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HomeMy WebLinkAbout00-03474 , HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. CO - ]1.{"'Ir Qo~( ~ CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You hav~ 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 the 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 o~ relief requested by the Plaintiff. You may lose money or property or other rights -important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE BAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANbA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. CUmberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243~9400 _ J ~ 0 ~, '" -'.. HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SlG01: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff . -~ "'-" " ~..- " "'-';" HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO . (t() - 3 Y71 Cl:uJ ...,- ~ vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville Florida 32256. 2. Defendant, CHRISTINA A. HECK, is an adult individual whose last known address is 11 EAST MANOR AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about June 28, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $57,822.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is Successor by Merger to Barnett Mortgage Company. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 11 EAST MANOR ~"'"'. - ~ "',~ ,-~"" - ; '~,:' " ~' ~ ,~; AVENUE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 55,727.42 (b) Interest at $11.64 per day from 9/1/99 to 7/1/00 (based on contract rate of 7.625%) 3,526.92 (c) Accumulated Late Charges 140.38 (d) Late charges at $20.32 per month for 10 months 203.20 (e) Escrow Credit 101.02 (f) 5% Attorney's Commission 2,786.37 $ 62,283.27 *Together with interest at the per diem rate noted in (b) above after July 1, 2000 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan -- --.-- e "'_,._~ . balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.625% ($11.64 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ByPUR~~LER Leon . Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 -<01,' il jj ,IIi iil ili~~,.ililliiii 1l1l~lijillilj ~1~iilJiiWlj.w...l,l 1 .1 ,.~... iJ j;;l I I I i ~ _I 'I H .. 'J.! 1I',!,I_c,1 1"",,.1, :,1 ,j . ~-.Jlllld~8ji~i!l-" ,1,1.",,, wn. " ,-->>. --"jl~.liliiLltIblUilliil.~F;;';'~""'~~ I I J,liil 1 i I Ii li'_iji'ill :.i;ii J.J.J;.i.i 1/' I'll" IJj Je_ I' IlLJ.~j: .'" l,t , ,,10 ~bll_itlilllllllil""Jil'-llll;.l-"",._,_ .."..~'III""""oli.twlliili~...kL.ii.I~~i'llI'iiilili.lIOJuj.Jlil~J.joij.lj_,~lljJilIJll"_"";',,~ Iilllihl;.j,i~ j Wbii~iliJllj~LJ.~.jio.....;~~Jiij~i:l1 IIJ il "lill~I_Wl:'I_i_ i"~.L.,...i' ",_'U' -,'_ k ,.,v~J_ ",,, >,' ,jjl~__1 ..._IiiiiiiIiiIUIiII~iiii.l.~JiI..iw..U;;;~b"""IO'i.; "- <,- '. ,- ,,-, - <h!<-- , ., ALl. -that certain tract or p,tcce of bnd liI1tuate. Eut Penn.bor",:; County o'f. 'Cumberland, Statl of Pl1nns 'd.icrlb.d u foUow.', to wit: the Town'Jlllp tI( \(\1a, hlHmrl~cl and &EC'tIr.fiMC a,~ a point on tho nor,thern IIlde of HIII:O; ,o\vllntle, ~\ t~,..t \.Illllt frofll_th"north~ilt corne~ ot Kanor AvenuII and liocon~~ Altey; ,.h'-I..l". nurtl,\.IMdly throouJ!. the _pat~1tion wall at A douhh fume dwdltnr. and beytll1d tOO r"ftt to hods, MOW or, 1-~te "f Muy E. Myets; l:h~1'1c. Hut.wndl)' along th~ ,'d' d l.lnd ,parallel 'lith ~nor Av..n~Je. 25 fftdt to. pn.int _on th_ LJne of I.at No. '\1. , .B1Dck' C, on -. PJ'U Qf LOti la:Ld out by A. I. ~u-p1ey and I eccrdf'd tn the :Offlce lor the :".cordlnli of De.de in And for ClIIaburJand- C~lmcy in ~ec:ord ,Book "0"" Volum'. 6, Pase: 6001 thence sOlJthwardl)' atong sa1d lot" 100 feet, 'lIOn or !t..., ,to Kanor Av~nuf!; cherlce eastwardly aleng M:l1lot' Avenue, 25 fut to .1' polnt;~ the Phc, of BEGINIUNG. HAVING thereon erectl!d C;\It Ioleltllrn hdf _of ..- doubL~ fralll\J dwelling. ItXUnlT (fAll .-, . . VERIFICATION -~ ' :,.;, """1:il1ll'!1i\' I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 5, 2000 ~ Leon P. Haller, Esquire ",.",~"~",._="",,,,"j , ",. .~ " " . .. .... SHERIFF'S RETURN - OUT OF COUNTY CASE NO,: 2000-03474 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMES IDE LENDING INC ET AL VS HECK CHRISTINA A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HECK CHRISTINA A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE 16th , 2000 , this office was in receipt of the On October attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep. Perry Co 18.00 9.00 10.00 35.80 .00 72.80 10/16/2000 PURCELL, KRUG s~~~ R. Tomas Kline Sheriff of Cumberland County & HALLER Sworn and subscribed to before me this N*=- day of (]~ 20-0-0 A.D. Qu,~Q~~ Prothonotary ......_iIlotl'--~ .~, - .~ . ""'-, ~~ '''','e_ .. ... SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-03474 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMES IDE LENDING INC ET AL VS HECK CHRISTINA A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly SWorn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HECK CHRISTINA A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE 16th , 2000 , this office was in receipt of the On October attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep. York Co 6.00 9.00 10.00 26.40 .00 51. 40 10/16/2000 PURCELL, KRUG ~ R. Thomas Kli e'/ :;..--- Sheriff of Cumberland County & HALLER Sworn and subscribed to before me this 1Cf'ld-- day of (flrr;;t,. > ,.2trlrO A.D. ~P9:t~'# = ,-, '" I ... SHERIFF'S RETURN In the Court of Common Pleas of Perry County, Pennsylvania Homeside Lending, Inc. Successor by Merger to Barnett Mortgage Co. NO. 00-3474 vs Christina A. Heck 2204 Whispering Pines Drive MarysvilIe, Pa. 17053 George W. Frownfelter, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant to wit, Christina A. Heck at 2204 Whispering Pines Drive MarysvilIe, Pa. 17053 but was unable to locate him/her in his bailiwick. He therefore returns the Complaint in Mortgage Foreclosure NOT FOUND", as to the within named Defendant Christina A. Heck. Defendants stepfather was at residence and stated defendant lived at 300 3rd St West Fairview, Pa. Sworn and subscribed to before me thisOl7+h day of ~-kvnbe.r, 2000. SO ~1:'..J ~o~elte Sheriff of Perry County , '. tl011\R11\L SEAL . ". ,~F.FtiCKINGER, NOTAIlYPU8lIC BLOOMREIJl BORO. PERRY COuNlY MY' 'S ION R f 6 "1": ;j,' t ! M t " L ~ . L".W.;:JI ~ . ,-""j, """",, '-",~,~,--, ,-, -- '~"'- ""m' "._' ! . In The Court of Common Pleas of Cumberland County, Pennsylvania Homeside Lendng, Inc. VS. Christina A. Heck No. 20-3474 CiVil Now, 9/25/00 ,200 it' , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Perry- County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .///./t . . rr;.?'-~~-i! Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof So answers, Sheriff of County, PA Sworn and subscribed berore methis_dayof ,20_ COSTS SERVICE JvlILEAGE AFFIDAVIT $ $ < COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST" YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DETACH ANY COPIES 'v/I 1. PLAINTlFF/SI /1 3, 7. INDICATE SERVICE: NOW 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDJTIN_G S_EBYJCll j Ik IK{Jf 3 X 0i- y!lfurX-. . ADVANCED FEE PAID BY ATTY. SHERI 0 OUNlY Cumberland OUT OF COUNTY CUMBERLAND NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. T,VPE NAME AN DDRESS of ATTORNEY J ORIGINATOR an IGNATURE J..e. v;. r ;I)' , SERVICE COPY NAME AND ADDRESS BELOW: (This area must b c mpJeted if . /,?t.f/ u CUMBERLAND CO. SHERIFF ~ SPACE BELOW FOR USE OF THE SHERIFF. DO NOT WRITE BELOW THIS LINE 13. I acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as indicated above. R. AHRENS 9-27 -00 10-21-00 16, HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED ( ) POE ( ) SHERIFF'S OFF ( ) OTHER ( SEE REMARKS 11. DATE FILED 9-21-00 17. I hereby certify and return a NOT FOUND because I am unable to locate the -individual, company, etc. named above. (See remarks below.) 18. AME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19, Date of Service Int. NOT KNOWN AT GIVEN ADDRESS - PER P.O. 41. AFFIRMED and s b 47. DATE ~ 23. Advance Costs c{ $100.00 ~ 34. Foreign County Costs 48, DATE 49, DATE 51. DATE RECEIVED 1. WHITE. Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE. Sheriff's Office .- ~" .. ~tet.\'4~lt.,,\fr "r ST" rr\Ct. v \"~ "'(O\\\\.., '2. '2.1 ~f\ II 1 'GG <2,tV " Tllll'1'l1 ,"" i';~mI!\....~"~~~~~~mlffl:~~~F;j~~:;r,:,'';~~;'~~''-m!;-;;~JQ;~i'f.-'N<''kE'i~>""",':.,y-' '{;,r~",;';~-c:'--'H-i'.,W'-'-~',;'#,~i~i;,\Jtj.I1!-tE ;;~"k',,,,,;,>- ,," '-"'-i',_f~:-"ijt~(_~;l);~#0F . --~''::_'''i'~; ~."'- .. .~I""" COUNTY OF YORK OFFICE OF THE SHERIFF ,~- SERVICE CALL (717) 771-9601 " 28 EAST MARKEr ST., Y9RK, PA 17401 . ' ~ j,-. ~... : INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DETACH ANY COPIES ;: SHERIFF SERVICE PSOCESS RECEIPT, and AFFIDAVIT OF RETURN t:, Ju/-;>,' '" 1. PlAINTIff/Sf .--- IIi,,:;; t~~. 1/.-' -; (i I - I'" j -- - 2. COURT t}UMBEB, {.-, /( r i nljJ~1 "'J'T':",. /1/ ~ IF I! / ! - _ ., <y /...... .I . ,-,..--~..-:,I _ B..), ifJ f.''....tf'~ "jll - ,., [.!, 4.-TYPEOF..WRITORCOMPLAINT- 3, DEFENbANTIS ' ,'" 'J I I " - (I hr'r,:'5)-h .()', '#E ~{j I (,' ! J.