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HomeMy WebLinkAbout99-06988s 'N V L 1 U FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. MORTGAGE LOAN TRUST 1997-1-136 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 WITHOUT RECOURSE 505 SOUTH MAIN STREET, SUITE 6000 ORANGE, CA 92868-5262 Plaintiff V. BRIAN M. MORROW DONNA L. MORROW 350 WEST PENN STREET CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM /? NO. 44 - ?(?550 L toy ??/L>+? CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE. DE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE.. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE. IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by 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 or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. MORTGAGE LOAN TRUST 1997-LB6 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER I, 1997 WITHOUT RECOURSE 505 SOUTH MAIN STREET, SUITE 6000 ORANGE, CA 92868-5262 V. Plaintiff BRIAN M. MORROW DONNA L. MORROW 350 WEST PENN STREET CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 94 ?i?55D CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE C?, 0; l /C4-n PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL 11E USED FOR THAT PURPOSE.. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE. IS NOT AND SHOULD NOT BE CONSTRUED TO BE. AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTIii'm MORTGAGE SECURITIES VII, INC. MORTGAGE LOAN TRUST 1997-1-B6 UNDER POOLING AND SERVICING AGREEMENT DATED AS OP NOVEMBI'sR I, 1997 WITHOUT RECOURSE 505 SOUTH MAIN S'T'REET, SUITE. 6000 ORANGE, CA 92868-5262 2. The name(s) and last known address(es) of the Del'cndvu(s) are: BRIAN M. MORROW DONNA L. MORROW 350 WEST PENN STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the proper q, hereinafter described. 3. On 7/25/97 mortgagor(s) made, executed wtd delivered it mortgage upon the premises hereinafter described to AMI:ItIQUIiS'I' AIORTOAGI'. COMPANY which mortgage is recorded in the Office of the Itecorder ofCOMHIiI(LANO County, in Mortgage Book No. 1396, Page 1138. PLAINTIFF-is now the legal owner of the mortgage and is in the process of formalizing an assignment ofsante. 4. The premises subject to said mortgage is described as nnnclted. 5. The mortgage is in default because monthly payments ofprincipal and interest upon said mortgage due 6/1/99 and each month therealle arc duc and unpaid, and by the terms of said mortgage, upon failure of mortgagor it) make such payments aller a date specified by written notice sent to Mortgagor, the entire principal balance and all interest clue thereon are collectible forthwith. A copy ol'such notice is attached its Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $62,382.60 Interest 2,648.43 5/1/99 through 10/1/99 (Per Diem $17.31) Attorney's Fees 3,119.00 Cumulative Late Charges 133.00 7/25/97 to 10/1/99 Cost of Suit and Title Search 550,00 Subtotal 68,833.03 Escrow Credit 0.00 Deficit 0.00 Subtotal 0.00 TOTAL $68,833.03 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 ct seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty, (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $68,833.03 , together with interest from 10/1/99 at the rate of S 17.31 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. q•/? /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: September 29, 1999 FORECLOSURE TO: Brian M. Morrow 350 west Penn Street Carlisle. Pa 17013 Donna L. Morrow 350 West Penn Street Carlisle. Pa 17013 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEhIPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mormaste on vour home is in default and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. if HEMAP can hell). you must MEET WITH number of This Notice contains important legal information. Ifyou 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 NOTIFICACION EN ADJUNTO ES DE SUMA INIPORTANCIA, PUEDE AFECTA SLI 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 POR EL PROGRANIA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. STATEMENTS OF POLICY HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LEND ER/SERVICER: Brian %I. Morrow and Donna L. Morrow 350 West Penn Street - Carlisle, Pa 17013 0003501533 Ameriquest Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ! BE ELIGIBLE FOR FINANr iAt. ICCTC7A.V cV ..-?, .- IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stav of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that' time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR ENIERGENCV MnRTr. r? ecc?cT9_ APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth later in this Notice (see 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, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, vau 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 complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set faith above. You will be notified directly by the Pennsyhania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have riled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date) NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 350 West Penn Street - Carlisle, Pa 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: StarUEnd: 6/1/99 thin 9/1/99 at 5554.16 per month. Monthly Payments Plus Late Charges Accrued $2,319.00 NSF: $0.00 Inspections: $0.00 Other: $0.00 (Suspense): $0_00 Total amount to cure default 52,394.00 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,394.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PER10D. Payments must be made either by cash, cashier's check. certified check or money order made pavable and sent to: FEDERMAN AND PHELAN, Suite 900,Two Penn Center Plaza, Philadelphia, PA 19102, attention: Reinstatement Department. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable.) N/A. IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mormage debt. The means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS. the lender also intends to instruct its attorney to start legal action to foreclosure upon your mortgage property. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to S50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pav atornev's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by pavine the total amount then past due, plus anv late or other ch_arees then due, reasonable attomev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-it is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: FEAttorney Representing Lender: DERMAN AND PHELAN Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102 Phone: (215) 563-7000 Fax Number: (215) 563-5534 Contact Person: Phyllis Levin, Reinstatement Department EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You may or_X_may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and anomey's fees and cost are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. ` YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF 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 NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED Very truly yours, FEDERMAN AND PHELAN Cc: Ameriquest Mortgage Co. (Orange. CA) Account No.: 0003501533 Attn: James Brownell Mailed by I" Class mail and by certified Mail No: Z 367 127 561,562 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5;99) Lycoming•C:i:.con CC auatin in s i a 8 L : or Community Aeon (S, yP) P. 213P BOX 13 13X Ser-et 29 (5 Oll) g JSd PA 17703 FI-C (570) 322.2297 CCCS of Norheaste^a ps 201 Basin Street Vrdl (5 0)r?port, F 17703 FAX (570) 3 323.6626 CLL`IT00LNI^( CCCS of Yart!:eastera PA 1631 S Atherton Sc Suite 100 State College, PA 16301 (814) 238.3668 F9.Y (814) 238.3669 COLMNIBL1 C0UN'PY CCCS of Northeastern Pennsvlv=ia 31 W. Market Street POB 1127 1400 Abington Executive Park Wilkes-Bare, PA 18702 Suite I Clarks Summit: PA 18411 (570) 821-083. or (800) 922.9537 F4.Y (570) 821.1795 (570) 587.9163 or (800) 922-953^ ' FA. C (570) 587.9134!9135 Commission on Economics Opportunity of Lu:ene Counts 163 Amber Lane Wilkes-Bare, PA 18702 (570) 826-0510 or (800) 822-0359 F4%(570) 829-1665-CALL BEFORE FXaN-G (570) 455-4994 FL4ZELTON Fa)C (570) 455-5631--CALL BEFORE F IMiG (570) 836-4090 TLWUL3.NN0CK Booker T. Washington Center 1720 Holland Street Ere, P.a 16503 (814) 453-5744 FAX (814) 453.5749 John F Kennedy Center, Inc. 2021 East 20th Street Ere, P4 16510 (814)998.0400 F--*'X (814) 898-1243 CRAWFORD COGN'IY Greater Erie Community Action Commir..ee 18 West 9th. Street Erie, PA 16501 (814) 459-4581 F.4% (814) 4560161 Shen-go Valley Urban Leag,-e. Inc 601 Indiana Avenue Farrell. PA 16L'i (412) 981.5310 CCCS of Western Pennsylvania, Inc. 2000 Linglestow. Road Harrisburg, PA 17102 (717) 541-1.57 Urban League of Nlee-opolitan Harrisburg N. 6Lh Street F-ar-:sbu g, PA 17101 (717) 234-5925 F4% (717) 234.9459 C`U-N F-MAN,D COL-N-ry Financial Counseling Serrices of F-anklin 31 West 3rd Street Waynesboro, P4 17268 (717)762.3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 F.:( (717) 731.9589 Cammwn're Action Coma of the Capital Region ?dams County Housing Authorr1 1514 Derry Street 139-143 Carlisle St Harrisburg, PA 17104 Gettysburg, PA 17325 (717) 232.9^,07 (717) 334-1518 FAX (717) 224-2227 MX (717) 