The URL can be used to link to this page

Home My WebLink About02-3224Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC. One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, PLAINTIFF, Cora Ann Haas DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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 of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Lancaster Bar Association 28 East Orange Street Lancaster, PA 17602 (717)393-0737 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguiemes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demand& Usted puede perder dinero o sus edades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTANCIA LEGAL. Lawyer Referral Service Lancaster Bar Association 28 East Orange Street Lancaster, PA 17602 (717)393-0737 Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC. One Jenkintown Station, Suite I04 115 West Avenue Jenkint~wn, Pa 19046 Telephone: 215-886-8790 F~x: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, PLAINTIFF, Cora Ann Haas DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 0'2. -- CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, through its attorney, Richard M. Squire, Esquire, brings this action in mortgage foreclosure upon the following cause of action: 1. Plaintiff, Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aq 1 Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse ("Plaintiff'), is a corporation with a principal place of business at 505 S. Main Street, Suite 6000 Orange, CA 92664. The Name and mailing address of each Defendant is: Cora Haas, 1323 Concord Road, Mechanicsburg, Pa 17055. On 02/24/1999 Cora Ann Haas made, executed and delivered a mortgage upon the premises hereinafter described to Ameriquest Mortgage Company, which mortgage is recorded in the Office of the Recorder of Cumberland County, in Mortgage Book No. 1523, Page 335. By Assignment of Mortgage recorded 07/24/2000 the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 649, Page 940. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original mortgagee, or is the present holder of the Mortgage by virtue of the above-described assignments. Each Mortgagor named in paragraph 3 above executed a note as evidence of the debt secured by the Mortgage (the "Note"), and is incorporated herein by reference as though fully set forth at length. The real property which is subject to the Mortgage is generally known as 1323 Concord Road, Mechanicsburg, PA 17050, (the "Mortgaged Premises"). The legal description of the Mortgaged Premises is attached hereto and marked as Exhibit "A" and is incorporated herein by reference as though fully set forth at length. The interest of each individual Defendant is as Mortgagor, Real Owner or both. If any Defendant above-named is deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through his/her estate, however, the estate of said Defendant is hereby released from liability for the debt secured by the Mortgage. 2 The Mortgage is in default because the monthly payment of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of 11/01/2001 and have not been paid. Upon failure to make such payments when due, the whole of the principal, together with the charges specifically itemized below, are immediately due and payable. The following mounts are due as of June 26, 2002: Principal of Mortgage debt due and unpaid Interest due and owing from 10/01/2001 to 06/26/2002 at 8.45%, $19.49 per diem Plus Late Charges of $45.65 per month, assessed on the 16t~ day after payment is due Corporate Advance Other Fees Escrow Advance Attorney's Fees $83,047.92 5,223.32 365.08 1,113.21 32.00 1,069.76 4,152.39 10. TOTAL $95,003.68 Interest accrues at a per diem rate of $19.49 and late charges accrue at a monthly rate of $45.65, assessed on the 16th day payment is past due for each date after the payment due date, and Plaintiff may incur additional attorney's fees and costs as well as other expenses, costs and charges collectable under the Note and Mortgage. 3 11. Notice of intention to Foreclose pursuant to 41 P.S. § 403 and Notice pursuant to the Homeowner's Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq. was mailed to each individual Defendant via regular and certified mail, return receipt requested, on 04/08/2002. A true and correct copy of said notice is attached hereto and marked as Exhibit "B" and is incorporated herein by reference as though fully set forth at WHEREFORE, Plaintiff demands judgment against Defendant Cora Ann Haas, for foreclosure and sale of the Mortgaged Premises in the amounts due as set forth in paragraph 09, namely $95,003.68 plus the following amounts accruing after 6/26/02, to the date of judgment: (i) interest at a per diem rate of $19.49; (ii) late charges of $45.65 per month assessed on the 16t~ day payment is past due; and (iii) additional attorney's fees hereafter incurred and costs of suit. ,~ Rich~:l/M. S,~e, Esqt~ire J One Jenkintown Stationy~fite 104 115 West Avenue Jenkintown, PA 19046 215-886-8790 Attorneys for Plaintiff Date: June 26, 2002 UNLESS YOU NOTIFY US IN WRITING WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4 VERIFICATION Richard M. Squire, hereby states that he is the attorney for the Plaintiff, a corporation, unless designated otherwise; that he is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiffs agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S.