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Home My WebLink About03-3413GOLDBECK McCAFFERTY & McKEEVER BY: JOSEP/;I A. GOLDBECK~ ,IR. ATTORNEY I.D. #16132 SUITI~500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Reel Owner(e) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term CIVIL ACTION: MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIlE PURPOSE OF COLLECTING THE DEBT. NOTICE You have b¢~n sued in court. If you wish to defend against the claima set forth in the following pages, you must teke action within twenty (20) deys at'er the Complaint and notice are served, by entering a written appearance p~sonally or by a~omey and filing in writing with the cour[ your defenses or objections m the elairos se1 forth against you. You are warned that if you fall to do so the caa~ may pn~d without you and a judgrc~nt may b~ entered against you by the Coua't without further notice for any money claim in the Complaint of for any other claim or relief requested by the PlaintifE You may lose money or property or other Egh~ important to you. YOU SHOULD TAKE THIS POPER 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 V~rHI~RE YOU CAN GET LEGAL HELP. LEOAL SERVICES INC 8 Irgin¢ Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libe~ Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A IJSTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEIAS PERESENTADAS, ES AB SOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI US'fED NO E.EPONDE A ESTA DEMANDA, SE PUEDE PROSEGU1R CON EL PROCESO SIN SU PART~CIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECID1R A FAVOR DEL DEMANDANTE Y REQUERIRA QUE us'rED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. LEGAL SERVICES ]?NC COMPLAINT IN MORTGAGE FORECLOSURE I.~ Plaintiffis THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B, One Old Country Road, Suite 429 Carle Place, NY 11514. The name(s) and address(es) of the Defendant(s) is/are ROBERT A. YOUNG, 38 W. Coover Street, Mechanicsburg, PA 17055 and JENNIFER L. YOUNG, 38 W. Coover Street, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On April 19, 1996 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to TMS MORTGAGE INC. D/B/A THE MONEY STORE, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1316 Page 91, The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B by Assignment of Mortgage dated June 20, 1997 as Book 550 Page 557; and these documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due December 0l, 2002, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 11/01/2002 through 07/31/2003 at 9.9900% Per Diem interest rate at $38.80 Attorney's Fee at 5.0% of Principal Balance Late Charges from 12/01/2002 to 07/31/2003 Monthly late charge amount at $50.00 Costs of suit and Title Search Corporate advance $141,779.62 $10,592.39 $7,088.98 $500.00 $900.00 $160,860.99 +$1,277.07 $162,138.06 The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth &Pennsylvania, on the date(s) set forth in the tree and correct copy of such notice(s) Schedule "A" A~L that cart&in premises co~possd of the fallowing two (2) adjoining pieces or ~arcels Of ~eal estate situated in the. Borough ~f Hechaniceb~rg, cuml~rland county, Pennsylvania, more p&~ticul~rly bounded and deGoribed as ~AK~: Ail those entrain two lots of ground numbered 29 and 31, with dweX1A~ house ereo~ed hho=eon~ An tho conaral ~lan Cumberland Co~ty, P~lvan~a, ~u~ed and descried as foll~s, to wit: owned by C~arlos F. ~vors~ ~on~ w~tw&rd alon~ ~aid Co,er Co.lin& ~enco alo~ sa~d lot not.ward, a dIstancm of 143 feet, ~ or ~ss, to HAll Alley~ thenoe along said ~ley. e~s2wa~, a dAy,ante of 5~ fee~ ~o ~= Nm. 27 a~oreaaid~ thence along stid ~o~ gou~ard, a dA~tance of X~9 X/2 feet to Coover SCreet, ~e ~VIN~ erec~ea ~eon a dwellAng houseman and n~red ~eed da~ April 1. 1946. a~ recorded An ~e Offic~ of t~e 7%Record~ of ~edm In and ~or ~rla~ County, PennsylV~ia, In M~lton R. Wm~r a~d Phyllis ~. ~eber, hJ~ w~ff~, the Gran~ors herein. Parcel A de.~Lbec~ he~einabove on the no]~:h~rn 91de o£ C~er $~"eet; thence alo~ Baid~ern G~e Of We~ C~V~ Street, ~uth 75 d~ees Nest. a ~tan~ of 25.04 feet Co a point on ~e same at ~e dividinq line ~tween ~ Nos. 2 and 1 as ~ho~ on ~e h~rei~t~ ~ntloned plan of lotg~ ~e~e ~long said div;ding line ~tween ~ts Nos. 2 and 1, North 16 de~4~ 31 minutes ~o seco~s ~st, ~ diet--ce o~ ~9.