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HomeMy WebLinkAbout02-5597FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 56q-7000 WELLS FARGO HOME MORTGAGE, 1NC. F/K/A NORWEST MORTGAGE, 1NC. 5024 PARKWAY PLAZA BUILDING 7/F/C CHARLOTTE, NC 28217-4207 Plaintiff JONATHAN B. HEINZE TRACEY M. HEINZE 217 SOUTH 15TH STREET CAMP HILL, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CiVIL DiVISION TERM NO. o=-..Cs'q7 CUMBERLAND COUNTY Defendant(s) CMl. ACTION - LAW COMPLAINT IN MORTGAGE FORECI~O,qIYRE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** YOU have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 1217795 BJP IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BUILDING 7/F/C CHARLOTTE, NC 282174207 The name(s) and last known address(es) of the Defendant(s) are: JONATHAN B. HEINZE TRACEY M. HEINZE 217 SOUTH 15TH STREET CAMP HiLL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 7/21/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST ADVANTAGE MORTGAGE CORPORATION ~vhich mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1152, Page 479. By Assignment of Mortgage recorded 11/24/93 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 459, Page 1007. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 1/1/02 through 11/1/02 (Per Diem $14.38) Attorney's Fees Cumulative Late Charges 7/21/93 to 11/1/02 Cost of Suit and Title Search Subtotal $62,769.35 9,634.60 1,250.00 565.40 $74,769.35 Escrow Credit 0.00 Deficit 2~2fiL~ Subtotal $.3~XzLg~ TOTAL $78,031.33 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. ffthe Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an m rem Judgment against the Defendant(s) in the sum of $78,031.33, together with interest from 11/1/02 at the rate of $14.38 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff · /~ THAT CE~TAII~ ~r~ct argareel ~land andpr~mi$~$, situate, lying and being ~ the Borough ~ Camp Hill In t&# Co~o~ C~M~RLAND ~nd C~rtunonw~alth ~Penn~lvanta. more ~artlaularO d~crtb~d B~GINNING at a pbint on t~e east side of Fifteenth Street, said No. 106 in 9lan ~f~'lots hereinafter mentioned to a ~oint on the western side ~ a 20 foot'wide ~llegl thence ecuthwardly along the sa~d alley.20 f~e~t more or less, to a ~0in~$ thence westwardiy no~hwardly alon~ th~ e.as~ern si~e of F~fteenth Str~t, 20 feet, more ~ING th~ northern ~rt. Lon ~f Lot No. 107 on a plan of lots known as in ~lan Book ~, ~age 20. HAVING THEREON erected ~:he northern hal~ of = double two and on,-half etory dwelling No."217 ~. Fifteenth Street. ~EING.the_e~un~'pre~ieee which Harry Pillock and Lucinda Pillook by oeed uate~ November.0, L991 and re~erded November 12, 1991 in the PRE~IISES BEING: 217 S. 15TH STREET. -- _ VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiffin this matter, that Plaintiffis outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unswom falsification to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-05597 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HEINZE JONATHAN B ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland CountY, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HEINZE JONATHAN B the DEFENDANT , at 5045:00 HOURS, on the ~5th day of November , 2002 at 217 SOUTH 15TH STREET -- CAMP HILL, PA 17011 TRACEY HEINZE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing ~er attention to the contents thereof. Sheriff,s Costs: Docketing 18 00 Service ' 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this I?~ day of _ k~j~ ~-t~o 2~ A.D. -- P~ot h~n~t ary ~ So Answers: R. Thomas Kline 11/27/2002 FEDERMAN & PHELAN By: Deity Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-05S97 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HEINZE JONATHAN B ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HEINZE TRACEY M the DEFENDANT , at 204S:00 HOURS, on the 25th day of ~ovember , 2002 at 217 SOUTH 1STH STREET - CAMP HILL, PA 17011 TPJtCEY HEINZE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6 00 Service Affidavit .00 .