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HomeMy WebLinkAbout02-5878FEDERMAN 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) 563-7000 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY 2300 BROOKSTONE CENTER PARKWAY COLUMBUS, OH 31904 V. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. OP,- 5 klg CUMBERLAND COUNTY MARY A. WETHERELL 1713 LOCUST STREET NEW CUMBERLAND, PA 17070 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 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 #: 0071507156 NZB 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 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY 2300 BROOKSTONE CENTER PARKWAY COLUMBUS, OH 31904 2. The name(s) and last known address(es) of the Defendant(s) are: MARY A. WETHERELL 1713 LOCUST STREET NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 7/20/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES L.P which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1558, Page 811. By Assignment of Mortgage recorded 1/24/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 636, Page 450. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $82 103 45 Interest , . 3/1/02 through 10/1/02 4,351.60 (Per Diem $20.24) Attorney's Fees Cumulative Late Charges 1,225.00 7/20/99 to 10/1/02 101.01 Cost of Suit and Title Search 550 00 Subtotal . $88,331.06 Escrow Credit Deficit 0.00 Subtotal 562.01 562.01 TOTAL $88,893.07 7. 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. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P. S. §1680.403 c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,893.07, together with interest from 10/1/02 at the rate of $20.24 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. FEDERMMAN AND P13E By /S/F7an Hallman FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALLTHA r CERTAIN lot of land situate In the Borough of New Cumberiand, county of Cumberland and State of Penns flvania, more particularly bounded and described as follows: BEGINN NG at a point an the easterly line of Locust street eighty (ao) feet South of the southeast comer of Locus Street and St. Clair Road; thence northeastwardly at right angles to Locust Street and along the southerl) line of Lot No. 3, Black C. on the hereinafter mentioned plan, eighty-five and ninety-seven one hundredths (85.97) feet to a point; thence Southeastwardly along a Play Area as shown on said plan, sixty- six and fifteen one-hundredths (66.15) feet to a point; thence Southwestwardly along the northerly line of lots Nos. 12 and 1, Block C. one hundred thirteen and seventy-nine one-hundredths (113.79) feet to a point on the eastinly line of Locust Street; thence by the latter line Northwestwardly Sixty (60) fact to the place of BEGINNING. BEING Lot No. 2, Block C on the Plan of lots of Highland Park Extension, said Plan being recorded in the Cumben and County Recorder of ?esds Office In Plan Book 5, Page 59. BEING KNOWN AS: 1713 LOCUST STREET. VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is 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. See. 4904 relating to unsworn falsification to authorities. ??, ? W., Francis S. Hallinan, Esquire Attorney for Plaintiff DATE: n W ?? A' r L p a r, ?._ ?._. „' '- R _? -' _'' iJ J 0 5 ,? 0 S SHERIFF'S RETURN - REGULAR CASE NO: 2002-05878 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREENPOINT MORTGAGE FUNDING IN VS WETHERELL MARY A 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 WETHERELL MARY A the DEFENDANT at 1856:00 HOURS, on the 30th day of December , 2002 at 120 HUMMEL AVENUE LEMOYNE, PA 17043 MARY A WETHERELL 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 18.00 Service 22.08 Affidavit .00 Surcharge 10.00 .00 50.08 Sworn and Subscribed to before me this J3 x day of L /*z3 A.D. 'P othonotary ?rJ So Answers: R. Thomas Kline 12/31/2002 FEDERMAN & PHELAN By : ????e6???J Deputy S eriff 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 12151 563-7000 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY 2300 BROOKSTONE CENTER PARKWAY COLUMBUS, OR 31904 V. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5878 MARY A. WETHERELL Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against MARY A. WETHERELL, 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 10/2/02 to 2/4/03 TOTAL $88,893.07 2,550.2 4 $91,443.31 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: 5 - 03 INDICAT i ,^ r PROTwYJ W / -- i 01d CJ r li- t% tJ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (2.15) 563-7000 GREENPOINT MORTGAGE FUNDING, INC., F/K/A HEADLANDS MORTGAGE COMPANY Plaintiff vs. MARY A. WETHERELL Defendant(s) TO: MARY A. WETHERELL 1713 LOCUST STREET NEW CUMBERLAND. PA 17070 DATE OF NOTICE: JANUARY 22, 2003 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. 