~ ~eet to a ~e~e a~o~ land~ n~ 9~ formerly o~ Ralph W. Norstick ~ ~WAllI~ ~. ~cDade. Nor~ 16 d~ees 38 m~nutes 30 ~con~s Went~ di=ta~ce of 52.9a ~t ~ a post; ~ance along lands n~ or fo~rly of M~l~n R. W~r, Nor~ 72 degree~ 14 ~inu~es ~st. land~ ~ or formerly Ot ~lzcon K. N~ an~ land~ n~ or fo~erly ~f Janet ~. S~en~ Hoverter, Nor~ 14 d~re~ 46 P~COI'A a~va desmar; ~ alo~ said Parce~ A, S~th 1~ de~ee~ S mlgutes,~st, a dl~a~ of 139,83 feet to an iron DF785 XHIBIT A ROBERT A YOUNG 38 W COOVER/REAR W MECHANICSBURG, PA 17055 April 3, 2003 NBRC 0073040685 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgaee on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the a~ached pa~tes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can heln you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of thins Notice. If you have any questions, you may call the Pennsylvania Housing Finance Attencv toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780~1869~. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCC1ON IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) S1N CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO PeR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing Corporation is a debt collector. HomEq is attempting to collect a debt and any information obtained will be used for that purpose. SEE LAST PAGE FOR ADDITIONAL IMPORTANT DISCLOSURES THIS NOTICE CONTINUES ON THE NEXT PAGE DF785 JENNIFER L YOUNG 38 W COOVER/REAR W MECHANICSBURG, PA 17055 April 3, 2003 NBRC 0073040685 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is_ an official notice that the mortv, age on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling a~encv. The name. address, and phone number of Consumer Credit Counseling Agencies servine vour county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGKAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing Corporation is a debt collector. HomEq is attempting to collect a debt and any information obtained will be used for that purpose. SEE LAST PAGE FOR ADDITIONAL IMPORTANT DISCLOSURES THIS NOTICE CONTINUES ON THE NEXT PAGE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: · YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, · YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND · YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange for and attend a "face-to-face" meeting with one of the consumer counseling agencies listed at the end of this notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY ¢301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take further action against yon for thirty (30) days afl.er the date of this meeting. The names, addresses and telenhone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this notice. It is necessary to schedule only one face-to-face meeting. You should advise this lender/servicer immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this notice (see the following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender/servicer, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to fue Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LF~TTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. Funds will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. THIS NOTICE CONTINUES ON THE NEXT PAGE P~g~ 3 NOTE: IF YOUA RE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. NATURE OF THE DEFAULT The MORTGAGE debt secured by your property located at: 38 W COOVER/REAR W MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number of Payments Delinquent: 5 b) Delinquent Amount Due: $6,532.40 c) Late Charges: $350.00 d) Recoverable Corporate Advances: $1,264.19 e) Other Charges and Advances: $$0.00 0 Less funds in Suspense: $150.10 g) Total amount required as of (due date): $$7,996.49 2. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT - You may cure this dePault within THIRTY (30) days fi'om the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER/SERVICER, WHICH IS $6,532.40 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's check, certified cheek, or monev order made oavable to: Regular Mail HomEq Servicing Corporation P.O. Box 96012 Charlotte, NC 28296-0012 Overnight Attn: Cash Central NC 4726 1100 Corporate Center Drive Raleigh, NC 27607-5066 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this notice: (Do not use if not applicable) THIS NOTICE CONTINUES ON THE NEXT PAGE Page 4 1F YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY (30) days of this notice, the lender/servicer intends to exercise its rights to accelerate the mortgage debt. This means that the entire omstanding balance of this debt will be considered due immediately and you may lose the opportunity to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE DATE OF THIS LETTER, HomEq Servicing Corporation also intends to instruct its attorneys to start a legal action to foreclose uoon your mort~aoed orooert¥. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender/servicer refers your case to its attorneys, but you cure the delinquency before the attorney begins legal proceedings against you, you will still be required to pay the reasonable attorneys' fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred even if they are over $50.00. Any attorneys' fees will be added to the amount you owe the lender/servicer, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY oeriod, you will not be reouired to nay attorneys' fees. OTHER LENDER/SERVICER REMEDIES The lender/servicer may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time un to one hour before the Sheriff's Sale. You may do so bv paying thc total amount then oast due plus any late charges, other char~es then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writin~ by the lender/servicer and bv performing any other requirements under the mortgaee. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE It is estimated that the earliest date that such Sheriff's sale could be held would be approximately five (5) months from the date of this notice. A notice &the actual date of the Sheriff's Sale will be sent to you before the sale. The amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. HOW TO CONTACT THE LENDER/SERVICER BY TELEPHONE OR MAIL: Name of Lender/Servicer Address Telephone Number: HomEq Servicing Corporation Attn: Account Research, Mail Code CA3345 P.O. Box 13716 Sacramento, CA 95853 1-800-795-5125 EFFECT OF SHERIFF'S SALE You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender/servicer at any time. ASSUMPTION OF MORTGAGE You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 5 YOU MAY ALSO HAVE THE RIGHT · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR BORROW MONEY FROM ANOTHER LENDiNG INSTITUTION TO PAY OFF THIS DEBT; · TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF; · TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. HOWEVER, YOU DO NOT HAVE THE RIGHT TO CURE YOUR DEFAULTS ANY MORE THAN THREE TIMES IN A CALENDAR YEAR; · TO ASSERT THE NON-EXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS; · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER/SERVICER; OR · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED TO THIS LETTER If you received a discharge of the account through the Bankruptcy Court and if your account has not been reaffirmed, the acceleration and sale will not result in your being held personally liable for the debt and this letter is not an attempt to collect a personal debt. However, failure to pay the delinquent balance is necessary to avoid foreclosure. You are notified that this default, and any other legal action that may occur as a result thereof, may be reported by HomEq to one or more credit reporting agencies. Please take appropriate action with respect to the important matters discussed herein. Sincerely, HomEq Servicing Corporation THIS NOTICE CONTINUES ON THE NEXT PAGE Page 6 IMPORTANT DISCLOSURES Colorado Collection agencies are licensed by the Colorado Collection Agency Board, 1525 Sherman Street, 5th Floor, Denver, Colorado 80203. Please do not send payments to the collection agency board. Minnesota This collection agency is licensed by the Minnesota Department of Commerce. Nebraska Any credit insurance issued in connection with the loan contract may be canceled unless the borrower cares the default. New York City Collection Agency License: gl 099500 - North Highlands, CA (Main office) #1099501 - Raleigh, NC (Branch) #1099512 - Boone, NC (Branch) North Carolina North Carolina Department of Insurance Permit: #3677 - North Highlands, CA (Main office) #3676 - Raleigh, NC (Branch) #3675- Boone, NC (Branch) This collection agency is licensed by the Collection Service Board, State Department of Commerce and Industry, 500 James Robertson Parkway, Nashville, Tennessee 37243 SHERIFF ' S CASE NO: 2003-03413 P COMMONWEALTH OF PENNSYLVANIA: COI/NTY OF CUMBERLAND BANK OF NEW YORK THE VS YOUNG ROBERT A ET AL RETURN - REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE YOUMG ROBERT A DEFENDANT , at 1950:00 HOURS, on the at 38 W COOVER STREET MECFIANICSBURG, PA 