian
King of Prussia, PA 19406 113 Esst Main Street
(610) 354-9922 Norristown, PA 19401
(215) 277-6263
FAX (215) 277t-2123
Consumer Credit Counse!ino_ Service
of Delaware County
1211 Chestnut Street Suite 400 Media Fe!lowshio House
Philadelphia. PA 19107 202 S. Jackson Street
(215) 5663-Seas Media. PA 19063
Fax (215) 864-2666 (215) yes-0846
La Casa De! Pueblo Philadelphia Counse! for
815 W. Baltimore Pike Community Advancement
Kennett Square, PA 19348 100 North 17th Street Suite 600
(215) 444-3731 Philade!phia, PA 19103
FAX (215) 444-3178 (215) Sal=803
FAX (215) 983.0041
rroacur-Ci ML1c79rtra.03UC"fBar 15
MONTOUR COUNTY
Consumer Credit Counseling Service
of Northeastern Pennsylvania
Human Services Building
541 Wyoming Avenue
Box 168
Scranton, PA 18501
(717):342-1072 or (800) 922-9537
FAX (717) 3423040
Consumer Credit Counseling Service
of Northeastern Pennsylvania
Human Services Building
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 922-9537
FAX (717) 821-1785
NORTHAMPTON COUNTY
Consumer Credit Counselino_ Service
of Lehigh Vailev
3671 Crescent Court E2st
Whitehail. PA 18052
(215) 821-1011 or (800) 220-2733
(717) and (814) ONLY
FAX (215) 821-0137
Consumer Credit Counseling Service
of Northe_stem Pennsvivania
Human Services Suiidina_
541 Wvomina_ Avenue
Box 168
Scranton, PA 18501
(717) 342-1082 or (800) 922-9537
FAX (717) Z42-3040
NORTHUMBERLAND COUNTY
Consumer Credit Counsaiina Service
of Northeastern Fennsvivania
Human Services Euildina_
31 W. Market Street
Wilkes-Barre. FA 18702
(717) 821-0837 or (800) C22-0527
FAX (717) 821-1785
Eccncmic Ooparrunity Cabinet
ai Scnuvlkiil Caunrv
118 Norwegian street
Pottsville. PA 17901
(717) 622-1095
FAX (717) 82=-0429
rlmetirrrrueuasoneCLO. 9iNCr 16
PERRY COUNTY
Consumer Credit Counseling Service Weatherizatlon Office
of Western Pennsylvania Inc. 917 Mifflin Street
2000 Unglestown Road Huntingdon, PA 16652
Harrisburg, PA 17102 (814) 643-2343
(717) 541-1757
YMCA of Cariisle
Financial Services Unlimited 301 G. Street
117 West 3rd Street Carlisle, PA 17013
Waynesboro, PA 17268 (717)243-3818
(717) 762-3285 FAX (717) 243-3948
Urban League of
Metropolitan Harrisburg
25 n. Front Street
Harrisburg, PA 17101
(717) 234-5-325
FAX (717) 232-4985
PHILADELPHIA COUNTY
Acorn Housing Corporation Housina Assac!ation of Delaware Valley
846 north Hraad Street 1314 Chestnut Street. Room 900
Philadelphia. PA 19130 Philadelphia. PA 19107
(215) 76 1221 (215) 545.6010
FAX (215) 765-1427 FAX (215) 790-9132
AM Credit Caunse!fna Institute 658 North Warts Street
144 Esst Dekafb Pike. Suite 100 Phiiade!ohia. PA 19123
I(Ina of Prussia, PA i 9406 (215)9-
6) (610) 354-?922 FAX (215) 765-7614
Centro Pedro Claver Media Fe!lowshio House
3565 North 7th Street 302 S. Jack=on Street
Philadelphia. PA 19140 Media. PA 19063
(215) 227- i 111 (610) 565-0846
FAX (215) 227-7117
Philadelphia Council for
Consumer Credit Counseiina Service Community Advancement
of Delaware Valley 100 North 17th Street. Suite 600
1211 Chestnut Street. Suite 400 Phifade!ohia, P.4 19103
Philadelphia. PA 19107 (215-)5 67-7803
(215) 56s-5665 FAX (215) 9624-041
FAX (215) 864-26666
Urban Leaaue of Phiiadeiohia
Hispanic Association of Contractors 251-3 South 24th Street
& Enterprises Philade!ohia. PA 19103-5E29
2921-27 North 5th Street (215) 731-4100
Philadelphia. PA 19133 FAX (215) 731-4112
(215)426-8025
FAX (215) 426-8027
?=CW ST-C7usuar6NEC0A C.V1.Nar 17
PIKE COUNTY
Consumer Credit Counseling Service Consumer Credit Counseling Service
of Northeastern Pennsylvania of Northeastern Pennsylvania
Human Services Budding 31 W. Market Street
541 Wyoming Avenue Wilkes-Barre, PA 18702
Box 168 (717) 821-0837 or (800) 922-9537
Scranton, PA 18501 FAX (717) 821-1785
(717)342-1072 or(800)922-°537
FAX (717) 342-8040
POT7E? COUNTY
Northern Tier Community Action Corp.
135 W. Fourth Street
Emporium, PA 15834
(814) 486-1161
FAX (814) 486-3270
SCHUYLKILL COUNTY
Eudaet Counselina Canter Economic Conarrunity Cabiner
247 Ncr[h Firth Street or Schuvikiil County
Reading PA 1°601 118 Norwegian Street
(215) 375-7866 Portsviile. PA 17901
FAX (215) 376-6575 (717) 1995
FAX 9717) 6224429
Commission an Economic Opportunity
of Luzeme County
211 =13 South Main Street
Wilkes-Barre, PA 18701
(717) 826-0510 or (800) 822-0359
FAX (717) 829-1665
call before fxina
(717) 455_994 Hazeltan
FAX (717) 455 563 ,
call before faxing
(717) 835=090 Tunkhannock
SNYOE.4 COUNTY
Consumer Credit Counseling Service
of Westem Pennsylvania, Inc.
2000 Llnaiestawn Road
Harrisburg, PA 17102
(717) 541-1757
r:?m?rr<+rueuesaeea aMavIJ= 18
SOMERSET COUNTY
Bedford-Fultan Housing Services Keystone Economic Development Corp.
R.D. 1, Box 384 1954 Mary Grace Lane
Everett: PA 15537 Johnstown, PA 15901
(814) 623-9124 (814) 535-655-3
FAX (814) 623-7187 FAX (814) 539-1688
Consumer Credit Counseling Service Tableland Services. Inc.
of Western Pennsylvania, Inc. 131 North Center Avenue
1 North Gate Square Somerset. PA 15501
2 Garden Center Drive (814) 445-9628
Greensburg, PA 15-301 FAX (814) 443-3690
SULLIVAN COUNTY
Consumer Credit Counseling Service German Street
of Northeastern Pennsylvania P.O. Box 389
Human Services Buiidina Oushore, PA 18614
541 Wyoming Avenue (717) 928-9668
Box 168
Scranton, PA 18501
(717) 342-1072 or (800) 9-22-0-537 His Maiesty Fellowship CSurc:n
FAX (717) 342s3040 207 Penn Ave., P.O. Box 104
Athens. PA 18810 (Wed.-Fri.)
