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HomeMy WebLinkAbout02-5613WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. JESSICA B. ARNOLD Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA )lx Oy_ 513 CIVIL ACTION-LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 claim in the Complaint of 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN 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, O 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 DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. JESSICA B. ARNOLD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 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 with 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 & 1 ALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. JESSICA B. ARNOLD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE )U n1-/3 t'10,?J -rt--- COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust indenture dated as of April 1, 1982 ("Trust'), is a National Association with a servicing agent of Pennsylvania Housing Finance Agency, with an address of 2101 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, JESSICA B. ARNOLD, is an adult individual, whose last known address is 317 SOUTH FREDERICK STREET, MECHANICSBURG, PENNSYLVANIA 17055. 3. On or about, December 30, 1998, Jennifer M. Beaman, executed and delivered a Mortgage Note in the sum of $59,000.00 payable to BROADVIEW 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, Jennifer M. Beaman, 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 in Mortgage Book 1511, Page 523 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and recorded in the aforesaid County in Mortgage Book 599, Page 658. The Mortgage was subsequently assigned to WACHOIVA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 317 SOUTH FREDERICK STREET, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. 6. On May 23, 2000, An Assumption Agreement to the Mortgage was recorded in the aforesaid County in Mortgage Book 646, Page 555, between Jennifer M. Beaman, original Mortgagor, and Jessica B. Arnold. By the terms of the Assumption Agreement to the Mortgage, Jennifer M. Beaman, is released from all liability, and therefore is not named as a party to this Action. The said Defendant, Jessica B. Arnold, is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on June 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $7.77 per day From 05/01/2002 To 12/01/2002 ( based on contract rate of 5.000%) Accumulated Late Charges Late Charges $15.84 From 06/01/2002 to 12/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $55,919.68 $1,662.78 $142.56 $126.71 $799.75 $2,795.98 $61,447.46 "Together with interest at the per diem rate noted above after December 01, 2002 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 balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that that 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 her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.000% ($7.77 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PU CELL, KRUG & H LLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) -NOTE DECEMBER 30.1998 HARRISBURG PENNSYLVANIA Ickyl IS'.ld 317 S FREDERICK STREET, MECHANICSBURG, PA 17055 IPrapeny Addre[5I 1. BORROWER'S PROMISE TO PAY Intention for a loan that I have received, I promise to pay U.S.$ 59,000.00 (this amount is called "principal"), plus interest, to the order of the Lender. The Lender is BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 .Iunderstand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly mte of 5.000%. }! The interest mte required by this Section 2 is the mte I will pay both before and after any defu It described in Section 6(B) of this Now. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the I ST day of each month beginning on FEBRUARY 1 , 1999 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied m interest before principal. If, on JANUARY 1, 2029 , I still owe amounts under this Note, I will pay those amounts in full on that dam, which is called the "maturity date." I will make my monthly payments at BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 or at a different place if required by the Now Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S.$ 316.72 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they are due, A payment of principal only is known as a "prepayfaCtl When I make a prepayment, I will tell the Now Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The Now Holder will use all of my prepayments to reduce the amount of principal that I owe under this Now. If I make a partial prepayment, there will he no changes in the due dare or in the amount of my monthly payment unless the Nom Holder agrees in writing m those changes. S. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, dam: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (it) any sums already collected from me which exceeded permitted limits will be refunded to me. The Now Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment m me. If a refund reduces principal, the reduction will be treated as a partial prepayment. - 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late charge for Overdue Payments If the Now Holder has not received the full amount of any monthly payment by the end of FIFTEEN**** calendar days after the date it is due, I will pay a taro charge to the Nom Holder. The amount of the charge will be 5.00 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or mailed to me. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Now Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Nam Holder has required me to pay immediately in full as described above, the Nate Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Now m the extent not prohibited by applicable law. Those expenses include, for example, reasonable avomeys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Now will be given by delivering it or by mailing it by foot class mail m me at the Property Address above or at a different address if I give the Now Holder a notice of my different address. Any notice that must be given to the Now Holdex under this Note will be given by mailing it by first class mail m the Now Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different "By initialing, the Borrower(s) acknowledge(s) that this page is page 1 of 2 of the Multistate Fixed Rate Note." ACCTR 935507 Is Family - FNMA/FHLMC UNIFORM INSTRUMENT Form 320012183 000762 01611W991JUtlnn, {olmt ln[. Nas61'I00'16aarw OMl t U035A 264306aa I6111V4L1111 J. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Now, each person is fully and personally obligated to keep all of the promises made in this Now, including the promise to pay the full amount owed. Ally person who is a guatamor, surety or endorser - of this Note is also obligated in do these things. Any person who takes a* these obligations, including the obligations of a guarantor, sure ty or endorser of this Note, is also obligated to keep all'of the promises made in this Note. The Note Holder may enforce its rights under this Now against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder in demand payment of mounts due. "Notice of dishonor" means the right to require the Now Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in somejurisdiclions. In addition to the protections given to die Note Holder under this Note, a Mortgage, Deed of Trust or Security Dead (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might recut if I do not keep the promises which I make in this Now. That Security Instrument describes how and under what conditions I mate required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (a if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent Lender may, at its option, requite immediate payment in full of all sums secured by this Security Instrument However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies pertained by this Security Insoumenl without further notice or demand on Borrower. " WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. (Seal) IFER BEAMAN .a=?=••(Sign Original Only] 4J(',ltrh00 lp?siMa"ELLON BANK NA. : ' Without Recourse, Pay To The E UrP rnLiUST INDENTURE Order Of: :YifluU1 SASS ES9CRTRU.,T E r nNNSti Li111 ?OUt Fi{[t1NCE AGENCY PENNSYLVANIS HOUSING %R ?ESHLfl FINANCE AGENCY Broadview Mortgage Company Rosemary By al Myers, vice Fresictent dice preside nt?? 7 "By initialing, the Borrower(s) acknowledge(s) that this page is page 2 of 2 ?i la;d.h, h,;wh, of the Multistate Fixed Rate Note." ACCT# 935501 orm teaetz...... ..... ... Dodd 0000e007e3 cr«Lim. B.I.F...W.?Dal 1W-20 W9? w ruoortam? ux 1811.9,.1131 ALL THAT CERTAIN ,use and lot of ground sit .e on the East side of South Fredei._k Street (First ward) ?n the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a pin on the building line of said Frederick Street, corner of lot formerly of Andrew K. Garrett; thence Southward along the building line of said Street, 21.95 feet to a pin at the center of double frame dwelling house; thence Eastward, passing through the center of said house, 97.00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, to a pin; thence Northward along lot now or formerly of said George A. Stoner and Marion G. Stoner, his wife, 22.2 feet to a pin; thence Westward along said lot formerly of Andrew K. Garrett, 97.00 feet, more or less, to a point on the building line of Frederick Street to a point, the point and place of BEGINNING. HAVING THEREON ERECTED, the northern one-half of a double two story frame dwelling house known as No. 317 South Frederick Street. VERIFICATION Anthony J. Julian hereby states that he is the Director of Accounting and Loan Servicing Program of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. 