17055 ROBERT YOUNG a true and attested copy of COMPLAINT - was served upon 6th day of August the , 2003 by handing to MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this ~'7 ~ day of ~ A.D. Pgofihonot ary So Answers: 08/07/2003 GOLDBECKBy: M~KEEVER // I~eputy Sheriff ? SHERIFF'S RETURN - CASE NO: 2003-03413 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK THE VS YOUNG ROBERT A ET AL REGULAR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly ~worn according to says, the within COMPLAINT - MORT FORE YOUNG JENNIFER L DEFENDANT , at 1045:00 HOURS, at 19 GETTYSBURG PIKE #5 MECHANICSBURG, PA 17055 JENNIFER YOUNG a true and attested copy of COMPLAINT on the was served upon 1st day of August the by handing to - MORT FORE together with law, 2003 and at the same time directing Her attention to the contents thereof. ~eriff's Costs: )ocketing 6 ervice 8 ffidavit ~rcharge 10 24 00 28 00 00 00 28 rn and Subscribed to before his 3? ~ day of ~ ~t~O-~ A.D, tProthonotary '-- Thomas Kline 08/07/2003 GOLDBECKBy: MCCAFFERTY~~MCKEEV~ff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 SuiJce 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-62%1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLI2gG & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 VS. Plaintiff ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechauicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3413 ORDER FOR JUDGMENT Please enter Judgment in favor of THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLiNG & SERVICiNG AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B, and against ROBERT A. YOUNG and JENNIFER L. YOUNG 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 $163,906.46. Joseph A. £ Attorney roi I hereby certify that the above names are correct and that the ~recise~esidence address of the judgment creditor is THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 and that the name(s) and last known address(es) of the Defendant(s) is/are ROBERT A. YOUNG, 38 W. Coover Street Mechaniesburg, PA 17055 and JENNIFER L. YOUNG, 19 Gettysburg Pike #5 Meehanicsburg, PA 17055; GOLDBECK ERTY & McKEEVER BY: Joseph 3o~dl~eck, Jr. Attorney for 1~ intiff~ ASSESSMENT OF DAMAGES TO TH~ PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $141,779.62 Interest ~omll/01/2002through 09/12/2003 $12,260.79 ARomey's Fee at 5.0000%ofpfincipal balance $7,088.98 Late Charges $600.00 Costs of Suit and Title Search $900.00 Escrow Balance Deficit $1,277.07 ($0.00) $163,906.46 AND NOW, this ~[.~"day of Attorney for Plaix~iff 2003 damages are assessed as above. 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, ROBERT A. YOUNG, is about unknown years of age, that Defendant's last known residence is 38 W. Coover Street, Mechanicsburg, PA 17055, 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: 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, JENNIFER L. YOUNG, is about unknown years of age, that Defendant's last known residence is 19 Gettysburg Pike ~5, Mechanicsburg, PA 17055, 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 of 1940 and its Amendments. Congress Date: In the Court of Common Pleas of Cumberland County THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover S~'eet and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) No. 03-3413 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 the Judgment in favor of Pla'mtiff and against ROBERT A. YOUNG and JENNIFER L. YOUNG by default for want of an Answer. Assess damages as follows: $163,906.46 Debt Interest- 11/01/2002 to 09/12/2003 Total (Assessment of Damages attached) I CERTIFY THAT 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 prior to the date of the is to be entered and to his attorney of record, if any, after the default occurre~l, and at lea~ %'~ days filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ~x~ Joseph ^n~ ~ Jr. A~omey ~r t ~fiff I.D. ~16 ~ AND NOW .