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McCABB, WEISBBRG, CONWAY & WATSON, P.C.
BYI TBRRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia. Pennsylvania 19103
(215) 790-1010
Household Finance Consumer
Discount Company
961 Weigel Drive, P.O. Box 8632
Elmhurst, IL 60126
v.
Heni-iris Morehead
425 Pawnee Drive
Mechanicsburg, Pa 17055
and
James Barry Morehead
425 Pawnee Drive
Mechanicsburg, Pa 17055
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
Number
q? 5f-S[o
(7: {~L
NOTICB
CIVIL ACTION/MORTGAGE FORECLOSURE
AVISO
You have been sued in court. If you wish to defend
llgatnst the claims set forth in the following
pages, you Il'1lst take action wIthin twenty (20) days
after thts cClq)lafnt and notice ere served, by
entering 8 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 fait to do
so the case may proceed without you and 8 judgment
may be entered Bgsinst you by the court without
further notice for any money claimed in the
conplalnt or for any other claim or relief
r~uested by the platntiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LA WYER 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
HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlfsle. PA 17013
(717) 240.6200
Le han demandado a usted en la corte. Si usted
qui ere defenderse de estas demandas exepuestas en
las pagfnas sigui~ntes. usted tfene velnte (20)
dies de plazo al partir de la fecha de la demanda V
la notlficaclon. Haee felta esentar una
c~rencfa escrite 0 en persona 0 con un obogado V
entregar a la corte en forma escrfta sus defenses 0
sus objeciones alas demandas en contra de su
persona. Sea avisado que si usted no se defiende.
la corte tomara medidas y puede continuer la
demanda en contre suva sin prevlo aviso 0
notlffcaclon. Ademes, la corte puede decidfr a
favor del demandante y requiere que usted clXl'lpla
con todas las provisiones de esta demanda. Usted
puede perder dinero 0 BUS propfedades u otros
derechos Importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDlATAMENTE. SI NO TlENE ABOGADO
o SI NO TIENE EL DINERO SUFICIENTE DE
PAGAR TAL SERVICO, VAYA EN PERSONA 0
LLAME POR TELEFONO A LA OFICINA CUY A
D1RECCION SE ENCUENTRA ESCRITA ABAJO
PARA A VERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Court Administrator
4th Floor, Cumberland County Courthouse
CarliSle, PA 17013
(717) 240-6200
Plaintiff which mortgage is recorded in the Office of the Recorder
of Cumberland County in Mortgage Book 1192, Page 426.
5. The premises subject to said mortgage is described in the
mortgage attached as Exhibit "A."
6. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due November 1995 and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
7. The following amounts are due on the mortgage:
Principal Balance
Interest 11/95 through 9/11/96
(Plus $34.38 per diem thereafter)
Attorney's Fee
Cost of Suit
Appraisal Fee
Title Search
$85,367.14
$10,925.09
$ 4,268.35
$ 225,00
$ 125.00
$ 200.00
$101,110.58
GRAND TOTAL
8. The attorney's fees set forth above are in conformity
with the mortgage documents and Pennsylvania Law and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the mortgage is reinstated prior to the Sale, reasonable
attorney's fees will be charged based on work actually performed,
9, Notice of Intention to Foreclose as required by Act 6 of
1974 (41 P.S. ~403) and notice requested by the Emergency Mortgage
Assistance Act of 1983 have been sent to Defendants by certified
mail on the date set forth in the true and correct copies of such
notices attached hereto as Exhibit "B,"
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MOKi'GAGEl
[J] IF BOX IS CIIECKED, TillS MORTGAGE IS AN OPEN-END MORTGAGI, AND SECURES FUTURE ADVANCES
19 .!1.!--' between the Mortgagor,
THIS MORTGAGE is made this 13TH day of JANUARY
HENI-IRIS MOREHEAD AND JAMES BARRY MOREHEAD
WIFE ANO HUSBANO
{herem "l3orrower J. and Mortgagee HOUSEHOLO F I NANCE CONSLMER 0 I SCOUNT COMPANY
a corporation organi:.~eJ and e.\iSling Uiiatr tllClaws of PENNSYL v AN I A
25 GI.TEWAY ORIVE , SUI TE 107. MECHAN I CSBURG , PA 17055
(he,e.n "Lender"),
The lollowing paragraph preccded by a checked box is applicable.
n WHEREAS, Borrower is indebted to Lender in the principal sum 01 $ ,
Cvia'eneed by Borrower's Loan Repayment and Security Agreement or Secondary Mortgage Loan Ag,eement dated
and any e,1ensions or ,enewals the real (herein "Note'), providing for monthly installments
of pClnclpal and .nterest, including any adjustments to the amount of payments or the contract rate jf that rate is
variable, with the balance of the indebtedness. if not snoner paid. due and payable on
[J] WHEREAS, Borrower is indebted to Lender in the principal sum of $ B5 ,000.00 ,or so much thereof
as may be advanced pursuant to Borrower's Revolving Loan Agreement dated JANUARY 13, 1994 and
extensions and renewals thereof (herein "Note"), providing for monthly installments, and Interest at the rate and under
the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a
creditlimiLstated in the principal sum above and an initial advance of $ B5 , 700.00
TO SECURE to Lender the repayment of (I) the indebtedness evideneed by the Note, with interest thereon,
including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the
payment of all other sums. with interest thereon. advanced in accordance herewith to protect the security of this
Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does
hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property
located in the County of CLMBERLANO Commonwealth
of Pennsylvania:
,
,whose address is
BRIEF LEGAL DESCRIPTION,
ALL THAT CERTAIN PROPERTY SITUATEO IN THE TOWNSHIP OF
HAMPOEN I N THE COUNTY OF CUMBERLANO ANO COIvMONWEAL TH OF
PENNSYLVANIA, BEING OESCRIBEO AS FOLLOWS: LOT 13, BLOCK G
PBV 21, PAGE 13. BEING MORE FULLY OESCRIBEO IN A OEEO OATEO
01/301B7 ANO RECOROEO 02/05/B7, AMONG THE LANO RECORDS OF
THE COUNTY AND STATE SET FORTH ABOVE, IN OEEO VOLUME 32-M
ANO PAGE 220.
TAX MAP OR .PARCEL 10 NO. 10-19-1600-89
ADORESS: 425 PAWNEE OR.
,
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which has the address of 425 PAWNEE OR,
MECHANICSBURG
ISlrectl
(City)
Pennsylvania 17055
(Zip Codel
03-01.92 Mortgage PA
(herein "Property Address");
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TOGETHER with all the improvement:> nuw or here,'lftcr ercl:lt:d on the property, and ail ea~<:meIHs, right:;,
appurtenances and rents, all ot which shall he dcemC'd 10 be and rem:lln a p,ut of the property co\'ercd by this ~fort~agc:
and all of the foregoing, togl.'ther with SJid propcn}' ({lr the Ic.:a.<;c.:hold c.';tatc if this ~Iortgagc is em a Ica5chold) are
hereinatter referrcd to as the "Property,"
Borrower co\'enant5 that Borrower is lawfully sci~cJ of the cstak htrcby conveyed and lia:. (he right to mortg,1ge, gram
and convey the Property, and that the property is unencumberl.'d. except for cnl.;um brancc!i of rct.:ord. Borrower covenants
that Borrower warrants and will defend gcncrallj' the title to the Property against all claims and demands, subject to
encumbrances of record,
UNIFORM COVENANTS. Borrower and Lender Covenant and agrec ao follows:
L Payment of Principal and Interest at Variable Rates. Thi" mortgage secu'e, all parments of p,incipal and
interest due on a variable rate loan, The contract rate of intt:n:st and payment amounts m<lY be subject to change as
provided in the Note. Borrowers shall promptl}. pay when due all amollnts required by the :'\ote,
2. Funds lor Taxes and Insurance. Suhjel.:t to applicable: Jawor w,lj\"cr by Lender, lJorrower shall pJ}' to Lender on
the day monthly payments of principal and intert:st art: payable under the r\ote, until the' :\otc is paid in full, a sum
(herein "Funds") equal to one.twelfth of the yearly ta.\eS and assessmt.:nts (including condominium and planned unit
development aSSe5.<;ments, if any) which may attain priority o\"er this ~fortgJge and ground rents on the Property, if any,
plus one-twelfth of yearly premium installments for hazard insurance, plus one-twelfth of yearly premium installments
for mortgage insurancr., if any, all as re,1sunably estimated iniriall}' and trom time to time by Lender on the basis or
assessments and bills and ,easonable estimates thereof. Borrower shall not be obligated to make such payments of Funds
to Lender to the extent that llorrower makes such payments to the holder of a prior mortgage or deed of trust if such
holder is an institutional lender.