§4904 relating to unswom falsification to authorities. A~o~ey ;r Plaintiff ' ~ Date: June 26, 2002 AI~I~ THAT cERTaIN lot: o~ ~ound ~tuate ~n ~he to..~hip o~ Harden, County ~er~and and s~a~e o~ Penn~y!van~a. ~unded and de~:r~bed a~ ~o]lo~s. BEG~I~ a~ a point, in =he Southern line of Concord Road (50 feet wide~, which ~m~ion~d pian of ~=~; =hence along =h~ Sou:he~ Xine o~ Concord Road. :~oxth 84 de,ecs 38 minutes Eas~, i00.0 ~ee= =o a po%n= in =he division l~ne ~s. 145 and 146 on ~aid Plan: thence along the divi~o~ line between ~=u Not,. 14~ and 146. Sou=h 05 degre~ 22 m~nutes Eas~. 125.0 fee= =o a porn= in =he line of land ~w or late of H~; thence along the line o~ sai~ las= mentioned land. Sou:h NOS. 144 and 145 on ~aid Plan. aforementioned; t~eace along ~he division !Ine of ~rl~d County Recorder's O...ce :n Amc~qucs~ Moflsn~ Company P.O. Box 11000 · qsnta Am, CA 92711-1000 CORA A HAAS 1323 CONCORD RD MECHANIC~BURG, PA 17050-1957 I.,,lll,,,lll,,,.I,hll,,,,,,lll,l,.I.l,l,,,I,,I,l,,ll,ll,,,I April 08, 2002 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE STATEMENTS O]F POLICY Loan l~umb~r: 0010748721 PtOlm~y Add~ess: 1323 CONCORD RD, MECHANICSBURO PA, 17055 Cummt Lende~',~,icer: Ammiqu~t Mo~sge Company THIS FIRM IS A BEBT COLLECTOR A3~FKMPTING TO COLLECT A B~BT. THIS NOTICE IS SENT TO YOU IN AN A'rt'~MPT TO COLLECT THE INDEBTEDNESS BltlFERRED TO wltmltIN AND ANY INFORMATION OBTAINED lqtOM YOU W]T.I. BE USEB lion THAT PURPOSE. IF YOU HAVE ]PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, CORRESPONDENCE IS NOT AN~ SHOULD NOT BE CONSTRUEB TO BE AN A~ TO COLLECT A DEFF, BUT ONLY BNIK)RCY, M]:NT O1~ A Lnt~ AGAINST PROPERTY. This il an dfieid letlce that the mOrtHne mt veer bm,. is bt d,~..~.~, and b lender :--~-- J; to f~, ~ q "_-.-- ? SDecHie hf'm'mafioa abeett the Ra4ure al'the dd'auR b provided it the .*~,.k,,~_ The HOM~OWN'ER'S MORTGAGE ASSISTANCE PROf~UAM 011:MAP) may be tide ~o kelp to nye kma* This NMice exphims it~ff ~e prolram work[ ?0 see ir HEMAP ean beb. Tea must M~ET WITH A CONSUMT. U L~r,D IT COUN.qlt J.l~'G AGE~C~ wra]im 30 BAYS OF THE DATE OF Trim NOTICr. Take fids Notice ~tth 7or what you meet with ~- Comudian Amev. 'fke mme. add[~/and ubae numbe~ O! Canmm~ Crdit ~,--_~__~f A~--,do. ~ vanr County a.-'~ Ibted at ~ke ead d this No,lee. Ir you have ny en,~_dL~-_ .= veu mY call b Pewsvlvania R~.~_. Al~m~' ~ free at 1-800-342-239T.(PeFSOES wiHI hn.n sired kf~l can call ('/1~) ~lb Nob mtalmf ~ lep] im~oma~oL 1~ 7u have my quesflans, repruettatives at ~be Costmmer Credit Ceunfdbtg Aieney may be aMe to hdp explain it. You may also want ts eomaet aft tttomey h your ma. The local bar ameelallan may be able t. hdp 3ran hd · lawyer. LA NO'z'~tCAL~ON EN Al)JUNTO ES BE SUMA IMI'ORTANCIA, pUY, S AYECTA SU DEREC~[O A CONTINUAR ~IVIENDO ]EN SU CAS~ SI NO COMPRENDE EL CONTEN1DO DE ESTA NOTIYICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO M~NCIONADO ~,UU ~BA. PUEDES SER ELEGIBLE PARA U'N' PRESTAMO POR EL PROGRAMA LLAMADO 'HOM~EOWNEFS EMERGKN~' MORTGAGE ASSISTANCE PROGRAM" KL CUAL PUEDE SAt,VAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMm SU H]POTECA. HOMI:OWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM[ YOU MAY DE ELIGIBLE FOR IFI~AN;~A~ A~SISTAqNCF WHICH CAN SAR YOUR HOM~ FROM IrORE~I, O3u~E ANn HELP YOU MAKE FUTURE MORTGAGE PAYM~NT~ IF YOU COMPLY ~'l'l~t THE PROV/SION.S OF THE HOMEOWATER'S ~M~RGENCY MORTGAGE ASSISTANCE ACT OF 1~83 (rtt~ "ACT"), YOU MAY BE ELIGIBLE I~OR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS EEEN CAUSED DY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOUHAW A REASONABLE PROSPECT OIt BEING ABLE TO PAY YOUR MORTGAGE PAYM]CNTS~ IF YOU M~ET OTHER ELIGIBILITY RE(~UIREM]:NTS ESTABLISHED BY PENNSYLVANIA HOUSING FIN.ANCE AGENCY. TEMPORARY STAY OF FORECLOSUltI~ -Undcr thc Act. you are outMed to a tcmpornxy stay of forccl~orc on your moflgef~ for {l'i'tY (30) days f~mn thc datc of this Nc4ice. Dining that timc yo~ rout anuge and attcnds face-to=face [ccii~g w~h o~c of thc co~s{l~ler cr~ co{lls~litg agencies listcd at the end of this Notice. -i-HIS MEETING MUST OCCUK WFFIIIN THE NEXT (30) DAYS. ~' YOU DO NOT APPLY FOR ~l~q'C'~' i~IO~.'i~AGB ASSISTANCB, YOU MUST BRING YOUR MORTGAGE UP TO DATE. 'ltl~ PART OF NOTIC]~ CALLED ~fl~W TO CUR~ YOUR MORTGAGE DI~AUL?' EXPT..AII~ HOW TO BRING MORTGAGB UP TO DATE. CONSUMER CI~I~IT COUNSELING AGEN Cl~,,q - If you meet with on~ of the conrnnnev er ~'fl_ COUmtM. llu w nfcncv listed ai*~' cnd of this notice, flic lend~, may NOT take .__~_'_~_ ...~,~ ¥~ ~ ~ f30) ~s ~ ~ ~=~ ihe county in which thc ~,~.~nlv is located sre set forth at thc oud of this .N_~_ i,,. It is only nocessary to schedul~ one face-to-face meeting. Advise youx Icnder i~..