334.3325 PENNSYLVANIA BULLETIN, VOL 29, NO. 22, JUNE 5, 4999 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, said point being n'/4 inch. drill. hole 6 feet South of the Southern curb line of Nest Penn Street aad 209.85 feet Past of the Eastern line of Pranldin Street; thence along lands now or formerly of William D. Shultz, South 15 degrees 58 minutes Wesc 120.00 feet to u stake on the Northern side of a 12 foot wide?pubLic alloy: thence along the Northern side of said public alley North 74 degrees 00 atinutes West 44.83 feet to a stake; thence North 15 dcgrces 58 minutes East 120.00 feet through the parfitiotl wail of a concrete block garage and the partition wall of 350 West Penn Street and 352 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet SOU[Il of the Southern curb line of West Penn Street and 165.02 feet Fast of the Eastern side of Franklin Street; thence South 74 degrees 00 minutes East 44.83 feet to a V4 inch drill hole, the place of BEGINNING. HAVING thereon erected a two story frame dwelling house [he Eastern portion of which is included herein and frame garage and Eastern half of a concrete block garage; being known and numbered its 350 Wesc Penn Strect, Carlisle. Pennsylvania. BL-ING THL' SAIvIE property which Ronald W. Madison and Margaret P. Madison, his wife, by their deed dated April I, 1969, and recorded April 1, 1969, in the Office of the Recorder of Dcuds for Cumberland County in Deed Book I-23, page 782, granted and conveyed to Ronald L. Morrow and Lorctta A. Morrow, his wife. Grantors herein. Under and subject to any and all restrictions, objections, etc., as they appear of record. Willi the appurtenances: TO liA VE AND TO HOLD the same unto and for the use of said parties or the suennd part their heirs and usslgns forever, PREMISES:350 WEST PENN STREET +fi +'= VERIFICATION JAMES BROWNELL hereby states that he is FORECLOSURE SPECIALIST 'i Ij of AMERIQUEST MORTGAGE COMPANY mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this I Verification, and that the statements made in the foregoing civil j' Action in Mortgage Foreclosure are true and correct to the best of j his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the ?I ] penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to i authorities. DATE: I SHERIFF'S RETURN - REGULAR CASE NO: 1999-06988 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWF.ST BANK MINNESOTA ETC VS. MORROW BRIAN M ET AL DAWN KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORROW BRIAN M the defendant, at 15:13 HOURS, on the 29th day of November 1999 at 350 WEST PENN STREET CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to DONNA L. MORROW a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's costs: So answers: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 Ft-Thomas ine, eri -FEDERMAN99 PHELAN by `' \l NdLL" y - vat epu y S eri Sworn and subscribed to before me this /y cc? day of ( Qw 19A. D. .L., 0_ ?1k? -?I rotnonorcr SHERIFF'S RETURN - REGULAR CASE NO: 1999-06988 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA ETC VS. MORROW BRIAN M ET AL DAWN KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORROW DONNA L the defendant, at 15:13 HOURS, on the 29th day of November 1999 at 350 WEST PENN STREET CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to DONNA L. MORROW a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So anP Docketing 6.00 ? Service .00 Affidavit .00 Surcharge 8.00 omas ine, eri FEDERM1999 PHELAN by eput y Slierif'- Sworn and subscribed to before me this /yam day of Xecee,,,,., 19 7 A.D..? rotnonotatry FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Norrvest Bank Minnesota, N.A., As Trustee of Salomon Brothers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November 1, 1997 Without Recourse 505 South Main Street, Suite 6000 Orange, CA 92868 Plaintiff VS. Brian M. Morrow Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 Defendant(s) Attorney for Plaintiff : Cumberland COUNTY :COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 99-6988 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DANIAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Brian M. Morrow and Donna L. Morrow, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 10/1/99 to 1/04/00 $68,833.03 $1.661.76 TOTAL $70,494.79 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237. 