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. a COs?GdPn? Anthony J. Julian Director of Accounting & Loan Servicing PFrAEYWANUA MMU FR4*M AGM-Y, MWICSn NEE KE F= UUM ITT \AL BAZK KW IZOW AS FPII-DJIA ffi W r? AS9JQA CN AS 'IR= KR T-IE FH4ZMVRUA HIZIM FRWNU AGRCY Date: rNEEER 19, 2002 v. V C l.1 / l ?? ..? CTS ^C. -a? SHERIFF'S RETURN - REGULAR CASE NO: 2002-05613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WACHOVIA BANK NA VS ARNOLD JESSICA B RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ARNOLD JESSICA B the DEFENDANT , at 1451:00 HOURS, on the 16th day of December , 2002 at 504 W KELLER STREET MECHANICSBURG, PA 17055 by handing to CHARLES ARNOLD, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 34.90 12/17/2002 PURCELL KRUG HALLER Sworn and Subscribed to before By: .!? me this 3 day of Deputy Sh riff I „?a7J j A.D. rothonotary rTr WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PLAINTIFF NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant JESSICA B. ARNOLD 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 $55,919.68 Interest $ 1,662.78 (Per diem of $7.77 from 5/1/02 to 12/1/02) Accumulated late charges $ 143.56 Late charges $ 126.71 ($15.84 per month to 12/02) Escrow Deficit $ 799.75 5% Attorney's Commission $ 2,795.98 TOTAL $61,447.46** ** 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. er PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 PUELL/ KRUG & HALL _ 3Y7 Leon P. H 1 KAM KFIDOCSICUMBERLAIARNOLD.P WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JESSICA B. ARNOLD, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on JANUARY 9, 2003 I served the Ten Day Notice required by Pa. R.C.P. 237.11 on thepDepfae dances s) in t is matter by regular first class mail, postage r, 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 WACHOVIA BANK, NATIONAL ASSOCIATION F/KJA FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. JESSICA B. ARNOLD Defendant DATE OF THIS NOTICE: January 9, 2003 TO: JESSICA B. ARNOLD 504 WEST KELLER STREET MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-05613 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. 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: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALLER By LEON P. HALLER"Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed be ore me this /U day of L2 0 o ry u is L.tvly P. HALLER, ESQUIRE EA RY NOTARIAL SEAL RYLAp D K. FSRREM, N©t?y, public Lower axton NP., Dauphin County Commission Expires Au , g 8,6 N w r pit O - 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 05613 WACHOVIA BANK, NATIONAL ASSOCIATION, F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JESSICA B. ARNOLD, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $61,447.46 Interest at $7.77 per diem to sale date $ 1,476.30 Late charges at $15.84 per month to sale date $ 95.04 Escrow Deficit $ 2,000.00 TOTAL $65,018.80* *SALE DATE: WEDS., JUNE 11, 2003 (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: Issue Writ of Execution in the above captioned case. Date: March 10, 2003 Attorney for Plaintiff 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K AM KF\DOCS\CUM BERLA\ARN OLD. W kf Rg" Z o r e, o C ? o . 0 CAP A"K THAT CERTAIN x>U t ?. ._ b ait i r Ader:i k ` tr ,t: (( .fit Ward) 1t1 '1f icr „ .??s1.a1CC) r_r2i; 'l. t:. t- East d Tit a ,t the Wrong of s3 ounded and jes __ 1i 1b"116110 and t cribed as J:O.I1 ilti`s tr;, t, iI;,.1%l.,,ani-z;, ?I?tir;, lot "! ,t_ !'I cif t ' ? ? e building r tc of _ c 1 t i d.j . Lwerl o Andz h '' aid ,r. e'?ra7i :{C daub- _i n of , x,95 thence L__cet the ,le fraye dWellin ;10115'`2` 67_ c fc_:t to a? southward along _ enter of aid t , , e; thence eastward, Pin at the center sF formed- ,. 97,00 feet, Passing t 1 gh y of George A. Stoner and more or_ less, h "; thence rarthw and Marion G. Stoner, along t northward al ?:?ner, lo Stcner anald Ma 2 G. Stoner, lhiotsnow or f- ?`-rmerly of saidWGee, tcA a ;,re g said lot f_?rmerl feet to a o A. less, to pai Y of Andrew K. Garret pi.n' the nce le to a Point, point an the >uildin t, 97.00 fe the Point and 7 9 lime of et, P -ace of BEGIt?LV, Frederick ING• Street ' ?'I!vC 1: HERi'?}}id r trEC1'ED, the rart,`lerll one-half dwe l.lln9 of se n loT 7 ,,,I'• as NO. a double 317 South Frederick two stt rti, ric.. titre tucETt1t-,"'• with t. P right et. PlOperties known a8 ?J LO use, co, C;T7 ith the owner r F`.1.. Private r 3?15 and ? '' ! > t?:r 9 ?7 _ all,, South Frederic k :. ;. `dry r y I j y.t i ?t, C r i r ?' _F 2 a., lv?1 c? 1rlMarion I t:a Maude i a , r, HAVTN;; ; :. s t.ereirt . THEREON ERECTED A STREET, DWELLING MECHANICSBURG KNOWN AS 317 PA 17055. SOUTH FREDERICK ASSESSMENT # 16-24-0787-050 BEING THE SAME PREMISES WHICH 6//9 00 and recorded in Dee Jennifer M. Je,S=Lca B. Deed Book 223 Beaman by deed TO BE Arnold- Page 284 granted and convdeyeedd 2002_ TOLD AS THE PROPERTY OF JESSICA B. 0?6i3 ARNOLD ON JUDGMENT NO. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5613 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHOVIA BANK, NATIONAL ASSOCIATION, F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From JESSICA B. ARNOLD, 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in 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 enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $61, 447.46 L.L. $.50 Interest AT $7.77 PER DIEM TO SALE DATE $1,476.30 Atty's Comm % Due Prothy $1.00 Atty Paid $116.90 Plaintiff Paid Date: MARCH 12, 2003 (Seal) REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Other Costs LATE CHARGES AT $15.84 PER MONTH TO SALE DATE - $95.04 ESCROW DEFICIT - $2,000.00 CURTIS R. LONG Prothonota Deputy WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT 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 317 SOUTH FREDERICK STREET, MECHANICSBURG, PENNSYLAVNIA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): Jessice B. Arnold 504 West Keller Street Mechanicsburg, PA 17055 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. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7 Name and address of every other , interest Plaintiff has knowledge who has any may be affected by the sale: TENANTS IF AN7 Tenant/Occupant 317 South FredePAckl7055et Mechanicsburg, Charles Arnold 504 West Keller SStr et Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Streets Hanover & High Carlisle, PA 17013 person of whom the in the property which information, where addresses could not be (In the preceding reasonably ascertained, the same is indicated.) and I verify that the statements made made in knowlthisedge, Affidavit informatiareon true subject and correct to the best of my Pe to susworn are belief. I understand that false S ecate n ment4s9he04rerelinat ng made su jto the penalties of 18 PA C. falsification to authorities. 7 Leon P. Haller HA -L. #15700 Purcell, Krug & 1719 North FrPoon Street Harrisburg, (717) 234-4178 DATE: March 10, 2003 c?> -? , - ,- __ . f_ .._ _ - c `i ..7 ty? - WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT 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 11, 2003 TIME: 10:00 O'clock A.M. LOCATION: 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: 317 SOUTH FREDERICK STREET MECHANICSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $61,447.46 under or pursuant to which your property is being sold is docketed in the within C_ornmonwealth and County to: NO. 2002 05613 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property i ,:; . ^>ua us cur i? rpI A'Apf 0L) NOS JESSICA B. ARNOLD- REAL OWNER 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 film exceptions to it within ten (10) days of the date it is filed. g 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 T YOUR PROPERTY. I PAY THE JUDGMENT. S 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. 3 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: You may file a petition with the Court of Common Pleas of. t 11f' ?ATi thin County to open the judgment if you have a meritorious 1F i 'I e arTainst the person or company that has entered judgment aCrain<t- you You may also file an petition with the same Court if you ire 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 ro 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) 234-4173 n r I THAT <`f-t',R 'AIN t.o"u-e, an _I clt Of 9rOUnd s-i r.uat(-> o i E. l., Ilst se ?t1t rz deri T_ ck rE et (? r_ Y4 lyd _ ?.cYlar.r o } , the I3. is id ;tql srsarcl, ??u r?ty o f ' Lie:?h t 1 _<I.: 7;-i bounded, and c l;E E 'I!I18C 1 , aTiJ.c , and described as tollot.:;, t?; wiE,.: ,:. CINNIN7C; 3E :. Lf2 ) ti"I C' z}Llllll:nC1 l ile r cc:rnet of lot t S.1lC r':ret f, lc x Street, L trierly of Andrew K. Garrett i ?•E ?.I1u it 7 1':Ii+ tnellCe southward alOtlCj said Ctlr•ee_., 21.95 feet t <l in at ±!Ie of double frame dwelling :louse; thence eastward,passing through the center of said house, 97,00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, to a pin. thence northward along lot nota or formerly of said George A. Stoner and. Marion G. Stoner, his wife, 22.2 feet to a pin; thence westward along said lot formerly of Andrew K. Garrett, 97.00 feet more or leas, to a point on the building line of Frederick Street to a point, the print and place of BEGINNING. rt VI NI. THEF2E0:d F'F, «?? , ECTED, the nort ,fern one-half of a double + :ame Iwe l _j ar}L1Se IQ ;Own u two u CrrV [ c. 31 1 SaL<t!1 F'reder.ick. Street . HOC"ETF?E:.`. with the right to uae, comv.