(717) 888-6024
31 W. Market Street
Wilkes-Bane, PA 18702
(717) 821-0837 or (800) 922-9637 17 Crafton Street
FAX (717) 821-1785 Welisboro, PA 16901
(71 t) 724-5252
The Trehab Center of
Northeastern Pennsylvania 602 Y: Church Street
7 Lake Avenue P.O. Box 97
Box 339 Homesdaie, PA 18431
Montrose. PA 18801 (717) 2581987
(717) 278-3338 or (800) 982=045
FAX (717) 278-1889
103 Warren Street
P.O. Box 709
185 Emir Street Tunkhannock. PA 18657
P.O. Box 218 (71 7) 836-6840
Troy, PA 16247
(717) 297-2101
F?aoaw-C4'Muc1oOEC=S3 C.91.Nw 19
Consumer Credit Caunseiina Service
of Nartheastem Pennsylvania
Human Services Building
541 Wyoming Avenue
Sax 168
Scranton, PA 18501
(7177) 242-1072 or (800)922-9537
FAX (717) 342-8040
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 92-1-S537
FAX (717) 821-1785
The Trehao Center of
Northeastern Pennsylvania
7 Lake Avenue
Box 339
Montrose. FA 18801
(71, 7) 275-3338 or (800) 9a2=045
FAX (717) 278-1889
SUSQUE:-IANNA COUNTY
185 Ernh Street
P.O. box 218
Troy, PA 16947
German Street
P.O. Box 389
Oushore, PA 18614
(717) 928-9688
His Maiesy Feilowshio Church
207 Penn Ave.
P.O. Sax 104
Athens, PA 18810 (Wed.-Fr.)
(717) 888-6024
17 Caftan Stree*-
WelLbaro. PA 16901
(717) 724-525--
602 Y- Church Street
F.O. Box 97
Hamesdale, PA. 16421
(717)826.866"40
103 Warren Street
P.O. Box 709
Tunkhannac:t, P,4 18667
r'DOC:wr? ."M iCi PXCLa3V1 . I1 or 20
Consumer Credit Counseling Service
of Northeastern Pennsylvania
Human Services Building
541 Wyoming Avenue
Box 168
Scranton, PA 18501
(717) 342-1072 ar (800)922-9537
FAX (717) 342-8040
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 922-9537
FAX (717) 821-1785
Tne Trehab Center of
Northeastern Pennsylvania
7 Lake Avenue
Box 339
Montrose. PA 18801
(717) 272-3338 or (800) 982-4045
FAX (717) 278-1889
TIOGA COUNTY
185 Emira Street
P.O. box 218
Troy, PA 16947
German Stree*-
P.O. Box 389
Oushore, PA 18614
(717) 928-9668
His Majesty Feflowshio Church
207 Penn Ave.
P.O. Box 104
Athens, PA 18810 (Wed: Fri.)
(717) 888-6024
17 Craftan Street
Wellsbaro. PA 16901
(717)724-5252
602% Church Street
P.O. Box 97
Homesdale. PA 18431
(717) 836-6840
103 Warren Street
P.O. Box 709
Tunkhannock. PA 186=7
Lycominc-C;inton Counties
Commission for Community Action
(STE=) .
2138 Lncain Street
P.O. Box 1328
Williamsport. PA 17703
(717) 322-2197
UNION COUNTY
Consumer Credit Caunseiint Service
of Western Pennsylvania, Inc.
500-02 3rd Avenue
Past Office box 278
Ouncansviile, PA
(814) 696-3546
F.'n0ClICp(1CSORE2031AG91NOT 21
VENANGO COUNTY
Greater Erie Community Warren-Forrest Counties Economic
Action Committee Opportunity Council
18 West 9th Street 1209 Pennsylvania Avenue, West P.O. Box 547
Erie, PA 16501 Warren, PA 16265
(814) 4E9_1581 (814) 726-2400
FAX (814) 456-0161 FAX (814) 722-0510
Greater Erie Community
Action Committee
18 Wes: 9th Street
Ere, PA 16501
(814) 45?-1581
FAX 9814) 456-0161
WASHINGTON COUNTY
Action Housing, Inc, Hcusina Opportunities. Inc.
Number Two Gateway Center 122 Seventh Street
91h Fiaor McKeescorr PA 15132
Pittsburgh, PA !52_;) (412)65 4- 1 S90
(412) 391-1956 FAX (412) 654-0873
Ccmmunity Ac---an Southwest Man-Valley Unetnploved Committee
22 Wes: Hiah Street 120 9th Avenue
Wavnesttura, PA 15370 Homestead. PA 15120
(412) S°2--2895 (4121462-9962
Consumer Credit Counseling Service
or Western Pennsylvania, Inc.
1 North C-ate Square
2.Garden Center Drive
Greensburg, PA 15601
r:m¢urramuaroneaasuc??ror 2?
Consumer Credit Counseling Service
of Northeastem Pennsylvania
Human Services Building
541 Wyoming Avenue
Box 168
Stanton, PA 18501
(717) 342-1072 or(8o0)922-9537
FAX (717) 342-8040
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 922-9537
FAX (717) 821-1785
The Trehab Center of
Northeastern Pennsylvania
7 Lake Avenue
Box 339
Montrose. PA 18801
(717) 278-3338 or (800) 982-4045
FAX (717) 2718-1889
WAYNE COUNTY
185 Emit Street
P.O. box 218
Troy, PA 16947
(717) 297-2101
German Street
P.O. Box 389
Dushore, PA 18614
(717)928-9668
His Majesty Fellowship Church
207 Penn Ave.
P.O. Box 104
Athens. PA 18810 (Wed.-Fri.)
(717)888-6024
17 Crafton Street
Wellsbora, PA 16901
(717) 724-5252
602 Y Church Street
P.O. Box 97
Homesdale, PA 18431
(717) 8364i840
103 Warren Street
P.O. Box 709
Tunkhannock, PA 18657
(717)836-6840
r:UxlrryvueuwoUe -a (MtAar 23
PPiZE'Iu `iLOW-aff_1:I•yeloPIiI\I
Action Housing, Inc. Indiana County Community
Number Two Gateway Center Action Program
9th Fgor 827 Water Street, Box 187
Pittsburgh, PA 15222 Indiana, PA 1501
(412) 391-1956 (412) 465-26577
FAX (412) 465-5118
Community Action Southwest
22 West High Street Keystone Economic Development Corp.
Waynesburg, PA 15370 1454 Mary Grace Lane
(412) 852-2893 Johnstown, PA 16:01
(814) 535-6556
FAX (814) 639-1688
Consumer Credit Counseling Service
of Western Pennsylvania, Inc.
1 North Gate Square Man-Vailey Unemployed Committee
2 Carden Center Drive 120 E 9th Avenue
Greensburg, PA 1 401 Homestead, PA 15120
(412) 462-9962
Housing Opportunities, Inc.
