HomeMy WebLinkAbout04-1108MILSTEAD & ASSOCIATES, LLC
BY: Corina M. Connors, Esquire
ATTORNEY ID NO.: 83509
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attomeys for Plaintiff
Norwest Bank Minnesota, National Association, as Trustee
For the Amresco Residential Securities Mortgage Loan
Trust 1998-2, Under the Pooling and Servicing Agreement
Dated as of June 01, 1998 C/O Wendover Financial
Services
P.O. Box 26953
Greensboro, NC 27419
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants of
119 Yorkshire Drive
Mechanicsburg, PA 17055
Defendant
: COURT OF COMMON PLEAS
: CUMBERLAND COUNTY
:
:
:
CIVIL ACTION
COMPLAINT IN
EJECTMENT
MILSTEAD & ASSOCIATES, LLC
BY: Corina M. Connors, Esquire
ATTORNEY ID NO.: 83509
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association, as Trustee:
For the Amresco Residential Securities Mortgage Loan :
Trust 1998-2, Under the Pooling and Servicing Agreement:
Dated as of June 01, 1998 C/O Wendover Financial :
Services :
P.O. Box 26953
Greensboro, NC 27419
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants of
119 Yorkshire Drive
Mechanicsburg, PA 17055
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
: NO.:
.
:
CIVIL ACTION (REAL PROPERTY)
LEASE OR EJECTMENT
You have been sued in Court. If you wish to defend against the claims set forth on 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 an attorney and filing in writing with the
Court, your defense or objects 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 claims or
relief requested by the Plaintiff. You may lose money or personal 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.
Lawyer Referral Service
Lawyers Referral Service of the Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
MILSTEAD & ASSOCIATES, LLC
BY: Corina M. Connors, Esquire
ATTORNEY ID NO.: 83509
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association, as Trustee
For the Amresco Residential Securities Mortgage Loan
Trust 1998-2, Under the Pooling and Servicing Agreement
Dated as of June 01, 1998 C/O Wendover Financial
Services
P.O. Box 26953
Greensboro, NC 27419
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants of
119 Yorkshire Drive
Mechanicsburg, PA 17055
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
COMPLAINT IN EJECTMENT
1. Norwest Bank Minnesota, National Association, as Trustee for the Amresco Residential
Securities Mortgage Loan Trust 1998-2, Under the Pooling and Servicing Agreement Dated as of
June 01, 1998 C/O Wendover Financial Services. (herein referred to as "Plaintiff') is a bank,
conducting business under the laws of the Commonwealth of Pennsylvania and brings this
Ejectment action against Debra Dee Reed and Known/Unknown Occupants of 119 Yorkshire
Drive, Mechanicsburg, PA 17055 (hereinafter referred to as "Defendants").
2. Defendants are the individuals occupying 119 Yorkshire Drive, Mechanicsburg, PA
17055 ("premises") more fully described in the legal description attached as Exhibit "A".
3. Plaintiff is the record owner of the premises where Defendants reside, having filed a
Complaint in Mortgage Foreclosure proceeded to judgment in that action and acquired Title to
the premises by a Sheriff Sale, which took place on December 10, 2003 in favor of Norwest
Bank Minnesota, National Association, as Trustee for the Amresco Residential Securities
Mortgage Loan Trust 1998-2, Under the Pooling and Servicing Agreement Dated as of June 01,
1998 C/O Wendover Financial Services. Please see a copy of the filed Sheriff Deed attached
hereto as Exhibit "B".
4. The Defendants have no valid legal right to possession and Title to the premises.
5. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants.
WHEREFORE, Plaintiffrequests that this Court enter a Judgment for Possession against
the defendants, Debm Dee Reed and Known/Unknown Occupants of 119 Yorkshire Drive,
Mechanicsburg, PA 17055.
Corina M. Connors, Esquire
#83509
VERIFICATION
I, Corina M. Cormors, hereby certify that I am an Attorney for Plaintiffand am
authorized to make this verification on Plaintiffs behalf. I verify that the facts and
statements set forth in the forgoing Complaint in Ejectment are true and correct to the
best of my knowledge, information and belief. This verification is made subject to the
penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities.