If Borrower pays Funds to Lender. the Funds shall be held in an institution the deposits or accounts of which are
insured or l,:uaranteed by a Federal or state agencr (including Lender if Lender is such an institution). Lender shall apply
the Funds to pay said taxes, assessments, insurance premiums and ground rents. Lender may not charge tor so holding
and applying the Funds, analyzing said account or verifying and compiling said assessments and bills, unless Lender pays
Borrower interest on the Punds and applicable law permits Lender to make such a charge. Borrower and Lender may
agree in writing at the time of execution of this ~lortgage that interest on the Funds shall be paid to Borrower, and unless
such agreement is made or applicable law requires such intc:rest to be paid, Lender shall not be requirc:d to pay Borrower
any interest or earnings on the Funds. Lendc:r shall give to Borrower, without charge, an annual accounting of the Funds
showing cn:dits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are
pledged as additional ,ocuritr for the Sums sccurcd br this Mortgage.
If the amount of the Funds held by Lender. together with the future monthly installments of Funds payable prior to
the due dates of taxes, as<,;essmcnts, insurance premiums and ground rents, shall exceed the amount rcquired to pay said
taxes, assessments, insurance premiums and ground rents as they fall due, such excess shall be, at Borrower's option,
either promptly repaid to Borrower or credited to Borrower on monthly installments of Punds. If the amount of the
Funds held by Lender shall not be sufficient to pay taxes, assessments, insurance premiums and ground rents as they fall
due, Borrower shall pay to Lender any amount necessary to make up the deficiency in one or more payments as Lender
may require.
Upon payment in full of all sums secured by this Mortgage. Lende, shall pmmptly refund to Borrower any funds held
by Lender, If under paragraph 17 hereof the Property ;s sold or the Propertr is otherwise acquired by Lender. Lender
shall apply, no later than immcdiately prior to the sale of the Property or its acquisition by Lender. anr Funds held by
Lender at the time of application as a credit against the sums secured by this Mortgage.
3. Aprlication or Payment!:. Exccf)t for loan:> made pur5uant to the Pennsylvania Consumer Discount Company
Act. ail payments received oy Lender unde, the Note and paragraphs I and 2 hereof shall be applied by Lende, first in
payment of amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest, and then to the principal.
4. Prior Mortgages and Deed of Trust; Charges; Liens, Borrowe, shall perform all of Borrower's obligatIOns
under any mortgage, deed of trust or other security agreement with a lien which has priority over this l\fortgage,
including Borrower's covenants to make payments when due. Borrower shall payor causc to be paid all taxes.
assessments and other charges, fines and impositions attributable to the Property which may attain a priority over this
Mortgage, and leasehold parments Of ground rents. if anr.
5. Hazard Insurance, Borrowe, shall keep the improvements now existing or hereafter erected on the Propertr
insured against loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may
require,
!'he insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender;
provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a
form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender,
Lender shall have the right to hold the policies and renewals thereof, subject to the terms of anr mortgage. deed of trust
or other security agreement with a lien which has prioritj' over this l\fortgagc.
In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender, Lender may make proof
of loss if not made promptlr by Borrower.
rr the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 d,ys from the date
notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance hcnefits, Lender is
authorized to collect and apply the insurance procceds at I.ender's option either to restoration or repair of the Property or
to the sums secured by this ~Iortgagc.
03.01'92 Mottgege PA
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6. Preservation and Maintenance of Property; Lca.'ieholds; Condominium.'i; Planned Coil Developments.
Borrower shall keep the: Propertf in gO<:XJ repair and shall not commit waste or permit impairment or deterioration of
the ProperlY and shall campi). with the provisions of any lease if this Mortgage is on a leasehold. Ir thi, ~l"'tgage is on a
unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the
declaration or co....cnanL'i creating or gm'crninc the cundominium or planned unit dcn:lopm<.'nt. the by.Jaws and
regulations of the condominium or planned unit development. and constituent dex:uments,
7. Protection or Lender's Security. H Borrower r3ils to perform the co\'en3nts and agreements nlntained in this
Mortgage, or if any action or proceeding is commenced whil.:h materially affects I.ender's interest in the Property, then
Lender, at Lender's option, upon notice to Borrowcr, may make such appearanc~, disburse: 5lH:h sums, including
reasonable attorneys' fees, and take such action as i:; neccs.".ary to protect Lender's intere.'it.
Any amounl.. disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall
bewme additional indebtedness of Ilo((()wer 5<:curcd by this ~lo<tgafe. Unless Borrower and Lender ag,ee to other
terms of payment, such amounts shall be pa)'able ll[Xlll notice from ,ender to Borrower requesting payment thereof.
Nothing contained in this paragraph 7 shall require Lender (0 incur any expense or ~ake any action hereunder.
8. Inspection. Lender may take or cau$(: to be made reasonable entries ur.on and inspections of the Property,
provided that Lendcr shall gi,"c Borro\\'(.'r notice prior to any such inspection speCifying reasonable cause therdor related
to Lenders interest in the Property.
9. Condtmnation. "j'he proceeds of any award or claim for damages. direct or consequential, in connection with an}'
condemnation or other taking of the Property. or part thereof, or for conveyance in lieu of condemnation, are hereby
assigned and shall be paid to Lender. subject to the term' of any mortgage, deed of t,ust or other secu,ity ag,eement
with a lien which has prio,ity OVc< this Mortgage.
10, Borrower /-:ot Released; Forbearance By Lender /-:ot a Waiver, Extension of the time for payment or
modification of amortization of the sums secured by this Mortgage granted by Lender to any suc.:cessor in interest of
Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in
interest. Lender shall not be required to commence proceedings against such Successor or rcfus<: to extend time for
payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the
original Borrower and Borrower's suc.:ceS!iors in interest. Any forbearance by Lender in exercising any right or remedy
he,eunde" or otherwise afforded by applicable la". shall not be a waive, of or preclude the exercise of any such right or
remedy.
II. Successors and Assigns Bound; Joint and Sevcral Liability; Cowsigners, The covenants and agreements
herein contained shall bind, and the rights herl.:under shall inure to. thl.: respective sllccessors and assigns of Lender and
Ilormwer. subject to the pm visions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and
several. Any Borrowcr who co-signs this Mortgage. but docs not execute the Notc, (a) is cowsigning this Mortgage onty to
mortgage, grant and convey that Borrower's interest in the Pro~rty to l.ender under the terms of this Mortgage, (b) is
not personally liable on the Note or under this Mortgage. and (c) agree' that Lende, aod any other Ik>rrower he,eunder
may agree to extend, modify. forbear. or make any other accommodations with regard to the terms of this Mo,tgage or
the Note without that Borrower's consent and without releasing that Borrower or modifying thi, Mortgage as to that
Borrower's interest in the Property.
12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to
Ilorrower pmvided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail
addressed to Ik",ower at the Property Address or at sllch other address as Borrower mal' designate by notice to Lender
as provided herein, and (b) <lny notice to Lender shall be given by certified mail to Lender's address stated herein or to
such other addrl~ss ~s I.ender may dCl'iEII:lte hy notice to Borrower 3S provided hcrdn.' :by no~ic~ provid~d for in this
Mortgage shall be deemed to have been given to Borrower or Lender wben given in the manner ciel>ignated herein.
13. Governing Law; Severability. The state and local laws applicable to this ~Iortgage ,hall be the laws of the
jurisdiction in which the ProperlY is located. The foregoing sentencc ,hall not limit the applicability of Federal law to
this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflice' with applicable law, such
conflict shall not affect other provision, of this Mortgage or the Note which can be given errect without the conflicting
provision. and to this cnd the provisions of this Mortgage and the Note are declared to be severable. As used herein.
"OO5t.<;," "expenses" and "attorneys' fl.:es" include all sums to the extent not prohibited by applicable law or limited
herein.