-icn ._LLh the owners -If the p-ope.rties known as Nos. 31.1, 313, 215 ar: r 3114 South r " i aaty li i, reclerl c'c L a It-,, or ati f Brut ray t e 1c,,Iq 1)9 tr, M ?e a r _.t.i_ ...c='_ HAVING THEREON ERECTED A DWELLING KNOWN AS 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055. ASSESSMENT ## 16-24-0787-050 BEING THE SAME PREMISES WHICH Jennifer M. Beaman by de dated 1,/9/00 and recorded in Deed Book 223 Page 284 granted and econveyed unto Jessica B. Arnold. TO BE SOLD AS THE PROPERTY OF JESSICA B. ARNOLD ON JUDGMENT NO. 2002.-05613 ' . t ?5 WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JESSICA B. ARNOLD, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . NO. 2002 05613 . IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 3-31-03 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: Jessice B. Arnold 504 West Keller Street Mechanicsburg, PA 17055 Tenant/Occupant 317 South Frederick Street Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Charles Arnold 504 West Keller Street Mechanicsburg, PA 17055 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL, KR UG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 JOHN W. PURCELL TELEPHONE (717) 234-4178 HOWARD B. KRUG FORECLOSURE DEPT. FAX (717) 234-1206 LEON P. IIALLER JOHN W. PURCELL.IR. BRIAN.I. TYLFR .111,1. M. WINIKA (717) 533-8836 NOTICE TO: Jessice B. Arnold 504 West Keller Street Mechanicsburg, PA 17055 Tenant/Occupant 317 South Frederick Street Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Charles Arnold 504 West Keller Street Mechanicsburg, PA 17055 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD 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. 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. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and ?t you have an opportunity to protect your interest, if a being notified of said Sheriff's Sale. By. Leon P. Haller PA I.D.15700 Attorney for Plaintiff WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, JUNE 11, 2003 TIME: 10:00 O'clock A.M. LOCATION: 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: 317 SOUTH FREDERICK STREET MECHANICSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $61,447.46 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 05613 is: THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property K:1MKFIDOCSICUMBERLAIARNOLD. NOS JESSICA B. ARNOLD- REAL OWNER 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 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 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 at-:?ached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN house and lot of ground situate on the East side of South Frederick Street (First Ward) in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a pin on the building line of said Frederick Street, corner of lot formerly of Andrew K. Garrett; thence southward along the building line of said Street, 21.95 feet to a pin at the center of double frame dwelling house; thence eastwarcl, passing through the center of said house, 97.00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, to a pin; thence northward along lot now or formerly of said George A. Stoner and Marion G. Stoner, his wife, 22.2 feet to a pin; thence westward along said lot formerly of Andrew K. Garrett, 97.00 feet, more or less, to a point on the building line of Frederick Street to a point, the point and place of BEGINNING. HAVING THEREON ERECTED, the northern one-half of a double two story frame dwelling mouse known as No. 317 South Frederick Street. TOGETHER with the right to use, in common with the owners of the properties known as Nos. 311, 313, 315 and 319 South Frederick Street-, a private alley or passageway (formerly belonging to Maude E. Sheaffer and now or formerly of George A. Stoner and Marion G. Stoner, his wife) extending from the rear of the premises herein descri.Lec.«, northward to Hill Alley. HAVING THEREON ERECTED A DWELLING KNOWN AS 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055. ASSESSMENT # 16-24-0787-050 BEING THE SAME PREMISES WHICH Jennifer M. Beaman by deed dated 6/9/00 and recorded in Deed Book 223 Page 284 granted and conveyed unto Jessica B. Arnold. TO BE SOLD AS THE PROPERTY OF JESSICA B. ARNOLD ON JUDGMENT NO. 2002-05613 Re: PHFA v. Arnold Cumberland 6/11/03 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 One piece of ordinary mail addressed to: Jessice B. Arnold 504 West Keller Street Mechanicsburg, PA 17055 Postage: Postmark: 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: Tenant/Occupant 317 South Frederick Street Mechanicsburg, PA 17055 m ?c 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 One piece of ordinary mail addresse( Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Postage: 1• ?b ! - `l:?