133 Seventy Street Tableland Services. Inc.
Mc.Keesporr. PA 15132 131 North Canter Avenue
(412) 664-15-G0 Somerset P.4 IS901
FAX (412) 664-0873 (814) ,45-9628
FAX (814) d43-1.6?O
F.^agC:IST?`,Wp(.{ciVMaASVLL?INQT 24
Consumer Credit Counseling Service
of Northeastern Pennsylvania
Human Services Building
541 Wyoming Avenue
Box 168
Scranton, PA 18501
(717) 342-1072 or (800)922-9537
FAX (717) 342-8040
31 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or (800) 922-9537
FAX (7177) 821-1785
The Trehab Center of
Northeastern Pennsylvania
7 Lake Avenue
Box 339
Montrose. PA 18801
(717) 278-3338 or (800) 982-4045
FAX (7177) 278-1889
Commission an Economics Opportunity
of Luzeme Countv -
211-213 South Main Street
Wilkes-Barre, PA 18701
(717) 826-0510 or (800) 822-0359
FAX (717) 829-16665
call before faxino
(717) 455-4994 Hazeiton
FAX (717) 455-55631
=II before faxino
(717) 836-4090 Tunkhannock
WYOMING COUNTY
185 Emira Street
P.O. box 218
Troy, PA 16947
(717) 821-1785
German Street
P.O. Box 389
Dushore, PA 18614
(717) 928-9668
His Majesty Fellowship Church
207 Penn Ave.
P.O. Box 104
Athens, PA 18610 (Wed.-Fri.)
(717) 888-6024
17 Crafton Street
Wellsbora, PA 16901
(717) 724-5252
602 Y: Church Street
P.O. Box 97
Homesdaie, PA 18431
(717) 836-6840
103 Warren Street
P.O. Box 709
Tunkhannock, PA 18657
(717) 836-6840
25
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) M7-3768
FAX (717) 637-3294
Consumer Credit Counseling Service
of Western Pennsylvania, Inc.
2600 Unglestown Road
Harrisburg, PA 17102
Q17) 541-1757
YORK COUi Y
Housing Caunal of York
116 North George Street
York, PA 17401
Q17) 854-1541
FAX (717) 845-7934
26
MAY-17-1999 1041 CAPLAN 8 LUBER
P.08
VERIFICATION
11W1aittBiantiBonfhiFFw:ia elrgy certify that I am an agent for Plaintiff and am
authorized to make this verification on its behalf. I verify that the facts and statements set forth in
the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge,
information and belief. This Verification is made subject to the penalties of Ig Pa C.S. § 4904
relating to unworn falsification to authorities.
}x"11 6S
P7t1e-c Litig a ?tio I .:nS?pe?iCA "1
Date:
F-WMS\171AI34DNETLEAOINa,CMFLAOC
TOTAL P.08
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03558 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF NEW YORK THE ET AL
VS.
BRENIZER CHESTER L
KATHY J. CLARKE Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon BRENIZER CHESTER L the
defendant, at 2028:00 HOURS, on the 14th day of June
1999 at 1819 HEISHMAN GARDENS DRIVE
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to CHESTER L. BRENIZER
a true and attested copy of the COMPLAINT - MORT FORE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
18.00 So answers:
/y
Service 3.10
Affidavit .00
Surcharge 8.00 mas Kline, eri
X1 PLAN UBER, LLP
06/15 1999
by e
n
-
,prizz
Sworn and subscribed o before me
this /J day of
19 9_ A.D.
Axel A. Shield, 11, Esquire
Attorney I.D. No. 17440
Stephen M. Madik, Esquire
Attorney I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Fax: (610) 640-9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
PLAINTIFF,
V.
CHESTER L. BRENIZER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO. 99-3558 CIVIL
CIVIL ACTION
DEFENDANT.
MORTGAGE FORECLOSURE
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter judgment in favor of Plaintiff, The Bank of New York as Co-Trustee under
the Pooling and Servicing Agreement dated as of July 31, 1998, Series 1998-13, and against
Defendant, Chester L. Brenizer, for failure to respond to the Complaint in Mortgage Foreclosure
within twenty (20) days of service thereof. On July 12, 1999, Plaintiff provided Defendant with
10 days Notice of Default pursuant to Rule 237.1 and in accordance with Pa.Civ.R.P. A copy of
said Notice is attached hereto. Please assess damages as prayed for in the Complaint, in the sum
of $40,452.27 determined as follows:
F OOCS\I313\134 aREWLEADINGUFLT.PAC
Principal of Mortgage debt due and unpaid ........................... $35,969.67
Interest due and owing as of August 24, 1999
at 10.25%, $10.24 per diem ........................................ 3,031.30
Late Charges of $16.13 per month
assessed on the 16th day payment is past due ............................ 161.30
Corporate Advance ............................................... 100.00
Current NSF Charges ............................................... 30.00
Defen-ed NSF Charges .............................................. 30.00
Attorneys' fees ................................................... 800.00
Title Report ..................................................... 330.00
TOTAL ..................................................... $40.452.27
Plus interest and costs of suit.
CAPLAN & LUBER, LLP
By: Qj ?CL 0
Axel A. hield, II, Esquire
Date: - 5 e7
ENTRY OF JUDGMENT AND
ASSESSMENT OF DAMAGES
AND NOW, this ay of k;*I*t b 1999, judgment is hereby entered
in favor of Plaintiff, The Bank of New York as Co-Trustee under the Pooling and Servicing
Agreement dated as of July 31, 1998, Series 1998-B, and against Defendant, Chester L. Brenizer;
damages are assessed in the sum of $40,452.27 aforesaid, plus interest and costs of suit.
Prot ono"
Axel A. Shield, 11, Esquire
Attorney I.D. No. 17440
Stephen M. Hladik, Esquire
Attorney I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Fax: (610)640.9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF,
V.
CHESTER L. BRENIZER,
DEFENDANT.
DOCKET NO. 99-3558 CIVIL
CIVIL ACTION
MORTGAGE FORECLOSURE
CERTIFICATION OF LAST KNOWN ADDRESS
I, Axel A. Shield, II, Esquire, hereby certify that the last known address of Chester L.
Brenizer is, 1819 Heishman Gardens Drive, Carlisle, Pennsylvania 17013, and the last known
address of Plaintiff, The Bank of New York as Co-Trustee under the Pooling and Servicing
Agreement dated as of July 31, 1998, Series 1998-B, c/o The Money Store, 4111 South
Darlington, Suite 800, Tulsa, Oklahoma 74135.
CAPLAN & LUBER, LLP
By:
p f /? Axel A. Shi Id, II, Esquire
Date: o I? `1 v,
Axel A. Shield, R, Esquire
Attorney I.D. No. 17440
Stephen M. Madik, Esquire
Attorney I.D. No. 66287
CAPLAN & LUBER,LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Fax: (610) 640-9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF,
V.
CHESTER L. BRENIZER,
DEFENDANT.
DOCKET NO. 99-3558 CIVIL
CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
To: Chester L. Brenizer
1819 Heishman Gardens Drive
Carlisle, PA 17013
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
judgment by default has been entered against you in the above proceeding.
Prothonotary
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CONTACT
Axel A. Shield, II, Esquire
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Axel A. Shield, U. Esquire
I.D. No. 17440
Stepben M. Madik, Esquire
I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Fax: (610) 640-9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
PLAINTIFF,
V.