Title: Attorney
%~.27,2004 IO:48AM MATTLEMAN WE]NROTH AND MILLER "'NO. 7018--~P. 4
,iLL THAT CERTAIN piece or psrc .'I of larsd situat~ in Lower Allen Township, Cumberlm~i
Count)', Perm. sylvania, being bounded and described as follows, to wit:
BI, GINNING at a point on file Easter y side of Yorksh/rc Drive (50 feet widO at the dividing line
between Lots Nos. 10 and II, Block .-' on ~hc hereinafter memioncd Phal of Lots; ~cnce ~long the
clividing line bet'ween Lots Nos. 10 etd 11 on said plan North ~5 de~ees 22 minul~ East the
disla~ce of 110 feet to a point in line ~f Lot no. 16: th~ncz along thc Westerly line of Lots Nos,' 1/5
and 17 South 44 degrees 38 minutes } asr the dist~ace of 75 feet to a point at ~he dividing li~e
be~een Lo~ Nos. 9 and 10 on said tlan; thel~ce along said dividing line South 45 degrees 22
minutes West the d/stance of 110 feet to a point on the ~Sasterly side of Yorkshire Drive; t~.ea~e
along said Drive North 44 detrees 38 minutes West ~he distance of 75 feel to a point, ~he place of
B~ginning,
BEING Lot No. 10, Block !~ on Pla~ qo. 7 of Windsor Park, also known as Orchard Cres~: Ma.no/,
az recorded in Plan Book 19, Page 44
BEING known as 119 Yorkshire Driw,
Tax Pzrcel ~11-2~.-0793-071
MAR. 10,2004 3:!3PM
MATTLEMAN WEINROTH AND MILEER
Parcel No. 13-24-0793-071
Know all Men by these Presents
N0.7634 P, 3
:'!L'COR:;.Z~ OF D£ED$
"-'.'.' '.i"~LANp OOUNTY~; ,,,
· "! dfiN 30 fll 8 38
That I, R. Thomas Kline, Sheriffof the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of $1.oQ, (one Dollar), to me in hand
pa/d, do hereby grant and convey to Norwest Bank M/nnesota, National Association,
as Trustee for the Amresco Residential Securities Mortgage Loan Trust
REAL F. STATE SALE No. 53
Writ No. 200~.2100
CMl Term
Nontte~ Bank Minnesota,
NatiOnal AssoeiaUen, as
Trustee for the Amresao
Residential Seouritles
· MorlF~e Loan Trust 1998-2,
Under The Pooling and
Se~vlcing Agreement Dated
a~ of .luna 1, 1998
C/O Wendover Financial
v~
Debts Dee Reed
At~. Sharon Moq~en
DE$C~[PFION
ALL THAT CEP, TA,~' piece or
panel of la~d situate
To--hip, Cumberland
P~ylv~
d~ ~ ~ ~ wi~
B~G at a ~t on
Hastily s~de of York~ Drive
(50 F~et wi~e)
Block E on ~e h~ma~er
mendon~
nl~ ~ divi~fn
~ Nos, I0 ~d 11 On ~aid
· e dis~ of H0 f~ ~ z ~t
· e W~ly line of~ No~. I~
'~d 17 Sou~
~U~ ~sgt ~ dist~ce OF 75
fe~ ~o a p~t at ~z d~g I~e
~ ~ ~os. 9 ~d 10 o~
~id PI~; ~en~ ~ong said ,,
di~g line Seu~ 45 de~ea 22
~u~ West ~e ~e of 110 '
f~ to a ~int on &e E~ side ,
of Yo~im ~ve;
s~d Dfiv~ No~ ~ d~es 38
~utea W~ ~e dis~ of
MAR. lO, 2004 3:13PM MAT~L~MAN WEINROTH AND MILLER NO, 763& P, 4
Tb.¢ same having been sold by me to the said grantee on the 10th day of December Armo
Domini Two Thousand and Three (2003) a/~er due advertisement according to law,
under and by Virtue ora Writ o£Execution issued on the 10th day of Seutember Anne
Domini 2003 out of thc Court of Common Pleas o£Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and One (:2001) Number 2100 at the suit of ~Torwest Bank
Minnesota. National Association. as Trustee for the Amrcsco Residential Securities
Mortgage Loan Trust 1998-2, Under the Pooling and Servicing Agreement Dated as
of June 1~'19.98 edo Wendover Financial Services against Debru Dee Reed
MAR. lO, 2004 3:147M MATTLEMAN WEINROTH AND MILLER NO, 7634 P, 5
In Witness Whereof, I have hereunto affixed my signature th~sl 6th day of J~.nuar¥
Anne Domini ~o Thous~d ~d Four (2004) ~.~.~ ,,~' .... --~' ~ ~ ?