1, co attached. ?,L7 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: fit- fi PRO PRO THY V "TI [IS FIRM IS A I)Elrr COI.LF.CrOlt A7"I'E\II'TING'ro COLLECT A DEBT AND ANY INFOItmxno q OBTAINED will, BE USED FOR TIIAT I'CRPOSF.. IF YOU IIAVF. PREVIOUSL Y RECEIVED A DISCIIARGF. IN IIANKRITI'TCV AND THIS DEBT WAS NOT ItEAFFIIt.NiEI).'rIIISCOItRFtiI'ONIIF:NCF: ISNOTANDSIIOULD NOT RECONSTRUED TO REAN ATrE.Nu rTo Co1.1.F.CT A DEBT, BIT ONLY ENFORCEMENT OF' ,\ LIEN,\G,\INSt' I'ItOi'F.ItT\'. •• FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. MORTGGAE LOAN TRUST 1997-LB6 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 WITHOUT RECOURSE Plaintiff VS. BRIAN M. MORROW DONNA L. MORROW Defendant TO: DONNA L. MORROW 350 WEST PENN STREET CARLISLE, PA 17013 DATE OF NOTICE: DECEMBER 21, 1999 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS . CIVIL DIVISION CUMBERLAND COUNTY . N0.99-6988-CIVIL THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE You are in default because you have failed 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 (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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12298 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. MORTGGAE LOAN TRUST 1997-LB6 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 WITHOUT RECOURSE Plaintiff VS. BRIAN M. MORROW DONNA L.' MORROW Defendant(s) TO: BRIAN M. MORROW 350 WEST PENN STREET CARLISLE, PA 17013 DATE OF NOTICE: DECEMBER 21, 1999 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-6988-CIVIL THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 (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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 239-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plva Philadelphia, PA 19102 (215) 563-7000 Norwest Bank Minnesota, N.A., As Trustee of Salomon Brothers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-1,136 Under Pooling and Servicing Agreement Dated as of November 1, 1997 Without Recourse Plaintiff Brian M. Morrow Donna L. Morrow VS. Attorney for Plaintiff : Cumberland COUNTY : Court of Common Pleas : CIVIL DIVISION : NO. 99-6988 Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Brian M. Morrow is over 18 years of age and resides at 350 West Penn Street, Carlisle, PA 17013. (c) that defendant Donna L. Morrow is over 18 years of age, and resides at 350 West Penn Street, Carlisle, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. A FRANK FEDE MAN Attorney for Plaintiff .. 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UMM HAD 8869-66 'ON NOISIAI4 '11AD scald uoulwoa Jo l.lnoO : A.LNCIOJ puelaagwnO : asanoaag lnogllM L661 11 .(agwanoN So se pal(:Q luawaaa2V 3ulaIAA3S puu 2u1100d .lapufl 99'I-L661 lsnay ueo l AuBaaoW 'aul `IIA salli.(naaS aSe?lAOW s.Jagloag uowolcS Jo aalsn.I L sV''V'N'nlosauutWyueg lsaeuoN (paslAaM - 9£Z 'oN aJnpaao.(d I!A!O Jo alnH) .. v+ ??- i? _. 9? F r _ ?\? `gyp ,`' ? ? ? M\ '. I 1 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Norwesl Bank Minnesota, N.A., as Trustee of Salomon Cumberland County Brothers Mortgage Securities VII, Inc. Mortgage Lam Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November 1, 1997 Without Recourse No. 99-6988 Civil Plaintiff, V. Brian M. Morrow Donna L. Morrow Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/4/00 - 6/7/00 (per diem - $11.59) $70,494.79 $1.796.45 and Costs $72.291.24 TOTAL FRA K F ER AN, ESQUIRE TW PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. oz o z O uu > > W, u . 7 u A u i ? a Z y.?aQ W Z Z ?? r Q W O C,y Vc• ++ (/I Q v Q\ G G O L V y w °., Q ° o Z ?nLa3 ?? ?w U w o ° F" oa ? 3 on 00 to y U ` F CGA s.a ?? 1G 0. ? o a Z O a ? o OuO VI u a? n.o'° a? U Ca co x=? .• W W m ° ° `0 > W b w Y u u Y •My O G ^ J u' r oM AMU u L _ M L ? O ?aa • Y y u =3= ` N e qMU H V v 4 u G H N a E L u a ° a s 3 DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected Situate in the Fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn Street, and 209.85 feet East of the Eastern line of Franklin Street; thence along lands now or formerly of William D. Shultz, South 15 degrees 58 minutes West 120.00 feet to a stake on the Northern side of a 12 foot wide public alley; thence along the Northern side of said public alley North 74 degrees 00 minutes West 44.83 feet to a stake; thence North 15 degrees 58 minutes East 120.00 feet through the partition wall of a concrete block garage and the partition wall of 350 West Penn Street and 352 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet South of the Southern curb line of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street; thence South 74 degrees 00 minutes East 44.33 feet to a 1/4 inch drill hole, the place of beginning. HAVING thereon erected a two story frame dwelling house on the Eastern portion of which is included herein and frame garage and Eastern half of a concrete block garage: being known and numbered as 350 West Penn Street, Carlisle, Pennsylvania. Tax Parcel i# 05-20-1798-212 TITLE TO SAID PREMISES IS VESTED IN Brian M. &Iorrow and Donna L. Morrow, husband and wife by Deed from Ronald L. Morrow and Loretta A. Morrow, his wife dated 5/31/96, recorded 6/10/96, in Deed Book 140, Page 731. - .J t j ?rZQ \ \ ` / __ ` O AZ3 d 0 0 G1 ?