- ;>)/ I., (.i! (' SERVE ; {" - 5, NAM. ;,.QFY~DIVI~UAL C?M~AN:- CORPORATIOfttfTC, TO SEYVE OR DESCfllPTION OF PRO~ER'TY(1tO BE LEVIED, ATTACHED, OR SOLD. ...... (//1r/,,)'t-/I'IC2 /I. 1-1r'(lK ..,.. ,/ Ap.;'ESSpTfEp~R RFO WITH;El,OX NUMBER: APIJT' N~CITY,BQfl1 ,,0, 1We, STATEEANfD Z1l' COrDEs ')/1) 7 ~'.') f j AT : _ .Y /f/J~; {c> .J).. (}/j)(j )(1 . Jr., -- Tr' , /7 ,,. , ,. 7. INDICATE SERVICE: t.Q~ERSONAL ~SON IN C'HI)ffGE ~,DEPUTIZEC-L::r._b:CERI.:MNl~ Q 1ST CLA SMAIL 0 POSTED 0 OTHER NOW , ....'~, ;nf\ ,20 ..... I, SHERIFF QFycrRKCOUNT'(PA, do hereby deputize the sheriff of " \1;01:'1< ' . 00.' ", ~:. q""T:'~"CC)()NTY fiJexecut!itliis writ aria' ma:ke-return thelrElOf according to law, This. deputation being made atthe request and risk oJthe pTalrlt[fC - TH_~U -.. . ~.. ~ . un. . .~- . SHERIFF OFYOFtKCOUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATlONTHATWJLLASSIST Ihl EXPEDJTlNG SEFiVle?1 /lilt IKfJf 3 X 0;. W-/vrlf. . > 10VANCED FEE PAID BY ATTY. --- G-umberla,;--;"i OUT OF COUNTY CUMBERL.~'C NOTE ONLY AePUCABLE ON. WAIT OE EXECUTION: to!.B. WAIVER OF WATCHMAN - Any_deputy sheriff levying upon or attachln,g any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any lQ~s, destruction, or removal of any property before sheriff's sale thereof. 9/TY;~~,r:tN ;ZS;~TTrORNEYI O;;'~~TQ~ a.~D ~~R~ . ~ f / / I 4/ /] I/Ji ') '~ ~E.=:PH~N; N:~~E~r 11 DATE FILED A, ,-,,/, . . /If' II Y IV: !-$fl, 7" ,) /-f'S/2::::; 1/1 If( Iff' // / -;-' ,/ T'W /J 12. SEND ~Ol'J E OF SERVICE CQPY NAME AND ADDR~SS BE~QW: (This area must b~cc:implel~d !f&Otlce is to be mailed)." ~. . ,,-/'~~~ CUMBERLAND CO. SHERIFF, ~;-1:i~'~1ifiAC!;.pr;::t.OW-t:OR (,fSf;OJ=T8.In>l'U;F((fF'; J~O:NOrW.f1ITE lll;J,.QW TtIl$l,'~IL .. ...., .... . 13. I ac;knoWleage receipt of the writ 14: dAtE -R'E-CEIVED 15. Expiration/Hearing Date orcomplai~~indicatedabove. R. AHRENS J-27-0J ~ ,"-_ 16. HOW SERVEb: PERSONAL { r RESIDENCE ( ) _eOS.JEO__( POE ( )__"'" SHERIFF'S OEE{ _) _ I OTHER ( SEE REMARKS =~ ~ ",. ' - , 17. Ii. J hereby"certlfY and return a NOT FOUND because I am unable to locate the individual, comp~YI etc. named abo:ve. -(See remarks below.) 18. NAME AND_ TITLE OF INDIVIDUAL SERV'ED / usr'ADDRESS HERE' IF NOT SHOWN ABOVe (~e:rationshlp to Defendant)' 19. Date of Service Int. 22. REMARKS -, " ~. --f7- ;~ N::Jr ~JN AT GI~ ADDRESS PER P.O. ~ ,-; ,,,",, """", , ,23. Advance Costs :;r: ~. 40, Cost Due or Refund .. , 44. Signature of 41. AFFIRMED q~d sub~..crlbed, to before me thl~l: " .'"l";o Dep. Sheriff - ~ . ., ,~," ! '___ -45, Signature of York 42. day of ,~O ~ 43, _ __ __ __ / - -. County Sheriff "'" "O)~", ,'C'j PROT~ARY / 1;-' >~~ I _'yo; \. ,/", N;- .,.; ",-:;- 46, Si~nature o! Foreign hj ~.:>I.A:.~ FL.{ ,_ ;Jr;t:,t _p./ Coun Shenff 50. , ACKNOWt1;DGE RECEIPLOF THE SHER1FF':::; R.l;TU~N SJGI'\IAT_U8E OF AUTH0F31ZED ISSUING AUTHORITY AND TITLE' 1. WHITE - Issur~g Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE._- Sberiff's Office 47. DATE 48. DATE 49. DATE 51. DATE RECEIVED - , ,~,,-' ;:;-' -'-"~~ ,.", , , HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 3Lf14 CiVi//erfY/ VS. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM ISA DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOT I CE yoti 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 the Complaint and notice are served, 'by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if' you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.' IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUmberland County Bar Association 2 Liberty Ave" Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 A V ISO LE RAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS,. ESABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA E$CRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION, ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y. REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDADU OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, st NOCONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. CUmberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Servic~s, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 TRUE COPY FROM RECORD In Testimony whereof. there unto _my hand amt~of saidCooj1 at Carlisle. Pa. ,-Th .. ~y~~-:~;;-~ Prothonotary . , HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. S1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount . of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff _ ,'" ,n , ~-~1IiliiW. , , h" , i-.; oJ; ~ " ~ '," HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville Florida 32256. 2. Defendant, CHRISTINA A. HECK, is an adult individual whose last known address is 11 EAST MANOR AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about June 28, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $57,822.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit 11 A 11,. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is Successor by Merger to Barnett Mortgage Company. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 11 EAST MANOR :"0 I!io' AVENUE, ENOLA, PENNSYLVANIA 17025 and is--more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 55,727.42 (b) Interest at $11.64 per day from 9/1/99 to 7/1/00 (based on contract rate of 7.625%) 3,526.92 (c) Accumulated Late Charges 140.38 (d) Late charges at $20.32 per month for 10 months 203.20 (e) Escrow Credit 101.02 (f) 5% Attorney's Commission 2,786.37 $ 62,283.27 *Together with interest at the per diem rate noted in (b) above after July 1, 2000 and other charges and costs to date of Sheriff's Sale. 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 that are actually incur~ed by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan .'':'' ,~""~ ",; '."" '~-- balance pursuant to pennsylvania Act No", 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.625% ($11.64 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ByPUR~~R Leon . Haller Attorney for Plaintiff LD. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 ~~ "- .i ,,,,, ,~ '._, I .<1 "l"ljjlhillllllilllillilllllli"~iILIiIIWI,iilljil-.~,I.".................. .....'u.C ~ ,~" ' ~ " k'- U I I .", "'~tJ. IIWIIllifIIlJ_kIlI~IiidiI~~~~JiLtwi~~....... '- :'~lIIIImiiIiUii~iiiililidliillrjj~~ ,-~ 'II .....u..J,~~~........J..Jji_f.'......."""L " L ~ " ."", 'i _ "" I~_' - , .. ALl. 'that ci!U'tatn tract l.1t' p.{ece of bnd situa.te tue Penn.bor", County of Cumberland, State of Pnnns ducribed u followa, to wit: the 'rO\oln'lhlp iI( \lI[a. hour,flo,cl and &EC'tN9IMC It a polnt on thll northu'n dde of Hllt:o; AV1lnue, ~, rt!,~t YIL,>t from ,th"'nolthwllt cornet of Hanot Avenuo and f1econ~\ Al1eYi r.ht"t'l'1it nllltl,wlIrdly throUI~1 the partition wall of ... doubhl f"ama dwdltnr. and bllymlll tOO ft!lIt tn hnd.. r.ovor late .,r ~fuy E. Hyus; l:hence lfur.wtU"dl)' .along thtl "did' L1nd parallel lihh Mano~ AVlIn'Je, 25 !edt tv . pn.int OR th Lllu!: of J,ot No. "\1, 8lbck C, on a Phil of Loti laid QUe by A. R. \\.u~1ey and It'cot'rlt.tl in the Office lot' the a.cording of Deedll In IInd for Cumb..:rJand' r.~lInty in ~I!cord Book "0", Volume 6. ,Page 600; thonct' IO\lthwardl)' stong said Jot" loa fut, mon or lUfI, to Hanor AvenuflJ th.mce eastwardly along HnllClt" Avenue. 25 het to d paint, the rhee (If BECINIIING. HAVING thereon erl!ctl!d tjU! ",C':,ellrn hdf of .- doul)'itl tramJ dwell1ng. KXlIllltT "All f"- v '. ;, ' " " ,"~ -,-' , ,- 1'-'-1 . . VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 5, 2000 ~ Leon P. Haller, Esquire ~- ; ""_0'< -__;,_:~",_,,,,;~_~~ c~~-,-" ~, '_"~ '~, Page 1 SOCIAL - 201-44-3593 . TRACE: 201-44-3593 , TRANS UNION TRACE PLUS REPORT FOR SBJ P HB0034840 RPT ON HECK, CHRISTINA A. MKT/SUB 17 HB SSN 201-44-3593 INFILE 5/83 DATE TIME 09/05/00 11: 58CT DOB 12/62 CURR/ADD 11 E. MANOR AV., ENOLA PA. 17025 FRMR ADD 2204 WHISPERING PINES DR., MARYSVILLE PA. 17053 98 WHITE DOGWOOD DR., ETTERS PA, 17319 CURR EMP & ADD NEW CUMBERLAND ARMY DEPOT NEW CUMBERLAND PA. FRMR EMP & ADD NAVEL DEPO RPTD 07/1996 12/1994 TEL# 732-0898 PSTN INCM DATA TRANSCRIBER EMPDATE RPTD 6/89R 5/83R **END OF NETWORK TRACE PLUS** COPYRIGHTED TRANS UNION 1993 **************************************************************************** Yo dr. 714 $ (OKG>) . /00 u,., r"'rtV'11: (l (IUrYJv(\j.r: l!n<.J,. .s.A ....;(10 ~~ ([)u')~ G -11 c(l ..-' ". ,. :i~ ~- ~ ~'~ {~ JCA . . :. .<". 'co" ". OI:C, " [, ~ ; , "", , 'E" 77 ...1 j (..,_ ..............,. . , '. ' t'> ~) -.', - _10," '- -~", -" -- - , -",.. ;::-:'}1~~f "~ ,~, "~ , : , ~ .--. ,,~ . ^ '_J'~ " - - ",..~J'c...;-__i'"..<'-"""-",,< -',t,'!i;_.i\e;o ,;",,~,," C~";;'JI; ~ ~ ~ 0 U) C ....~" ~- U) f'Tlm 1"'1 ~::D " ::tJ:;; N -<-.; n' -J aU) :roo co :x =Crl -I"" <;:? -<(") f'Tl W W , ,II'!-"', " ,"',~ - '::-._"';"~ t"" .< -~h. . HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT .OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA '::!, l.J1d ii,' 1/) /. 7 eJ n1 NO. 00 . ,fT "1 L v VS. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOT ICE You have been sued in court. If you wish to defend against the claims set forth in the following )?ages, you must take action within twenty. (20) days after the 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 wamed that if. you fail to do so. the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE,' IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. CUmberland County Bar Association 2 Liberty Ave" Carlisle, PA 17013 717-249-3166 Legal Services, Inc. S Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE BAN DEMANDADO A US TED EN LA CORTE. SI DESRA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS" ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DE8PUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE US TED , 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: 81 USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION, ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIRA FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONE8 DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDADU OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300, CUmberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 TRue copy F-ROM .RECORD \11 Testimony wl\efeot. I here unto set my hand ~fld tIWl seal. d'" y' PI. '- Thi~-Q-~~ ~. 'n'A_~~ honotary Legal Services, Inc. S Irvine Row, Carlisle, PA 17013 717-243-9400 ,. w, , "~~ .,. "Ii<" I I r I I, I " HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. fi1601: The undersigned attorney is attempting to collect a debt owed to the Pleintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff . HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville Florida 32256. 2. Defendant, CHRISTINA A. HECK, is an adult individual whose last known address is 11 EAST MANOR AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about June 28, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $57,822.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is Successor by Merger to Barnett Mortgage Company. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 11 EAST MANOR - ~ -,. AVENUE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 55,727.42 (b) Interest at $11.64 per day from 9/1/99 to 7/1/00 (based on contract rate of 7.625%) 3,526.92 (c) Accumulated Late Charges 140.38 (d) Late charges at $20.32 per month for 10 months 203.20 (e) Escrow Credit 101. 02 (f) 5% Attorney's Commission 2,786.37 $ 62,283.27 *Together with interest at the per diem rate noted in (b) above after July 1, 2000 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in tpe 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan """0 -, c ~ Ii -' balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.625% ($11.64 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ByPUR~~ER Leon . Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 - ~ ' -1~li ".jlUiIiIIll~".,IIlIl_II:Ulliutl.llllliilliliillllltilili"liIIi.IlII_.i~ii!lli_~ilifMilIiiiiIiiiid 1.._' ;., " Jty" II,"'~ .....'U..IIIOllliiIi<Jl.J~UllEllil!lltiillil iililllb"i',~IiWI, ,I;i i lilllli"i'~~~ltill~~lliIlibill;lI!lIIllilIlllliilll~otl,UlillllilUliJ"lii~,iiijiM~_i~t. ~. .' ,d~,,- It+',- ~ ;,-."~. ~.. 1iliIi&~1"1ld~I~iIIIIl!iliil&'l ".-, .J.. .... f.IL ~, ..' ALL'that certaIn tract ~r piece of land situate. E..t 'ennllbor". County of CUll\berland, Statw of Ponns d..crlb.d a~ followl. to ~it: the Tovn'llllp u( lllla. hlHmri~cl and &8CUCftltC dt a point on tho northern IIlde of HIII;o; !'IVj~nue, ~, f\!'.'l Yl!llt from ,th"'t'uu'th",..t corner o( Hanor AV"nun and Raeond Alley; r,hI'I',l'Q nllttl,w4rdly throul~' the partition'lo'all vf It dOUGh fram" dwallf,nr. and beyul1d tOO ft!lIt tn hnd,. r,o;t or late ':If N4L'Y E. Hyera. theNce Hut;wtllrdl)' along tht! I-dld- land parallel ..,ith Mano~ AV4n'Je, 23 tedt tll . po.lnt OR th !JIUt of I.oe No. '\l, IlbCk C. on a Plau of Lota la1d OU~ by A. R. t.:up::'ey Bnd It"cOrdf'd In the OfUce for the lecordinB of Oeedll tn nnd tor ClImb..:rJanti C6unty In -'Ilcof.l Book "0", VollJld. 6, Paso 600; thence 8outhwllrdl" atong saId ',ol", lOO -feet, Illon or lcu, to H.mor Avenu.q therlce eastwardly donK Hll110r Avenue, 25 teet tD .:1 poLnt. the rbce (If BECINlflNG. HAVING thereon erected till! lole.'Jtflfn h.df of 6. dOUl)L~ frama dwelling. KXntlltT "Au y' o. , VERIFICATION ,,;" ""~*, I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief ,based upon information provided by Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 5, 2000 --r~ Leon P. Haller, Esquire '. '0 '0 , ........~" . , Page 1 SOCIAL - 201-44-3593 TRACE: 201-44-3593 TRANS UNION TRACE PLUS REPORT FOR SBJ P HE\0034840 RPT ON HECK, CHRISTINA A. MKT / SUB IN FILE 17 HB 5/83 SSN 201-4.4-3593 DATE TIME 09/05/00 11:58CT DOB 12/62 CURR/ADD 11 E. MANOR AV" ENOLA PA. 17025 FRMR ADD 2204 WHISPERING PINES DR., MARYSVILLE PA. 17053 98 WHITE DOGWOOD DR., ETTERS PA. 17319 yo dr. 714 ,1,:' (~;la~) I. POT Yi''i ;,) 'OO?~l/1lf1 ,'I (/U/y3J<-. I, i I, I "",,),...-, I,. /_( f1&,;,.'. ~Lv1 - /6, (",-/f' :=~??;,:~~~ RPTD 07/1996 TEL# 732-0898 12/1994 PSTN INCM DATA TRANSCRIBER EMPDATE RPTD 6/89R 5/83R PLUS** COPYRIGHTED TRANS UNION 1993 **************************************************************************** " /-;) ')' ,/ I iJ ~ 1 . ~ l(~U c C 1 r.- ~- L _ "'--, ~,- i ~1 1/~ - '"t J] ~ ;=t. c.j ..1 ?"r} c:5 V/ lJ,.. lJ,.. . a:: . w 4: ~:t:o.. '> <J) . -lJ,..""c WoO:: o 0 Ww>- 0::0 . lJ,.. I.>- o 'ill- N rl rl rl E a:: r- N 0- L.J ,- U_ Cl Cl "-, " ~- ,.....,., e~'(- (' -n .)[P I.L ""Ff '-:ny r , . ~ ,) :;-1. ~'lIlf!tt~;w.;-"fFt'1(""~~, ~ ,---~ ~ ~ ~ J.iI\I~'...~~,,~ ,- "'"'''''.-' , HOMESIDE LENDING, INC SUCCESSOR BY MERGER TO BARNETT MORTGAGE CONWANY Plaintiff vs. CHRISTINA A HECK Defendant c __ ~.'" ~- ~ ""~ < : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 00-3474 CIVIL TERM : CIVIL ACTION - LAW : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE CONWLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: November 2,2000 PURCELL, KRUG & HALLER A .. BY Leon p, Haller 1719 North Front Street Harrisburg, P A 171 02 Attorney for Plaintiff Attorney ID# 15700 "" -~ --. "'"~- -~ ^' " , .;., 0<- ~~'-Fi{i SHERIFF'S RETURN REGULAR CASE NO: 2000-03474 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMES IDE LENDING INC ET AL VS HECK CHRISTINA A WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HECK CHRISTINA A the DEFENDANT , at 0017:30 HOURS, on the 16th day of November, 2000 at 300 3RD ST APT 2 WEST FAIRVIEW, PA 17025 by handing to CHRISTINA A. HECK a true and attested copy of COMPLAINT - MORT FORE together with RIENSTATED W/ NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So ;:;~~! R. Thomas Kline 11/20/2000 PURCELL, KRUG & HALLER me this ..2.2~ay of Sworn and Subscribed to before By: ~ c2tnnJ A.D. C)F'P~th~Y~ . !ilII'" ~ . ~ ILL' , HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 4-14\(')\ , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Christina Christine 300 Third Apt. #2 Enola, PA A. Heck A. Heck Street a/k/a 17025 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By ~ PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 .'- "-- '">~ . . ~""-' JOHN W, PURCELL HOWARD B. KRUG LEON p, HALLER JOHN W, PURCELL JR BRIAN j, TYLER JILL M, WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DISANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Christina Christine 300 Third Apt. #2 Enola, PA A. Heck A. Heck Street a/k/a 17025 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. I l', r YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. By: gainst the said you have an ing notified of YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. Leon P. Haller PA I.D.15700 Attorney for Plaintiff """..-~~ ,'" . -~. ',I; HOMESIDE LENDING, IN0c, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 6, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 11 East Manor Avenue ENOLA C~BERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 3474 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: CHRISTINA A. HECK ,...d-..... ~ 1. ~ ~ " ~-" ...",.;,.-~ "-,~- ,- ..' " A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAy THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FR~E LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ~"""-~ ~- ~- " ~, ~. petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~" ~~tJk, ALL THAT CERTAIN tract or parcel of land situate and being in the Township of East Pennsboro, Cumberland County, pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Manor Avenue, 25 feet west from the northwest corner of Manor Avenue and Second Alley; thence northwardly through the partition wall of a double frame dwelling and beyond 100 feet to lands, now or late of Mary E. Myers; thence westwardly along the said land parallel with Manor Avenue, 25 feet . to a point on the line of Lot No. 31, Block C, on a plan of lots la~d out by A. R. Rupley and recorded in the Office for the Recording of Deeds in and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot, 100 feet, more or less, to Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling known as 11 EAST MANOR AVENUE, ENOLA, PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kimberly A. Goudy by deed dated 6/26/96 and recorded 7/1/96 in Deed Book 141 Page 1111 granted and conveyed unto Christine A. Heck. TO BE SOLD AS THE PROPERTY OF CHRISTINA A. HECK A/K/A CHRISTINE A. HECK ON JUDGMENT NO. 2000 3474. PARCEL: 09-15-1291-170 ~. - ~ . ~ ~hi ALL THAT CERTAIN tract or parcel of land situate and being in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern side of Manor Avenue, 25 feet west from the northwest corner of Manor Avenue and Second Alley; thence northwardly through the partition wall of a double frame dwelling and beyond 100 feet to lands, now or late of Mary E. Myers; thence westwardly along the said land parallel with Manor Avenue, 25 feet . to a point on the line of Lot No. 31, Block C, on a plan of lots la~d out by A. R, Rupley and recorded in the Office for the Recording of Deeds in and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot, 100 feet, more or less, to . Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a po~nt, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling known as 11 EAST MANOR AVENUE, ENOLA, PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kimberly A. Goudy by deed dated 6/26/96 and recorded 7/1/96 in Deed Book 141 Page 1111 granted and conveyed unto Christine A. Heck. TO BE SOLD AS THE PROPERTY OF CHRISTINA A. HECK A/K/A CHRISTINE A. HECK ON JUDGMENT NO. 2000 3474. PARCEL: 09-15-1291-170 ~ ..;;^ . . Re: Homeside v. Heck Cumberland County Sale 6/6/01 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece Christina Christine 300 Third Apt. #2 Enola, PA of ordinary mail A. Heck a/k/a A. Heck Street addressed to: Postmark: 17025 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 t.::=----- ~~S_~~~ /(>.' ",'~"'~ ---. !~~ "::"l,\,~ ';..' I, \ ::; I~-~~-r: ,'..... ,--'~l""'o,,~/>;;j ,,,,..)>.:-,,1,. '''' 0..& A~R~<J.r,1 "".'Y~" ~I I: :\ ., ,~, Cl"~T;~j;;~1 ~ I~ t; r; ;: ,',. /!'-B'l~.~:" ....,. 10) ... ['1< '-.r" ....' L I" ~_.LY 6?6~'t-:;: ." . -- . , ~-~-._.-.,_._,.J-t: _ C.'~~"" HOMES IDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000 3474 vs. CHRISTINA A. HECK, Defendant CIVIL ACTION LAW IN MORTGAGE FORECLOSURE -~, VOLUNTARY SUBSTITUTION OF HOMESIDE LENDING. INC. PURSUANT TO RULE 2352 (a) Material facts in which the right of succession and substitution is based are as follows: On July 1,1996, said Defendants executed and delivered a Mortgage Note is the sum of $67,822.00 payable to BARNETT MORTGAGE COMPANY. On October 31, 1997, BARNETT MORTGAGE COMPANY, assigned all of its right, title and interest to HOMESIDE LENDING, INC., Said Assignment is recorded in Mortgage Book 560, Page 54. HOMESIDE LENDING, INC., does voluntarily substitute itself as BY: Plaintiff herein. Leo . Ha er, Esqui e Attorney for Plaintiff Date: June 4, 2001 - ',_m~WA~~ '~-.~,...~ ,- " '<,- -<- ~ = ! ! I.: i ~ c:. r;; - "Os: "- Q) =-r' 111m ~ <;:1:1 """ ,'il.;Q <~. , (;j~ -;:;In ;:S< '.n :'{JO () L ",0 "'" -~;!,y ,Ii"O ::J:' ?'j:;d ~O ~ C,_. (') ~ iSm I\.) ;j;i f\) :t:l .... ,~ ~ "^ . '.':';;;, , . STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ____________________________________________________-.________________________Recorderof Deeds in and for said Counly and Slate do 'hereby certify that the Sheriff's Deed in which _____________n_ _g.?.l'J!.:!:!!E>__Ii:._l}EE_~_~~~"_!~P.!'!."_!!E__~':c:E_e_t;.~EY___ ______________________n____________ is the grantee the same having heen sold to said grantee on the _______o.t.h._________________n_____n____n____ day of __________..l:w:le______n_________________ A. D., ; 200 L___, under and by virtue of a writ______n___n_ Execution . ____________________________n__________________ JSSued on the ___________14.1;."n__n______n_______ day of _____!l_'!.':c:!:_m___________ A. D., Civil ------------------__________ --.., _______ --_ _______ __ _______ _________n__ ____ ______ _ Term, , 2~.9J:_, out of the Court of Cornman Pleas of said County as of 2000 Number _1~1.A'._______, at the suit of _!!.o3.!=~_i_~=_!__e_~~~E_.L!~:__~~::_':.':~~:__~L~'::~:_':.._:~__________ ~~!_~=~E_~~:E~_':~~_~~_____________against--------------_____~~:~~_:~~~__~_~:_:~______________ is duly recorded in Sherifrs Deed Book No. _n_2A.L___, Page __J.llJiQ_____. IN TESTIMONY WHEREOF, I have hereunto sel my hand and seal of said office Ihis ___~l_n_ day of ____________~----------- A. D., J-o..9_J -~-J3-~-~i~!;t~eds ....t1......dlIlIf............ fa _oar J..l~wea.IlIll__t1....- "'~---" , 'C , , Homeside Lending, Inc. Successor By merger to Barnett Mortgage Company VS Christina A Heck In the Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-~ Civil 3'11'1 Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 12, 2001 at 6:10 o'clock P.M, EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Christina A Heck located at II East Manor Avenue Enola, Cumberland County, Pennsylvania, according to law. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 12, 2001 at 6:10 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Christina A. Heck, by making known unto Christina A Heck at 300 Third St Apt2 West Fairview, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R, Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to the within named defendants to wit: Christina A Heck by regular mail to her last known address, 300 Third St. Apt,2 West Fairview, PA, This letter was mailed under the date of April 16, 2001 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock AM., E.D.S.T, and sold the same for the sum of$1.00 to Sharon Dunn for The Secretary Of Housing And Urban Development, of Washington, D,C" his successors or assigns. It being the highest bid and the best price received for the same The Secretary Of Housing and Urban Development, of Washington, D.C., his successors or assigns, C/O Golden Feather Realty 1600 Sacramento Inn Way, Suite 220 Sacramento, CA, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $800.77 it being costs, Sheriff s Costs Docketing 30.00 Poundage 15.70 Posting Bills 15.00 Advertsing 15.00 Acknowledging Deed 30.00 Auctioneer 10,00 Law Library .50 County 1.00 Mileage 18.60 Certified Mail 1.69 Levy 15,00 Surcharge 20,00 _ _- ~L" "----, !!" '-- , . LawJournal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 270.05 281.64 25,09 25,00 26.50 $800.77 Sworn and subscribed to before me This .q/~ day of q,Qr 2001 A,D. ctr- ,Q. 7Ir..-!/;,. , A~ thonotary I 0< So answers: ~~~-e/2.u R. Thomas Kline, Sheriff By i~~ 1,0'0':> Co, ~ I-J..r I,~ C-k.- 330 7,2,.1 /1..-. I/LI '73 Y ,'"".. -~ , ,. "-~, , .( , . HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA VS. CIVIL ACTION - LAW . 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 11 EAST MANOR AVENUE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) : Christina Christine 300 Third Apt. #2 Enola, PA A. Heck A. Heck Street a/k/a 17025 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the ",;', " -~ ," f UNKNOWN 7. 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 TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, 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. ~- --_//~ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2001 ~ -,,~ '. --'~ " ' IH':I!S,j: ,,," J HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 6, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 11 East Manor Avenue ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 3474 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: CHRISTINA A. HECK v"~~ - < " ~"'~1 ,- ~ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ;;:~ ,~ "''',-- ,- -. ~a ,.. J petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 , .,,' ~,~ , ALL THAT CERTAIN tract or parcel of land situate and being in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described as follows: BEGI1INING at a point on the northern side of Manor Avenue, 25 feet west from the northwest corner of Manor Avenue and Second Alley; thence northwardly through the partition wall of a double frame dwelling and beyond 100 feet to lands, now or late of Mary E. Myers; thence westwardly along the said land parallel with Manor Avenue, 25 feet . to a point on the line of Lot No. 31, Block C, on a plan of lots la~d out by A. R, Rupley and recorded in the Office for the Recording of Deeds in and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot, 100 feet, more or less, to . Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a po~nt, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling known as 11 EAST MANOR AVENUE, ENOLA, PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kimberly A. Goudy by deed dated 6/26/96 and recorded 7/1/96 in Deed Book 141 Page 1111 granted and conveyed unto Christine A. Heck. TO BE SOLD AS THE PROPERTY OF CHRISTINAA. HECK A/K/A CHRISTINE A. HECK ON JUDGMENT NO. 2000 3474. PARCEL: 09-15-1291-170 . , , . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00-341'J CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Homeside Lending, Inc., Successor by merger to Barnett Mortgage Company PLAINTlFF(S) from Christina A. Heck, 300 Third St., Apt 2, Enola PA 17025. DEFENDANT(S) Real estate located (1) You are directed to levy upon the property of the defendant(s) and to sell at 11 E. Manor Ave., Enola PA 17025. (See attached legal description.