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /~ day of _'~0 ~,~ ~17~o~ A.D. P~otKo~ot ary So Answers: R. Thomas Kline 11/27/2002 FEDERMAN & PHELAN Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. F/KdA NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BUILDING 7/F/C CHARLOTTE, NC 28217-4207 Plaintiff, V. JONATHAN B. HEINZE TRACEY M. HEINZE Det'endant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5597 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JONATHAN B. HEINZE and TRACEY M. HEINZE, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 11/'2/02 to 12/30/02 TOTAL $78,031.33 $848.42 $78,879.75 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. IF. RANK F)~DERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 1~ 30 PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (21q) 56%7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff VS. JONATHAN B. HEINZE TRACEY M. HEINZE Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-5597 Defendant TO: JONATHAN B. HEINZE 217 SOUTH 15TH STREET CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER 17, 2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT ~THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTA/qT NOTICE YOU are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 L~ERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federm~n, Esquire Attorney for Plaintiff FEDER~MAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff VS. : COURT OF COMNON PLEAS : CIVIL DIVISION : CUMBERLAAFD COUNTY JONATHAi~ B. HEINZE TRACEY M. HEZNZE : NO. 02-5597 Defendant TO: TRJkCEY ~{. HEINZE 217 SOU~3H 15TH STREET CAMP HI3fL, PA 17011 DATE OF NOTICE: DECEMBER 17, 2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NG:TICE IS SENT TO YOU IN kN ATTEMPT TO COLLECT tTHE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, B~ ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. %MPORTkNTNOTIC~ You are.in default because you have failed enter a written appearance Fersonally 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 ma{> lose your property or other important rights. You should take ~his notice to a lawyer at once. If you do not have a law%/er or cannot afford one, go to or telephone the following office to find out where you can get legal help: i CUMBERLAND COUNTY _, CUMBERLAND COUNTY BAR ASSOCIA~0N .,_ 2 L~ERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULDING 7/F/C Plaintiff, V. JONATHAN B. HEINZE TRACEY M. HEINZE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DIVISION NO. 02-5597 VERIFICATION OF NON-MILITARY SERVICE the a .FRANK FEDERMAN, ESQUIRE, hereb verifies · . . . bove-capt~oned matter, and that on informai Y . that he ~s att.orney for the Plmnt~ff~n to wit: t on and behef, he has knowledge of the following facts, (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JONATHAN B. HEINZE is over 18 years of age and resides at, 217 SOUTH 15TH STREET, CAMP HILL, PA 17011 . (c) that defendant TRACEY M. HEINZE is over 18 years of age, and resides at, 217 SOUTH 15 STREET, CAMp HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, JONATHAN B. ltEINZE TRACEY M. HlgINZE Defendant(s). No. 02-5597 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 12/31/02 to 6/11/03 (per diem -$12.97) TOTAL $78,879.75 v/ $ 2,114.11 and Costs $80,993.86 ~,ANK FE]~E~VI~, ESQUIRE One Penn Ceflter at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN lot or piece of ground situate in the Borough of Camp Hill, Cumberland County and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the east side of Fifteenth Street, said point being 160 feet south of the southeast comer of Fifteenth and Second Streets; thence eastwardly 150 feet along the southern line of Lot No. 106 in plan of lots hereinafter mentioned to a point on the western side of a 20 foot wide alley; thence southwardly along the western side of said alley 20 feet, more or less, to a point; thence westwardly through the center of the partition wall separating premises No. 219 S. Fifteenth Street from the premises herein conveyed and beyond 150 feet to a point on the eastern side of Fifteenth Street; thence northwardly along the eastern side of