CHESTER L. BRENIZER,
DEFENDANT.
TO: Chester L. Brenizer
1819 Heishman Gardens Drive
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 99-3558
CIVIL ACTION
MORTGAGE FORECLOSURE
Date: July 12, 1999
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN 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:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Zl?
Axe ield, II, Esquire
Axel A. Shield. 11, Esquire
I.D. No. 17440
Stephen M. Hladik, Nquire
I.D. No. 66287
CAPLAN dt LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610)640.1200
Fax: (610) 640.9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
PLAINTIFF,
V.
CHESTER L. BRENIZER,
DEFENDANT.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 99-3558
CIVIL ACTION
MORTGAGE FORECLOSURE
CERTIFICATION OF MAILING PURSUANT TO RULE 237.1
I, Axel A. Shield, II, Esquire, attorney for Plaintiff, hereby certify that on the nday of
July, 1999, 1 served a true and correct copy of the 237.1 Notice upon the following Defendant via
first class mail, postage pre-paid.
Chester L. Brenizer
1819 Heishman Gardens Drive
Carlisle, PA 17013
C LAN & LUB , LLP
O
Axel hield, II, Esquire
JUL-27-1999 10:00 CAPLAN 8 LUBER 610 640 9865 P.02/02
Axel A.9bield ZEsquim
I.D. No. 17440
Sb*bm AoE Mdik EvcjWm
1.D. No. 66287
CAPL.AN & L1BEIt, LLP
40 Darby Rod
Paoli, PA 19301
640.9865
THE BANK OF NEW YORK AS CO.
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31,1998, SERIES 1998-B,
PLAINTIFF,
V.
CHESTERL. BRENIZER,
' IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 99-3558
CIVIL ACT10N
MORTGAGE FORECLOSURE
DEFENDANT.
STATE OF OKLAHOMA
COUNTY OF ?<C0
Mandy O'Brien, being duly awom according to law, deposes and says that she is a
Litigation SPeaialist for PWntW that she is authorized to snake this affidavit on behalf of RlainK
and that Defendam, Chester L. Brenizcr, is not in the military service of the United States, nor
any State or Territory thereof or its allies as deSned in the Soldiers' and Sailors' Civil Relief Act of
1940 and the amendments thereto.
Date:
Swom to
before nw
MY COMM&ION EXPIRES JANUARY 26, 2002
TOTAL P.02
Axel A. Shield, 11, Esquire
Attorney I.D. No. 17440
Stephen M. Hisdik, Esquire
Attorney I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610)640.1200
Fax: (610) 640-9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
PLAINTIFF,
V.
CHESTER L. BRENI%ER,
DEFENDANT.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO. 99-3558 CIVIL
CIVIL ACTION
MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE +
1, Axel A. Shield, 11, Esquire, hereby certify that on the-e1 Sda Y of September, 1999, I
served a true and correct copy of foregoing Default Judgment by first class mail, postage prepaid,
to the following party:
Chester L. Brenizer
1819 Heishman Gardens Drive
Carlisle, PA 17013
F U=MISI N34 BREWLEADINGWLTYAC
d D
AeIA hieid, II, Esquire
1
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS. Term
CHESTER L. BRENIZER No. 99-3558
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR
THE PURPOSE OF COLLECTING THE DEBT.
Enter Judgment in favor of Plaintiff and against CHESTER L. BRENIZER
by default for want of an Answer.
(X) Assess damages as follows:
Debt $ 44.135 35
Interest 11/ 1/98 to 8/31/00
Total $
(Assessment of Damages attached)
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS
ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM
THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be entered and
to his attorney of record, if any, after the default opn?urred and at least
ten days prior to the date of the filing of this prae A copy of the
notice is attached. R.C.P. 237.1 1 1 nn
Attorney fjoryPlaint
I.D. #1613112'
AND NOW Ut a1?J-p Z/ Judgment is
entered in fa or of THE BANK OF NEW YORK AS CO-TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF JULY, 31 1998 SERIES 1998-B, and
against CHESTER L. BRENIZER by default for want of an Answer and damages
assessed in the sum of FORTY FOUR THOUSAND ONE HUNDRED THIRTY FIVE DOLLARS
AND 35 CENTS ($44,135.35), as per the above certification.
Prothonotary
:•,
°
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-?
_
;;.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING
SERVICING AGREEMENT DATED AS
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite
Tulsa, OK 74135
Plaintiff
VS.
: IN THE COURT OF COMMON PLEAS
AND :
OF OF CUMBERLAND COUNTY
800
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-3558
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF
JULY, 31 1996 SERIES 1998-B, and against CHESTER L. BRENIZER for
failure to file an Answer in the above action within (20) days
(or sixty (60) days if defendant is the United States of America)
from the date of service of the Complaint in the sum of FORTY
FOUR THOUSAND ONE HUNDRED THIRTY FIVE D?JrDN/T`CENTS
($44,135.35). I'
Attornlef for Plaifitiff
I hereby certify that the above names are correct and that
the precise residence address of the judgment creditor is c/o The
Money Store, 4111 South Darlington, Suite 800, Tulsa, OK 74135
and that the name(s) and last known address(es) of the
Defendant (s) is/are CHESTER L. BRENIZE1 X18 ?/iI i an Gardens
Drive, Carlisle, PA 17013; ; II
BY: Jd,%eph A. Gcbydbeck, Jr.
Attornev for Plaintiff
?-? ? -
- ?-
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ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal balance $ 35,969.67
Interest from 11/ 1/98 through 8/31/00
Attorney's Fee at 5% of principal balance
Late Charges
Costs of Suit and Title Search
Escrow Balance Deficit
6,850.82
800.00
354.86
$ 43,975.35
160.00
$ ?44,135.35
UULUb?; -MCCAFF RFY & McKEE
BY: Jo ph A. ldbeck, Jr.
Attorn for Plaintiff
AND NOW, this (Y ?? day of ?Pwl?l^ 2000
damages are assessed as above.
Pre Prothy J?(e
v
:.?
??:
;.?:
-
.., ' :'
;
?_ ;;
__ ?,_
-
?,
-,
_:, :?