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(S) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt tooff()r 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 attachment is found in the possession of anyone other than a named garnishee, you are directed to notHy him/herthat he/she has been added as a garnishee and is enjoined as above stated, $3,957.60 Due Prothy Other Costs Escrow Deficit $2,000.00 Late charges $20.32 per month to sale date $223.52 $.50 $1.00 Amount Due $ 6 2 , 283.27 Interest $11.64/diem to 6/6/01 L.L. Ally's Comm Atty Paid PlaintHf Paid % $276.42 Date: March 14, 2001 CURTIS R. LONG Deputy by: REQUESTING PARTY: Name Leon P. Haller, Esq. Address: 1719 N Front St Harrisburg PA 17102 Plaintiff Allorney for: Telephone: Supreme Court ID No, (717) 234 4178 15700 ,~ ,~ ~~"~"'''''7' '.ifil.11W~IJ;n=<;.L-~'J""."""-"-,,,.Lk'~""" - ,- __~~..illMi ~r' l ~ ~ '---"--'--rm.lf:li" --~'.- - HEAr ESIAYESA\fr NrJ~J-lY vr"qY;~ )(, _ ~ 001 the sheriff levied upon the detenOanlil interest in the real property ,situated in Ed j/~J- ~'~~'r' cumberland County, Pa., knowrlnrl numbered as: liE /WJ,,_, .. ~ ~ _ and more hil,\('OAO on Exhibit "A" filed with this writ and by this reference '"\::Ite:,,/111/u "L Jt :200 J 1('nroorated herein. B~l~ C-l c:;n1 CViJ c:::::a , s:e> y;;a.. . r"C~ileAI.'ESTATESj;1:.ElI< - .' ,_ ".'.'" 'Illl\1I0:2aa.a.'.347~'44 .' " CMITe,m' . . _ ,Yomeside Lendlnil -d'~-- -,,~ ~-Icl:eS!10r'DYl'r'Jl_nc., _ L -S... ....... 1-+ ~~_,Je:rger , ~'.-:: - _'---~' ~tOBarl'Je\r-11'10,.rt9age' _~'~~~-f~~~~~-,_cq~~any -. - , .__c-" . Cft.rsflna A. Heck ~' .' Ally: Leon P. Haller _'- 'DESCRIPTIOIl '~~I cEl1TAIN\1'~<t ~r 1"";;1 ofl,nd ' , ate..aI1(;Ll?eing in the Township of East en_rlsboro, Cumberland County, Eerinsylvania, bounded and described as 1OIlo",,: . . ' . EGfl'lNlNG at a point on fhe northern _':de.oL'Manor avenue, 25 feet west from the Orthwesf _comer of Manor Avenue and ~ni:1 AllEiy; -.!:h~n'e northwardly through . _~ partition wan of a double frame ([~:~mni_and peyond 100 feet to lands. now or - tite.- of _ Marv E.,_Myers; thence weStWardly ~long "the said land parallel n~ :~_anor A~' ue,2S feet to a point on .tlie)ine-of Let Q. 31, Block C, on a plan of IOts--Jaidout A. R. Rupley and recorded,: tJ.tt01e q{fice of !he Rt!cording, of Deeds in ~~ )Qt Cumberland County in Record , ook_O...Yolume 6, Page 600; thence '.' p..lhwardIY along sa. id 10. t, 100 {ee~ morc ::or less" to Manor Avenue; thcnce. e<jstwardiy along M.anor Avenue. 2S feet to -, ~1fomt. the place of BEGtNNING. HftVlNGtHEREON erected the western pfiME-ola double frame dwelling known as r:.ll_EastManor Avenue, Enola, PA. ~gIKG. THE . SAME premises whkh J!~ yvilliam R. GO!Jdy and Kimberly A. Goudy .-~ .Aeed dated 6/26/96 and recorded 711/96 .ln~ Deed Book 14L"Page 1111 granted and -c'o"hveyeati,'1to_Y:'risbr._,Q A. Heck. ~,:Jt'GS.0D5 as the prc,."erty of Christina '2.ji~A afk(~ Christin>'~ A. Heck on tiagmeht No. 2000 3474. ,~ARC~L: 09-15-1291-170, _ c , .'.' , ',"0' . ~ ------_.--'-'--~---~,~---< --'I'J' ~ - ~, - ""'__o! , '" - ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he Is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, Counfy of Dauphin, State of Pennsylvania, owner and publisher of Th e Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 24th day(s) of April and the 1 st and 8th day(s) of May 2001. 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 Dauphin in Mtlaneous Book "M", V;I~:~I~:~~~:' ,,,,,,,,,,.,,....,,.,,,,,,,,,,,,,,<2,,,,,:,,,............,,,,,,,...,,,,,,,,,,,,,,,,,,,,,,, COpy Sworn to and subscribed before me this 21st da~'of Ma 2001 A.D. SALE #44 Notarial Seal . Tony l, Russell, Notary P~b1lc " Hallloburg, Oall1lhin COUnty . My Commlaslon elCplres June 6, 2002 Mel11ll1lr, Pennsylvania AssoCiatiOn 01 NotalNy commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUR1HOUSE 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 $ 280,14 1,50 281,64 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By,.,.,.,.".,."'.,.''''''''......,.'''.,.'''''''.,.,.''""".,.,.,. ','" ._n. " -. ~ - _ r ~._,! - - '--='-"-., ,,-'",,--'---"-" lUi$. EST. ~N:0. 44 Wrtt No, 2000-3474 Civil Homeside Lending. Inc. Successor by merger to Barnett Mortgage Company VS, Christina A. Heck Atty,: Leon p, Haller ALL TIfAT CERTAIN tract or par- cel of land situate and being in the Township of East Pennsboro, Cumberland County. Pennsylvania. bounded and descrtbed as follows: BEGINNING at a point on the northern side of. Manor Avenue, 25 feet west from the northwest comer of Manor Avenue and Second Alley; thence northwardly through the par- , tition wall of a double frame dwell- ! ing and beyond 100 feet to lands. now or late of Mary E. Myers; thence : westwardly along the said land par- allel with Manor Avenue. 25 feet to a point on the line of Lot No, 31. Block C. on a plan of lots laid out by A. It Rupley and recorded in the Office for the Recording of Deeds ill and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot. 100 feet, more or less, to Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling known as 11 EAST MANOR AVENUE. ENOlA. PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kim- berly A. Goudy by deed dated 6/ 26/96 and recorded 7/1/96 in Deed Book 141 Page 1111 granted and con- veyed unto Chrtstine A. Heck. TO BE SOW AS THE PROPER- lY OF CHRISTll'!IA A. HECK A/K/ A C~m1!l'l!lill}E A. HECK ON JUDG- MENT NO. 2000 3474, PARCEL: 09-15-1291-170. -" l'- '"" l'- Total Postage & FeCts $ IT" m Postage $ -" .::r Certified Fee ru 'Return Receipt Fee M (Endorsement Required) CI Restricted DeUvery Fee C (Endorsement Required) t:I t:I ;T m IT" IT" t:I l'- PATRICK WOODS 129 THIRD STREET WEST FAIRVIEWPA 17025 ,.. '~-'~~ ~ Re: Bank of Am vs. Woods Cumberland Sales 12/6/00 u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Fo~ 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Patrick Woods 129 Third Street West Fairview, PA 17025 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Fo~ 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 -" ~~ .' '"""""">,,> " ,,",~"'~'''':'' ~ ,,~ 1 . ""'.""i>..""'.... .~ -"'- ,~'~"I,c" ~ij--I >X '::<' C,__,,:,}. " ,-.."~ 0 (:--J C} C C:J '-1'1 _c "::i"""' '"'[) fi) -.:;...') t11{n <: ZC" Z(-' ,., US,..t~: ~.--.i -,--'-.\ ' / e:C-' ."I:J _:_l':""O'-, -" , " ~(~1 .-- ) ~C} ~..,) :'-) j i'i PC: ::;::-2 Z ~ ~XJ -i -< -< ~ --'.-'--, STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler ~ -----------______---------____________________________________________________llecorderof Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ______u__u_u_ Veterans affairs of Washington ____________________________________._______________________________________________ 5 the grantee the same having been sold to said grantee on the ______________~:~_uuu_____________________u day of Dec ____h______u_____h___________________ A. D., 2000 ______, under and by virtue of a WriL___h________ Execution 12th __u_u_ _______ ____.____.-__ _u ___u un___ u_u issued on the _ __ _h __ _____ ___ ____ u ___u_uu_____ day of _________~_':~:_____._.____ A. D., Civil _____________________ _____ ____._________ _____ ___ __ ____ _____ _______ __ ________ __ __ ___ Term, 2~9!>_" out of the Court of Cornman Pleas of said County as of 2000 3475 Bank of America Number ______________, at the suit of ___________________h____________________h________--__________ Patrick Woods _ __ ___ ________________""'_____ ..,.__ ___ _ against___ _____ __ ___ _____ __ ___ __ ________ __ __ ____ __ __ _______ is 237 632 duly recorded in Sheriffs De~ Book No. _hUU_____, Page _____uu___. IN TESTIMONY WHEllEOF, I have hereunto set my hand and seal of said office th5 ___(!!.-!:!... day of ------1;;::zyi711: D., ~~:0.1 ------.--------~~~i);~ Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan, 2002 .. o~, , '~ llI'~,,- . Bank of America, N.A, Successor In interest of Bank of America, FSB -vs- Patrick Woods In the Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-3475 Civil Kenneth E. Gossert, Deputy Sheirff, who being duly sworn according to law, says on October 6, 2000 at 2:45 o'clock PM, EDST, he served a true copy of real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Patrick Woods by making known unto Patrick Woods at 129 Third Street, West Fairview, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, says on October 6, 2000 at 2:25 o'clock P,M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Patrick Woods located at 129 Third Street, West Fairview, Cumberland County, Pennsylvania according to law. R. Thomas Kline Sheriff who being duly sworn according to law says 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 defendant to wit: Patrick Woods by regular mail to his last known address 129 Third Street, West Fairview, PA. This letter was mailed under the date of October 9, 2000 and never returned to the Sheriff's Office, R. Thomas Kline, Sheirffwho being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania, on December 6, 2000 at 10:00 0' clock A,M, EST, and sold the same for the sum of $ 1.00 to Jill Winkea for The Secretary of Veterans Affairs of Washington D.C., his successors and/or assigns. It being the highest bid and best price quoted for the same The Secretary of Veterans Affairs of Washington D.C" his successors and/or assigns ofWissahickon Avenue and Manheim Street, Philadelphia, P A being the buyer in this execution paid to SheriffR. Thomas Kline the sum of$ 741,72 it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News 30.00 14.54 15.00 15.00 30.00 10.00 .50 1.00 9.92 ,86 15.00 20.00 288,65 216,60 - Share of Bills Distribution of Proceeds Sheriff s Deed Sworn and Subscribed To Before Me ~ /1 This ;Cf ~ Day o'--!lA<._V A'I 2001, A.D, Q~I f1 ~JJff o onotary . 