14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this ~lortgage at the time
of execution or aftcr recordation hereof.
15, Rehabilitation Loan Agrcemcnt. Borrower shall fulfill all of Borrower's obligations under any home
rehabilitation, improvement, repair, or other 10:111 agreement which Borrower enters into with Lender. Lender, at
Lender's option, may require Borrow!.:r to eXec.:ute and deliver to Lender, in a form acceptable to Lender. an assignment
of any righlc;, claims or defenses which Borrower may ha"c against partier. who supply labor, matcri:lls or services in
connection with improvements made to the Property,
16. Transfer of thc Property. If Ik>rrower sells or transfers all or any part of the Property or an interest therein,
excluding (a) the creation of a lien or encumbrance subordinatc to thi, ~lortgagc, (b) a transfer by devi,c. descent, or by
operation of law upon the death of a joint tenant. (c) thc grant of any leasehold interest of threc years or less not
containing an option to purchase, (d) the creation of a purcllil,;,c money security interest for household appliances, (e) a
transfer to a relative resulting from the death of" Ik>rrower, (f) a tran,rcr where thc "pouse or children of the Borrower
become an owner of the property, (g) a transfer resulting from a decree of dissolution of marri:Jgc, legal separation
03.01-92 MOllgllgO PA
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PAOOl20J
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agreement, or from an incidental pro(Xrt)' settlement agreement, by which the SpoU5C of the Borrower becomes an
owner or the property, (h) a transfer into an inter vivos trust in which the Borrowe, is and ,emains a benericiary and
which does not relate to a transfer or rights or occupancy in the property. or (i) any other transfer or disposition
described in regulations p,escribed by the Federal lIome Loan Bank lJoard, Borroller shall cau'e to be submitted
information required by Lender to evaluate the transferee as if a new 10:10 were being made to the transferee. Borrower
will continue to be obligated under the :\otc and this ~fortgage unless Lender releases Borrower in writing.
If Lender does not agree to such sale or transfer, Lender may dc.:darc all of the sums sc:cllrcd by this ~lortg3ge to be
immediately due and payable. If Lender exercises such option to accelerale, Lender shi1l1 mail Borrower notice of
acccle,ation in accordance with paragraph 12 hereof. Such notice shall provide a period or not less than 30 days rrom the
date the notice is mailed or delivered within which Borroller may pay the sums declared dlle. If Borroller rails to pay
such sums prior to the expiration of S!Jch period, Lender mar, without further notice or demand on Borrower, invoke
any remedies pe,mitted by paragrap:. 17 hereor.
/'ION-UNIFORM COVENANTS. Borrower and Lender rurther cOl'enant and agree as rollows:
17. Acceleration; Remedies, Except as provided in paragraph 16 hereor. upon Borrower's breach or any
covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums
secured bv fl"i.' ~forto3''''. I coder pr;~r to a"'~"le-"f:l\" t'"..1I ...;,... 1'H't;'.,. tq Rry-o....... ...~ ""rnv:ded in
par;graph '12'he~eof S;;c;'r;:ing: i I) the b';ea~h; (i)';h~ ~~l'i~n";e~;'i;~d 'to ...u;~ -s~~h b;~~ch: -(3) -; dat~, ~otle~'~
than 30 dars rrom the date the notice is mailed to Borrower. br which such breach must be cured; and (4)
that failure to cure such breach on or before the date specified in the notice may result in acceleration of the
sums seeured by this Mortgage, foreclosure by judicial proceeding. and sale of the Property. The notice shall
further in(orm Borrower or the right to reinstate after acceleration and the right to assert in the foreclosure
proceeding the nonexistence of a default or any other derense of Borrower to acceleration and roreclosure, If
the breach is not cured on or berore the date specified in the notice, I.ender, at Lender's option, may declare
all of the sums secured by this Mortgage to be immediatelr due and parable without further demand and
may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all
expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary
evidence, abstracts and title reports.
18, Borrower's Right to Reinstate. Notwithstanding Lender's acceleration or the sums by this Mo,tgage due to
IJorrower's breach. Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage
discontinued at any time prior to entry of a judgment enforcing this ~Iortgage ir: (a) Borrower pa}'s Lender all sums
which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all
breaches of any other covenants or agreements of Borrowcr contained in this Mortgage; (c) Borrower pays all reasonablc
elt:pen~ incurred by Lender in enforcing the covenants and agreements of Borrower contained in this ~fortgage, and in
enforcing Lender's remedies as provided in paragraph 17 hereor, including. but not limited to, reasonable attorneys' rees;
and (d) IJorrower takes such action as Lender may reasonably require to assure that the lien or this Mortgage, Lender's
interest in lhe' Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired.
Upon' such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full rorce
and eHect as if no acceleration had occurred.
19. Assignment of,Rents; Appointment or Receiver, As additional security hereunder. IJorrower he,eby assigns
to Lender' ~he rents of-the, Property, providc'd r.!1at Borrower Sh3~11 prior tf) at:c.:eleration under ?ar::!j;;,~?h 17 hereof, in
abandonment of the Property, have the right to collect and retain such rents as they become due and pa}',ble.
Upon acceleration under parag,aph 7 heceor or abandonment of the Property, Lender shall be entitled to have a
receiver appointed by a court to enter upon, take possession of and manage the Propert}' and to collect the rents or the
Property including those past due. All rents collected by the receiver shall be applied first to payment or the costs of
management or the Property and collection or rents, including. but not limited to, receiver's rees. p,emiums on
receiver's bonds and reasonable attorneys' rees. and then to the sums s<'Cured by this ~lorlgage. The receiver shall be
liable to account only for those rents actually received.
20, Release, Upon payment of all SUms secured by this Mortgage, Lender shall release this Mortgage without charge
to Borrower, Borrower shall pay all costs or recordation. if any.
21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or
Federal law,
22, Interest Rate After Judgment. IJorrower agrees the interest rate payable arter a judgment is entered on the Note
or in an action of mortgage foreclosure shall be the rate stated in the Note.
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03.01.92 Mortgllglll PA PAOO1'204
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REQUEST fOR 1\0TlCE or DEI'AULT
A:'I1D FORECLOSURE UI\DER SUPERIOR
MORTGAGES OR DEEDS or TRUST
Borrower and Lende, request the holde, 01 any mortgage, deed of trust or other encumbrance with a lien which has
p,iority over this Mo,tgage to give /\otice to I-"nder. at Lender's address set lorth on page one 01 this Mortgage, 01 any delault
under the superior encum bra nee and or any sale or othcr roreclosurc action.
IN WITNESS WIIEREOF, Borrower has emuted this ~lortgage.
Witness: / . )
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reby certily that the precise address 01 the I-"ndor (Mort~a~"l Ga ~"!JJ!j;; ~~ -Borrower
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On behall 01 the Lender, Ily: Ubu./../ E. !CAUl.< b Title: BHl.llr h /VlaY/cW,.?r
COMMOJljWEALTII or PE/\I\SYLV ANIA, CUi::]{ tu.//a.rd County ss: u
I. ~ b.e.v/ 1::, KiUu.Lh , a Notary Public in and lor s~id COl)llty and state, do hereby certily that
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personally known to me to be the same person(s) whose ame(s) are subscribed to the loregoing instrument,
appearoo belore me this day in person. and acknowledge that ~ he ..'f--.-c. signed and deliveroo the said instrument as
-1-/1 e,"" free voluntary act, lor the uses and purposes therein set lorth.
Given under my hand and official seal, this /3.f:!J day 0 .J(ini-Ui. rc-; 1991.
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Return To:
Household Finance Corporation
961 Weigel Drivc
Elmhurst. II. 60126
i~G[ .'130
PA001205
NOTICE OF INTENTION TO FORECLOSE r'10RTGAGE
Customer(s): James Barry Morehead
and Heni-Iris Morehead
Address: 425 Pawnee Drive
Mechanicsburg, PA 17055
Account Number: 713303-10-888669
Date of Loan: 1/13/94 Date
Creditor: HOUSEHOLD REALTY
CORPORATION
Phone: (800)333-5848 Ext.7946
Address: 961 Weigel Dr.,P.O.