~'{1 ¥%'~ I { · , ~ ~)~M~ , Jud~ent is entered ~ favor of THE BANK OF NEW YO~ AS ~USTEE ~DER THE POOL~G & SERVIC~G AG~E~NT DASD AS OF ~Y 31, 1996 SE~ES 1996-B ~d agaMst ROBERT A, YO~G ~d JE~IFER L. YO~G by default for w~t of ~ ~swer ~d d~ages assessed M the s~ of $163,906.46 ~ per ~e above ce~ificati~ ~othono~ 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. DATE OF THIS NOTICE: August 27, 2003 'ro: ROBERT A. YOUNG 19 Gettysburg Pike #5 Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3413 TO: ROBERT A. YOUNG 19 Gettysburg Pike #5 Meehanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRiTI'EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A 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. I~ 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: LEGAL SERVICES fNC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 B~seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215427-132 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. DATE OF THIS NOTICE: August 27, 2003 TO: JENNIFER L. YOUNG 19 Getlysburg Pike #5 Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechaniesburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Terln No. 03-3413 TO: JENNIFER L. YOUNG 19 GetXysburg Pike #5 Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI'I'IEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT KIGHTS. 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: LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 717 -243 -9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libeay Avenue Carlisle, PA 17013 ~oldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - ~he Boarse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 THIS LAW FIRM IS A DEBT COLLECTOR AND V~E 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. DATE OF THIS NOTICE: August 27, 2003 TO: JENNIFER L. YOUNG 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tern~ No. 03-3413 TO: JENNIFER L. YOUNG 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 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. LrNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TI-HS 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: LEGAL SERVICES 1NC 8 Ir,fine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ~CC ~~EVER B 'GO~h(A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 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. DATE OF THIS NOTICE: August 27, 2003 TO: ROBERT A. YOUNG 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3413 TO: ROBERT A. YOUNG 38 W. Coover Street and 38 Rear W. Coover Street Mechaffmsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT fEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A 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: LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 Philadelplxia, PA 19106 215-627-1322 Attorney for Pla'tariff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 vs. Plaintiff ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Record Owner(s) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3413 PRAEC1PE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest f~om 11/01/2002 to 09/12/2003 at 9.9900% (Costs to be added) $163,906.46 GOLDBE~ BY: Joseph A. C4~6~k,] Attorney for Pla~a~ff \1 ~& McKEEVER BBO~NH~NO on ~oovor ~reO~ ~ ~orner a~ ~t ~o, ~7, ~o~er~y loc southward, a ~/s~anoe o~ 139 plao~ of deed dat~ Apr~l 1, 194~, a~d roosted 1~ ~he Office o~ the ~t~t off ~ho ~ama a~ ~e d~v~dln~ llne ~ Borg Nos. 2 and 1 ~h~nee alon9 ~l~es 30 ~eco~s ~eStf a thee al~g Ln~ now or W~ll~a~ B. ~cDadee N~ 16 de~8 3e m~nu~es ~0 ~eoond~ West, a mlnu~ weBt~ a d~eta~e og 97,10 gee~ =o a sp~ke a~ Hill AlleY; da ~ee~ ~ ~nuCes ~S~, o~g~he ~o~r~ ~de of Coover Se~ee~, ~e pla0e oE Goldbeck McCafferty & MeKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-657-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG (Mortgagor(s) and Record Owner(s)) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3413 AFFIDAVIT PURSUANT TO RULE 3129 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-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 conceding the real property located at: 38 W. Coover Slxeet and 38 Rear W. Coover Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT A. YOUNG 38 W. Coover Street Mechanicsburg, PA 17055 JENNIFER L. YOUNG 19 Getlysburg Pike #5 Mechaincsburg, PA 17055 2. Name and address &Defendant(s) in the judgment: ROBERT A. YOUNG 38 W. Coover Street Mechanicsburg, PA 17055 JENNIFER L. YOUNG 19 Gettysburg Pike #5 Mechaincsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MECHANICSBURG BOROUGH MECHANICSBURG, PA 17055 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ALLIANCE FUNDING, A DIVISION OF SUPERIOR BANK One Ramland Road Orangeburg, NY 10962-2606 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. TENANTS/OCCUPANTS 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsbmg, PA 17055 (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. GOLDBECK ~ RTY & McKEEVER BY: JosephA. G~lc }ecl Jr., Esq. Attorney for Plaintiff' 03-3413 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. ARomey I.D.