Fifteenth Street, 20 feet, more or less, to a point, the place of BEGINNING. BEING the northern portion of Lot No. 107 on a plan of lots known as "Greater Harrisburg" Estate of Jackson Free recorded in the Office for the Recording of Deeds in and for Cumberland County aforesaid, in Plan Book 1, page 20. HAVING THEREON erected the northern half of a double two and one-half story dwelling No. 217 S. Fifteenth Street. PARCEL #01-22-0826-085 BEING the same premises that David D. Herr and Paula A. Herr, h/w, by it's deed dated 7/21/93 and recorded in the Office of Recorder of Deeds in and for Cumberland County, Pennsylvania on 7/23/93 in Deed Book Volume 36-K, Page 742, granted and conveyed unto Jonathan B. Heinze and Tracey M. Heinze, Grantor herein. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. JONATHAN B. HEINZE TRACEY M. HEINZE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5597 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FJEDERMA~!, ESQUIRE Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. JONATHAN B. I-IEINZE TRACEY M. HEINZE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5597 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WELLS FARGO HOME MORTGAGE~ INC. F/IGA NORWEST MORTGAGE~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~217 SOUTH 15TH STREET~ CAMP HILL~ PA 17011. 1. Name and address of 0wner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JONATHAN B. HEINZE 217 SOUTH 15TH STREET CAMP HILL, PA 17011 TRACEY M. HEINZE 217 SOUTH 15 STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Narne None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Sallie iN[one Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Sallie Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 217 SOUTH 15TH STREET CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 December 23 2002 DATE I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. [FRANK FEI~ERMAN, ESQUIRE Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. JONATHAN B. HEINZE TRACEY M. HEINZE Defendant(s). TO: JONATHAN B. HEINZE 217 SOUTH 15TH STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-5597 December 23, 2002 TRACEY M. HEINZE 217 SOUTH 15 STREET CAMP HILL, PA 17011 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTE ** Your house (real estate) at ~ 217 SOUTH 15TH STREET~ CAMP HII.L~ PA 17011~ is scheduled to be sold at the Sheriff's Sale on JUNE 11~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of ~78~879.75 obtained by WELLS FARGO HOME MORTGAGE~ INC. F/K/A NORWEST MORTGAGE~ INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: {215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value ofybur property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distr/bution of the money bid for your house will be filed by the Sheriffwitkin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (I0) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot or piece of ground situate in the Borough of Camp Hill, Cumberland County and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the east side of Fifteenth Street, said point being 160 feet south of the southeast comer of Fifteenth and Second Streets; thence eastwardly 150 feet along the southern line of Lot No. 106 in plan of lots hereinafter mentioned to a point on the western side ora 20 foot wide alley; thence southwardly along the western side of said alley 20 feet, more or less, to a point; thence westwardly through the center of the partition wall separating premises No. 219 S. Fifteenth Street from the premises herein conveyed and beyond 150 feet to a point on the eastern side of Fifteenth Street; thence northwardly along the eastern side of Fifteenth Street, 20 feet, more or less, to a point, the place of BEGINNING. BEING the northern portion of Lot No. 107 on a plan of lots known as "Greater Harrisburg" Estate of Jackson Free recorded in the Office for the Recording of Deeds in and for Cumberland County aforesaid, in Plan Book 1, page 20. HAVING THEREON erected the northern halfofa double two and one-half story dwelling No. 217 S. Fifteenth