Box 8632,Elmhurst,IL 60126
of Notice: April 11, 1996
The MORTGAGE held by Household Realty Corporation, d/b/a Household
Finance Consumer Discount Company (hereinafter called we, us or ours) on your
property located at 425 Pawnee Drive, r~echanicsburg, Pennsylvania, IS IN
SERIOUS DEFAULT because you have not made the monthly payment of $15,66 for
the month of December of 1995 and $1,099.00 each for the months of January,
February, March and April of 1996 inclusive. Late charges (and other charges)
have also accrued to this date in the amount of $none. The total amount now
required to cure this defaul t, or in other .,ords, get caught up in your
payments, as of the date of this letter is $4,411.66.
You may cure this default within THIRTY (30) days of the date of this
letter, by paying to us the above amount PLUS any additional monthly payments
and late charges which may fall due during this period, Such payment must be
made either by cash, cashier's check, certified check or money order, and
made at 961 Weigel Drive, P.O. Box 8632, Elmhurst, 11, 60126, Payment may be
made by mail, but must be received in our office by the time specified by
this notice.
If you do not cure the default within THIRTY (30) DAYS, we intend to
exercise our riqht to accelerate the mortqaqe pavments. This means that
whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to payoff the original mortgage in
monthly installments. If full payment of the amount of default is not made
within THIRTY (30) DAYS, we also intend to instruct our attornevs to start a
lawsuit to foreclose your mortqaqed propertv. If the mortqaqe is foreclosed
vour mortqaqed property will be sold bv the Sheriff to pav off the mortqaqe
debt, If we refer your case to our attorneys, but you cure the default
before they begin legal proceedings against you, you will still have to pay
the reasonable attorney's fees, actually incurred, up to $50,00, However, if
legal proceedings are started against you, you will have to pay the
reasonable attorney's fees even if they are over $50,00. Any attorney's fees
will be added to whatever you owe us, which may also include our reasonable
costs, If yOU cure the default within the thirtv dav period, vou will not be
required to pav attornev's fees. We may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage. If you
have not cured the default within the thirty day period and foreclosure
proceedings have begun, vou still have the riqht to cure the default and
prevent the sale at any time up to one hour
before the Sheriff's foreclosure sale. You mav do so bv pavinq the total
amount of the unpaid monthl V pavments plus any late or other charqes then
due, as well as the reasonable attorney's fees and costs connected with the
foreclosure sale (and perform anv other requirements under the mortqaqe).
It is estimated that the earliest date that such a Sheriff's Sale could be
held would be approximately six (6) months from today, A notice of the
date of the Sheriff's Sale will be sent to you before the sale Of
course, the amount needed to cure the defaul t will inc~'ease the longer you
wait. You may find out at any time exactly what the required payment will
be by calling us at the following number: (800) 333-5848 Ext 7946, This
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payment must be in cash, cashier's check, certified check or money order and
made payable to us at the address stated above,
You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to remain in it, If you continue to live
in the property after the Sheriff's Sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the
property, YOU 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. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE
DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES, AND ATTORNEY'S
FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER
REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED, CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS
DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If ou cure the default the mort a e wi be restored to the same
position as if no default had occurred. Hower, you are not entitled to
this right to cure your default more than th ee ti es in any calendar year,
/
BY:
FOR:
eene, Esq.
LTY CORPORATION
Si ud. no comprende el contenido de este avi 0 tanga la bondad de hacer
traducirlo ya que contiene informacion de suma importancia con respecto a su
propiedad,
2
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania'G Homeowner's Emergency Mortgage
Assistance Program may be able to help you, Read the following notice to
find out how the program works.
La notificacion en adjunto es de suma importancia, pues afecta sue
derecho a continuar viviendo en su casa. 5i no comprende el contenido de
esta notificacion obtenga una traduccion immediatemente llamanda esta agencia
(Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba.
Puedes ser elegible para un prestamo por el programa llamando "Homeowner's
Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca,
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE, YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
Customer(s): James Barry Morehead
and Heni-Iris Morehead
Address: 425 Pawnee Drive
Mechanicsburg, PA 17055
Account Number: 713303-10-888669
Date of Loan: 1/13/94 Date
Creditor: HOUSEHOLD REALTY
CORPORATION
Phone: (800)333-5848 Ext,7946
Address: 961 Weigel Dr.,P.O,
Box 8632,Elmhurst,IL 60126
of Notice: April 11, 1996
Your mortqaqe is in serious default because you have failed to pay
promptly installments of principal and interest, as required, for a period of
at least sixty (60) days, The total amount of the delinquency is $4,411,66,
That sum includes the following: $15.66 for the month of December of 1995
and $1,099.00 each for the months of January, February, March and April of
1996 inclusive,
You mav be eliqible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of the
Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"), You may
be eligible for emergency temporary assistance if your default has been
caused by circumstances beyond your control, and if you meet the eligibility
requirements of the Act as determined by the Pennsylvania Housing Finance
Agency. Please read all of this Notice, It contains an explanation of your
riqhts.
Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice. During that
time you have the right to arrange a
"face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose of that
meeting is to attempt to work out a repayment plan, or to otherwise settle
your delinquency. That meetinq must occur in the next thirtv (30) days.
If you attend a face-to-face meeting with this lender, or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days after
the date of that meeting.
The name, address and telephone number of our representative is:
Shirelle Chew, Household Realty Corporation, 961 Weigel Dr" P,O, Box 8632,
Elmhurst, n. 60126, 1-800-333-5848 Ext 7946.
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of pennsylvania's Homeowner's Emergency Mortgage
Assistance Program may be able to help you, Read the following notice to
find out how the program works.
La notificacion en adjunto es de suma importancia, pues afecta sue
derecho a continuar viviendo en su casa, Si no comprende el contenido de
esta notificacion obtenga una traduccion immediatemente llamanda est a agencia
(Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba,
Puedes ser elegible para un prestamo por el programa llamando "Homeowner's
Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE, YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
Customer(s): James Barry Morehead
and Heni-Iris Morehead
Address: 425 Pawnee Drive
Mechanicsburg, PA 17055
Account Number: 713303-10-888669
Date of Loan: 1/13/94 Date
Creditor: HOUSEHOLD REALTY
CORPORATION
phone: (800)333-5848 Ext.7946
Address: 961 Weigel Dr.,P,O.
Box 8632,Elmhurst,IL 60126
of Notice: April 11, 1996
Your mortqaqe is in serious default because you have failed to pay
promptly installments of principal and interest, as required, for a period of
at least sixty (60) days. The total amount of the delinquency is $4,411.66,
That sum includes the following: $15,66 for the month of December of 1995
and $1,099,00 each for the months of January, February, March and April of
1996 inclusive.
You mav be eliqible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of the
Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may
be eligible for emergency temporary assistance if your default has been
caused by circumstances beyond your control, and if you meet the eligibility
requirements of the Act as determined by the Pennsylvania Housing Finance
Agency, please read all of this Notice, It contains an explanation of vour
riqhts.
Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice, During that
time you have the right to arrange a
"face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency, The purpose of that
meeting is to attempt to work out a repayment plan, or to otherwise settle
your delinquency. That meetinq must occur in the next thirtv (30) davs,
If you attend a face-to-face meeting with this lender, or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days after
the date of that meeting,
The name, address and telephone number of our representative is:
Shirelle Chew, Household Realty Corporation, 961 Weigel Dr., P,O. Box 8632,
Elmhurst, 11. 60126, 1-800-333-5848 Ext 7946,
The names and addresses of designated consumer credit couns0ling ageni~s
are attached. It is only necessary to schedule one face-to-face meeting, You
should advise this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or after
your face-to-face meeting, you have the right to apply for financial
assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order
to do this, you must fill out, sign, and file a completed Homeowners'
Emergency Assistance Application with the Pennsylvania Housing Finance
Agency, The consumer credit counseling agency will assist you in filling out
your application, It must be filed or postmarked within thirtv (30) days of
your face-to-face meetinQ,
It is extremely important that YOU file vour application promptly. If
vou do not do so, or if vou do not follow the other time periods set forth in
this letter, foreclosure mav proceed aqainst your home immediately.
Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria
established by the Act.
It is extremely important that vour application is accurate and complete
in everv respect. The counseling agency will help you to fill out the
application, The Pennsylvania Housing Finance Agency has sixty (60) days to
make a decision after it receives your application. During that additional
time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by that
Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front
Street, P.O, Box 8029, Harrisburg, PA 17105, Telephone No. (717)780-3800 or
1-800-342-2397 (toll free number).