<.S t 1 hf Its )t,'.1 • . $ 00.900 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 One piece of ordinary mail addressed to: Charles Arnold 504 West Keller Street Mechanicsburg, PA 17055 Postmark: to qqh Postage: ?? ?-?ES ?oSrQ? $ QQ.900 MIAILEDrFRON4 ZIP CODE c7 Cry . E,^r r; -1 "? :aa CJi :Z COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Wachovia Bank N A fka First Union Natl Bk Tr for Pennsylvania Housing fin Agency is the grantee the same having been sold to said grantee on the 11th day of June A.D., 2003, under and by virtue of a writ Execution issued on the 12th day of March, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 5613, at the suit of Wachovia Bank N A fka First Union Bk Tr for Pennsylvania Housing fin agency against Jessica B Arnold is duly recorded in Sheriff s Deed Book No. 258, Page 804. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 7 day of A.D. 2003 77 ? ?c r`v'""" Recorder of Deeds Wachovia Bank, National Association, In The Court of Common Pleas of f/k/a First Union National Bank, as Cumberland County, Pennsylvania Trustee for Pennsylvania Housing Writ No. 2002-5613 Civil Term Finance Agency VS Jessica B. Arnold Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on March 31, 2003 at 7:00 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: Jessica B. Arnold, by making known unto Jessica Arnold, personally, at 504 W. Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 08, 2003 at 2:37 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 Jessica B. Arnold located at 317 South Frederick St., Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Jessica B. Arnold, by regular mail to her last known address of 504 W. Keller Street, Mechanicsburg, PA 17055. This letter was mailed under the date of April 07, 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 Leon P. Haller for Wachovia Bank, National Association, f/k/a First Union National Bank, as Trustee for Pennsylvania Housing Finance Agency. It being the highest bid and best price received for the same, Wachovia Bank, National Association, f/k/a First Union National Bank, as Trustee for Pennsylvania Housing Finance Agency of 2101 North Front Street, Harrisburg, PA 17110, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $845.67. Sheriffs Costs Docketing $30.00 Poundage 16.58 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library 50 Prothonotary 1.00 Mileage 13.80 Certified Mail Levy 15.00 Surcharge 20.00 Law Journal 325.85 Patriot News 263.20 Share of Bills 25.24 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 845.67 Sworn and subscribed to before me This s ? day of 2003, A.D. ro honotary So Answers: R. Thomas Kline, Sheriff 1 BY Vti Real Estate puty 30.0 ylvy7 J". 1407 9? WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGFNC Y , PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT 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 317 SOUTH FREDERICK STREET, MECHANICSBURG, PENNSYLAVNIA 17055: L. Name and address of the Owner(s) or Reputed Owner(s): Jessice B. Arnold 504 West Keller Street Mechanicsburq, PA 17055 Name and address of Defendant(s) in the Judgment, if diC-Lerent from that listed in (1) above: SAME Name and address of every judgment creditor whc-se judgment appears of record on the real property to be sold: Name and address of last recorded holder of every mortgage of record: FT_;AINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): ) . Name and address of every other person who has any record lien -,ii th, property: UNKNOWN Name and address of every other person who has any record interest i_n the property and whose interest may be affected by the <A le: UNKNOWN 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: 'T'ENANTS IF ANY Tenant /Occupant 317 mouth Frederick Street Mechanicsburg, PA 17055 Charles Arnold 504 West Keller Street Mechanicsburg, PA 17055 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.) 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 f?'tlsitication to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 2 34 -4178 DATE: March 10, 2003 WACHOVIA BANK, NATIONAL ASSOCIATION F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 05613 VS. JESSICA B. ARNOLD, IN MORTGAGE FORECLOSURE DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: 'Chat the sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, JUNE 11, 2003 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail i_n 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) HE LOCATION of your property to be sold is: 317 SOUTH FREDERICK STREET MECHANICSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $61,447.46 under or pursuant to which your property is being sold is docketed in the within C'ommonwe'alth and County to: NO. 2002 05613 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property ?