~istely of youx htoutlon~ APPLICATION' FOR MORTGAGE ASSISTAN~Ig. _ Your moi~a~¢ Js in a de~_sit for tb~ icaMn~ set forth kter in this Notice (see followiag pages for specific information 8b0ut the n~ure ofyo~u dcfituit.) If you have tried and Homeowner's ~e~,ency MOllgege Assislance ProgmnL To do so, you must 611 mit, sign and file a completed Homeowners Bm~gcncy A~islanoe Pro. am Al~Hcsfim ~ ono of Ibc designaied cot~,,,~ credit coumehg program md thcy will assis~ you in cebnl~ a comp{cie atviicafion to thc pennfylvsn~. Homing irmance Agency' Yo~ al~lic~ion MUST be fl~i or pcemad~d withh thin~ (30) days ofyoor fac~to-facc mceth~ YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW 's]l r. Orn~R ~ PERIODS SET FORTH IN ']'H !8 LETTER, FORECLoSuRE MAy PRO ~L'ED AGAINST YOUR HOME IMMZDIATELy AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Av-~,~,h]c faads for cmergency mortgsgc a~stancc are very linked. They will be d/sbursed by the Agency under the eligigl Jly criteria established by the Act The rouns~v~.ta Housing rhance Agea~ has sixty (60) drys to ~-t~ a dechdon aftcr it rcceivcs your apl~cation. Du'inS that time. no forccionuc procecdings will I~ t~,,,,~i ....i~d you if you hay~ met ~1~ ti,.~_ requ~v,m~s sct foflh abeve. You re'Il b~ notified ~ by the Poumylyania Housing F'mance Agency of its dec{sion on your applicefiOB. Ap~108.2002 Loan Number: 0010748721 NOTE: IF YOU Ant CUBI~ t-LY PROTE(.~t-E~ BY THE FILinG OF A PKTFFION ~ P~OSES O~Y ~ ~O~D NOT BE CONtEnD ~ ~ A~T TO ~LLE~ DEBT. (If you k~ve filed baMl~p*ey yR eat i tpply rot HOW ~ ~ YOUR MOR~AGE DEFA~T ~ffn~ ituD to d~ ~F ~ D~A~T -~e M~TGAGE ~ ~ 1323 ~NCO~ ~. ~C~G, PA 17055 IS A. ~U ~ N~ ~E MO~Y MORTGAGE PA~S f~ 1 ~1/01 ~ 0~01~2 m $933.% ~r Mon~ P~ ~s I~ ~g~ or ~er ~s: ~935. T~d ~mt to ~ Ddml~ ~93S.76 B. YOU HAVE FAILED TO TA~'I~ Tflr. IrOLLOWI~GACTION ouo~uMifnotm k bie:~/A HOW TO CUSE THE DEFAULT--You may curc ~c d~nlt ~ THIRT~ (30) DAYS o~th~ ~ o~tMs no~J~ BY PAYING -,-~f~ TOTAL AMOUNT PAST DUE TO ',]f~ LE~DER, WHICH IS S693S.76 PLUS ANY MORTGAGE PAYI~fl~ITS AND LATE CUARGES WHICH BECOME DU~ DURING '~TY (30) DAY PEI~OD. PaymenU mst be mtd~ ~h,~ by cash. ~'~'~s r _J~ ~fi~ ~.r~ or order nud~ Jxiysbl~ find f~nt M: Am~quest Mortgage Company 505 Smelt ~ S~, Suite 6000 Orange. CA 92686-4509 You c~ core ouY oth~ det~nl! by la~ing the following action within THIRTY (30) DAYS of the dalc of ~s ~ ('Do ha< us~ if not a~licable.) N/A ~ YOU DO HOT CURE THE DEFAULT-If you do no~ cme thc df~b withh ~ (30) DAYS ~ ~ ~ ~ N~, ~e ~r h~ ~ e~ ~ d~ ~ -~ ~e me~ debt ~s ~ ~ &a ~ mo~ h m~ ~. ~ M ~ ~ ~ ~ ~ ~ duc k nm ~ ~ .~ (30) THE MORTGAGE IS IDRBCLOSED UPOIq' - Th~ m~tflgcd prove~ will be Mid b~ ~hc Shc~Eto psy o~ RIGHT TO em THE DEFAULT PRIOR TO ~W~,UTVF*S ~A! r -- Lfyou Imvc Bo( oumi the default wJthh ~hc 't'.tm~l'Y 00) DAY Pe~od md for~cJosorc I~calings hayo beSu, you frill lmve the r~_f~ to cum the d~mb Derformlnf any othc~ ~eou~m~,~*~ under the mflff,*** Curing your dO'walt ia the manner let forth/st this mo~lce wBI rutore your mot~tk, e to the im~ posf~ u ffyou hid meyer dermtlted~ HOW TO CONTACT 'rnE LENDtu, Amerfquort Morfgag~ Cempsuy SOS South Msht St., Suite Ph~t~ Nm mll~ Fax Number 714-24S-0S98 · I~FI~CT OF SHEB~'I~S SALE -- You should realize that & Sh~fiflus Sa]~ will cml your own~shJp of*thc mo~f~_~d ~,~rty nd yo~ right to occupy/t. If you com~nu~ to li~ im the properly after the Sh~.~l~ Sale, a lawsuit to rcmov~ you and your ~nishings and otl~r belongings could b~ rm~d by the kadet at any gme. ASSUMPTION OF MO]RI'GA~I~ _ You may or X may no~ (CH~CK. ON~ scl or transfer ymtx home to a buyer or t~.~ who will amumc thc mmtpgc debt, ~vldcd that all tiM: o~*=t-~ug payments, cimrges and atto~-y's fees and eom ~re ~ prior to or at the sale m~d that the other rcq~i~eMs of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO .q_~ .L THE PROPERTY,~O OBTAIN MONEY TO PAY OFF 'll-l~ MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF TH~ DEBT. TO HAVE THIS DEFAULT CUR]~ BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HA~E THE MORTGAGE RESTOR]~ TO T-~ SA.~fl~ POSITION AS ~ NO DEFAULT HAD OCCURRED, IF YOU CURE 'rli.t~ DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREI~. TIMES IN ANY CALENDAR. YEAR.) TO ASSERT THE NONEXIb-ii:iii'CE OF A DEFAULT IN ANY FORECLOSURE PRO(:~D1NG OR ANY ~ LAWI~UIT INSTITtFflgD UNDER TH~ MORTGAGE DOCUMHNTS, TO ASSERT ANY OTHER DI~.FI~ N'SE YOU BELII~-VE YOU iVLA. y HAVE TO SUCH ACTION BY TH~ TO Sl~q: PROTECTION UNDER THE i,m~ERAL BANKRUPTCY LAW. CONSUMER CB]EDIT COI]~'SELI~G AGENCIES SERVING YOUR COUNTY ARE ATTACH]CD Veq' Tndy Yours, Ammiqucst Moflgngc Comlmny Collections Depm~ent Loan Nunbor: 0010748721 Mm'lea by 1st Cio Mm'l md by Certified Md Homeowners* Emergency Assistance Program CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Lin~]estown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitnn Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 CommHl~ A~tion Co,nm of the Capkal Region 1514 Der~ Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franldin 31 West 3rd Street Waynnsboro, PA 17268 (717) 76~-32S5 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3SlS FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334.151S FAX (717) 334.8326 SHERIFFIS RETURN - CASE NO: 2002-03224 P COMMON-WEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS HAAS CORA ANN REGULAR RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPI~AINT - MORT FORE was served upon HAAS CORA ANN the DEFENDANT , at 1901:00 HOURS, on the 10th day of July at 45 ASHBURG DR. APT 32 , 2002 MECHANICSBURG, PA 17055 CORA ANN HAAS a true and attested copy of COMPLAINT by handing to - MORT FORE together with and at the same time directing Her attention to the contents Additional Comments 1323 CONCORD ROAD MECHANICSBURG IS VACANT. thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this ~;/~-,t day of /Pr6t honor ary So Answers: R. Thomas Kline/ 07/11/2002 RICHARD M SQUIRE Deputy Sheri/f f Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire ID No. 04267 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215 -886-8790 Fax: 215-886-8791 Attome7s for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aq 1 Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann Haas DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO 02~3224 CIVIL ACTION PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Cora Ann Haas, Defendant for her failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in the Complaint $95,003.68 Interest from 07/08/2002 to 8/13/2002 $ 701.64 TOTAL 7,705.32 / the addresses of the Plaintiff and p)~fend~tnt(s) ~1~ as.