R.~om~ Kline, She~ff
Commonwealth of Pennsylvania, ss.
County of Cumberland
Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common
Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline,
Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said de~ might be recorded.
Witness my hand and seal of said Court, this 16th day of Jan. Anno Domini
Two Thousand and Four (2004)
261 P, 1578
f' ~c u~ P ~'~ ~;'~ v
j ~COM~ION~?¢~r'~ ~.~"*'."
I hereby ce~fy ~at the residence
~d Post 0fflee address of the
Within ~t~ is
~.O. Box 70808
Charlo~ NC 28272
! C~cd~'y this to be recorded
h'~ Cu.tr~bcrland County PA
i'. "': ~ ;J *;,'~..~
SHERIFF' S RETURN -
CASE NO: 2004-01108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NORWEST BANK MINNESOTA NA
VS
REED DEBRA DEE ETC
REGULAR
KENNETH GOSSERT ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - EJECTMENT
REED DEBRA DEE
DEFENDANT , at 2050:00 HOURS,
at 119 YORKSHIRE DRIVE
MECHANICSBURG, PA 17055
DEBP~A DEE REED
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 16th day of March , 2004
by handing to
- EJECTMENT
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this ~g_ day of
'~ ~OV A.D.
! t Prothonotary
So Answers:
R. Thomas Kline
03/17/2004
MILSTEAD & ASSOC
Mi~stead & Associates, LLC
BY: Corina M. Connors, Esquire
Attorney ID# 83509
Woodland Fails Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
856-482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association,
As Trustee for the Amresco Residential
Securities Mortgage Loan Trust 1998-2, Under
The Pooling and Servicing Agreement dated
As of June 01, 1998, C/O Wendover Financial
Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 04-1108 Civil
PRAECIPE TO ENTER
JUDGMENT FOR POSSESSION
TO THEPROTHONOTARY
Kindly enter Judgmem in favor of Plaintiff, Norwest Bank Minnesota, Nationai Association, as
Trustee for the Amresco Residential Securities Mortgage Loan Trust 1998-2, Under the Pooling and
Servicing Agreement dated as of June 01, 1998 C/O Wendover Financial Services, and against the
Defendants, Debra Dee Reed and Known/Unknown Occupants of 119 Yorkshire Drive, Mechanicsburg PA
17055, for failure to Answer the Complaint in Civil Action - Ejectment.
Service on made on Defendants, Debra Dee Reed and Known/Unknown Occupants of 119 Yorkshire
Drive, Mechanicsburg PA 17055 via Sheriff of Cumberland County on March 16, 2004.
Mechanicsburg, PA 17055.
Kindly enter Judgment as to Possession of the property located at 119 Yorkshire Drive,
Milst~d ~l~ssoci.ate~/~ ////~
Corina M. Connors, Esquire #83509
Mi}stead & Associates, LLC
BY: Corina M. Connors, Esquire
Attorney ID# 83509
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
856-482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association,
As Trustee for the Amresco Residential
Securities Mortgage Loan Trust 1998-2, Under
The Pooling and Servicing Agreement dated
As of June 01, 1998, C/O Wendover Financial
Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants
Defendant(s)
: COURT OF COMMON PLEAS
: CUMBERLAND COUNTY
_-
..
:
No.: 04-1108 Civil
AFFIDAVIT OF ADDRESSES
STATE OF NEW JERSEY:
COUNTY OF CAMDEN:
SS
I, Corina M. Connors, being duly sworn according to law, upon my oath, depose and say:
1. 1 certify that the Plaintiff's address is P.O Box 26953, Greensboro, NC 27419.
2. I certify that the Defendants address is 119 Yorkshire Drive, Mechanicsburg PA 17055.
3. 1 certify that the foregoing information is true and correct to the best of my knowledge,
information and belief.