# 16132 Suite 500 - ~[he Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Record Owner(s) 38 W. Coover Street and 38 Rear W. Coover Street Meehanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3413 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMI~T TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SI-IERIFF'S SALE OF REAL PROPERTY TO: YOUNG, ROBERT A. ROBERT A. YOUNG 38 W. Coover Street Mechaniesburg, PA 17055 Your house at 38 W. Coover Street and 38 Rear W. Coover Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $163,906.46 obtained by THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 03-3413 1. The sale will be cancelled if you pay to THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B, the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by fding 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may f'md out the price bid price by calling the Sheriff of 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. Thc sale will go through only if the buyer pays the Sheriff the full mount due in the sale. To fred out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the mount 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 Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 Sheriffwithin 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIAT/ON 2 Liberty Avenue Carlisle, PA 17013 03-3413 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 TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Record Owner(s) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3413 Defendant(s) 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 Sl~ ~:RIFF'S SALE OF REAL PROPERTY TO: ¥otn,;a, m~,mIvER L. JENNIFER L. YOUNG 19 Gettysburg Pike #5 Mechanicsburg, PA 17055 Your house at 38 W. Coover Street and 38 Rear W. Coover Street, Mechauicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $163,906.46 obtained by THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 03-3413 1. The sale will be cancelled if you pay to THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B, the back payments, late charges, costs and reasonable attorney's fees due. To f'md 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 fights. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fred out the price bid price by calling the Sheriff of 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 mount due in the sale. To fred out if this has happened, you may call the Sheriff of 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 tha property until the full amount dna 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 distxibution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libexly Avenue Carlisle, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3413 Civil 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 TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B, Plaintiff (s) From ROBERT A. YOUNG AND JENNIFER L. YOUNG (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the proper~ty of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachmem is found in the possession of anyone other than a named ganfishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $163,906.46 Interest FROM 11/1/02 TO 9/12/03 AT 9.9900% Atty's Corem % Atty Paid $141.18 Plaintiff Paid Date: SEPTEMBER 16, 2003 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonota.ry Deputy 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 Atlome7 for plaintiff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Record Owner(s) 38 W. Coover Stxeet and 38 Rear W. Coovcr Street Mechanicsburg, PA 17055 Defendant(s) IN ~I~IE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3413 CERTIFICAI ', 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 made by: ~1~ Personal Service by the Sheriffs Office/c -,},, v..~,-.-. -,----ed)- Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).zSo,4Ft~ Certified mail by Sheriffs Office. Ordinary mail by Joseph A. Ooldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defimdant(s) (proof of acknowledgment attached). ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified 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. Rester/ful~ submitted. ~ J~seph A. Goldbec, k~. ~Attomey for Plaintiff 7160 3901 9848 1554 5462 · '~O:YOUNG, JENNIFER L: JENNIFER L. YOUNG 19 Gettysburg Pike #5 Mechanicsburg, PA 17055 SENDER: GOLDBECK MCCAFFERTy & MCKEEVER September 12, 2003 REFERENCE: YOUNG, ROBERT A. / MS.1096 03/03/04 _ Cumberland PS Form 3800 June 2000 RETURN -~ RECEIPT SERVICE Receipt for Certified Mail Do Not Use for InternatiOnal Maild AFFIX pOSTAGE TO MAIL,PIECE TO CovER FIRST C~J~"~$ pOSTAGE, CERTIFIED FEE, RETURH RECEIPT FEE AND cHARGES FOR ANY SELECTED OPTIONAL SERVICES $~ liyouwantth~s .