t---------------------------------------------------------Time OnLine: 0: 0:24+
IOFC-YR-DOCKET NO. (DATE FILED I CHAPTER I TYPE OF CASE IBUSINESS? No I I
I 1-99-03409 RJW 1 08/06/99 I 13 1 Voluntary (ASSETS ? Yes IPAID? Yes I
i------------------------------------------------------------------------------I
INAME AND ADDRESS OF DEBTOR INAME AND ADDRESS OF JOINT DEBTOR I
IBRENIZER, CHESTER L I I
11819 HEISHMAN GARDEN I
I CARLISLE, PA 17013 I I
I--------------------------------------+---
IDEBTOR SSAN OR TAX ID IJOINT DEBTOR SSAN OR TAX ID I
1 192-34-7118 1 I
1--------------------------------------+---------------------------------------I
IATTORNEY FOR DEBTOR 717-240-0296 ITRUSTEE ASSIGNED 717-566-6097 1
I JAMES K. JONES 1 CHARLES J. DEHART III
17 IRVINE ROW I P.O. BOX 410
! CARLISLE, PA 170133019 ( HUMMELSTOWN, PA 17036 t
I--------------------------------------+---------------------------------------I
1341 MEETING: 09/23/99 @ 12:00 P.M. 50 ICONF HEARING: N/A
I ------------------------------------------------------------------------------I
ICLAIMS DEADLINE: 12/22/99 (ORIGINALLY FILED: 08/06/99 IDISMISSED: 06/16/00 1
(COMPLAINTS DATE: Not Set 10RIGINAL CHAPTER: 13 (DATE CLOSED: 06/16/00 1
+----------------------------------------------------------
(A)dversaries, (D)ocket, (O)thers (aka/dba), (M)tgs/hrgs, a(R)chive info
(P)rint, (C)laims, Mailing (L) ist, (N)ext case, Pre(V)ious case, (Q)uit
99-03909 BRENIZER, CHESTER L
Entry Date No. Entry
+-----------------------------------------
Time OnLine: 0: 0:39
-------------+
Schedules I
[BMM]
I
meeting 1
108/06/991 1 IVOLUNTARY PETITION under Chapter 13, Matrix, all
I I I & Statements, Plan and Summary [EOD 08/09/991
108/30/991 2 ICERTIFICATE of Mailing of Notice of 341 Meeting.
I [ I Objections to the plan are due 15 days after
I I I held. [EOD 08/30/99] [CA]
109/27/991 3 1341 meeting held. [EOD 09/27/99] [CA]
110/12/991 4 IORDER Confirming Plan [EOD 10/12/99] [BW]
111/12/991 5 1ENTRY OF APPEARANCE of Martin S. Weisberg,
I I I & Luber, LLP, on behalf of The Bank of
I 1 1 11/12/99] [BW]
I
I
I
Esq., of Caplan I
New York [EOD 1
I
101/25/001 6 INOTICE to parties of filing of claim by Debtor on behalf of ]
I I I THE MONEY STORE in the amount of $40,452.27 [EOD I
I I 1 01/25/00] [DS]
102/14/001 7 ISTIPULATION by Parties re: Trustee's Motion to Dismiss [EOD I
I 1 1 02/14/00] [BW]
+-----------------------------------------------
(N)ext 1, pre(V)ious 1, pg(U)p, pg(D)own
(T)op, (B)ottom, (Q)uit
Time OnLine: 0: 1: 4
99-03409 BRENIZER, CHESTER L
Date No. Entry
+------------------------------------------------------------------------------+
102/14/001 7 (APPROVED by the court. [EOD 02/14/001 (BW]
103/16/001 6 1MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR [EOD I
I 1 1 03/16/001 [SP] [Disposed] 1
103/16/001 9 (ORDER to pay trustee. Re: Item # 8. [EOD 03/16/00] [SP] 1
105/10/001 10 IMOTION for relief from stay filed by THE BANK OF NEW YORK 1
I I I as co-trustee under the pooling & servs agrmt dated July I
I I 1 31, 199 series 1998-B (fee pd. $75.00, rec. #558359-CG) I
I I I [EOD 05/10/001 [BW] [
I I ICERTIFICATE OF NON-CONCURRENCE [EOD 05/10/001 [BW] 1
105/10/001 11 (ORDER that answers are due on 05/30/00 by Re: Item # 10. I
I I I [EOD 05/10/001 [BW] [Rescheduled]
105/22/001 12 ICERTIFICATE OF DEFAULT Re: Item # 7. (EOD 05/22/001 (BW] I
105/25/001 13 (NOTICE to creditors that answers /objections are due on I
I 1 1 06/14/00 by Re: Item # 12. [EOD 05/25/00] [BW]
+---------------- --------------------------------------------------------------+
(N)ext 1, pre(V)ious 1, pg(U)p, pg(D)own
(T)op, (B)ottom, (Q)uit
Time OnLine: 0: 1:19
99-03909 BRENIZER, CHESTER L
Date No. Entry ---------------------------
-------------------------------- ?
--due to non-servie per I
Item N 10. [EOD 06/01/001
( 19 (ORDER that answers are (Reissued
06/01/001 Movant) due on 06/21/00 by
I [Sel
[This entry cancels the previous due date. to at Re: I ;
[ Item A 11. [EOD 06/01/001 [Spl I
item # (06/12 49 {- 15 (CERTIFICATE of serviceuRe: Trusteels CerOtificate/oflDefault
6 (ORDER dismissing case [EOD 06/16/001 [Bwl
(06/2 of dismissal of case Re: Item N-16-------+
0/001 17 (NOTICE to creditors
[EOD 06/20/001 [Bwl ------
-------------------------------------
(N)ext 1, pre(v)ious 1, pg(U)p, pg(D)own
(T) op, (B) ottom, (Q)uit
k;
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant, CHESTER L. BRENIZER, is
about unknown years of age, that Defendant's last known residence
is 1819 Heishman Gardens Drive, Carlisle, PA 17013 and is engaged
in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions
of the Soldiers' and Sailors' Civil Relief Action of Congress of
1940 and its Amendments.
Date:
81023558 - BRENIZER,CHESTER L.
e*i
Axel A. Shield, H. Esquire
I.D. No. 17440
Stephen M. Hladik, Esquire
I.D. No. 66287
CAPLAN & LUBER, LLP
40 Darby Road
Paoli, PA 19301
(610) 640-1200
Fax: (610) 640-9865
THE BANK OF NEW YORK AS CO-
TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY 31, 1998, SERIES 1998-B,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 99-3558
PLAINTIFF,
V.
CHESTER L. BRENIZER,
DEFENDANT.
TO: Chester L.Brenizer
1819 Heishman Gardens Drive
Carlisle, PA 17013
CIVIL ACTION
MORTGAGE FORECLOSURE
Date: July 12, 1999
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN 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:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166 Axe field, 6IUIjEsquire
Olt)
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND
CIVIL ACTION
:ACTION OF MORTGAGE
COUNTY
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant (s)
- LAW
FORECLOSURE
Term
No. 99-3558
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due $ 44.135 35
Interest from 11/ 1/98 to
8/31/00 at C
(Costs to be added) $
Joseph Goldb Jr.
Attorn for P1 intiff
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ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in
North Middleton Township, Cumberland County, Pennsylvania, bounded and described in
accordance with survey of Carl D. Bert, Registered Surveyor, dated November 4, 1983, as follows:
BEGINNING at a point on the North side of Heishman Gardens Drive, Township Road T-716 said
point being the dividing line between Lot Nos. 1819 and 1819A on the hereinafter mentioned plan
of lots; thence by said dividing line and through the center of a party wall dividing the dwelling
house herein conveyed from the dwelling house known as 1819A Heishman Gardens Drive, North
37" 55' 22" East 119.26 feet to a point in line of land now or formerly of William M. Croft; thence
by land now or formerly of William M. Croft, North 83" 28' 40" West 57.63 feet to a point at the
Northeast corner of Lot No. 1817A on the hereinafter mentioned plan of lots; thence by said Lot
No. 1817A South 32" 02' 47" West 107.51 feet to a point on the Northern side of Heishman
Gardens Drive; thence by Heishman Gardens Drive South 76" 57' 58" East 42.09 feet to a point, the
place of beginning.