23.15 25,00 26.50 $ 741.72 Pd by Atty 01/08/01 ~ " .dn",~~j',i So anil,wer:,/:",'"'' ~E".c..e /"';;::/'-;~;'tjt~;'~~:t~'7~~ ,~ R. Thomas Kline, Sheriff By {};tuA- Jl:1l Real Estate Deputy ~,~ .!;~_tP ,,(0 cJu 31077 ~ /61,.0{::1'1 ~ '1!IiiJll!:ll::M'c;': " t COpy BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 129 THIRD STREET, WEST FAIRVIEW, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): Patrick Woods 129 Third Street West Fairview, PA 17025 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN ~."-~ ~~ . ~'"bil"'1fio"" . 7 . 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 TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are ~de subject to the penalties of 18 PA C.S. Section 4904 relat' ,g to unsworn falsification to authorities. ' ~~/ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 7, 2000 o ~';_-, '-c"'-:'-< BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 129 THIRD STREET WEST FAIRVIEW CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 3475 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: PATRICK WOODS ,ill - . -~.......~'~ . , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00-147')'" CIVIb:IJti~ CIVIL ACTION -LAW TO THE SHERIFF OF CllmhRrl Fmn To satisfy the debt, interest and costs due Merqer of Bank of America, FEB from Patrick Woods 129 Third Street, West FaiIview, Pa. 17025 COUNTY: Bank of America, N. A. Successor in Interest by PLAINTIFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real Estate: 129 Third Street. West FaiIview. Pa. 17025 (2) You are also dir~i:t~d18Iktt'h6h'lhe'property of the defendant(s) not levied upon in the possession of ".;','.>,,0 GARNISHEE(S) as follows: , , ( __~;: i ':~ ,.:i '; '. and to notffy tI1e garnishee(s) that: (a) an a,tta<.:hment has been issued; (b) the garnishee(s) is/are enjoi/'led from paying any debt to or for the account of the defendaRI'(t)"ahd from delivering any property of the defendant(s)' orbtherwise disposing thereof; (3) If property ofthe defendant(s) noUevied upon an subjectto attachment is found inthe 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, AmountDue 5 56.004.92 from 7-1-00 to 12-6-00 at $11.24 Interest 1 ,77" 'l? LL $0.50 per diem Due Prothy 1 00 Other Costs at $20.02 lmo Late Charqes 580.08 Atty's Comm Atty Paid Plaintfff Paid % 109.30 1500.00 Escrow Deficit Date: Seotember 12. 2000 Curtis R. Lonq Prothonotary, Civil Division by: 0 'IlL<-- (J ~ oo~. <J Deputy REQUESTING PARTY: 11 Purcell, KIug & Ha er Name LROn P. Haller. Esa. Address: 171'l Nort-h Frnnt- ~t-rRRt- Harrisburq, Pa. 17102 Attorney for.: Plaintiff Telephone: (717) ?14-417R Supreme Court ID No. 15700 m11l ~ ...~"""'~ '~>'~iM~;ij~.w",~~,ItIM"'"b;..;.J);tii~:ili.ll&.'i"""~-- - -~ -, ",-,',- i!iIIio"'""''''--'''''''''1r~- "~- '1 "' -U.I!I REAL ESTATE SALE NO.31 ' 'In ~ J'b. ;;-rrv the sheriff levied upon the defendam::. tnterest in the real property situated in E:..bOII,.-.-Lj Lu, ~.I..:.o Cumberland County, Pa., known and numbered as: /:J. "I-aJ h.../' !J~f E.;~~ and more fully described on exhibit "A" filed with this writ and by this reference incorporated herein. nate:A.p".d~~ .J~Nro ~u_ '~:i ~A~.:~- , ~,~ ","~ _~~1" ': L: 11 (, i "'...J YJ R'" __ ,<.. <r "~"_~" , ~_ ~" iIriiIlllI1iiIlliil1IliI ..' e I;i;] ~ fi) &'Vi " ~~~E1U.cSTATE'SAlINO:-JI--'--- . ~~='"7\\rritNQ:&:34t5'. .. .. =.-: aM QfAm~riC!~, N.!\._5.t!9,CeSspr in fnrerest ,,_~ MElrger of ~nk of AmerIca, FSB- -' " -"', '-'iIIS ' . '"' _: ~-.'- ,~,C;:;.";",~cl\ WOCld. . " ,:.'"=-__':" '_ :_>leOri~RalTer''''-- -- ~li --- ffi'ES'CRIPTION i~ __=1H&. C~~~-"Cce or_ parcel of land ~~teml:he LT~ p of East ~nnsboro . ,~JfQnner1y Borough of est Fairview), County of ~'ber}and,. Comm~lth of Pennsylvania. tbQiirided __and, describE{ In accordance Wllb. a .:lWvey made bv Gcriit j, Bell, Registered --,Surveyor, dated May 5, 1976, as follows: EBEGINNING at a h.ub on the East side of Third 1:'% 33_feet Wide} at the oomer of la_nds of ~ .._R'.2binsQn, ,5:r.! said point being '_. along said Road. 416.82 feet to the ne- of Market Street; thence extending _ pointOt beginning and along the :;,sat _sgie of _Third Street, North 15 degrees 00 ~!lUt.es--: West. the - distance of 20.06 feeno a t9rllfnore~at)lte _~om,~ of Jands of William' C. ~lllip,s; _ thence along said lands, South. as . r~~ 31_ minutes 17 seconds East the ~dfsiatl(e' of 129.23 feet to a'hub on_the_West ..s1d.e_Qf.iiuukY (20 feet wide); thence- alo'ng ~id.~ll~y ~o~tl'!,92 degr~~,59 minut~ ~est :~,;aJ1c5! ofl~W ~t too. a hub at the ~omer ,..ofJan9s of Earl A. 'Robin~n, Sr.; then~ .along I~sald lands North 85' degrees 29 minufeS West ~~tlteal~n,c;e of 123.04 feet to a point, 'the place ofJ\E.Cl/\/NINC, ' ,,!!AVlNC, Tll.~~Ol'i EREmD.., ,"../ling :.:.Jm-9W as 129 l1md Sfreet, West FalMew, PA. ,'HElNG THE sAME PREMISES WHICH Sieve ~;:f{Qu~~., a.ad facl<ie l. Rousch by deed dated :&'UI::U]~ and t:e<orded 1/5f93 in ,Deed Book B- ~~~:_~2i 'granted' and conveyed unto PafiiCk tI'Ili.ogj, ..... .... . '. ~ijE ~t6tn a~ the proper-ty" of Patrick Woods -Li;i1fJ~dronent No, 2000 3475. ,ASSESSliIEl>'T' ~S-I7.1044.2IQ =-~-'-_..::---'-----...~---.--~~-_._-"_.~ ~,.'=~~ . , .'-- ',' """I . ' THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly Sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is secureiy attached hereto is exactly as printed and published in their reguiar daily and/or Sunday/ Metro editions which appeared on the 31st day of October and the 7th and 14th day(s) of November 2000. 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 '~;'~:,~:~:::'''"" ., 0000. '" .~ ,,,."'COO""":"'t'"M"'''''"~",BOO'.M.m COpy m is 1st day of ece 2000 AD, Notarial Saal S ALE #37 Terry L, Russell, Notary Public Harriaburg, Deuphln County My Commission Expires June 6, 2002 Mambal, Pennsylvania ASSOCiaUon 01 Notaries ARY PUBLIC My commission expires June 6, 2002 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) $ Totai $ 215,10 1.50 216,60 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duiy paid. By.,.,."".,.,.",."""..,.,....."...,.""",.,.,.,...'",.""" ",,-- ~ ,-,,- '-, '" -- - " H!lAL ESTATE 'S4iJ!.E I'!O. 37 Writ No. 2000-3475 Civil Bank of America. N.A. Successor" In Interest By Meger of Bank of America, FSB vs, Patrick Woods Atty,: Lean p, Haller ALL THAT CERTAIN piece or parcel of land situate 1n the Town- ship of East Pennsboro (formerly Borough of West Fahview). County of Cumberland. Commonwealth of Pennsylvania, bounded and de- sCribed in accordance with a sur- vey made by Gerrlt J. Betz. Regis- tered Swveyar. dated May 5, 1976, as fallows: BEGINNING at a hub an the East- side of Third Street (33 feet wide) at the corner of lands of Earl A. Robinson. Sr.. said pOlnt being meas- ured along said Road. 416.82 feet to the centerline of Market Street; thence extencllng from said paint of beglnnJng and along the said side of 'Third Street. North 15 degrees 00 minutes West the distance of 20,06 feet to a drtll hale at the car- ner of lands of William C. Pb1llips; thence along said lands, South 85 degrees 31 mInutes 17 seconds East the distance of 129,23 feet to a hub on the West side of an alley (20 feet wide); thence along said al- ley South 02 degrees 59 minutes West the distance of 19.00 feet to a hub at the carner of lands of Earl A. Robinson. Sr,: thence along said lands North 85 degrees 29 minutes West the dIstance of 123,04 feet to a polnt, the place of BEGINNING. HAVING THEREON ERECTED A dwelling known as 129 Third Street, West Fa1rV1ew. PA. BEING THE SAME PREMISES WHICH Steve R. Roush and Jackie L. Roush by deed dated 12/31/92 and recorded 1/5/93 in Deed Book B-36, Page 822 granted and con- veyed unto Patrick Woods, TO BE SOLD AS THE PROP- ERTY OF PATRICK WOODS ON JUDGMENT NO. 20003475, ASSESSMENT: 45-17-1044-210. -",~'~ ~ ~'U"_< ."1. ~~O"., , , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), p, L.1 784 STATEOFPENNSYLVANIA : . 55. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esqnire, Editor of the Cumberland Law Journal, ofthe 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 27, NOVEMBER 3, 10,2000 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. R~ SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 NOTARn SliAL LOIS e, SNYDeR, I4rary Pubfic Carlitl. Boro. Cuml>iorianil ~unty. PI. My Commillion expi....Malth5, 2001 ~ , . .j " I, 'n'f_".' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16, 1929), P. L,1784 STATE OF lPENNSYL VANIA : SS. COUNTY OF CUMBERLAND : 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: APRlL 27, MAY 4,11, 2001 Affiant further deposes that he is authorized to verity this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~Edito; SWORN TO AND SUBSCRIBED before me this 11 day of MAY. 2001 . NOli '. LQIlI e: SNYOER, NoIaiy Publlc CdiIe.8oro. Cumberland ColJI1Iy My ComI'nlllllmn Expires'Man:I! 5, 2005. , " , ' " "'alll'J .