~tp ~d the mailpiece, and slid? th.e,, 4. Enter fees for the sewices requested i~ the appropriate of this receipt. s aceso~th~front.. =-,~s ~titiI oumake~,n!~qulrY, ~P. Save this receipt a~,~ ~.~ e ¥ ~o ~ z · GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.# 16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-B One Old Country Road Suite 429 Carle Place, NY 11514 Plaintiff VS. ROBERT A. YOUNG JENNIFER L. YOUNG Mortgagor(s) and Record Owner(s) 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3413 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 THE BANK OF NEW YORK AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT DATED AS OF MAY 31, 1996 SERIES 1996-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: 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 1 .Name and address of Owner(s) or Reputed Owner(s): ROBERT A. YOUNG 38 W. Coover Street Mechanicsburg, PA 17055 JENNIFER L. YOUNG 19 Gettysburg Pike//5 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: ROBERT A. YOUNG 38 W. Coover Street Mechanicsburg, PA 17055 JENNIFER L. YOUNG 19 Gettysburg Pike #5 Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: MECHANICSBURG BOROUGH MECHANICSBURG, PA 17055 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Burean of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 BEAL BANK 6000 Legacy Drive Suite 200E Piano, TX 75024-3601 4. Name and address of the last recorded holder of every mortgage of record: ALLIANCE FUNDING, A DIVISION OF SUPERIOR BANK One Ramland Road Orangeburg, NY 10962-2606 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. TENANTS/OCCUPANTS 38 W. Coover Street and 38 Rear W. Coover Street Mechanicsburg, PA 17055 (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 subje,:t to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: January 14, 2004 3Lr, BEC : ;cCA'FFERT¥ 3 c EVER y/BY: Joseph A. Goldbeck, Jr., Esq. ~ Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Zie~ler, 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 3r__0_d day of March A.D., 2004, under and by virtue ora writ Execution issued on the 16th day of September, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 3413, at the suit of Bank of New York Tr against Robert A & Jennifer L Young is duly recorded in Sheriff's Deed Book No. 262, Page 850. 1N TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this o~2~ ~ day of ~/~ ,A.D2004 , {r~ ~Recorder of Deeds The Bank of New York as Trustee Under the Pooling & Servicing Agreement Dated as of May 31, 1996 VS Robert A. Young and Jennifer L. Young In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3413 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on November 25, 2003 at 8:26 o'clock PM, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Robert A. Young, by making known unto Robert Young, personally, at 38 West Coover Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2003 at 4:24 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Jennifer L. Young, by making known unto Jennifer Young, personally, at 402 Mt. Allen Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2004 at 6:40 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert A. Young and Jennifer L. Young located at 38 and 38 Rear West Coover Street, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Robert A. Young, by regular mail to his last known address of 38 West Coover Street, Mechanicsburg, PA 17055. This letter was mailed under the date of January 9, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jennifer L. Young, by regular mail to her last known address of 402 Mt. Allen Road, Mechanicsburg, PA 17055. This letter was mailed under the date of January 9, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 3, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for The Bank of New York as Trustee under the pooling and servicing agreement dated as of May 31, 1996, Series 1996-B. It being the highest bid and best price received for the same, The Bank of New York as Trustee under the pooling and servicing agreement dated as of May 31, 1996, Series 1996-B of 1100 Corporate Center Drive, Raleigh, NC 