BEING Lot No. 1819 on the Plan of Lots known as Heishman Gardens as recorded in the Office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 19, page 43.
HAVING thereon erected a dwelling being the western half of a duplex and being known as 1819
Heishman Gardens Drive.
Tax Parcel /# 29-17-1585-235
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 1819 Heishman Gardens Drive, Carlisle, PA 17013
SOLD as the property of CHESTER L. BRENIZER
TAX PARCEL 029-17-1585-235
r.?
GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND
CIVIL ACTION
:ACTION OF MORTGAGE
COUNTY
- LAW
FORECLOSURE
Term
No. 99-3558
AFFIDAVIT PURSUANT TO RULE 3129
THE BANK OF NEW YORK AS CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF JULY, 31 1998 SERIES 1998-B,
Plaintiff in the above action, by its attorney, Joseph A.
Goldbeck, Jr., 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:
1819 Heishman Gardens Drive, Carlisle, PA 17013
1. Name and address of Owner(s) or Reputed Owner(s) :
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
2. Name and address of Defendant (s) in the judgment:
CHESTER L. BRENIZER
1819 Iieishman Gardens Drive
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
THE PACESETTER CORPORATION
4787 Whitepine Road
Chesterfield Business Center
Richmond, VA 23237
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
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. /1'1%
DATED: August 30, 2000
GOLDBEC bCAFFE ? McKEEVER
Jr., Esq.
BY: Joseph V. Gold be Ftiff
Attorney for Pla
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
TO:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-3558
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
Your house at 1819 Heishman Gardens Drive, Carlisle, PA
17013 is scheduled to be sold at Sheriff's Sale on December 6,
2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing
Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the
court judgment of $44,135.35 obtained by THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to THE BANK OF NEW
YORK AS CO-TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT
DATED AS OF JULY, 31 1998 SERIES 1998-B, the back payments, late
l
charges, costs and reasonable attorney's fees due. To find out
how much you must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
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 below on how to obtain an attorney).
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid price
by calling the Sheriff of 4111 South Darlington, Suite 800 County
at (717) 240-6390.
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid
for your house. A schedule of distribution of the money bid for
your house will be filed by the Sheriff thirty (30) days from the
date of the Sheriff's Sale. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990 9108
Legal Services Inc.
9 Irvine Row, Carlisle, PA 10013
(917) 243-9900
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GOLDBECK MCCAFFERTY & MCKEEVER
Joseph A. Goldbeck, Jr.
Attorney I.D,#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS IN THE COURT OF COMMON PLEAS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF OF CUMBERLAND COUNTY
JULY, 31 1998 SERIES 1998-B
c/o The Money Store CIVIL ACTION - LAW
4111 South Darlington, Suite 800
Tulsa, OK 74135 :ACTION OF MORTGAGE FORECLOSURE
Plaintiff Term
No. 99-3558
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant (s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am
the attorney of record for the Plaintiff in this action, and I
further certify that this property is subject to Act 91 of 1983
and the Plaintiff has complied with all the provisions of the
Act.
Joseph Goldb Jr.
Attorn for Pl n iff
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GOLDBECK MCCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Plaintiff
vs.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
Term
No. 99-3558
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance in the above-captioned matter.
GOLDS 4GGdbecck, & MCKEEVER
BY: J s pJr.
Attor y ff
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GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I,D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-3558
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment with reference to the above-
captioned matter, insofar as judgment was entered in error due to
the filing of a Petition in Bankruptcy on August 6, 1999.
BY: Jose'?Sh A. Goldbeck', Jr.
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
C/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS. Term
CHESTER L. BRENIZER No. 99-3558
(Mortgagor (s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant (s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR
THE PURPOSE OF COLLECTING THE DEBT.
Enter Judgment in favor of Plaintiff and against CHESTER L. BRENIZER
by default for want of an Answer.
(X) Assess damages as follows:
Debt
Interest il/ 1/98 to 8/31/00
$ 44 135.35
Total $
(Assessment of Damages attached)
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS
ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM
THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be entered and
to his attorney of record, if any, after the default occurred and at least
ten days prior to the date of the filinth' prima cipe. A copy of the
notice is attached. R.C.P. 237.1 1
Attornby for Plat ti
I.D. ##'16132 V
AND NOW Judgment is
entered in favor of THE BANK OF NEW YORK AS CO-TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF JULY, 31 1998 SERIES 1998-B, and
against CHESTER L. BRENIZER by default for want of an Answer and damages
assessed in the sum of FORTY FOUR THOUSAND ONE HUNDRED THIRTY FIVE DOLLARS
AND 35 CENTS ($44,135.35), as per the above certification.
Prothonotary
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GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE HANK OF NEW YORK AS CO-TRUSTEE
UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF JULY, 31 1998
SERIES 1998-B
C/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
Vs.
CHESTER L. BRENIZER (Mortgagor(s)
Record Owner(s))
(Record Owner(s))
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
and: Term
No. 99-3558
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P 3129 2(c)(2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
mad by:
(X) Personal Service by the Sheriff's office' (copy of
return attached)
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached).
( ) Certified mail by Sheriff's Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached).
( ) Ordinary mail by Sheriff's office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Cer':ified mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the
penalties provided by 18 P.S. Section 4904.
Respect ul' s m'
GOLDBECK FE TY CKEEVER
BY: Josep A. Goldb ck, Jr.
Attorney for Plaintiff
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The Bank of New York as Co-Trustec Under In the Court of Common Pleas of
The pooling and Servicing Agreement Dated Cumberland County, Pennsylvania
As of July 11, 1998 Series 1998-B No. 1999-3558 Civil
Richard E. Smith Deputy Sheriff, who being duly sworn according to law says on October 9, 2000 at
12:35 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in
the above entitled action upon the within named defendant to wit: Chester L. Brenizer by making known
unto Mark Brenizer adult in charge at time of service at 1819 Heishman Gardens Drive, Carlisle,
Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said
true and attested copies of the same.
Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on October 9, 2000 at
12:35 o'clock P.M. EDST, he posted a copy of Real estate Writ Notice Poster and Description on the
property of Chester Brenizer located at 1819 Heishman Garden Drive, Carlisle, Cumberland County,
Pennsylvania according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate
Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the
pendency of the action to the defendant to wit: Chester L. Brenizer by regular mail to his last known
address 1819 Heishman Gardens Drive, Carlisle, PA This letter was mailed under the date of October
10, 2000 and never returned to the Sheriffs Office.
/ ri?'
So Q
R. Thomas Kline, Sheriff
By
Real Estate Deputy
GOLD13ECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS IN THE COURT OF COMMON PLEAS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF OF CUMBERLAND COUNTY
JULY, 31 1998 SERIES 1998-B
c/o The Money Store CIVIL ACTION - LAW
4111 South Darlington, Suite 800
Tulsa, OK 74135 :ACTION OF MORTGAGE FORECLOSURE
Plaintiff Term
No. 99-3558
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
THE BANK OF NEW YORK AS CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF JULY, 31 1998 SERIES 1998-B,
Plaintiff in the above action, by its attorney, Joseph A.