Street. PARCEL #01-22-0826-085 BEING the same premises that David D. Herr and Paula A. Herr, h/w, by it's deed dated 7/21/93 and recorded in the Office of Recorder of Deeds in and for Cumberland County, Pennsylvania on 7/23/93 in Deed Book Volume 36-K, Page 742, granted and conveyed unto Jonathan B. Heinze and Tracey M. Heinze, Grantor herein. WR/T OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTy OF CUMBERLAND) NO 02-5597 Civil TO THE SHERIFF OF CUMBERLAND COUNTy: CIVIL ACTION _ LAW To satisfy the debt, interest and costs due WELLS FARGo HOME MORTGAGE, INC. f/k/a NORWEST MORTGAGE, iNC. Plaintiff(s) From JONATHAN B. and TRACEY M. HEINZE, 217 SOUTH 15Tn ST '~ , ~ -- 17011. · , ~.~vlp HILL PA (1) You are d/rected to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 217 SOUTH 15~u ST., CAMp HILL PA 17011 (SEE ATTACHED LEGAL DESCRIPTON) . (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) paying any debt to or for the (s) or otherwise account of the defendant (s)and from delivering any propertyi~;7~e°/ned from (3) If property disposing thereot~ of the defendant(s) not defendant of anyone °therthananamed garnisheeleyVoi~d upon an subject to attachment is found in thepossession garn/shee and is enjoined as above stated. Amount Due $78,879.75 Interest 11/2/02 TO 6/11/03 Atty's Corem % AttY Paid $136.35 Plaintiff Paid Date: DECEMBER 30, 2002 $848.42 are directed to notify h/m/her that he/she has been added as a L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LQNG (Sea/) Protho/~tary / /~ REQUEST/NG PARTy: By: ~~ Name FRANK FEDERMAN ESQ. Address: ONE PENN CENTER ~ SUBURBAN STATION 1617 JFK BLVD., SUITE 1400 HILADELPHIA PA 19103-1814 Attorney for: PLA/NTIFF Telephone: (215) 563-7000 SUpreme Court ID No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. ~)E~OA~T(S) JONATHAN B. HEINZE TRACEY M. HEINZE SERVE TRACEY M. HEINZE AT 217 SOUTH 15 STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-5597 ACCT. #1217795 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 11, 2003 Served and made known to at /: 0 fi-., o'clock V.rrL, at ~] 7 SERVED ., Defendant, on the of Pennsylvania, in the manner described below: day of '~ o~,~, 2002~ ...... Commonwealth _ Defendant personally served. ~_~Adult family member with who.m_ Defendant(s) reside(s). Relationship is [,~{J :SlOe> q'J ~k_ "~ta · ' · · · -~ Adult in charge of Defendant(s) s residence who refused to g~ve name or relationship. ~Ma"ager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. __Other: . a ht i, ~ ~ ~,~., C.~ ~. ~3La comp. eteut ad.alt, being duly sworn accordin.~ to. law, a. epose and.state that I verso.ally, handed a CtrCu!7~anrrd correct copy of the NVotice of Sheriff's Sale m the manner as set f°rth herem' issued m the capt'°ned cas~°n the date and at the address indicated above. Sworn to and subscn~,bed I 61~!~ T~., F ' ~ ~ I before me this /X~'day ~ /~ ,f~ /~x / I~~~l~X]~,.l~,~ll~ ,,I P'~E~ ATTEMP~'~RVICE AT LE~T/3-~I~[S: II~DICATE D~TES~& TIMES OF SERVICE ATTEMPTED-. NOT SERVED On the day of Moved ~ Unknown~ 1st Attempt: / / ,200_, at No Answer Time: ' o'clock __.m., Defendant NOT FOUND because: Vacant 2~d Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this ~ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. FfK/A NORWEST MORTGAGE, INC. DEFENDANT(S) JONATHAN B. HEINZE TRACEY M. HEINZE SERVE JONATHAN B. HEINZE AT 217 SOUTH 15TH STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-5597 ACCT. #1217795 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 11, 2003 SERVED )-~,.~o ~: n ., Defendant, on the ... day of ~]'~,a oC~ ~, 200__~ , Commonwealth Served and made known to ~)'~I,o e,~ ~ I~, of Pe~ylvaMa, M the ~er described below: ~ Defendant personally se~ed. Adult fa~ly member ~ whom Defend~t(s) resi&(s). Relafio~p is Adult M c~ge of Defend~s)'s residence who reused to give rome or relafionsMp. M~ager/Clerk of place of lodgMg in which Defendant(s) reside(s). Agent or person M c~ge of Defendant(s)'s office or usual place ofbmMess. ~ officer of sa~d Defen~nt(s) co,any. ~O~er: [~ ~o Description: Age ~g~ Height ¢ Wei~t ~ Sex ~ O~er ~'"~ %~.