27607, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $1181.93, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 23.18 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.70 Levy 30.00 Surcharge 40.00 Law Journal 446.75 Patriot News 395.98 Share of Bills 29.32 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 1,181.93 Sworn and subscribed to before me This ~ 0 ~ day of ")~c ~ 2004, A.D. ,, ~.,~ ~t3 )~x~,~ ,tt)~ Prdthonotary R. Thomas Kline, Sheriff Real Estate Oeputy Real Estate Sale # 15 On November 05, 2003 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA Known and numbered as 38 and 38 Rear West Coover Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 05, 2003 By:~ ~'~ Real Esta'fe Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. 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 lfj iscellaneous Book "M", the office for the Recording of Deeds in and for said County Dauphi~ Volume 14, Page 317. My Commission Expires June 6, 2006 Vly commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 395~98 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday 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. W'dlt~n B. to anir~ ~non ~n~t tCoo~' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL E~TATE SALE NO. 15 Writ No. 2003-3413 Civil The Bank of New York as Trustee Under the Poohng & Servicing Agreement Dated as of May 31. 1996 VS. Robert ~ Young and Jemdfer L, Young Atty.: Joseph Goldbeck ALL that certain premises com- posed of the following two {2) adjoin lng pieces or parcels of real estate situated in the Borough of Mechan- icsburg. Cumberland County, Pem~ sylvania, more particularly bounded and described as follows: PARCEL ,~ All those certain two lots of ground numbered 29 and 31, with dwelling house erected thereon, in the General Plan as made by the Heirs of John Coover, deceased, in Mechaxacsburg. Cumberland Coun ty, Pennsylvania, bounded and de scribed as follows, to wit: (_~isa Made Coyne~ Editor SWORN TO AND SUBSCRIBED before me this 30 .day of JANUARY 2004 l~ot m-v , ~ NOTARIAl. SEAL t./ LOIS E. SNYDER, Notary Public Carlisle Bom, Cumberland County My Commission Expires March 5, 2005 in the General Plan as made by the Ileirs of John Coover. deceased, in Mechanicsburg. Cumberland Coun ty, Pennsylvania, bounded and de scribed as follows, to wit: BEGINNING on Coover Street at corner of Lot No. 27, formerly owned by Charles F. Devors; thence westward along said Coover Street, a distance of 58 lket to lot formerly of Edwai'd S. Cocklin; thence along said lot northward, a distance of 142 l~et, more or less. to Hill Alley; thence along said Alley. eastward. a distance of 58 feet to Lot No. 27 aforesaid; thence along said lot southward, a distance of 139 1/2 feet to Coover Street. the place of BEGINNING. HAVING erected thereon a dwell ing house know~ and numbered as 38 West Coover Street. together with a detached garage apartment building along Hill Alley. BEING the sm:ne premises which Annie M. Nailor. widow, by her deed dated April 1, 1946, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "F'. Volume 13, Page 173, granted and conveyed unto Milton R. Weber and Phyllis I. Weber, his wife. the Grant- ors herein. PARCEL B: BEGINNING at an iron pin on the western line of Par cel A described hereinabove on the northern side of West Coover Street; thence along said northern side of West Coover Street, South 75 de- grees West, a distance of 25.04 feet to a point on the same at the divid lng line between Lots Nos. 2 and 1 as shoval on the hereinafter men- tioned plan of lots; thence along said dividing line between Lots Nos. 2 and 1, North 16 degrees 38 mtn utes 30 seconds West, a distance of 29.28 feet to a post; thence along lands now or formerly of Ralph W. Horstick and William B. McDade, North 16 degrees 38 minutes 30 seconds West. a distance of 52.98 feet to a post; thence along lands now or formerly of Milton R. Weber. North 72 degrees 14 xrdnutes East, a distance of 10.30 feet to a post; thence continuing along said lands now or formerly of Milton R. Weber and lands now or formerly of Janet M. Stevens Hovertar. North 14 de- grees 46 minutes West. a distance of 57.10 feet to a spike at Hill Alley; thence along said Hill Alley, North 75 degrees East, a distance of 16.67 feet to a point on the same at the western line of Parcel A above described; thence along said Parcel A. South 15 degrees 5 minutes East, a distance of 139.83 feet to an iron pin on the northern side of West Coover Street. the place of BEGIN