Goldbeck, Jr., 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:
1819 Heishman Gardens Drive, Carlisle, PA 17013
1. Name and address of Owner (s) or Reputed Owner(s):
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
THE PACESETTER CORPORATION
4787 Whitepine Road
Chesterfield Business Center
Richmond, VA 23237
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED: August 30, 2000 nrm&
GOLDBEC bd%F MCKEEVER
BY: Joseph Goldbe , Jr., Esq.
Attorney for Pla ntiff
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STATE OF PENNSYLVANIA, t
COUNTY OF CUMBERLAND J ss'
Robert P Ziegler
I -------------------- ------------
_ _ Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
Bank of New York Tr
-----------------------------°^--------------------------------------------------- is the grantee
the same having been sold to said grantee on the -- 6th----------------------------------------- day of
Dec
---------------------------------------- A. D., 2000--, under and by virtue of a writ --------------
8th
------- Execution ------------- ----------------issued on the ------------
------------------------
day of -___-_ Sept ------------- A.D., 2000- out of the Court of Comman Pleas of said County as of
Civil 99
---------------------------------°--------------------
3558 Bank of New York Tr
Number--------------, at the suit of---------------------------------------------------------------
Chester L Brenizer
----------------------------------- against ---------------------------------------------------- is
237 620
duly recorded in Sheriff's Deed Book No -------------- Page ___--_----_-.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this -_-°_^ day
of -------- - ?' --------- D•>
------? -----
Q-, ( Recorder of Deeds
Recorder of Deeds, Cumberland County, Carlisle, PA
My Commission Expires the First Monday of Jan. 2002
The Bank of Ncw York as Co-Trustee Under In the Court of Common Pleas of
The pooling and Servicing Agreement Dated Cumberland County, Pennsylvania
As of July 11, 1998 Series 1998-B No. 1999-3558 Civil
-vs-
Chester L. Brenizer
Richard E. Smith Deputy Sheriff, who being duly sworn according to law says on October 9, 2000 at
12:35 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in
the above entitled action upon the within named defendant to wit: Chester L. Brenizer by making known
unto Mark Brenizer adult in charge at time of service at 1819 1lcishman Gardens Drive, Carlisle,
Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said
true and attested copies of the same.
Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on October 9, 2000 at
12:35 o'clock P.M. EDST, he posted a copy of Real estate Writ Notice Poster and Description on the
property of Chester Brenizer located at 1819 Heishman Garden Drive, Carlisle, Cumberland County,
Pennsylvania according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real
Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the
pendency of the action to the defendant to wit: Chester L. Brenizer by regular mail to his last known
address 1819 Heishman Gardens Drive, Carlisle, PA This letter was mailed under the date of October
10, 2000 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says that after due and legal search
had been given according to law, exposed the above described premises at public venue or outcry at
Court House, Carlisle, Cumberland County, Pennsylvania and sold the same for the sum of $ 1.00 to
Attorney Jill Winkea for The Bank Of New York As Co-Trustee Under The Pooling And Servicing
Agreement Dated as of July 31, 1998 Series 1998-B C/O The Money Store. It being the highest bid and
best price quoted for the same The Bank of New York et al of 4111 South Darlington Suite 800, Tulsa,
Ok being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 781.97 it being costs.
Sheriff's Costs:
Docketing 30.00
Poundage 15.33
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 3.10
Certified Mail .64
Levy 15.00
Surcharge 20.00
Law Journal 335.15
Patriot News 216.60
Share of Bills 23.15
Distribution of Proceeds 25.00
Sheriffs Deed 26.50
$ 781.97 pd by ally
Sworn and Subscribed To Before Me
This I/ t` Day ot?-""
2001, A.D. _ a.
Prothonotary
-R..Thonlas Kline, Sheriff.
.. _.-
By??
Real Estate Deputy
Fes`
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A. /04m
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor(s) and Record
Owner(s))
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-3558
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant (s)
AFFIDAVIT PURSUANT TO RULE 3129
THE BANK OF NEW YORK AS CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF JULY, 31 1998 SERIES 1998-B,
Plaintiff in the above action, by its attorney, Joseph A.
Goldbeck, Jr., 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:
1819 Heishman Gardens Drive, Carlisle, PA 17013
1. Name and address of owner (s) or Reputed Owner(s):
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
2. Name and address of Defendant (s) in the judgment:
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
THE PACESETTER CORPORATION
4787 Whitepine Road
Chesterfield Business Center
Richmond, VA 23237
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
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. n
DATED: August 30, 2000
GOLDBEC I F ! MCKEEVER
BY: Joseph V. Goldbe r, Jr., Esq.
Attorney for Pla ntiff
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-B
c/o The Money Store
4111 South Darlington, Suite 800
Tulsa, OK 74135
Plaintiff
VS.
CHESTER L. BRENIZER
(Mortgagor (s) and Record
Owner(s))
1819 Heishman Gardens Drive
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-3558
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
CHESTER L. BRENIZER
1819 Heishman Gardens Drive
Carlisle, PA 17013
Your house at 1819 Heishman Gardens Drive, Carlisle, PA
17013 is scheduled to be sold at Sheriff's sale on December 6,
2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing
Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the
court judgment of $44,135.35 obtained by THE BANK OF NEW YORK AS
CO-TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF
JULY, 31 1998 SERIES 1998-3 against you.
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to THE BANK OF NEW
YORK AS CO-TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT
DATED AS OF JULY, 31 1998 SERIES 1998-B, the back payments, late
charges, costs and reasonable attorney's fees due. To find out
how much you must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
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 below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid price
by calling the Sheriff of 4111 South Darlington, Suite 800 County
at (717) 240-6390.
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid
for your house. A schedule of distribution of the money bid for
your house will be filed by the Sheriff thirty (30) days from the
date of the Sheriff's Sale. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE :. AWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9100
Legal Services Inc,
8 Irvine Row, Carlisle, PA 17017
(717) 241-9400
ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in
North Middleton Township, Cumberland County, Pennsylvania, bounded and described in
accordance With survey of Carl D. Bert, Registered Surveyor, dated November 4, 1983, as follows:
BEGINNING at a point on the North side of Heishman Gardens Drive, Township Road T-716 said
point being the dividing line between Lot Nos. 1819 and 1819A on the hereinafter mentioned plan
of lots; thence by said dividing line and through the center of a party wall dividing the dwelling
house herein conveyed from the dwelling house known as 1819A Heishman Gardens Drive, North
37155' 22" East 119.26 feet to a point in line of land now or formerly of William M. Croft; thence
by land now or formerly of William M. Croft, North 83128' 40" West 57.63 feet to a point at the
Northeast corner of Lot No. 1817A on the hereinafter mentioned plan of lots; thence by said Lot
No. 1817A South 32° 02' 47" West 107.51 feet to a point on the Northern side of Heishman
Gardens Drive; thence by Heishman Gardens Drive South 76° 57' 58" East 42.09 feet to a point, the
place of beginning.
BEING Lot No. 1819 on the Plan of Lots known as Ileishman Gardens as recorded in the Office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 19, page 43.
HAVING thereon erected a dwelling being the western half of a duplex and being known as 1819
Heishman Gardens Drive.