~c ~ ~. Q~ ~./. ~ a co~etent adul~ berg dry sworn accord~g to law, depose and state t~tI persomlly handed I~ ~e ~d co~ect copy of ~e ~fice of ShenWs Sal~ m ~e ~er as set fo~ here~~d at · e ad.ess ~cated above. ~~~~~~ Sworn to and subscribed befo~me~s/~y ~ ~ ~ __~ m' ........ NOt . [. '~~ Y: _ ~EM LE TIMES OF SER~CE ATTEMPTED. NOT SER~D On the. day of ,200__, at ~ Moved ~ Unknown~ No Answer 1st Attempt: / / Time: ' o'clock __.m., Defendant NOT FOUND because: Vacant 2"d Attempt: / / Time: 3rd Attempt: / / Time: ' Sworn to and subscribed before me this ~ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. ) CIVIL ACTION ) VS. JONATHAN B. HEINZE ) CIVIL DIVISION TRACEY M. HEINZE ) NO. 02-5597 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. hereby verify that on 12/30/03 & 4/22/03 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: May 8, 2003 ~I~RANK FEDERMAN, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Zieeler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Home Mtg Inc is the grantee the same having been sold to said grantee on the 11 th day of June A.D., 2003, under and by virtue of a writ Execution issued on the 3oth day of Dec, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 5597, at the suit of Wells Fargo Home mt~ Inc against Jonathan B Heinze & Tracer M is duly recorded in Sheriff's Deed Book No. 257, Page 4332. IN TESTIMONY WHEREOF, I have hereunto set my hand eal of said office this / ~ day of ~ _ , A.D. 2003 Recorder of Deeds C Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. VS Jonathan B. Heinze and Tracey M. Heinze In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5597 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on February 10, 2003 at 12:55 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jonathan B. Heinze, by making known unto Jonathan B. Heinze, personally, at 217 south 15th Street, Camp Hill, Cumberland County, Pem~sylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on February 10, 2003 at 12:55clock PM, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tracey M. Heinze, by making known unto Jonathan B. Heinze, husband of defendant, at 217 South 15th Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 08, 2003 at 3:23 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jonathan B. Heinze and Tracey M. Heinze located at 217 South 15th Street, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Jonathan B. Heinze, by regular mail to his last known address of 217 South 15th Street, Camp Hill, PA 17011. This letter was mailed under the date of April 04, 2003 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Tracey M. Heinze, by regular mail to her last known address of 217 South 15th Street, Camp Hill, PA 17011. This letter was mailed under the date of April 04, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 11, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. It being the highest bid and best price received for the same, Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. of 5024 Parkway Plaza, Building 7/F/C, Charlotte, NC 28217-4207, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $782.44, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 15.34 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.01 Certified Mail Levy 15.00 Surcharge 30.00 Law Journal 284.00 Patriot News 225.85 Share of Bills 25.24 Distribution of Proceeds 25.00 Sheriff's Deed 40.50 $ 782.44 Swom and subscribed to before me This 34.*~ 2003, A.D. So Answers: -- -- . R. Thomas Kline, Sheriff Prothonotary Real Estate Deputy Real Estate Sale # 24 On February 6, 2003 the sherifflevied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA known and numbered as 217 South 15th Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2003 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller 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 Sundav 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 22nd and 29th day(s) of April and the 6th day(s) of May 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place 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 Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY and Sta~ ~, r'c~ylw~ bom~ and dm~il~d u follows, to ~,it: Sworn to and subscri ed b 's 14th day of.,,,nMay.