~d~,stead & Associates, LJt~C
Attorney I.D. No. 83509
Mi}stead & Associates, LLC
BY: Corina M. Cormors, Esquire
Attorney ID# 83509
Woodland Fails Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
856-482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association,
As Trustee for the Amresco Residential
Securities Mortgage Loan Trust 1998-2, Under
The Pooling and Servicing Agreement dated
As of June 01, 1998, C/O Wendover Financial
Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
: No.: 04-1108 Civil
;
;
;
;
:AFFIDAVIT OF NON-MILITARY
:SERVICE
STATE OF NEW JERSEY:
COUNTY OF CAMDEN:
SS
I, Corina M. Connors, Esquire, Attorney at Law, being duly sworn according to law, upon my oath,
depose and say:
1. That the Defendants are not in the Military, Naval of Air Services of the United States of any
other Country within the provision of the Soldiers' and Sailors' Civil Relief Action of Congress, as amended;
and
2. That the Defendants are at least 21 years of age and reside at 119 Yorkshire Drive,
Mechanicsburg, PA 17055. The affiant has ascertained the foregoing information by personal inquiry and
knowledge and makes this Affidavit with the authority.
Corina M. Cormors, Esquire
Attorney I.D. No. 83509
Mi~stead & Associates, LLC
BY: Corina M. Cormors, Esquire
Attorney ID# 83509
Woodland Fails Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
856-482-1400
Attorneys for Plaintiff
Norwest Bank Minnesota, National Association, :
As Trustee for the Amresco Residential :
Securities Mortgage Loan Trust 1998-2, Under :
The Pooling and Servicing Agreement dated :
As of June 01, 1998, C/O Wendover Financial :
Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 04-1108 Civil
AFFIDAVIT OF SERVICE
STATE OF NEW JERSEY:
COUNTY OF CAMDEN:
SS
I, Corina M. Connors, Esquire, Attorney at Law, being duly sworn according to law, upon my oath,
depose and say:
1. I am a member of the firm of Michael J. Milstead, Esquire, attorneys for Plainfiffin the above
entitled cause of action.
2. Notice, Rule 237.1 was forwarded to the Defendant(s), place of residence by regular mail on April
15, 2004 and has not been returned to this office, so it can be assumed that same has been delivered to
Defendant.
ead & Assoc~C
SHERIFF'S RETLrRN - REGULAR
CASE NO: 2004-01108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NORWEST BANK MINNESOTA NA
VS
REED DEB}lA DEE ETC
KENNETH GOSSERT ,
Cumberland County,Pennsylvania,
says, the within COMPLAI~Vf - EJECTMENT was served upon
REED DEBRA DEE
DEFENDANT , at 2050:00 HOURS, on the 16th day of March
at 119 YORKSHIRE DRIVE
MECHANICSBURG, PA 17055 by handing to
DEBRA DEE REED
a true and attested copy of COMPLAINT - EJECTMENT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
the
, 2004
together With
and at the same time directing ~e~ attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this day of
A.D.
So Answers:
R. Thomas Kline
03/17/2004
MILSTEAD & ASSOC
Prothonotary
OFFICE OF THE PROTHONTARY
COURT OF COMMON PLEAS
Prothonotary
Debm Dee Reed and Known/Unknown Occupants of
119 Yorkshire Drive, Mechanlcsburg, PA 17055
Date of Notice: April 15, 2004
Norwest Bank Minnesota, National
Association, as Trustee for the Amresco
Residential Securities Mortgage Loan Trust
1998-2, Under the Pooling and Servicing
Agreement. dated as of June 0l, 1998 C/O
Wendover Financial Services
Plaintiff
Debra Dee Reed
Known/Unknown Occupants of
119 Yorkshire Drive
Mechaniesburg, PA 17055
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 04-1108 Civil
NOTICE, RULE 237.1
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 claims set forth against you.
Unless you act within ten (I0) days fi.om the date of this notice, a judgment may be entered against
you without a heating and you may lose your property or other important fights.
You should take this paper to your lawyer at once. If you do not have a lawyer, go to or
telephone the office set forth below. This office can provide you with information about hiring a
lawyer.
If you cannot afford to hire a lawyer, this office may be able to provide you with information
about agencies that may offer legal services to eligible persons at a reduced fee or no fee.