~( I herebY(2) that noticeCertifYhasthat (1)givenbeen in accordance with Ru~_.~..d~c~t_~hff. //~ ,~ a~r~. ,'M~,~,S q~ire, Esquire , Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED ,q DATE:~ ~(.3~ok,..., /,l( 2~'~ PROTHONOTARY Assook~,¢s, LLC. oo B~ug ~'" t~, ~ '~'' as ..:eS ~ll, l~c.,~1° ~. Series ~9 [tDated aS Ce~if~cat~ ggree~eZ~' nd Se~z~ ~ t recourse' 1999 ~ithoU v. Coa~t of CommOn pleas CiVil DivisiOO ~o. Cora P~a'Baas i~[echa~icsbUrg' P p~ hea~m~ ~t once. ;~ ~oU ~n ~et ~ega; ~e,v · Xa~e' ~ ,-~re ~oU ~- ~ eferral Settee to find out mu~ ~a~er ~-- r ~ssOCiat~o~ ~ancaster ~a oe Street Richard M. Squire & AssoCia}es, LLC By: Richard M. Squire, Esqmre I enkintoWn, Pa 19046 Wells FargO Bank Minnesota, N.A. s/Nm to NorweSt Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VI1, Inc., · a e pass-Through CertincateS, ,~v.-- Servicing Agreement Dated as of March 1, 1999 without recourse pLAINTIFF, Cora Ann Haas DEFENDANT. IN TIlE COURT OF coMMON pLEAS OF cuMBERLAND coUNTY, pENNSYLVANIA qO 02-3224 CIVIL ACTION is attorney for the plaintiff in the on information and belief, he has knowledge of the following factS, to Richard M. Squire, Esquire, hereby verifies that he above-captioned matter, and that the Military or Naval Service of the United States or wit: civil Relief Act of CongreSS of (a) that the defendantS is/are not in ' s' and Sailors' its Allies, or otherwise w~thm the provisions of the Soldier 1940, as amended- is over 18 yearS of age and resides at 45 Ashburg that Defendant Cora Ann Haas (b). · ade subject to the penalties of 15 Pa. C.S. Se~{ion 4904 relating to Apt 32., Mechanicsburg, PA 17055. Drive, Th,s statement ).sm /~ ~ ~ f . .ont~es. unswo als, ,cat,on t° auth /// / , ., g Richard M. Squire, Esquire I.D. No. 04267 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 ~ for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Nor, vest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann. Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR WR/T OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Issue Writ of Execution in the above matter. Amount Due Interest From 08/26/02 to 03/05/03 ~ $19.49 per diem * plus fees and costs $95,705.32 $99,427.91 Dated ALU THAT CERTAIN lot of ground ~itua~e in the to'~~ship of Nampden, County of Cumberland and State of Pennsylvan,la, bounded and de~.cribed a~ follows. BEG~ING at a point, in r..P.6'Southern line of Concord Road (50 feet wide}, which sa,~d poin~ t~ in the division line between Lo~s Nos- 144 and 145 on :he he:'einaft~ ~n~ion~d ~ian of ~tu; ~h~nce along ~h~ South~ !in~ of Con.rd Road. North B4 d~ees 38 minu=es EasC, 100.0 fee~ Co a ~int in =he division line between Nos. 145 and 146 on said Plan: =hence along the division lin~ between ~=u ~los. a~ 146, ~uth 05 degrees 22 minu~es ~s=, 125.0 feet to a ~in~ in =he line of land ~w or la=e of Hoy; thence alo~ =he line of said las~ ~n=ioned land. South 84'-d~ree~ ~8 minu~es We~, 100,0 f~e: =o a ~in~ in =he division line Edt.ween NOS, 144 and 145 on said Plan, aforemen:toned; theace alo~ =he division l~ne be=',~en ~=~, Noa. 144 and 145. North 05 degrees 22 minutes Wear, 125~9 fee: =o a ,.~tnt i~ =he Sou=horn line of Concord Road. aforementioned, a= =he po~n% anu of BEING Lot No, 145 on Plan No. ~ of BU.,.LE., HILLS. which said Plan ~"%u~rland County Recorder's O:f=c~ ~n Plan Book No. 24. at Page HAVinG =heron erected a dwell:ng house kno,,.~ and numbered as 4376 C~:%cord Road. Richard M. Squire, Esquire I.D. No. 04267 One Jenkintown Station, Suite 104 115 West Avenue Jenkin~wn, Pa 19046 Telephone; 215-886-8790 Fax: 215-886-8791 A~o_~_~..~s for Plaintiff Wells Fargo Bank Minnesota, N.A. sPo/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreemem Dated as of March I, 1999 without recourse PLAINTIFF, Cora Ann. Haas 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION DEFENDANTS. WRIT OF EXECUTION (Mortgage Foreclosure) COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): (See attached legal description) AMOUNT DUE INTEREST FROM 08/26/02 to 03/05/03 G19.49 per diem, plus fees and costs ' $95,705.32 $99,427.91 Seal of Court PROTHONOTARY BY: Date DeputyProthonotary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO02-3224 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NA s/b/m TO NORWEST BANK MINNESOTA, N.A. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC., FLOATING RATE MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 1999- aql UNDER POOLING AND SERVICING AGREEMENT DATED AS OF MARCH 1, 1999 WITHOUT RECOURSE Plaintiff (s) From CORA ANN HAAS 1323 CONCORD ROAD, MECHANICSBURG PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Y°u are als° directed t° attach the property of the defendant(s) not levied upon in the possession ofl GARNISHEE(S) as follows: and to nohfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined fi.om 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) lfpr°perty °f the defendant(s) not levied upon an subject to attachment is found in the possession of 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. Amount Due $ 95,705.32 L.L. $0.50 Interest $3,722.59 FROM 8/26/02 TO 3/05/03 - O519.49 PER DIEM PLUS FEES AND COSTS Atty's Corem % Due Prothy $1.00 Arty Paid $112.59 Other Costs Plaintiff Paid Date: DECEMBER 2, 2002 (Seal) REQUESTING PARTY: Name RICHARD M SQUIRE ESQUIRE CURTIS R. LONG Prothonotary Deputy Address: 115 WEST AVENUE SUITE 104 JENKINSTOWN PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 04267 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire ID No. 04267 One Jenkintown Station, Suite I04 115 West Avenue Jcnkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann. Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION CERTIFICATION Richard M. Squire, 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 ~~4 relating3o unswom falsification to authorities. Atg>rfiey for Plaintiff Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 4376 Concord Road, Mechanicsburg, PA 17055. Name and last known address of Owner(s) or Reputed Owner(s): Cora Ann Haas 45 Ashburg Drive, Apt. 32 Mechanicsburg, PA 17055 Name and last known address of Defendant(s) in the judgment: Cora Ann Haas 45 Ashburg Drive, Apt. 32 Mechanicsburg, PA 17055 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: Name and address of every other person who has any record lien on the property: Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA Department of Revenue Bureau of Compliance Dept. 280946 Harrisburg, PA 17128-0946 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: Tenant/Occupant 4376 Concord Road Mechanicsburg, PA 17055 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. §4904 relating to unsworn falsification to authorities. ~ ,Rjch,~,, M: )Squire, Esquire~~ / ~ West A~,enue, Suit4 Jenkintown, PA 19046 Attorneys for Plaintiff Date: November 21, 2002 Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann. Haas DEFENDANTS. Date: November 21,2002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.02-3224 CIVIL ACTION MORTGAGE FORECLOSURE To: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHER/FF' SALE OF REAL PROPERTY OWNER(S): Cora Ann Haas PROPERTY: 1323 Concord Road Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on March 5, 2003 AT 10:00 am, in the Commissioners Meeting Room, One Courthouse Square, Cumberland County Courthouse, Carlisle, PA 17013. Our records indicate that you may hold a mortgage orjudgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within I0 days after the filing of the schedule. Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. sPo/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann. Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cora Ann Haas 1323 Concord Road Mechanicsburg, Pa 17055 Your house (real estate) at 1323 Concord Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on March 5, 2003 at 10:00 AM in the Cumberland County Courthouse, Commissioners Meeting Room, One Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $95,705.32 plus interest to the sale date obtained by Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: The sale will be canceled if you pay back to Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aq 1 Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, the mount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire at (215) 886-6354. 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 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 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 the Cumberland County Sheriffs Office at (717)240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at (717)240- 6195. 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. You have a right to remain in the property until the full amount due is paid to the Sheriffand the Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 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 no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ,Rifhard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. sPo/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VIii Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Vo Cora Ann Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agre¢~nent Dated as of March 1, 1999 without recourse, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1323 Concord Road, Mechanicsburg, PA 17055. Name and last known address of Owner(s) or Reputed Owner(s): Cora Ann Haas 45 Ashburg Drive, Apt. 32 Mechanicsburg, PA 17055 Name and last known address of Defendant(s) in the judgment: Cora Ann Haas 45 Ashburg Drive, Apt. 32 Mechanicsburg, PA 17055 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name and address of last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record lien on the property: o Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Harrisburg, PA 17128-0946 Commonwealth of PA .Department of Revenue Bureau of Compliance Dept. 280946 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: Tenant/Occupant 1323 Concx)rd Road Mechanicsburg, PA 17055 