` ?- to O" ? ? ? N Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November I, 1997 Without Recourse Plaintiff, V. Brian M. Morrow Donna L. Morrow Defendant(s). NO. 99-6988 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Norwest Bank Minnesota N.A. as Trustee of Salomon Brothers Morteaee Securities VII, Inc. 1997 Without Recourse, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 350 West Penn Street, Carlisle, PA 17013. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Brian M. Morrow 350 West Penn Street Carlisle, PA 17013 Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION None 4. 5. NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Central Money 8840 Stanford Blvd. Mortgage Company Suite 2200 Columbia, MD 21045 Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant Domestic Relations of Cumberland County 350 West Penn Street Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 16, ?- DATE FRX K FEDERMAN ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, N.A., as Trustee of Salommi Brothers Mortgage Securities V11, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November I, 1997 Without Recourse Plaintiff, V. Brian M. Morrow Donna L. Morrow Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6988 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ?? /lam FR K FEDERMA , ESQUIRE A eorney for Plain iff Norwesl Bank Minnesota, N.A., as Trustee of Salomon Brotbers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November 1, 1997 Witbout Recourse Plaintiff, v, Brian M. Morrow Donna L. Morrow Defendant(s). TO: Brian M. Morrow Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 CUMBERLAND COUNTY No. 99-6988 Civil February 16, 2000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 350 West Penn Street. Carlisle. PA 17013, is scheduled to be sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 170]3, to enforce the courtjudgment obtained by Nonvest Bank Minnesota. N.A., mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. I You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land with the improvements thereon erected Situate in the Fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn Street, and 209.85 feet East of the Eastern line of Franklin Street, thence along lands now or formerly of William D. Shultz, South 15 degrees 58 minutes West 120.00 feet to a stake on the Northern side of a 13 foot wide public alley; thence along the Northern side of said public alley North 74 degrees 00 minutes West =4=1.83 feet to a stake; thence North 15 degrees 58 minutes East 120.00 feet through the partition wall of a concrete block garage and the partition wall of 350 West Penn Street and 352 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet South of the Southern curb line of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street: thence South 74 degrees 00 minutes East 44.83 feet to a 1/4 inch drill hole, the place of beginning. HAVING thereon erected a two story frame dwelling house on the Eastern portion of which is included herein and frame garage and Eastern half of a concrete block garage: being known and numbered as 350 West Penn Street, Carlisle, Pennsylvania. Tax Parcel # 05-20-1798-212 TITLE TO SAID PREMISES IS VESTED IN Brian M. Morrow any and wife by Deed from Ronald L. Morrow and Loretta A. Morrow, recorded 6/10/96, in Deed Book 140, Page 731. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORWEST BANK MINNESOTA, N.A., AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC. MORTGAGE LOAN TRUST 1997-LB6 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1, 1997 WITHOUT RECOURSE Plaintiff CIVIL DIVISION VS. BRIAN M. MORROW DONNA L. MORROW Defendants No. 99-6988 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for NORWEST BANK MINNESOTA N.A. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII INC. MORTGAGE LOAN TRSUT 1997-1-136 UNDER POOLING AND SERVICING AGREEMENT DATED AS OF NOVEMBER 1 1997 WITHOUT RECOURSE, hereby verify that on FEBRUARY 18 2000 AND APRIL 28, 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on FEBRUARY 18. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. / FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: May 1, 2000 Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc. Mortgage Loan CUMBERLAND COUNTY Trust 1997-LB6 Under Pooling and Servicing Agreement COURT OF COMMON PLEAS Dated aS of November 1, 1997 Witlmal Recourse V. Plainliff, CIVIL DIVISION . Brian M. Morrow NO. 99-6988 Civil Donna L. Morrow Defendant(s). , AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) .•.•??? ,ecwurse, Plaintiff in the above action, by its attorney, FRANK FEDERMAN,vel ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was tiled the following information concerning the real property located at 350 West Penn Street Carlisle PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Brian M. Morrow 350 West Penn Street Carlisle, PA 17013 Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 2• Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be Same as above reasonably ascertained, please so indicate.) 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real } property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None i r rh I r i 1 1? 4. 5. 6. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Central Money 8840 Stanford Blvd. Mortgage Company Suite 2200 Columbia, MD 21045 IMC Mortgage Co., a/k/a 5901 E. Fowler Avenue Industry Mtg. Co. LP, Tampa, FL 33617 d/b/a Corewest Bank, d/b/a Corewest Mtg. Co., d/b/a NLG Mtg. Co. Altegra Credit Company 150 Allegheny Center Mall Pittsburgh, PA 15212 Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 350 West Penn Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. !i Mav 1. zooo -q.r(2e,,& .vl ..._. DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 0 0 a Z n N S c ?; o. L g!' = a e d •QUL F ? m 3 s LL F C- q L ?' N V f0 VI 9 y u ? L V 9 y zao T -T u V ?; RE y ou / o 4 ' c , 1 J } Z > ' p t U ? ` D o ll C ? C n 0 n u y o F a F o ?, a F U c vl "' G w ?> eo F Z xn F ^ F t47n f? v Gt7C N G O°r y Co u ma G oa O = 8 U 1 tl ?IL OG O a? U tsj 7. °= z ii= aj a= _ -It r r mo F Z 'G Z W n u ? U °D O pU ,? c F nU O ? < nV N' t-z z o O t X E 'Z V 9 C L N c s b' u rl n v h ? n oo a o = n f1 '? vi Z '? u o U.. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: FFnFRMAN ANT). PHFT AN TWO PENN CENTER PLAZA, SUIT ¢f3 _, sf etPtrr?-Pa-r?-rumor ?° One piece of ordinary mail addressed to: `r- IMC MORTGAGE CO., addressed INDUSTRK-. l v; n°rB" faT?GaRBWE?T $#B!E< D/B/A COREWEST MORTGAGE CO., D/B/A 5901 E. FOWLER AVENUE TAMPA, FL 33617 PS Form 3817, Mar. 1989 U ?. POSTAL SERVICE CERTIFICATE UI- NIAILINL3 MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: FEDERMAN AND DHE AM TWO PENN CENTER PLAZA, SUITE 900 P!11T=ADEzP!nir' PA 19102 ?i. JJ ry! One Piece of ordinary mail addressed to: • . C' ALTEGRA CREDIT CO. i II 150 ALLEGHENY CENTER MALL 111 Q 0 1N ,.a.. L. em N •r." rrt b .o CD III PS Farm 3817. Mar. 1989 J . i.:ot: SENDER: I also wish to receive the • check W. at rqn n nu roewre ReSlcvW De] a Y. following services (for an extra fel • pnnt ,our M1vne .vtl aooress on IN laerse or INS farm so Itut x Can return INS C.va I a you. • AHNSP, t%m form to on, front of Itn mak ace. or an IM to%k d spin oces net "Fret Restricted Deliver y • The Return Receipt walla le ." IM aIti was del.lod arm file Dale oelhwad. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number BRIM H. NWROW P 973 738 691 3SO X85"T PEEN mwyT 4b. Service Type CARLISLE,' PA 17013 ^ , / CERTIFIED OA K ) ( ? 7. Date of Delivery 5. Received By: (P, W PA FORM 3811, - Domestic Return 'Rece ..ii 1?/??iiliiii li ll ii; i I1; - N T, -11 b M r- m r- 07 CL A p' Co m r, m r` Er a ET"n" nSTh6TEDCEV'Env j,e GE"T RVICE _ CERi FED F[E • nETUrer RECE'I•T FETAL x$twE Arm FEES :JIJC-::if .-. aC[:dUT 330 1,1:,!S STREST Q.-tLISLEV, PA L70-13 IDMK PS FORM 3800 US Postal Service or a1 u"'.. 00 M ? -' Receipt for ` Certified Mail w ::A.^.E RETURN ,ESIF1,TEDCEUX? RECE.FT SERVICE <E=T:[ED[EE-UQUmr FfGE?T ..T iM.:AEE Y.O FEES :..'. s.._ . 'A ..... OmK V ? •7 ? 1 ? ' Q7 s PS FORM 3800 US Postal Service Receipt for Certified Mail c) Gj L7 T ::.'U7 J 1 G L U a ? ?+1{ r Bank of Minnesota, N.A. -vs- Brian Morrow and Donna Morrow In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-6988 Civil R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 16.35 Advertising 15.00 Posting Bills 15.00 Law Library .50 County 1.00 Mileage 3.10 Certified Mail 1,17 Levy 15.00 Postpone Sale 40.00 Surcharge 30.00 Share of Bills 24.80 Law Journal 353.75 Patriot News 2.