Tax Parcel # 29-17-1585-235
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 1819 Heishman Gardens Drive, Carlisle, PA 17013
SOLD as the property of CHESTER L. BRENIZER
TAX PARCEL #29-17-1585-235
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. _99-3558 CIVIL 19
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due The Bank of New York as Co-Trustee under the
Pooling and Servicing Agreanent Dated as of July 11, 1998 Series 1998-8 PLAINTIFF(S)
from Chester L. Brenizer, 1819 Heishman Gardens Dr., Carlisle PA 17013.
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 1819 Heishman Gardens Dr., Carlisle PA 17013 (See attached legal
description.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
L.L.
and to notify 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 propertyof thedefenclant(s) not levied upon an subject to attachment isfound in the possession of anyonecither
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due •$35,969.67
GARNISHEE(S) as follows:
$.50
Interest 11/1/98 - 8/31/00 $6,850.82 Due Frothy
Ally's Comm 5 % $800.00
Atty Paid
$110.10
Plaintiff Paid
Date: September 8, 2000
REQUESTING PARTY:
Name Joseph A. Goldbeck Jr., Esq.
butte ouu, the nourse tuag
Address: 11, S Independence Mall East
Philadelphia PA 19106
Attorney for: (215) 627-1322
Telephone: 16132
1.00
Other Costs Late Charges $354.86
Escrow Balance Deficit $160.00
CURTIS R. LONG
Prothonotary, Civil Division
f/?2
by: IL'tt-L
Deputy
Supreme Court ID No.
REAL ESTATE SALE No 5(o
V f I -Jx °)94w) the sneritt levied upon the defendantb
interest in the real property Ouated in,14,
Cumberland County, Pa km
(I ,? and mote n.
this writ and Dy this reference
gate:
numbered as: [jt-jxrad gcJ4-°'A,
"d on Exhibit "A" filed with
u:orporated herein, p
ova
B'
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
SS.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 27, NOVEMBER 3, 10, 2000
Afflant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALE NO. 56
Writ No. 1999-3558 Civil
The Bank of New York
As Co-Trustee Under The
Pooling And Servicing
Agreement Dated As Of
July 31,1998
Series 1998-B
VS.
Chester L. Brenizer
Atty.: Joseph A. Goldbeck, Jr.
ALL THAT CERTAIN tract of land,
together with the improvements
thereon erected, situate in North
Middleton Township, Cumberland
County. Pennsylvania, bounded and
described in accordance with sur-
vey of Carl D. Bert. Registered Sur-
veyor, dated November 4. 1983, as
follows:
BEGINNING at a point on the
North side of Heishman Gardens
Drive, Township Road T-716 said
point being the dividing line between
Lot Nos. 1819 and 1819A on the
hereinafter mentioned plan of lots:
thence by said dividing line and
through the center of a party wall
dividing the dwelling house herein
conveyed from the dwelling house
known as IS 19A Heishman Gardens
Drive. North 37° 55' 22" East 119-
.26 feet to a point in line of land
now or formerly of William M. Croft:
thence by land now or formerly of
William M. Croft, North 83° 28'40"
West 57.63 feet to a point at the
Northeast comer of Lot No. 1817A
on the hereinafter mentioned plan
of lots: thence by said Lot No. I817A
South 321 02' 47" West 107.51 feet
to a point on the Northem side of
Heishman Gardens Drive: thence by
Heishman Gardens Drive South 76°
57' 58" Fast 42.09 feet to a point.
the place of beginning.
BEING Lot No. 1819 on the Plan
of Lots known as Hershman Gar-
dens as recorded in the Office of
the Recorder of Deeds in and for
Cumberland County. Pennsylvania
In Plan Book 19, page 43.
HAVING thereon erected a dwell-
ing being the western half of a du-
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
10 day of NOVEMBER. 2000
--- NOTARIAL SEAL
LOIS E. SNYOER, Netory Pvblk
CadiAo Som, Cumberiond County, PA
My Commiraon Eapiro+ More, 5, 2001
? I
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND : SS.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly swom, 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.
Afffant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 56
Writ No. 1999-3558 Civil n -
The Bank of New York
As Co-Trustee Under The L V V
Roger M. Morgenthal, Editor
Pooling And Servicing
Agreement Dated As of
l
J
31
1998 SWORN TO AND SUBSCRIBED before
thi
y
u
. me
s
Series 1998-B 10 day of NOVEMBER 2000
VS.
Chester L. Brenlur
Atty.: Joseph A. Goldbeck. Jr.
ALL THAT CERTAIN tract of land,
together with the improvements ?9
thereon erected, situate in North NOTARIAL EAL
Middleton Township. Cumberland LOIS E. SNYDER, Notary Public
County, Pennsylvania, bounded and Cart;+ls 6oro, Cumbedand County, PA
described in accordance with sur- mmiulon Eapir- Morch S• 2001
C
vey of Carl D. Bert, Registered Sur- a
My
veyor, dated November 4, 1983, as
follows:
BEGINNING at a point on the
North side of Helshman Gardens
Drive, Township Road T-716 said
point being the dividing line between
Lot Nos. 1819 and 1819A on the
hereinafter mentioned plan of lots:
' thence by said dividing line and
through the center of a party wall
dividing the dwelling house herein
conveyed from the dwelling house
known as 1819A Helshman Gardens
Drive. North 37° 55' 22" East 119-
.26 feet to a point In line of land
now or formerly of William M. Croft;
thence by land now or formerly of
Wahern M. Croft, North 83° 29 40"
West 57.63 feet to a point at the
I
I Northeast comer of Lot No. 1817A
on the hereinafter mentioned plan
of lots: thence by said Lot No. 1817A
! South 32° 02'47" West 107.51 feet
to a point on the Northern side of
I Helshman Gardens Drive; thence by
Helshman Gardens Drive South 76°
_ 57' 58" East 42.09 feet to a point,
the place of beginning.
BEING Lot No. 1819 an the Plan
of Lots known as Helshman Gar-
dens as recorded in the Office of
the Recorder of Deeds In and for
Cumberland County, Pennsylvania
in Plan Book 19, page 43.
HAVING thereon erected a dwell-
. ':. Ing being the western half of a du-
plex and being known as 1819
Helshman Gardens Drive.
Tax Parcel # 29-17-1585-235
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 1819 Helsh-
man Gardens Drive. Carlisle, PA
®
17013 _
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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
James L. Clark being duly sworn according to law, deposes and says:
That he Is the Acoums Receivable Manager 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 Iba
Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriol-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 dally and/or Sunday/ Metro editions which appeared on the 31st day of October and the 7th and 14th
day(s) of November 2000. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin In Mjscellaneous Book "M",
Volume 14, Page 317. C
PUBLICATION .................................. ..c......(................................. .................
COPY Sworn to and subscribecPbefore m is 1st day of I)ecem 2000 A.D.
S A L E #56 Notarial Seel
Terry L. Russell, Notary Public
Harrisburg. Dauphin County
My Commission Expires June 6. 2D02 NOTARY PUBLIC
Member, Pennsylvania Association of Notaries My commission expires June 6, 2002
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 $ 215.10
Probating same Notary Fee(s) $ 1.50
Total $ 216.60
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunk 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 ....................................................................