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. §4904 relating to unswom falsification to authorities. By: ~ //;/ ~d~h_ar_d ~I. S~6*~r~, Es/q~e / ] 15 West Avenue~uite 104 Jenkintown, PA 19046 Attorneys for Plaintiff Date: December 10, 2002 Richard M. Squire, Esquire Richard M. Squire & Associates, LLC Attorney ID#04267 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL Ac'i'ION MORTGAGE FORECLOSURE Vo Cora Ann. Haas DEFENDANT AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attomey, Richard M. Squire, Esquire, hereby verifies that: A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for Writ of Execution on the date(s) appearing on the attached Certificates of Mailing. o A Notice of Sheriff's Sale was sent to the Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. RICHA/RD M. SQUIR~. e ASSOCIATES , Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of SalomonBrothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Corn Ann. Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.02-3224 CIVIL ACTION MORTGAGE FORECLOSURE Date: November 21, 2002 To: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF' SALE OF REAL PROPERTY OWNER(S): Corn Ann Haas PROPERTY: 1323 Concord Road Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on March 5, 2003 AT 10:00 am, in the Commissioners Meeting Room, One Courthouse Square, Cumberland County Courthouse, Carlisle, PA' 17013. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriffon a date specified by the Sheriffnot later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Wells Fargo Bank Minnesota, NA s/b/m To Norwest Bank Minnesota, NA, as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aq 1 Under Pooling and Servicing Agreement Dated As of March 1, 1999 without recourse VS Cora Ann Haas In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3224 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 2:55 o'clock PM, she served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Cora Ann Haas, by making known unto Cora Hass personally, at 45 Ashburg Drive, Apt. 32, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 06, 2003 at 8:39 o'clock P.M., she posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Cora Ann Haas located at 1323 Concord Road, 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 Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Cora Ann Haas by regular mail to her last known address of 45 Ashburg Drive, Apt. 32, Mechanicsburg, PA 17055. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This ~ day of 2003, A.D. Prothonotary So Answers: R. Thomas Kline, Sheriff ReaI EStat~lbeputy (! -- ~ AFFDAVIT OF SERVICE Plaintiff- Wells Fargo Bank Defendant(s) - Cora Ann Haas Serve at- 5-54 }'oiomac Street, Moiiiit guii~ei, FA i[343-- County- Cumberland Type of Action - Notice of Sale Complete Service by - ASAP Sale Date - March 5, 2003 Please serve defendant No.02-3224 SERVED known ' ~ Served and made to ~-{3(~- .~.~.d~ !~S defendant, on the~day of ~~:~~onwealth of Pennsylvania, in the manner described below: t'"~Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is __Adult in charge of Defendant(s) residence who refused to give name or relationship. __ Manger/Clerk of place of lodging in which Defendant(s) reside(s). .. Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other. I, [~-0., .~d[k"[r~P I {~9 _ tt23.,_.~t ~petent adult, being duly sworn according to law, depose and state. that I personally handed a tmeland correct copy of the Notice of Sale in the manner us set forth herein, tssued in the captioned case on the date and at the address indicated above. Me this _,_~,/-,~r'day of~J,~. 200~ because: ~Moved ~Unknown No Answer Vacant Other Sworn to and subscribed before me this ~ day of ,200 Notary:.__ Attorney for Plantiff Richard M. Squire, E]quire - l.D. No. 04267 115 West Avenue, Suite 104 Jenkintown, PA 19046 2 ! 5-886-8790 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State dd hereby.certify that the Sheriff's Deed in which Wells Fargo bank Minnesota N A sbm to Norwest Bk !Minnesota N A tr of salomon Brothers Mtg Securties VII Inc tr is the grantee the same having been sol~l to said grantee on the 5th day of March A.D., 2003., under and by virtue of a writ Execution issued oi~ the 2nd day of Dec, A.D., 2002., out of the Court of Common Pleas of said County as of Civil Term, 2p02 Number 3224, at the suit of Wells fargo Bk Minnesota NA sbm Norwest Bank Minnesota NA tr of Salomon Brothers Mtg Securities VII Inc Tr against Cora Ann Haas is duly recorded in Sheriff's Deed B~ok No. 256, Page 961.. IN TESTIMONY WHEREOF, I ha3e hereunto set my hand and seal of said office this F,q~ , A.D. 2003 day of Recorder of Deeds Wells Fargo Bank Minnesota, NA s/b/m To Norwest Bank Minnesota, NA, as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated As of March 1, 1999 without recourse VS Cora Ann Haas In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3224 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2002 at 2:55 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the withirl named defendant, to wit: Cora Ann Haas, by making known unto Cora Hass personally, at 45 Ashburg Drive, Apt. 32, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct cqpy of the same. Valerie Weary, Deputy Sheriff, who being duly swom according t~ law, states that on January 06, 2003 