Lawyers Referral Service
Lawyers Referral Service of Cumberland County Bar Association
32 S. Bedford Strefi~ ~ /~
Carlisle, PA 170/I~ I Q ~--//' ] ·
Noti~ lhn~ant Y~ ~ l~bt Collegium l~aeti~s Act
This is aa ntlam~ I~ collect a debt and any lnfommflon Corina M. Connors, Esquire # 83509
obtained wtll 1~ ~ foe that pm'pose. 220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
- · OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS CUMBERLAND COUNTY
Prothonotary
To:
Debra Dee Reed and Known/Unknown Occupants of
119 Yorkshire Drive, Mechanicsburg, PA 17055
Norwest Bank Minnesota, National Association, :
As Trustee for the Amresco Residential :
Securities Mortgage Loan Trust 1998-2, Under :
The Pooling and Servicing Agreement dated :
As of June 01, 1998, C/O Wendover Financial :
Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown Occupants
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
1No.: 04-1108 Civil
NOTICE PURSUANT TO RULE 236
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has
been entered against you in the above proceeding as indicated below.
Prothonotary
JUDGMENT AS TO POSSESSION
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
Corina M. Connors, Esquire
Milstead & Associates, LLC
856-482-1400
obtained w~ be ufed rot th~ purl~Je,
MILSTEAD & ASSOCIATES, LLC
BY: Corina M. Connors, Esquire
Attorney ID# 83509
Woodland Falls Corporate Park
220 Lake Drive E Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff(s)
File No.: 04.-12-02394
Norwest Bank Minnesota, National
Association, as Trustee for the Amresco
Residential Securities Mortgage Loan Trust
1998-2, under the Pooling and Servicing
Agreement dated as of June 1, 1998, c/o
Wendover Financial Services
Plaintiff
VS.
Debra Dee Reed
Known/Unknown occupants of
119 Yorkshire Drive
Mechanicsburg, PA 17055
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 04-1108 Civil
Praecipe to Satisfy Judgment as to
Possession and Discontinue and End
TO THE PROTHONOTARY:
Kindly Satisfy the Judgment as to Possession filed on April 30, 2004 and Discontinue
and End the above captioned Eviction Action without Prejudice.
Milstead & Associates, LLC
Attorney ID No.83509
WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
NORWEST BANK MINNESOTA, NATIONAL ,
ASSOCIATION, AS TRUSTEE FOR THE AMRESOO
pF~ID~'NTLA~L $ECtIRITI~9 MORTG/V~ [/~aAI TRUST
1998-2, UNDER THE POOLING AND SERVICING
AGF~.EMf~T DAT~3 AS OF JUNE 1, 1998, cpo
WmqgOV~R FINANCI~r cj~'RVIOWq
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 04-1108 Civil Term
No. Term
vs. Costs
DEBRA DEE R&t::O Att'y. $ 115.78
KNtJSN/~ OCCUPANTS OF Pl'ff (s) $
119 YORKSHIRE DRIVE
IvrvF~2~/,CSBUI3'3, P3 17055 ~ Prothy. $ 1.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of C[IW~ERrAND
County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the
following described property to:
NOF~6EST BANK MINNESOTA, NATIONAL ASSOCIATION, AS TRUSTEE FOR THE AMRESCO RESIDf~TIAL
SECURITIES MORTGAGE LOAN TRUST 1998-2, UNDER THE POOLING AND SERVICING AGREf~ENT DAT~:U
AS OF JUNE 1, 1998, C/O WENTDVER FINANCIAL SERVICES Plaintiff' (s)
being: (Premises as follows):
DEBRA DEE RF. RnD
KNOWN/~ OCCUPANTS OF
119 YORKSHIRE DRIVE
MEC~i~NIC~, PA 17055
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen-
dant (s) and sell his;her (or their) interest therein.
Date
JUNE 1, 2004
(SEAL)
CURTIS R. LONG
Pro,honor'y, Common Pleas Court of Cumberland County, Pennsylvania
By virtue of this writ, on the
1 caused the within named
_ day of
have possession of the premises described with the appurtenances, and WR iT OF POSSESS ION
RETURNED STAYED THIS DATE AS PER ATTY, PROPERTY IS VACANT.
SHERIFF'S RETURN
-DOC~TING
SURCHARGE
PROTHON.
POUNDAGE
MILAGE
20.00
1.00
,95
8.28
48.23
ADVANCE COSTS: 100.~0
SHERIFF'S COSTS~- 48.23
51.77