~~.~ I ~ III 'k--: , '" HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant CHRISTINA A. HECK for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $11.64 from 9/1/99 to 7/1/00) Accumulated late charges Late charges ($20.32 per month to 7/00) Escrow Credit 5% Attorney's Commission $55,727.42 $ 3,526.92 TOTAL $ 140.38 $ 203.20 $ 101. 02 $ 2,786.37 $62,283.27** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HA By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 1:\HOME\MKF\DOCS\CUMBERLA\HECK.P , , -- .- -~. , ,v ~~ I ~ , HOMES IDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS, 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 ~ u i J v ! ~ \ ~ I hereby certify that on FEBRUARY 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 fi ~! J 'I ~! ~ J ;i "''''' _J__ ~ - , I~ . , .-- '.,;.~~ -,; i ., ,.. HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 -3474 Vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: February 21, 2001 TO: CHRISTINA A. HECK 300 3~ STREET, APT. 2 WEST FAIRVIEW, PA 17025 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-249-3166 By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, PA 17102 717-234-4178 "'''' .~ ' H ..~ ij 1_ ". -"', , , I ,.", HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on~. /4 >06/ against you in the the above- $62,283.27 and for the sale and foreclosure of your property located at: 11 East Manor Avenue, Enola, PA 17025 Dated: ::r /4 - oJ (1/ Attorney for Plaintiff: Leon p, Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Christina 300 Third Apt. #2 Enola, PA A. Heck Street 17025 1:\HOME\MKF\DOCS\CUMBERLA\HECK.N r'"'~ ~-- i>~ "" r.LL ~~. '"C"....~~~ 'c' ~4>;;l..W'i~~ ~'lilnlj - --" ,~.,p" " \ ~\. ~ !-U d r'\) \\ \, \\\i ~ '~., 1 ~ ,:\ ---- \\ 0', (p, ~ ~ t: :::;,., \' .......... r t , , >~ ,- ""., ~ 0, ~ ,,\~' ~ "'_/ -- ~ , \JJ ~ - ---- "'<:'> fJ\) ~ ' \ ""0 C><:\ ~ ~~ , ~ - . "orA-J ~?D f' ~ c:J '-N ...\.. ~, "" ----- ~ ~ r C5 ;t. , . ~- 2 '"oS: !:tin' ;;::f-;-I >;::.;' 05'" is :~7: ~c! .r:-- .<:-C-' ""'r-. :s <:5 =iE i;; <- ~ I'v " "" CJ"I ,-",-. ,_."~,,. ~'~.'i \ ~ " .. <:;) -- ;1: 5; "0 " ---;-.: 'C', "h -- ,:~17~S~ <,.j ! ::..:!s.:; , ~ r---.,-"j C:....)--!:.I ,~0 (5n-r $ -.;: ~~I~ ~ ~- ... ~- , ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2000 3474 HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF TOTAL AMOUNT OF JUDGMENT $62,283.27 Interest at $11.64 per diem to sale date $ 3,957.60 Late charges at $20.32 per month to sale date $ 223.52 Escrow Deficit $ 2,000.00 TOTAL $68,464.39* VS. CHRISTINA A. HECK, DEFENDANT(S) *SALE DATE: WEDS.,JUNE 6, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Date: March 12, 2001 Issue Writ of Execution in the above Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To captioned described ENOLA' PA satisfy the judgment, interest and costs in the above case, you are directed to levy upon and sell the property in the attached description known as 11 EAST MANOR AVENUE, 17025. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ~- '<( "', l' 1'-; i I I I I I I I I I I I i i I ! , , ALL THAT CERTAIN tract or parcel of land situate and being in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described as follows: BEGI1:JNING at a point on the northern side of Manor P.venue, 25 feet west from the northwest corner of Manor Avenue and Second Alley; thence northwardly through the partition wall of a double frame dwelling and beyond 100 feet to lands, now or late of Mary E. Myers; thence westwardly along the said land parallel with Manor Avenue, 25 feet . to a point on the line of Lot No. 31, Block C, on a plan of lots laLd out by A. R, Rupley and recorded in the Office for the Recording of Deeds in and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot, 100 feet, more or less, to . Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a po~nt, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling Known as 11 EAST MANOR AVENUE, ENOLA, PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kimberly A. Goudy by deed dated 6/26/96 and recorded 7/1/96 in Deed BOOK 141 Page 1111 granted and conveyed unto Christine A. HeCK. TO BE SOLD AS THE PROPERTY OF CHRISTINA A. HECK A/K/A CHRISTINE A. HECK ON JUDGMENT NO. 2000 3474. PARCEL: 09-15-1291-170 '''~n...1': ii r: " 'I II II r! r! Ii tI i! II Ii II I: .~IIiI!M!l~;,~~'-"-_: ~.,.,~~~... ,.-'- ,. ~, >,' -, "'--,~ , c;:~ j I I ~~I ,'M ~ ~-"". ~) c:Jo . c <" ~" -ou; " \ mp"' , .. z:ii t5~ ;:S"'"' :..;:-C'; :J> O-J (~--.J -.c:::-.-."'- \, ZO __\ --....- \"'-1 ~O ....J -:-- 'l---J f'--J 01 -f0, )> ~ , =< ~ '-'). J--'. \) ~ -J --r 4=::- r--j tJ ~ UJ ~i:cg "'~~'...... '.' ~ .~- '~...: . , ~\ \\=_ J) o :3: := ':;;:J ~2 " :~J ;'fl:.!J >::;8 :~~6 ~: :g () ~- ;zC) om j;! :JJ -< .~ -0 -:c,. --- ~ ~ -.J , " .,<- .. "l.li~ ~" i~ -, i~)"- II , ..... , HOMES IDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, s~ts forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 11 EAST MANOR AVENUE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): Christina Christine 300 Third Apt. #2 Enola, PA A, Heck A. Heck Street a/k/a 17025 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the . UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 "~ <-'iI1lIi!!1l~,~ every other person of whom the any interest in the property which (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relat' g to unsworn falsification to authorities. DATE: March 12, 2001 r Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 =~'"""""~Il!~M~~~Bd A';,. - --- ~ - , l n 0 0 c;: ~n -~ ::Jl: s.. -ol:'JJ ~ rnp'l :::;;J ..- Z:V --~:~ ~cJ :ZC. .::-- (() C7 '~~S () ,<r_ r:;C) ~~ ,-;-, :::: ~ (,~~?~~ <';Q ~C) r:-:> (,) , :Pc:: ~ -? W ::r> =? ~ -.. -1 ".". ^," __~ Y"~"",.' "^__'''',~~,,''''P'_'''''''~" -- ~ ., ",,' r_ [); ~.._~= "----.. - " ~~._~ illiHllil;jl.IiI!IliH"" , . HOMES IDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. 2000 3474 CHRISTINA A. HECK, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, June 6, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 11 East Manor Avenue ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2000 3474 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: CHRISTINA A. HECK ....--,- ~ " . .,.~ - -~ . ~ ,,~ ~": .. . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This 'H. .-, I, ~. , . petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. ,If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 'Ii:: , f ALL THAT CERTAIN tract or parcel of land situate and being in the Township of East Pennsboro, Cumberland County, pennsylvania, bounded and described as follows: BEGI~NING at a point on the northern side of Manor Avenue, 25 feet west from the northwest corner of Manor Avenue and Second Alley; thence northwardly through the partition wall of a double frame dwelling and beyond 100 feet to lands, noW or late of Mary E. Myersj thence westwardly along the said land parallel with Manor Avenue, 25 feet . to a point on the line of Lot No. 31, Block C, on a plan of lots la~d out by A. R. Rupley and recorded in the Office for the Recording of Deeds in and for Cumberland County in Record Book 0, Volume 6, Page 600; thence southwardly along said lot, 100 feet, more or less, to . Manor Avenue; thence eastwardly along Manor Avenue, 25 feet to a p01nt, the place of BEGINNING. HAVING THEREON ERECTED the western half of a double frame dwelling known as 11 EAST MANOR AVENUE, ENOLA, PA. BEING THE SAME PREMISES WHICH William R. Goudy and Kimberly A. Goudy by deed dated 6/26/96 and recorded 7/1/96 in Deed Book 141 Page 1111 granted and conveyed unto Christine A. Heck. TO BE SOLD AS THE PROPERTY OF CHRISTINA A. HECK A/K/A CHRISTINE A. HECK ON JUDGMENT NO. 2000 3474. PARCEL: 09-15-1291-170 L"' ",- ~ !C3i""~_." ,.~~~~:itI;:tcl~i!MIjliiWll~~ .=,., _~ ~ _N ,_ , ^~, -. ,,^ "" , ~.....,; , """~'""-"'-" ~= (') c ~. -aQ'j nlf"'~ ~';;..' . , :!!-,:C 2 c'''' CI] )~, ""'-.< r(:; ~' S0 ~c5 >c :? ~ - , t a o -fl -.--[ - ~ ::."';} ,(::", :.-) d~ c~ ;;! "'::1 -< ;f; "" ':.v ..... "".-wJ!IU-'= .~ ~" . ,~ ' , ~~-~ ~~-'" t .. , ... ~ - HOMESIDE LENDING, INC SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-3474 CIVIL TERM CHRISTINA A, HECK Defendant : CIVIL ACTION - LAW : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: September 06, 2000September 19,2000 PURCELL, KRUG & HALLER :;/ -'... BY Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Attorney for Plaintiff Attorney ID# 15700 ~ -" -"" { 'I CASE NO: 2000-03474 P COMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERIFF'S RETURN - NOT FOUND HOMES IDE LENDING INC ET AL VS HECK CHRISTINA A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HECK CHRISTINA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , HECK CHRISTINA A DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT. NO FORWARDING, PROPERTY VACANT, PAPER EXP. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.92 5.00 10.00 .00 42.92 so~~/ / i1;;om::!~~ Sheriff of Cumberland County PURCELL, KRUG & HALLER 08/01/2000 Sworn and subscribed to before me this It:tR.. day of ~j1,~ 1 rrr-V;r .-r--zr- 'r'" ,. - ~" d',; ---.