at 8:39 o'clock P.M., she posted a true copy of tl~e within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Cora Ann Haas located at 1323 Concord Road, 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 f, )llowing manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Cora Ann Haas by regular mail to her last kno~ vn address of 45 Ashburg Drive, Apt. 32, Mechanicsburg, PA 17055. This letter was mailed under the date of January 13, 2003 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 thc :,within described premises at public venue or outcry at the Courthouse, Carlisle, (~umberland County, Pennsylvania on March 5, 2003 at 10:00 o'clock A.iM. He sold tl: e same for the sum of $1.00 to Attorney Richard M. Squire for Wells Fargo Bank Minne 5ota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, S{',ries 1999aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 with~ .ut recourse. It being the highest bid and best price received for the same, Wells Fargo B~ nk Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Bro :hers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Scurries 1999aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyer inlthis execution, paid to SheriffR. Thomas Kline the sum of $785.67, it being costs. I Sheriffs Costs: Docketing $30.00 Poundage 15.40 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 12.42 Certified Mail 3. ! 0 Levy 15.00 Surcharge 20.00 Law Journal 284.00 Patriot News 244.54 Share of Bills 25.21 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $785.67 Sworn and subscribed to before me This R. Thomas Kline, Sheriff o03, ^.o. ~rc~thonotary Real Estate Deputy Richard M. Squire, Esquire I.D. N(/: 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. sPo/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under · Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann Haas IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., aS Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-~l'hrough Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated a~ of March 1, 1999 without recourse, Plaintiff in the above action, being authorized to do so, setS t~rth as of the date the Praecipe for the Writ of Execution was filed, the following information cor~ceming the real property located at 4376 Concord Road, Mechanicsburg, PA 17055. Name and last known address of Owner(s) or Reputed Owner(si: Cora Ann Haas 45 Ashburg Drive, Apt. 32' Mechanicsburg, PA 17055 Name and last known address of Defendant(s) in the judgment:, Cora Ann Haas 45 Ashburg Drive, Apt. 32 Mechanicsburg, PA 17055 Name and last known address of every judgment creditor whos~ judgment is a record lien on the real property to be sold: [ Name and address of last recorded holder of ever./mortgage of ~ecord: 5. Name and address of every other person who has any record lien on the property: o Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013' Commonwealth of PA Harrisburg, PA 17128-0946 Department of Revenue Bureau of Compliance Dept. 280946 Name and address of every other person of whom the plaintiff hhs knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 4376 Concord Road Mechanicsburg, PA 17055 ~ ~:~:~: ": .~71 verify that the statements made in this affidavit are true and con-~~e best of my kno. wledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. B: ~ ~ West A'venue, Sui3edD4 Jenkintown, PA 19046 Attorneys for Plaintiff Date: November 21, 2002 Richard M. Squire, Esquire I.D: No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage SecuritiesViI,lnc., Floating- Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse PLAINTIFF, Cora Ann. Haas DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3224 CIVIL ACTION MORTGAGE FORECLOSUR[ TO: NOTICE OF SI-IERIFF'S SALE OF REAL PROP] ;RTY Cora Ann Haas 1323 Concord Road Mechanicsburg, Pa 17055 Your house (real estate) at 1323 Concord Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on March 5, 2003 at 10:00 AM in the Cumberland County Courthouse, Commissioners Meeting Room, One Courthouse Square, Carlisle, PA 17013 to enforce the cotr ~tjudgment of $95,705.32 plus interest to the sale date obtained by Wells Fargo Bank Minnesota, N.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Date( recourse against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIF To prevent this Sheriff's Sale you must take immediate action: as of March 1, 1999 without SALE The sale will be canceled if you pay back to Wells Fargo Bank Minnesota, lq.A. s/b/m to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers. Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-aql Under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse, the mount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire at (215) 886-6354. 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 ma3' als6 aSk the Court to P°~tP°ne the sale for good cause. 3. You may 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 TAKE PLACE. 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 the Cumberland County Sheriffs Office at (717)240-6390. 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. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at (717)240- 6195. 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. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. o 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 Sheriffno later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ' ~erland and State of pe~eylvania, ~unded and . .'< u~hern li~e of Concord ~o~d (~0 fee~ wide}, which t -~neioned p!.~n o:..~__,. ,00.0 f~ec ~o a mint intne · . ' '":" on ~ai8 plan: ~hbnce alon9 ~he division {~'::' "~:~:'-14a, ~U~h 05 OeO~e~- ~- "': -,~, ~ e line of ~ai6. ~as~ ne between Nos,' 144 and 145 on said plan, aforementioned; thence aloft, be=~.~en Lots. Nos. 144 and 145. [Iorth 06 degree~ 22 in ~he Southern line'of concord Road, aforemen!ti°ned ~rl.~d county Re~rdcr's Ofi~c~ ~n plan ~ok No. 24. ~ Pa9e 13; ~VI~ =he~n e=ec=ed a dweil~n9 house kno~ and nu~ered -i point 'in ~he line of mentioned land, Sou~h ¥i~ion line Le~een the division line We~t, 125.9 fee: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO02-3224 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK MINNESOTA, NA s/b/m TO NORWEST BANK MINNESOTA, N.A. AS TRUSTEE OF SALOMON BROTHERS MORTGAGE SECURITIES VII, INC., FLOATING RATE MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 1999- aql UNDER POOLING AND SERVICING AGREEMENT DATED!AS OF MUCH 1, 1999 WITHOUT RECOURSE Plaintiff (s) HAAS 1323 CONCORD ROAD, MECHANICSBURG PA 1~055 From CORA ANN L (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 property of the defendant(s) not levied upon in t e possession ofl GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment 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 attactunent is found in the possession of anyone other than a named garnishee, you are directed to notify hingher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $ 95,705.32 L.L. $0.50 Interest $3,722.59 FROM 8/26/02 TO 3/05/03 - ~$19.49 PER DIEM PLUS FEES AND COSTS Atty's Comm % Due Prothy $1.00 ' Other Costs Atty Paid $112.59 PlaintiffPaid Date: DECEMBER 2, 2002 CURTIS R. LONG Prothonotary (Seal) By: ( ~t~ ~ d/ Deputy REQUESTING PARTY: Name RICHARD M SQUIRE ESQUIRE Address: 115 WEST AVENUE SUITE 104 JENKINSTOWN PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 04267 Real Estate Sale # 32 On December 10, 2002 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known' and numbered as 1323 Concord Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 9, 2002 Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: Controller of The Patriot News Co., a corporation organized and existing under the laws of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and Tt newspapers of general circulation, printed and published at 812 to 818 Market Street, in th aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4t 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly a their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of Ja~ l'hat he is the Asst. :he Commonwealth of in the City of Harrisburg, e Sunday Patriot-News. e City, County and State l, 1854, and September s printed and published in ~uary and the 4th and 11th day(s) of February 2003. 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 [nd character of publication are true; and nl That he has personal knowledge of the facts aforesaid and is duly authorized a empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolutiqn unanimously passed and adopted severally by the stockholders and board of directors of the said Company and sul{)sequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellane~ook "M", Volume 14, Page 317. '~ '~ ~--'~'~'""'~" ...... D PUBLICATION "' / .... ~'"'! SALE #32 / ~'~'er~m~Ll'sslon Expires june 6, 2tx~__j- / ~r~ ' "EAL E-"TATE ~al.~ NO. a~ [ ~~F_:~r~- NOTAP~ PUBLIC W~#, I~k~l,.,l~.4 Member, Pennsytvanla My commissiol 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 Probating same Notary Fee(s) Total $ 242.79 $ 1.75 $ 244.54 Publisher's Receipt for Advertising Cost i, publisher of The Patriot-News and The Sunday Patriot-N,;ws, newspapers of general e receipt of the aforesaid notice and publication costs and certifies that the same have By ................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, State aforesaid, being duly sworn, according to law, deposes and says that thc Journal, a legal periodical published in the Borough of Carlisle in the County was established January 2, 1952, and designated by the local courts as the off periodical for the publication of all legal notices, and has, since January 2, 19 issued weekly in the said County, and that the printed notice or publication al exactly the same as was printed in the regular editions and issues of the said Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 >f the County and Cumberland Law and State aforesaid, [cial legal 52, been regularly tached hereto is ~.umberland Law REAL F29TATE SALE NO. 32 Writ No. 2002-3224 Civil Wells Fargo Bank Minnesota, N./L, s/b/m to Norwest Bank Minnesota, N.P~, as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates. Series 1999-aql, Under Pooling and Servicing Agreement Dated as of March 1. 1999 without recourse VS. Cora Ann Haas Atty.: Richard M. Squire EXHIBIT 'A' ALL THAT CERTAIN lot of ground situate in the township of Hampden, Affiant further deposes that he is authorized to verify this statement ~y 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 th~ foregoing statements as to time, place and character of publication are tree. isa Marie Coyne,,/Edit0r SWORN TO AND, SUBSCRIB]~D before me this 14 .day of FEBRUA~RY, 2003