You must either mail your application to the Pennsylvania Housing
Finance Agency, or you must file it at the office of one of the designated
consumer credit counseling agencies listed above.
An application for assistance may be obtained from this lender, from a
consumer credit counseling agency, or directly from the Pennsylvania Housing
Finance Agency.
Enclosed also is another notice from this lender under Act 6 of 1974, That
notice is called a "Notice of Intention to Foreclose Mortgage". You must read
both notices, since they both explain rights that you now have under
Pennsylvania law, However, if you choose to exercise your rights described in
this notice, we cannot foreclose upon you during that time,Also, if you
receive financial assistance from the Pennsylvania Housing Finance Agency,
your home cannot be foreclosed upon while you are rec 'ving that assistance,
By: James Ashton Greene, Esq.
539 Court Street
Reading, Pa, 19601
(610) 374-3148
FOR:
James Ashto
CUMBERLAND COUNTY
CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA, INC.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FINA}!CIAL SERVICES UNLIMITED
117 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Natalie Newcomer
URBAN LEAGUE OF METROPOLITAN HARRISBURG
25 N. Front Street
Harrisburg, PA 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA OF CARLISLE
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX # (717) 243-3948
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice that you dispute che validity of this
debt or any portion thereof, this office will assume that the
debt is valid, If you notify this office in writing within
thirty (30) days from receiving this notice, this office will:
obtain verification of the debt or obtain a copy of judgment and
mail you a copy of such judgment or verification. You are also
advised that any information which you supply to this office may
be used by us in the collection of the debt. If you request this
office in writing within thirty (30) days after receiving, this
office will provide you with the name and address of the original
creditor,
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. Pnnl your name and address on the laverse ollhis form so thai we can relurn this
card 10 you.
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permit.
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_The Retum Receipl.,.,;lIlhow 10 wnom the artiCle was dehvO/ad and the dale
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4b. Service Typo
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7. Date 01 Delivery
R ~,
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and lee is paid) \
SENDER:
. Complete ilems 1 and/or 2 lor additional services,
. Complete l1ems 3, 4a. and 4b.
. Print your name and address on the reverse olthis !:Irrn so thaI we can return this
card to you.
. A"ach this lorm \0 the Ironl 01 the mailpiece, or on the back il space docs not
permil.
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delivered.
3. Article Addressed to:
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1996-05556 P
COKKONWEALTH OF PENNSYLVANIA I
COUNTY OF CUKBERLAND
HOUSEHOLD FINANCE CONS DISC CO
VS.
KOREHEAD HENI-IRIS ET AL
R. Thomas Kline . Sheriff, who being duly sworn according
to law, .ays, that he made a diligent search and inquiry for the within
named defendant, to witl KOREHEAD JAKES BARRY
but was unable to locate
Him
in his bailiwick. He therefore
deputized the sheriff of LEBANON
to serve the within COKPLAINT - KORT FORE
County, Pennsylvania.
On October
30th. 1996
. this office was in
receipt of
Pennsylvania.
the attached return from
LEBANON
County,
Sheriff's CostSI
Docketing
Out of County
Suroharge
LEBANON COUNTY
6.00
9.00
2.el0
27.45
So answers I / /' .
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C. /'. //
/1 /~,/t.;-;-.:~I.:"" ...../_/"r----'
H.' Thomas Kline, Sheri~t
644.45 KCCABE WEISBERG CONWAY WATSON
10/30/1996
Sworn and subscribed to before me
this 1__ day of -n.,,~
19 'It.. A.D.
\..'-~{L "tt!.dL 'l~'
v I:'rothonotary
COMPLAINT & NOTICE
No. 96-5556 CIVIL TERM
Lebanon, PA, October 29, 1996
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
(RETURN TO CUMBERLAND CO. SHERIFF)
vs.
JAMES BARRY MOREHEAD
DOCKET PAGE 10321
STATE OF PENNSYLVANIA }
COUNTY OF LEBANON } SS:
Danny L. Heilman, Deputy Sheriff, being duly sworn according to law,
deposes and says that he served the within COMPLAINT & NOTICE upon
JAMES BARRY MOREHEAD, the within named DEFENDANT, by handing a true and
attested copy thereof, to him, personally, on October 21, 1996, at 1:47
o'clock P.M., at his residence, 124 Lehman Street, Lebanon (City),
Lebanon County, Pennsylvania, and by making known to him the contents
of the same.
Sworn to and subscribed before me
(' SO ANSW~R
I '_0 -1/.
!c r::t-Jk-U'1 (/\. l'TJ<
DEPUTY. HERIF}"_ /..,of 4/=
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this 29th day of October, A.D., 1996
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. . j':" \.---:'1'1, , , " Notary Public
'1"'C)iL,~\!:.L SEA.L
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SHERIFF'S COSTS IN ABOVE
Advanced costs paid on 10/21/96 Check No.
Costs incurred:
Refund: Check No. 3182
PROCEEDINGS
15087 Amount
Amount
Amount
75.00
27.45
47,55
All Sheriff's Costs shall be due and payable when services are
performed, and it shall be lawful for him to demand and receive from
the party instituting the proceedings, or any party liable for the
costs thereof, all unpaid sheriff's fees on the same before he shall be
obligated by law to make return thereof.
___Sec. 2, Act of June 20, 1911, P.L. 1072
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nine ....cun CT .::mrnC~i t1::::'5 o. \..:.J~.'~:::~;rl:::n= \..=t),,;,;",oy,
Hotsehold Finance Consumer,Discount Company
'is.
James Barry Morehead
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McCABE, WEISBERG, CONWAY << WATSON
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia, Pennsylvania 19103
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v,
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA
The undersigned, being duly sworn according to law, deposes
and says that the Defendants 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' Ci vil Relief Act of
Congress of 1940 as amended; and that the Defendants, Heni-iris
Morehead and James Barry Morehead, are over eighteen (18) years of
age, and Heni-iris Morehead resides at 425 Pawnee Drive,
Mechanicsburg, Pennsylvania 17055 and James Barry Morehead resides
at 124 Lehman Street, Lebanon, Pennsylvania 17042,
SWORN TO AND SUBSCRIBED
BEFORE ME THIS J/tJ',~ DAY
OF ;f..l.(L1J.cl.-"-:. , 1996,
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NOTARY P LIC
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TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELKER
Prothonotary
November 13, 1996
To: James Barry Morehead
124 Lehman Street
Lebanon, Pa 17042
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
NOTIFICACION IMPORTANTE
You ere to default because you hove foiled to
enter 8 written appearance personally or by
attorney end file In writing with the Court
your defenses or objectlon~ to the claims set
forth against you. Unless you act within tcn
(10) doys from the date of this notice, 0
judgment may be entered against you without
8 hoaring and you may lose your property or
other Important rights. You should toke this
notice to 0 lowyer at once. 11 you do not
hove 0 lawyer or cannot afford one, go to or
telephone the following office to find out
where you con get legal help:
Usted so cncuentro en estado de rebcldlo per
no hober prcscntedo uno comparccenclo escrlta,
yo seo personolmente 0 por abogado y por no
hober radicado por escrlto con cste Tribunal
sus defensa5 U objeciones 0 los reclemos
formulados en contra suyo. Al no tomor lo
occion debido dentro de diet (10) dins de 10
fecho de esto notificacion, cl Tribunal pedro,
sin ~ecesidod de comparccer usted en corte u
oir preubo olguna, dictor sentcncia cn su
contra y usted podrla perder bienes u otros
dercchos importantes. Debc llcvar cst a
notificacion a un abogado inmed;otomcnte. si
ustcd no tienc ebogado, 0 si no tienc dinero
suficicntc para tal servlcio, vayo en persona
o llome por telefono 0 la olicino, nombroda
para overiguar si pucde conseguir asistcncia
legDl.
Court Administrator
Cumberland County Courthouse
Carl isle, PA 17013
(717) 240-6200
Court Administrator
Cumberland County courthouse
Corl isle, PA 17013
(717) 240.6200
If you have any questions concerning this notice, please call:
Terrence J. McCabe, Esquire
McCabe, Weisberg, Conway & Watson, P.C.