• I ['n. CUrd UNPIBIOS I i JESSICA B. ARNOLD- REAL OWNER 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 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 ciefeilse against the person or company that has entered judgment against you. You may also file an petition with the same Court if yoL: are aware of a legal defect in the obligation or the procedure used against you 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 ffor a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. . 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. 1L a specific return date is desired, such date must be obr_ained 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 W& THAT CERTAIN Lcus,. r,d 1 Of yrc,und s _t.uate on t 1 r East- s_on 02 South Frederick Street (First hard) to the Borough of Mecharnrstury, County of CUw5 i l,ac n d -WatC -if PC >'} cania, bounded and described as follows, te; wit: BEGINNING a pin on the building line of rid Frederick Street, corner of lot formerly of Andrew ii. Garrett; thence southward along ..he building me of said .Street, 21 9 Eaet t., a pin at th cent._._ of double frame dwelling house; thence eastward, passing through the center of said house, 97.00 feet. more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, to a pir.: thence northward along lot now or formerly of said George A. Stoner and Marian G. Stoner, his wife, 22.2 feet to a pin; thence westward along said lot formerly of Andrea K. Garrett, 97.00 feet, snore or less, to a point on the building line of Frederick Street. to a point, the point and place of DEGINNING. -WIND THEREON rRSCTRO, the northern one-half of a double two story i rame dwe- r n house i tr o- i as No. 317 South Frederick Street. TOGETHER with the right to use, in corocn t4LIh the owner: of the properties known as No s. 311, 313, 315 and 319 South Frederick rseL, a }'rivat allay or jaa < yhy ; f „t mn1 l . belonging to Mande i Vn-aftn Pin Ow v 1 stir l k,1011- 1. L_ 11 wi t ,.._:., 1,., :t tka ._ Or rn.'-. isr, herein j?wlr _.. .,?r'_hward t' 01i . ]ej HAVING THEREON ERECTED A DWELLING KNOWN AS 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055. ASSESSMENT 0 16-24-0787-050 BEING THE SAME PREMISES WHICH Jennifer M. Beaman by deed dated 6/9/00 and recorded in Deed Book 223 Page 284 granted and conveyed unto Jessica B. Arnold. TO BE SOLD AS THE PROPERTY OF JESSICA B. ARNOLD ON JUDGMENT NO. 2002-0561.3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5613 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHOVIA BANK, NATIONAL ASSOCIATION, F/K/A FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From JESSICA B. ARNOLD, 317 SOUTH FREDERICK STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in 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 enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $61, 447.46 L.L. $.50 Interest AT $7.77 PER DIEM TO SALE DATE $1,476.30 Atty's Comm % Due Prothy $1.00 AttyPaid $116.90 Plaintiff Paid Date: MARCH 12, 2003 (Sea]) REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Other Costs LATE CHARGES AT $15.84 PER MONTH TO SALE DATE - $95.04 ESCROW DEFICIT - $2,000.00 CURTIS R. LONG Prothonotary ?@ti ? Off, e . Deputy Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Real Estate Sale # 70 On March 17, 2003 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA known and numbered as 317 S. Frederick Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 17, 2003 By? Real Estate Deputy ci?m s'?r THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 5B7, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) as 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 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 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 ................................. ....A..:..(ci..... COPY Sworn to and subscrib afore I 14th day ay 0 A. D. SALE #70 Notarial Seal Terry L. Russell, Notary Public City OtHanisourg,DaupbinCounty NO ARY PUBLIC My Commission Expires June 6, 2006 My commission expires June 6, 2006 Member, Pennsylvania Association or Ndaries 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 $ 261.45 Probating same Notary Fee(s) $ 1.75 Total $ 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... REAL ESTATE SALE No. 70 Writ No. 2002-5613 Civil Term Wa:.hovla Bank, National Association F/k/a First Union National Bank, As Trustee for F sLansylvanla Housing Finance Agency vs Jessica B. Arnold A}•ty• Leon P. Haller DESCRIPTION ALL THAT CERTAIN house and lot of ground situate on the East site of South Frederick Street (First Ward) in the borough of Mechanicsburg; County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a pin on the building line of said Frederick Street, comer of lot formerly of Andrew K. Garrett; thence south- ward along the building line of said street, 21.95 