~,~ A.D. - Notarial . ~,pe~nsyNania A~'a~n ~ commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs ~sm~, ~d peat b~ l~o,f~ ma~ To THE PATRIOT-NEWS CO., Dr. s~m;,~ mmeey 1~ ~ ~;~ For publishing the notice or publication attached ~ ~ ~ ~' ~ ~ ~ hereto on the above stated dates $ 224.10 ~a~f~;~ Probating same Nota~ Fee(s) $ 1.75 ~~ ~d~ Toter $ 225.85 ~.~ s. ~ ~ ~_~ ~ , . ~~i~n-~ Publishers Recmpt for Advertising Cost ~~F~S~'t;~ ~, ~ ~.~ Co., pubhsher of The Patriot-News and The Sunday Patriot-News, newspapers of general ~~mi~ ledge receipt of the aforesaid notice and publication costs and ce~ifies that the same have ~[ ~in~ By .................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : Lisa Marie Coyne, 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: APRIL 25, MAY 2, 9, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. REAL ESTATE ~L&LE NO. 24 Writ No. 2002-5597 Civil Wells Fargo Home Mortgage, Inc., f/k/a Norweai Mortgage. Inc. vs. jonathan B. Heinze and Tracey M. Heinze Atty.: Frank Federman ALL THAT CEI~TAIN lot or piece of ground situate ti1 the Borough of Camp Hill, Cumberland County and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the east side of Fifteenth Street, said point being 160 feet south of the southeast comer of Fifteenth and Second Streets; thence eastwardly 150 feet along the southern line of Lot No. 106 in plan of lots hereinaf- ter mentioned to a point on the west- ern side of a 20 foot wide alley; thence southwardly along the west- em side of said alley 20 feet, more or less. to a point; thence westward- ly through the center of the partition wall separating premises No. 219 S. Fifteenth Street from the prem- ises herein conveyed and beyond 150 feet to a point on the eastern side of Fifteenth Street; thence northwardly along the eastern side of Fifteenth Street, 20 feet, more or less, to a point, the place of BE- GINNING. BEING the northern portion of Lot No. 107 on a plan of lots known as 'Greater Harrisburg' Estate of Jackson Free recorded in the Of- rice for the Recording of Deeds in mad for Cumberland County afore- said, in Plan Book 1, page 20. HAVING THEREON erected the northem half of a double two and ~isa'M~e~Co~, E~itor SWORN TO AND SUBSCRIBED before me this 9 day of MAY, 2003 ALL THAT CERTAIN lot or piece of ground situate in the Borough of Camp Hill. Cumberland County and State of Pennsylvania. bounded and described as follows, to wit: BEGINNING at a point on the east side of Fifteenth Street, said point being 160 feet south of the southeast corner of Fifteenth and Second Streets: thence eastwardly 150 feet along the southern line of Lot No. 106 in plan of lots hereinaf- ter mentioned to a point on the west- ern side of a 20 foot wide alley: thence southwardly along the west- em side of said alley 20 feet, more or less, to a point: thence westward- ly through the center of the partition wall separating premises No. 219 S. Fifteenth Street from the prem- ises herein conveyed and beyond 150 feet to a point on the eastern side of Fifteenth Street; thence northwardly along the eastern side of Fifteenth Street, 20 feet. more or less, to a point, the place of BE- GINNING. BEING the northern portion of Lot No. 107 on a plan of lots known as 'Greater Harrisburg" Estate of Jackson Free recorded in the Of- flee for the Recording of Deeds in and for Cumberland County afore- said, in Plan Book 1, page 20. HAVING THEREON erected the northern half of a double two and one-half story dwelling No. 217 S. Fifteenth Street. PARCEL #01-22-0826-085. BEING the sm-ne premises that David D. Herr and Paula A. Herr. h/w, by its deed dated 7/21/93 and recorded in the Office of Record- er of Deeds in and for Cumberland County, Pennsylvania on 7/23/93 in Deed Book Volume 36-K, Page 742, granted and conveyed unto Jonathan B, Heinze and Traeey M. Heinze. Grantor herein.