1608 Walnut Street, Suite 402
Philadelphia, PA 19103
at this telephone number: (215) 790-1010
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELKER
Prothonotary
To: Heni-iris Morehead
425 Pawnee Drive
Mechanicsburg, Pa 17055
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
NOTICE
Pursuant to Rule 236, you are hereby notified that a JUDGMENT
has been entered in the above proceeding as indicated below.
Lawrence E, Welker
prothonotary
X Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment, please call
Terrence J, McCabe, Esquire at (215) 790-1010,
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McCABE, WEISBERG, CONWAY & WATSON
BYI TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia, Pennsylvania 19103
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
AFFIDAVIT OF SERVICE
I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in
the within matter, hereby certify that on the 31st day of December,
1996, a true and correct copy of the Notice of Sheriff's Sale of
Real Property was served on the following lienholders:
National Central Bank
Lancaster City, PA
Boscous
P.O. Box 4274
Reading, PA 19606
Occupant(s)
425 Pawnee Drive
Mechanicsburg, PA 17055
Copies of the letters and certificates of mailing are attached
hereto, made a part hereof and marked as Exhibit "B."
c
// (
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
BEFORE ME THIS "/" DAY
OF >i;., ".J. , ,1996.
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belief. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
IJj31/c(&
DATE
L7 ,J././\... / I (,
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
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ALL T1IAT cortain pioco lll' p,"cd of lalld ,iluate a",{ designated as Lot 1'\0, 13. BI"ck
"0", of Plan 1\0, 2 of Indian Croek. a, propMod b~' 0,1', Rl\fl~nsporger, Registered
Surveyor. daled Febnlal)' 11. ]%9. in Plan BOllk 21, Pago 13, Said tract is located in
Hampden Township. Cnlllberland Counly. POlulSylvania,
BEGINNI1\G lit II poinlun tho West sido uJ' l'a'.\11ee Dri'e. said poinl being a distance of
23\.0 feet south of the intersection of the \\'esl side of Pawnee Drive and the S,)uth side of
Osage "'a~': thence by ~1e "'ost side of Pawnoe Dril'e b~' a cur"c to the right have a radius
of870,O feet an arc length of93,() feel to a JlOinl at the line of Lot 1\0, 12: thence by the
same North 88 degrees 57 minntes 24 seconds WesI, a distance of 150,0 feel to a point at
other lands now or late of Realty Company of PelUlsyll'ania: thence by same l'\orth 02
degrees 01 minutes 09 seconds West, a distance 01'76.93 teet to a point at the line of Lot
No 14; thence by sallle North 84 degrees 55 minutes 07 seconds East, a distance of 150,0
feet to the place ofBEGll'\1\lNG.
EXHIBIT "A"
HA VI:>:G THEREON ERECTED a dwelling hOllse known as No, 425 Pawnee Drive,
L1'DER AND SUBJECT, ne"ertheless. to easements, restrictions, reservati,"B, conditions
and rights of way of record,
.'
,.11I
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 the following notice 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 Terrence J. McCabe, Esquire at (215) 790-1010.
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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your real estate. A schedule of distribution of the money bid
for your real estate will be filed by the Sheriff on Julv 7.
1997. 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 schedule
of distribution is wrong) are filed with the Sheriff within
ten (10) days after Julv 7. 1997.
7. You may also have other rights and defenses, or ways of
getting your real estate 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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
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L1'o:DER AND SUBJECT. neVer1helo~s. to easements, restrictions, reservali,)11<, conditions
and rights of way of record,
ALL THAT cortain piece 01' parcd uf land situate alld desigllated as Lut 1'0:0, 13. Uk,ek
"0", of Plan 1'0:0. 2 of Indian Crook. as prepared b~' D,I', Ranonsperger. Registerod
Surveyor. dated February 11. 1969. in Plan Book 21, Page 13, Said tract is loeated ill
Hampden Township. Cllmberland County. P.,",sylvania,
BEGINNING at a pClint un tho West side of l'a'.\11"" Drive. said poillt b.ing a dislc\nce of
231.0 I;'ot south of tho illtorsectioll of tho West sid. of I'awlloe Drive and the Scm;h side of
Osage Way: thonce by the West side of Pawne. Dril'e hy a e",Yo to the right have n radiu~
01'870,0 feet an arc length of93,U fOetto a point atlhe line "I' Lot 1'0:0. 12: thence by the
same North 88 dogrees 57 minutes 24 seconds WeSt. a distance of 150,0 feel to a point at
other lands now or late of Realt)' Compan)' ofPetUlsyll'ani:!: lhJnoe by same North 02
degrees 01 minuteS 09 seconds West. a distance 01'76,93 feet to a point at the line of lot
No 14; thenoe by ,;Imo North 84 degrees 55 minuteS 07 seconds East, a distanoe of 150,0
l;'et 10 the place of BEGIN NINO,
HA VI!'>1G THEREO!'>1 ERECTED a dwelling house kJlO\\11 as No, 425 Pawnee Drive,
McCABE, WEISBERG, CONWAY & WATSON
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia, Pennsylvania 19103
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
PLAINTIFF'S ANSWER TO DEFENDANTS' NEW MATTER
8. Admitted.
9, Denied. Paragraph nine (9) is denied as conclusions of
law to which a responsive pleading is not required.
10. Denied.
It is denied that the Debtor has significant
equity as set forth in her schedules estimating her approximate
fair market value of her residence and approximate mortgage
balances. Further, paragraph 10 is denied as a conclusion of law
to which a responsive pleading is not required.
11. Denied. It is specifically denied that Debtor has made
post petition payments.
Wherefore, Movant respectfully requests that it be granted its
Motion for Relief from Automatic
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3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Address
Household Finance
Consumer Discount Co.
961 Weigel Drive
P.O. Box 8632
Elmhurst, IL 60126
Boscous
P.O. Box 4274
Reading, PA 19606
P.A. Power & Light
1801 Brookward Street
Harrisburg, PA 17105
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address
National Central Bank
Lancaster City, PA
Household Finance
Consumer Discount Co.
961 Weigel Drive
P.O. Box 8632
Elmhurst, IL 60126
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
Name
Address
None.
6. Name and address of
Plaintiff has knowledge who has
may be affected by the sale:
every other person of whom the
any interest in the property which
Name
Address
Occupant(s)
425 Pawnee Drive
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. Section 4904 relating to unsworn
falsification to authorities.
1 /'31 /71
DATE I (
o (ce
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
ALL THAT c~rtaill pit:c~ or p3l'cd of land f,illlal~ ,Illd d~~igllat(:d as Lot ('\0, 13, Bl\)ck
"0", of Plan t\o, 2 of Indian Creek," prepared h\' [),P, Ranensperger, Registered
Sur\'eyor, dated Fd,ruary 11, 1969, in Plan BOOK 21, Page 13, Said tract is located in
Hampden Township, Cumberland County. Pe'lIlsyll'ania,
BEGINNING ill ~l p'Jint UI1 th~ \\'~st ~id~ u1" p;\I.\ll~-': Dri\'~, ~aid point bdng a di~t:tl1~t: uf
23\.0 teel soulh of tho inlersecliw oftlte W~sl sid~ of Pawnee Dri\'e and the South side of
Osage II'a\,; theuce hI' ~1<l II'est side of Pawnee Dril'e It\' a cur\'e tll the right ha\'~ a radius
01'870,0 t~el an arc I~ngth 01'93.0 teel 10 a poiUI at tlte line of 1.011'\0, 12~ th~nce by Ihe
same North 88 d~grees 57 minul~s 24 seconds \\'e,t. a distance of 150,0 f~el to a point at
other lands now or late of Realty Company of Pe'Ulsyll':lIlia; th~n~e by same North 02
degrees 01 minules 09 se~onds \\'esl, a distance 01'76,93 teello a pc,int allh~ line of Lot
!\o 14; then~e by s"me North 84 degrees 55 minutes 07 seconds East, a distan~e of 150,0
f~el to the place ofBEGll'\l'\lNG,
HA V1!'JG THEREON ERECTED a dwelling house Known as No, 425 Pawnee Dril'e,
L:J\DER AND SUBJECT. nel'ertheless, 10 easemenls, restrictions. reservati."", condilions
and rights of way of record,
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McCABB, WEISBBRG, CONWAY & WATSON
BY, TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia, Pennsylvania 19103
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
SUPPLEMENTAL AFFIDAVIT OP SERVICE
I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in
the within matter, hereby certify that on the 31th day of July,
1997, a true and correct copy of the Notice of Sheriff's Sale of
Real Property was served on the following lienholder:
P.A. Power & Light
1801 Brookward Street
Harrisburg, PA 17105
Copies of the letter and certificate of mailing are attached
hereto, made a part hereof and marked as Exhibit "B."