$$,30 $ 833.97 Pd by Atty 09/07/00 Sworn and subscribed to before me le4la? This Lday of R. Thomas Kline, Sheriff 2000, A.D. 7}u4- -? By r thonotary 7 Real Estate Deputy 9.7 03 „ o/ 014 Norwest Bank Minnesota, N.A., as Trustee of Salomon CUMBERLAND COUNTY Brothers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement No. 99-6988 Civil Dated as of November 1, 1997 Without Recourse Plaintiff, v. Brian M. Morrow Donna L. Morrow Defendant(s). TO: Brian M. Morrow Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 February 16, 2000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE M BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 350 West Penn Street. Carlisle PA 17013, is scheduled to be sold at the Sheriffs Sale on June 7.2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Norwest Bank Minnesota N.A. as Trustee of Calmmnn n-#Le.... Am ------- o_____,... .,.. _ _ _ --- --••• •- •- .-.. «.. _.? v? nUvem Der 1 lyy/ Without Recourse (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 n_: ALL THAT CERTAIN tract of land with the improvements thereon erected Situate in the Fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn Street, and 209.85 feet East of the Eastern line of Franklin Street-, thence along lands now or formerly of William D. Shultz, South 15 degrees 58 minutes West 120.00 feet to a stake on the Northern side of a 13 foot wide public alley; thence along the Northern side of said public alley North 74 degrees 00 minutes West 44.83 feet to a stake; thence North 15 degrees 58 minutes East 120.00 feet through the partition wall of a concrete block garage and the partition wall of 350 West Penn Street and 332 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet South of the Sourhern curb line Of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street: thence South 74 degrees 00 minutes East 44.83 feet to a 1/4 inch drill hole, the place of beginning. HAVING thereon erected a two story frame dwelling house on the Eastern portion of which is included herein and frame garage and Eastern half of a concrete block garage: being known and numbered as 350 West Penn,Street, Carlisle, Pennsylvania. Tax Parcel R 05-20-1798-312 TITLE TO SAID PREMISES IS VESTED IN Brian ivl. Morrow and Donna L. Morrow, husband and wife by Deed from Ronald L. Morrow and Loretta A. Morrow, his wife dated 3/31/96, recorded 6/10/96, in Deed Book 140, Page 731. Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc. Mortgage Loan Trust 1997-LB6 Under Pooling and Servicing Agreement Dated as of November 1, 1997 Without Recourse Plaintiff, V. Brian M. Morrow Donna L. Morrow Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6988 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Norwest Bank Minnesota. N.A., as Trustee of Salomon Brothers Morteaee Securities VII, Inc. 1997 Without Recourse, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 350 West Penn Street. Carlisle, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Brian M. Morrow 350 West Penn Street Carlisle, PA 17013 Donna L. Morrow 350 West Penn Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Central Money 8840 Stanford Blvd. Mortgage Company Suite 2200 Columbia, MD 21045 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 350 West Penn Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Februarv 16. 2000 ?- DATE FRANK FEDERM- ESQUIRE Attorney for Plaintiff, e ?? ?1. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) COUNTY: TO THE SHERIFF OF Cumberland To satisfy the debt, interest and costs due ? Brothers Mortgage Securities VII, Loan NO. 999g? CIVIL 1VXTerm CIVIL ACTION -LAW N.A PA (1) You are directed to levy upon the property of the defendant(s) and to sell ^1 naar i nri nn - (2) You are also directed to attach the property 01 the defendant(s) not levied upon in the possession of - as follows: paing any debt m delivering any property of the defendant(s) or otherwise disposing and to or for the account of)ththat: (a) an e defendant() and fro thereof; (3) Itproperty of the defendant(s) not levied upon an subject to attachment isfound inthe possessionof anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. $.50 L.L. Amount Due 1/4/004946/7/00 Interest $1 79 49 and Casts Atty'sComm ? % Atty Paid $115.10 Plaintiff Paid Date: February 22, 2000 REOUESTING PARTY: Name Frank Federman Esq. Address: Two Penn Center Plaza finite 209 Philad lnh'i^ PA 1910 Attorney for: Plaintiff - Telephone: -,-563 - Supreme Court ID No. 12243 Due Prolhy $1 00 Other Costs Curtis R. Long Prothonotary, Civil Division = - Deputy i REAL ESTATE SALE Cn? the sheriff levied upon the defendanis interest in the real properly situated in rl c J.a Q Cumberland County, Pa., known and numbered as: jvzel _ grid 1 ?, ncon,.n? 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