-4----- HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 60 - .3l./7'f C;Ul.( ~~ VB. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT.A DEBT OWED TO OUR CLIENT; ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOT ICE You have been sued in court. If you wish to defend against the claims set forth in the zollbwing pages, you must take action within twenty (20) days after the Complaint and notice ,are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE' A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUmberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal'Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 A V ISO LE RAN DEMANDADOA USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USrED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA PEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI US TED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS, LAS PROVISIONES DE ESTA 6EMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE US TED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A, UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 2~5-23a-6300. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 ,Legal Services I Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 TRUE COpy FROM RECORD In TestimOrIy whereof. I here Ui\lOHt my Ilalld ;: 2! ofd:~ Cou~ at eamste' Pa. 'An_ ~~~~AJ , ""k"""O""' ,.".-.~ ,,- '" , HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 u.s.c. 91601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days. after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said, thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff ,j~ ., . ' ; ~ - , HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville Florida 32256. 2. Defendant, CHRISTINA A. HECK, is an adult individual whose last known address is 11 EAST MANOR AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about June 28, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $57,822.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is Successor by Merger to Barnett Mortgage Company. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 11 EAST MANOR , ~..;. ~ , .--, , AVENUE, ENOLA, PENNSYLVANIA'17025 and is, more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ (b) Interest at $11.64 per day from 9/1/99 to 7/1/00 (based on contract rate of 7.625%) 55,727.42 3,526.92 (c) Accumulated Late Charges 140.38 (d) Late charges at $20.32 per month for 10 months 203.20 (e) Escrow Credit 101.02 (fl. 5% Attorney's Commission 2,786.37 $ 62,283.27 *Together with interest at the per diem rate noted in (b) above after July 1, 2000 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan I" , "~ _...,L~ ~-~'m;, balance pursuant to Pennsylvania Act No,.. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United states of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.625% ($ll.64 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By'UR~~BR Leon . Haller Attorney for Plaintiff LD. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 - .1~~ ....oIj~~ L. ~ . I""'" ~ 1J,1~..J,W_J~I"'l~i..lli,lIlli~iiM.,DliIlI!lRJli.u.iBJ.w;.~'~!lU~.idiWi~uidiiiJ....~i > ... I 1I1 ,jWli_ .L~J.I~~~___il~II;ii""~_",_,,,,"ri~~J"~ ~,.L,Iilil.!l~WiliI.i~"" ~.I",,,,,,,,",, Iliiilill_ '1-", -~ ._~ ;~.<~ L.~~.;; """:"'~ill,~~i~~L;J;~ ,~~ i~"j~Ji.oii[ ~ .; ~'''''",," .', " ".' ",,' .'" , ,i.h' ", I, " 1; ."" ',II.I~ -, ~-"- ..' ALl. that certain tract t'r p,(cu of lArad sir.uate !aat hon.born, Count)' of Cumberland, State of pqnna ducrlbed' u tollow.. to ",Lu till,! Town'llllp Il{ \11[11. hmmdl!d and &EC1N!ftKG It a polnt on tho northern did. of HIl.I~O; ."\VI!nUe, ~" f~H \,relit frolll ,tb"noC'thwllt cornu a! Hanor Av"nuo ,and Sac:ol;\d ^l 11)'; r.hf"l~l'1i! nilf [I,wl1rdly throul!. the partition wdl of .. douhh,fuma dwdlt.nr.' and beyutld 100 r~lIt to- hnds. foO" or laca "t ~fuy E. Hye.r..; thence Hur:w61l"dl)' "luna thl! htld l.3od parallel "hh Manor Av,n',.. 25 tfHtt tu . ptJ.int OR eft'. Line of 1.0.( No. ''1, Block C, an a Plall 'of Lot. laid out by A. R. t.:up',~e1 snd u'cordt'll In the Ottica Cor the aecording of Deede in land for ClImburJand' C"'llnty ht P,ecord Book "a". Vo!u~. ,6. Page 600; thene. lIol.l,thwardL)' atong said lot", 100 feet, man or bu, to Hunot Avenue; chel'lce ellltwardly along Hallor Avenue. 25 fe'et to .:1 ~olnt. the Flace (If BEGINU1NG. HAVING thereon e.rectl!d tiu! 1o'e3tllrn h~U 'of ,.. double", frlm" dwelling. KX11ll\IT "All c' I ~-. ~.iilli\i1ltJ VERIFICATION . I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 5, 2000 ~~ Leon P. Haller, Esquire 1 ~ seJ ~ G=i;fj i I I , ; ~n__ ._0 - , .H,.~., > ",~," .. " j o ;'['1 .,,,,,,,.,,,,,'",,,.,,.'..,. ~""-"~' >~~ ~ ~~ .'r.,'" ^''t:! !tf ~ ~ ~' '" IJJ=",~.,~ , ' "~ '. , '... "jJj'- HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT ,OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 3"1~~ Co~( T~ vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR. CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County B~r Association 2, Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE ,VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TOPAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESrA DEMANDA A UN ABOGADO IMMEDIATAMENTE. S1 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. S Irvine Row, Carlisle, PA 717-243c9400 TRUI;,OOPVFROM RECORD 17013 In Testimony wherl!Of,lherllllmO Satiny !land :. t~, ~=ld ~t~,;a tann,iisle., ..,:Pa. '- ~dQ~n ,J;~~~ . notary ~ HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. S1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Deb~or notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-:4178 Attorney ID #15700 Attorney for Plaintiff .', .,1 ,'",,;i. " '''.~.- HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. vs. CHRISTINA A. HECK Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville Florida 32256. 2. Defendant, CHRISTINA A. HECK, is an adult individual whose last known address is 11 EAST MANOR AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about June 28, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $57,822.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is Successor by Merger to Barnett Mortgage Company. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 11 EAST MANOR -~ .-" ,;".,,:.. ,',^,.i..,-," AVENUE, ENOLA, PENNSYLVANIA 17025 and is,more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid. principal balance $ 55,727.42 (b) Interest at $11.64 per day from 9/1/99 to 7/1/00 (based on contract rate of 7.625%) 3,526.92 (c) Accumulated Late Charges 140.38 (d) Late charges at $20.32 per month for 10 months 203.20 (e) Escrow Credit 101.02 (f) 5% Attorney's Commission 2,786.37 $ 62,283.27 *Together with interest at the per diem rate noted in (b) above after July 1, 2000 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaint,iff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan ^J' balance pursuant to Pennsylvania Act No;.. 6 of 1974 is not required in that the original principal balance exceeds $50,00Q.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject tb the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.625% ($ll.64 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. BYPUR~~ Leon . Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 .~ liII~,.......,.;j....."",~ ~. <~ ~'i' L, -~L "I I!I~ UIIl;0I.1mO.11.;....,.Ji1..b..j.i,"I,.,"I......iiii.~~"'~lIJl~".jiiol...... " ~'J ," ~ t!f~; _<I<I "" . Ukillt:l&i~lli~rMiliW~~'~lil"..'M~ilM.liili~~Jial!!l~I~lIIiltlhudltliH~~iool_.~~""".....l.; . ~~~ ", "" .at "' ,:.- ., - ,-.,j~I~,,"~~~~lMiIi.i~' :...;., ",- Lc ~ ,j, "I. , ~i' Mi.,. , ..' ALl. that certaln tract (ll" ptcce of land liI1tuate teat '.an.bo~a, County of Cumb~Tlan~1 Stat. of Ponna dnc:rlbed u followl. to wttl the Town'ltllp ur 111[11, hourllled and &EC1N!filfG at 4 poInt on tho northern IIlde of HIlI~O~ f\Y~nue, 2" fe'H ""ORt from ,th"nocthvut corner of Hanor Avenuo ..nd Recond Al leYi thf"n'Q nUl tl,wtlrdly throua!. the p4t'tition wall af A doublfl fT'lIllO dwalllnr. and beY{ln\l lOa f<<!ot to hnds, foOYOr let. .,f ~flty E. Mye.r8l I:ht!nce tfur:wlIlrdl)' ,.dong thl! l'd.ld 1.3nd parallel "1th M4~or Av.n'JI,t 25 tfldt to . pt).lnt on ttoe Lllul of t.ot Nn. 'Il. Block C. on a Pbll 'of Lots la:l.d out by A. R. lo:uple}l' and 1t"ccrdt.d in the .office Cor the Itlcoding of Deeds in And for Cumb\.!rhn(i" C~llnty in ~ecord Book "0". Volume ,6. "P8,88 6QO; thonce" 80uthwardlr slung aajd lot". 100 reet, mot't or J.eu, to Kunor Avenue; therlce eastwardly aleng M;lIlClr Avenue. 25 feet to it )101nt, the Fldce of BEGINIIING. RAVING thereon erectl~d tiu~ lo'f::3tllrn hllU of .' doubi~ frlma dwoJ.l1ng. " ~f~' ~~~~ ,,"u '~~:t RXlll1\1 T "All r- ,\ ' l~' ,~ '. " ,I 1< VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosu:r"e are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY that said facts contained herein are made subject to the penalties of 18 Pa. c. S. Section 4904 relating to unsworn falsification to authorities. Date: June 5, 2000 ~ Leon P. Haller, Esquire ;. ~ ~ ~ I I [ , .If ,PI' ~"~, ~<- -. . ,,"',", ",."". <' ".FF '" "...~ffl; _,".~"ILn~ " ",''''~ ".'^"';"""~"' "'0;-81 /. -.'0'" .... II".' . ~ ~ ~ . , ~. ~ i""' ' -.~,"', ,1lI:Y;