~..&--I? L-
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
SWOPE TO AND SUBSC~IBED
BEFJ&E ME THISJ/9f' DAY
OF ~!l ' 1996.
l'J/.d ,~
NOTAR:~LJ:C '
TAAC~OT ARIAL SEAL
M City of Phi~'d~;~~;a N~~~( PCUbliC
CommisSion Ex .' 0' a. Ounty
Iros ct. 23, 2000
McCABE, WEISBERG, CONWAY & WATSON
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
1608 Walnut Street, Suite 402
Philadelphia, Pennsylvania 19103
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Heni-Iris Morehead
425 Pawnee Drive
Mechanicsburg, PA 17055
James Barry Morehead
124 Lehman Street
Lebanon, PA 17042
Your house (real estate) at 425 Pawnee Drive, Mechanicsburg,
PA 17055 (more fully described as attached) is scheduled to be
sold at Sheriff's Sale on June 4, 1997, at 10:00 a.m. in the
Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania 17013, to enforce the court judgment of $103,929.74
obtained by Household Finance Consumer Discount Company against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Household Finance
Consumer Discount Company the back payments, late
charges, costs, and reasonable attorney's fees due. To
find out how much you must pay, you may call Terrence J.
McCabe, Esquire at (215) 790-1010.
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 the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
Ah~ 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 Terrence J. McCabe, Esquire at (215) 790-1010.
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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until th~ 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 real estate. A schedule of distribution of the money bid
for your real estate will be filed by the Sheriff on Julv 7.
1997. 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 schedule
of distribution is wrong) are filed with the Sheriff within
ten (10) days after Julv 7. 1997.
7, You may also have other rights and defenses, or "Jays of
getting your real estate 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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYI,VANIA 17013
(717) 240-6200
/'
,
-~ - ./"
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.........,
You may need an attorney to assert your rights, The sooner yo~
contacc one, che more chance you will have of stopping the sale.
(See the following notice on how to obtain an attor~ey.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
Ah~ YOU HAVE OTHER ~IGHTS
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 Terrence J. McCabe, Esquire at (215) 790-1010.
2. You may be able to petition che Court to set aside the sale if
the bid ~rice 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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amounC due from the buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened,
5.
You have a right to remain in
amounc due is paid to the Sheriff
to the buyer. At that time,
proceedings to evict you.
the property until the full
and the Sheriff gives a deed
the buyer may bring legal
6. You may be entitled to a share of the money which was paid for
your real estate, A schedule or distribution of the money bid
for your real estate will be filed by the Sheriff on Julv 7,
1997. 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 schedule
of distribution is wrong) are filed with the Sheriff within
ten (10) days arter Julv 7, 1997.
7. You may also have other rights and defenses, or ways of
getting your real estate 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,
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
~
Notes. It real property, supply six copies of description including improvements and an
original and copy of affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
-
,
-
-.
ALL THAT c~r1"ill piece or parcel oflalld ,ituat~ alld d~sigualed as Lot 1\0.13. Block
"0", of Plall No, 2 of IlIdian Creek. as propared b,' D,p, Raff""sp,,rger. R"gi,'tered
SlIrI'''yor. dat"d Febnlal)' II, 1969, in Piau Book 21, Page 13. Said tracl is located ill
Hampden TOIVn,hip. Cumberland County. p"IUlsylvallia,
BEGlNNING.1 a pClint ou the W.sl sid" 01'1';1'.111"" Dril'e. said poil1l b"ing" dist,"c" u1'
231.0 le,,1 sonlh Oftll" inler,,,ction ofth" W"st ,id" ofmwlI"" Driv" and th" SI1Utll sid" of
O'age Wny: thence by tlle We" side of Pnwnee Drive by n curv; to the right have n radin,
of870.0 feet an arc I"ngtll of93,O f"et to a point nllbe lille of Lot No, 12: lhenc" by tb"
,am" North 88 d"gr"es ~7 minutes 24 second, W"st.. di,tanc" of 150.0 feet to. point.t
other I.nds nolV or late ofR"alt)' Comp'IllY ofPeIUlsyl\'ania: th"nce by same Norlh 02
d"grees 01 minnl"s 09 second, W",t. . distanc" 01'76,93 te"t to. pI)int at the lin" of Lot
1\0 14; thence by ,.Ime Norlb 84 degree, 55 minn!", 07 seconds Enst, n distnnce of 150,0
f"etlo the pl.ce ofBEGI1\NING.
HAVING THEREON ERECTED n dwelling hOllse known as No. 425 P,lwnee Dri\'",
L!1\DER AND SlIBJECT, uevenhel.". to e",emonts, restriction" reserv.ti,)ns, condition,
and righl, ofw.y of record.
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McCABE, WEISBERG, CONWAY & WATSON
BY, TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
123 S. Broad Street, Suite 2080
philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Heni-Iris Morehead
425 Pawnee Drive
Mechanicsburg, PA 17055
James Barry Morehead
124 Lehman Street
Lebanon, PA 17042
Your house (real estate) at 425 Pawnee Drive, Mechanicsburg,
PA 17055 (more fully described as attached) is scheduled to be
sold at Sheriff's Sale on December 8, 1999, at 10:00 a.m. in the
commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 11-
Pennsylvania 17013, to enforce the court judgment of $103,929.74
obtained by Household Finance Consumer Discount Company against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Household
Finance Consumer Discount Company the back payments,
late charges, costs, and reasonable attorney's fees
due. To find out how much you must pay, you may call
Terrence J. McCabe, Esquire at (215) 790-1010.
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 attoI'n~~' t~ assert your rights. The sooner you
contact one, the m~rc cnance you will have of stopping the sale.
(See the followlng n~[ICc on how to obtain dn attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU MAVE 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 h.ghest bidder. You may find out the price bid
by calling Terrence J. McCabe, Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale
if the bid price wall 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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the
Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid
for your real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
on January 7. 2000. 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 schedule of distribution is wrong) are
filed with the Sheriff within ten (10) days after January
7. 2000.
7. You may also have other rights and defenses, or ways of
getting your real estate 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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
'.','
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ToRRENCEJ,McCABE
'-"..... Gi'HC(.S
McCABE, WEISBERG & CO;\jWAY, r.c.
~L.ln: 2050
tltt':.~ L.',"iO~ BLILm~G
l2J \()t,!H ~((O^D STREB
PUILAntlr'HLo\. PES"SSYLVAS1A :~I09
(;1,,790-1010
.-,,\(11'1)"190-1214
SUITE IlO)
52 V ANDERBIL T A VENUE
NEW YORK. NY 10017
(212)697.0011
FAX (212) 9l).0986
SUITE 600
216 HADDON AVENUE
WESTMONT. NJ 08108
(609) 8l8.7080
FAX (609) 8l8.7020
September 1, 1999
occupant(s)
425 Pawnee Drive
Mechanicsburg, PA 17055
Re: Owners: Heni-Iris Morehead and James Barry Morehead
property: 425 Pawnee Drive, Mechanicsburg, PA 17055
Dear Sir or Madam:
The above-captioned property is scheduled to be sold at the
Sheriff's Sale on December 8, 1999, at 10:00 a.m. in the
Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
pennsylvania 17013-3387. Enclosed please find Notice of Sheriff's
Sale of Real Property. Our records indicate that you may have an
interest in 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 10 days after the filing of the
schedule.