feet to a pin at the center of double frame dwelling house; thence eastward, passing through the center of said house, 97.00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, to a pin; thence northward along lot now or formerly of said George A. Stoner and Marion G. Stoner, his wife, 22.2 feet to a pin; thence westward along said lot formerly of Andrew K. Garrett, 97.00 feet, more or less, to a point on the building line of Frederick Street to a point, the point and place of BEGINNING. HAVING THEREON ERECTED, the northern one-half of a double two=story frame dwelling house known as No. 317 South Frederick Street. TOGETHER with the right to use, in common with the owners of the properties known as Nos. 311, 313, 315, and 319 South Frederick Street, a private alley or passage-way (formerly belonging to Maude E. Sheaffer' and now or formerly of George A. Stoner and Marion G. Stoner, his wife, extending from the rear 'nf the premises herein described, northward to Mill Alley. HAVING THEREON erected a dwelling known as 317 South Frederick Street, Mechanicsburg, PA 17055. ASSESSMENT #16-24-0787-050. BEING THE SAME premises which Jennifer M. Beaman by deed dated 6/9/00 and recorded in Deed Bohr 223 Page 284 granted and conveyed unto Jessica B. Arnold. TO BE SOLD as the property of Jessica B. Arnold and Judgment No. 2002-05613. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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 Afffant 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 true. REAL E9TAT6 BALE NO. 70 Writ No. 2002-5613 Civil Wachovia Bank, National Association, f/k/a First Union National Bank, as Trustee for Pennsylvania Housing Finance Agency vs. Jessica B. Arnold Atty.: Leon P. Haller ALL THAT CERTAIN house and lot of ground situate on the East side of South Frederick Street (First Ward) in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a pin on the build- ing line of said Frederick Street, comer of lot formerly of Andrew K. Garrett: thence southward along the building line of said Street, 21.95 feet to a pin at the center of double frame dwelling house; thence east- ward. passing through the center of said house, 97.00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, 22.2 feet to a pin: thence west- ward along said lot formerly of An- drew K. Garrett, 97.00 feet. more or less. to a point on the building line of Frederick Street to a point. the point and place of BEGINNING. HAVING THEREON ERECTED. the northern one-half of a double two story frame dwelling house known as No. 317 South Frederick Street. TOGETHER with the right to use, in common with the owners of the properties known as Nos. 311, 313, 315 and 319 South Frederick Street, a private alley or passage- - --__ 1- y minnei v to Maude S TO AND SUBSCRIBED before me this AT -,5 7- County Z ,lily cm ow :dC e?,y'.. u r axo J, L 9 day of MAY, 2003_ statements as to time, place and charac REAL ESTATE SALE NO. 70 Writ No. 2002-5613 Civil Wachovia Bank, National Association, f/k/a First Union National Bank, as Trustee for Pennsylvania Housing Finance Agency VS. Jessica B. Arnold Atty.: Leon P. Haller ALL THAT CERTAIN house and lot of ground situate on the East side of South Frederick Street (First Ward) in the Borough of Mechanicsburg. County of Cumberland and State of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a pin on the build- ing line of said Frederick Street, corner of lot formerly of Andrew K. Garrett: thence southward along the building line of said Street, 21.95 feet to a pin at the center of double frame dwelling house; thence east- ward. passing through the center of said house, 97.00 feet, more or less, along lot formerly of George A. Stoner and Marion G. Stoner, his wife, 22.2 feet to a pin: thence west- ward along said lot formerly of An- drew K. Garrett. 97.00 feet, more or less, to a point on the building line of Frederick Street to a point, the point and place of BEGINNING. HAVING THEREON ERECTED. the northern one-half of a double two story frame dwelling house known as No. 317 South Frederick Street. TOGETHER with the right to use, in common with the owners of the properties known as Nos. 311, 313, 315 and 319 South Frederick Street, a private alley or passage- way (formerly belonging to Maude E. Sheaffer and now or formerly of George A. Stoner and Marion G. Stoner, his wife) extending from the rear of the premises herein de- scribed, northward to Hill Alley. HAVING THEREON ERECTED A DWELLING KNOWN AS 317 SOUTH FREDERICK STREET, MECHAN- ICSBURG, PA 17055. ASSESSMENT #16-24-0787- 050. BEING THE SAME PREMISES WHICH Jennifer M. Beaman by deed dated 6/9/00 and recorded in Deed Book 223 Page 284 granted and conveyed unto Jessica B. Arnold. TO BE SOLD AS THE PROP- ERTY OF JESSICA B. ARNOLD ON JUDGMENT NO. 2002-05613.