Very truly yours,
~o/ Mtj!~i(
TJM/nas
Enclosure
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McCABE, WEISBERG, COllWAY & WATSON
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
123 S. Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 425 Pawnee Drive, Mechanicsburg, PA
17055, a copy of the description of said property is attached
hereto and marked Exhibit "A,"
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Address
Heni-Iris Morehead
425 Pawnee Drive
Mec~anicsburg, PA 17055
James Barry Morehead
124 Lehman Street
Lebanon, PA 17024
2. Name and address of Defendant(s) in the judgment:
Name
Address
Heni-Iris Morehead
425 Pawnee Drive
Mechanicsburg, PA 17055
James Barry Morehead
124 Lehman Street
Lebanon, PA 17024
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
~~
~~vY~~~
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
DATE
EXH\B\l "~'
ALL THAT c~r1"in piece or parcel of land situate and designated as Lot No. 13. lllock
"0", of Plan 1\0. 2 of Indian Creok. a' proparod by D,P. Ran.nsporgor, Rogistered
SlIri'eyor, dated Febnlary 11,1%9, in PI.n Book 21, Page 13. ,S.id tract is located in
Hampden Township. Cnmberland Connly. POIUlsyl"ania,
BEGINNING at a puint onlh. W.,I sid. or PIl'.\l1." Dri".. ,,,i,1 pllinl beillg " dislanc. or
231.0 f"el sonth of iiI. intu".ction o1'lhe Wesl sid., of Pawnee Drive and the SOUUl sid" of
Osage Way; thence by Ule West side of Pawne. Dri"e by a curv. to the right have a r"dius
01'870.0 feet an arc lengul 01'93.0 reetlo a point at the line ofLol No. 12; thenc" by the
same North 88 degrees 57 minutes 24 seconds West. a distance of 150,0 feet 10 a point at
olher lands nolV or late of Renlty CompllllY of PelUlsylvania; th"llce by same North 02
degree, 01 minutes 09 seconds West, a distance 01'76.93 feet to a pl1int at the line of Lot
!\o 14; thence by S'll11e North 84 degrees 55 minntes 07 seconds East, a distance of 150,0
feet tll the place of BEGINNING,
HA \lING THF.REON ERECTED n dwelling house known as No. 425 P"wnee Drive,
LrJ'DER AND SUBJECT. nevertheless. to easements, re$trictions, reservati-ms, conditions
and rights ofw.y of record,
'.
.'
McCABE, WEISBERG, CONWAY & WATSON
BY, TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
123 S. Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for plaintiff
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
v.
HENI-IRIS MOREHEAD
JAMES BARRY MOREHEAD
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 96-5556 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Heni-Iris Morehead
425 Pawnee Drive
Mechanicsburg, PA 17055
James Barry Morehead
124 Lehman Street
Lebanon, PA 17042
Your house (real estate) at 425 Pawnee Drive, Mechanicsburg,
PA 17055 (more fully described as attached) is scheduled to be
sold at Sheriff's Sale on December 8, 1999, at 10:00 a.m. in the
commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 11-
pennsylvania 17013, to enforce the court judgment of $103,929.74
obtained by Household Finance Consumer Discount company against
you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFP.'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Household
Finance Consumer Discount Company the back payments,
late charges, costs, and reasonable attorney's fees
due. To find out how much you must pay, you may call
Terrence J. McCabe, Esquire at (215) 790-1010.
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 the following notice 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 Terrence J. McCabe, Esquire at (215) 790-1010.
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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
4. If the amount due from the buyer is not paid to the
Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid
for your real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
on Januarv 7. 2000. 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 schedule of distribution is wrong) are
filed with the Sheriff within ten (10) days after January
7. 2000.
7. You may also have other rights and defenses, or ways of
getting your real estate 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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
h-r-~ ~""'~~~r'" ?\-'~I7" ':1"l
L/3
On ~ ? 1'7 'i the sheriff levied upon the defendant~,
Interest in the real property situated inJLj1-L- ~~..~
Cumberland County, Pa., known and numbered as: %1.1' ;t..,."" L..~
/fi/u1.._o .-1.., and more fully described on Exhibit "A" filed with
this writ and by this relerence incorporated herein.
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), p, L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss,
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 22, 29. NOVEMBER 5, 1999
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that hc is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 43
Wr1t No, 96-5556 Clvtl
Household Finance Consumer
Discount Company
VS.
HenHns Morehead and
.James Barry Morehead
Ally,; Terrence J, McCabe
ALL TIlAT certain pJccc or parcel
orland SlttJfltc .1Ile! dcslglliltccl i1S Lot
No, 13. Dlock "G", of Plan No.2 of
IndIan Creek. ilS prc!>;'Ired hy D P
Iltafrcl1spcr~cr. Registered Sllrvcy~r'
(.lIed F'CI~m;uy J I. IDGD. In Plm;
Book 21, rage 13. Snld !rolet Js 10C,lI-
ee! In I flllnpdcn Township, Cumber-
land Coullty, Pt'llllsylwHlla,
, 13EGINNING <H a pOint 011 the
\\cst slele of Pawnee Drl\'e. S<lJd pOint
belnl{ a dlstnnce of 231.0 feet south
of the Intersection of rile West side of
. ell' nr
'~)71/1
Roge M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
~day of NOVEMBER. 1999
~-<~)
L SEAL
lOts E, SNYDER, Note'Y Public
Carini. Bom, Curnborkmd County, PA
My Cornmi...Ofl Expirlts March 5, 2001
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Aet No. 587, approved May 16,1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
55.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the loeal courts as the official legal
periodical for the publication of all legal notices, and has, sinee January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
OCTOBER 22, 29, NOVEMBER 5, 1999
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that aU allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 43
Writ No, 96-5556 Civil
HouscllOld Finance Consumer
Discount Company
VS,
Iienl-Ins Morehead and
James Barry Morehead
Atty,: Terrence J. McCabe
ALL THAT certain piece or pflrcel
of land situate and designated as Lot
No, 13. llIock ~G", of Plan No, 2 of
Incllan Creek, as prepared by 0 P
Raffensperger, RC~lstcrcd Sur\'cy~r'
dilled Fcbmary II W69 111 1'1' '
B k 21 I) . , ,Ill
00 ,age 13. SaId traclls locat-
ed In J fnmpdcn Township, Cumher-
land County, Pcnnsylv,lIlJa,
BEGINNING at n pOint 011 the
West side ofPawllce Drive, said pOJnt
being a distance of 231.0 feet south
of the Intersection of the West side of
.. 0
Rage
SWORN TO AND SUBSCRIBED before me this
---L-dayof NOVEMBER. 1999
L SEAL
I.Ot& E. SNYDEft:, Notary Pub*c
Cortrsl. 80m, Cumbllliond Coont)', PA
My Comminion Expire" h\orch 5, '2001
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No,587, Aooroued May 16, 1929
Commonwealth 01 Pennsylvania, County of Dauphin} ss
Michael Morrow bei.ng duly sworn accordi.ng to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO" a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principai office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and pubiisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
In the City, County and State aforesaid; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd
and 9th day(s) of November 1999, That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of a phin in cMiscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
SALE #43
swornl to and subsaribe<i ,before m
Tcrr'{ l. 11I:S:~",\II, r~0,IJI'" Put,lie
t~J.:~I'jbur~, [l:IU;:!I'fl Co:mw
My CD:1H:';<;'C':l Enn,Y; ,]t:r,Q G:~r 2
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REAL ESTATE SAU, No.. I
Wrlt No. 96-5556 'I
. Civil Term :'
Household FInance .
Consumer DIscount co.!
, va
HanloJrla Morehead "J
,James Barry Morehead~
Atty:Terrence J. McCabe'
DES~IPTION ,i
ALL THAT certa pleoo or parcel of
land slluate and d slgnated as l.Ql. No.
13, Bloc:l< "G', 01 Ian No.2 of radian
Creek, as P pared by O.P.
Raffensperger, Registered SUMlyor,
dated February 11, 1969, In Plan Book
21, Page 13, said tract Ia located In
Hampden Township, Cumberland COUnty,
Pennsylvania.
BEGINNING at a point on the West
side of Pawnee Drlve, aald point being a isher's Receipt for Advertising Cost
riICltAnt'A nf ':\1 ,0 fAAt f;(')uth of the
THE PATRIOT.NEWS CO., publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies Ihat the same have
been duly paid. THE PATRIOT-NEWS CO,
MoJrnt:er, 1'~:"~lSYNar.:a (..s:;CClall"n 0: No!afles
My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
COURTHJUSE
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
$
$
$
265.50
1.50
267,00
By",...,..,.."""..."",....,..,.."...,....,..,',......"....,"'