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 you may lose your property or other important rights. u should take this notice to a lawyer at once. If you do not haveoa 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0. 02-5878 Frank Federman, Attorney for Plainttiiffe FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (2-15) 563-7000 GREENP INC., DINT MORTGAGE FUNDING, - INC., F/K/A HEADLANDS MORTGAGE' COMPANY Plaintiff vs. MARY A. WETHERELL Defendant (s) TO: MARY A, WETHERELL 120 HUMMEL AVENUE LEMOYNE" PA 17043 DATE OF NOTICE: JANUARY 22, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE RRED TO FROMINDEBYOUTEDNWILLESS AND ANY INFORMATION OBTAINED FORHTHATNPURPOSE.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. IMPORTANT NOTICE _y 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. lawyer or cannot afford one, go to or telepIf do hav a honeu he nfollowing office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-5878 Frank Federman, Esquire a? 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 (215)000 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY 2300 BROOKSTONE CENTER PARKWAY V. Plaintiff, MARY A. WETHERELL Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5878 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Serv or its Allies, or otherwise within the provisions ice of the United States of 1940, as amended of the Soldiers' and Sailors' Civil Relief Act of Congress . (b) that defendant MARY A. WETHERELL is over 18 years of age and resides at, 120 HUMMEL AVENUE, LEMOYNE, PA 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c ,} Imo'' y "?N k: Qj- c PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY Plaintiff, V. No. 02-5878 MARY A. WETHERELL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 2/5/03 to 6/11/03 (per diem -$15.03) TOTAL $91,443.31 $ 1,908.81 and Costs $93,352.12 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property-No. w? zz wo a ? a gyp" d? ? p O H Uz C7 zAz ? a E-? > F-c ?w w? da oaf ? 3 OV o F?U ? ? G ? FL zAz Od p ? f?, o W ? W ? ? ? p „ ?? i W W N w w .Y a w 0 0 Q M O r Q a w z w a z w 0 N ti b Q c; c: C? l ,n o. s iei DESCRIPTION ALL THAT CERTAIN lot of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Locust Street eighty (80) feet South of the southeast corner of Locust Street and St. Clair Road; thence norheastwardly at right angles of Locust Street and along the southerly line of Lot No. 3, Block C, on the hereinafter mentioned plan, eighty-five and ninety-seven one hundredths (85.97) feet to a point; thence Southeastwardly along a Play Area as shown on said plan, sixty six and fifteen one-hundredths (66.15) feet to a point; thence Southeastwardly along the northerly line of Lots Nos. 12 and 1, Block C, one hundred thirteen and seventy-nine one- hundredths (113.79) feet to a point on the easterly line of Locust Street; thence by the latter line Northwestwardly Sixty (60) feet to the place of beginning. BEING Lot No. 2, Block C on the Plan of lots of Highland Park Extension, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 59. HAVING THEREON erected a single dwelling house known as No. 1713 Locust Street, New Cumberland, Pennsylvania. Tax Parcel #23-0543-246 TITLE TO SAID PREMISES IS VESTED IN Mary A. Wetherell by Deed from Andrea K. Knaub, married dated 7/15/1999, recorded 7/22/1999, in Record Book 204, Page 359. Premises: 1713 LOCUST STREET, NEW CUMBERLAND, PA 17070 I CKI :._ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5878 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREENPOINT MORTGAGE FUNDING, INC., f/k/a HEADLANDS MORTGAGE COMPANY Plaintiff (s) From MARY A. WETHERELL, 120 HUMMEL AVENUE, LEMOYNE PA 17043. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTAE LOCAED AT 1713 LOCUST STREET, NEW CUMBERLAND PA 17070 (SEE ATTACHED LEGAL DESCRIPTION.). (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $91,443.31 L.L. $.50 Interest 2/5/03 - 6/11/03 @ $15.03 per diem $1,908.81 Atty's Comm % Due Prothy $1.00 Arty Paid $132.08 Other Costs Plaintiff Paid Date: FEBRUARY 5, 2003 CURTIS R. LONG Prothon tary (Seal) By: ,0 c_ d " 1 0417 Depu REQUESTING PARTY: Name FRANK FEDERMAN ESQ Address: ONE PENN CENTER AT SUBURGAN STATION 1617 JFK BLVD., SUITE 1400 PHILADELPHIA PA 191031814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY Plaintiff, V. MARY A. WETHERELL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5878 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GREENPOINT MORTGAGE FUNDING INC. F/K/A HEADLANDS MORTGAGE COMPANY, 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 1713 LOCUST STREET NEW CUMBERLAND PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): Name MARY A. WETHERELL Last Known Address (if address cannot be reasonably ascertained, please indicate) 120 HUMMEL AVENUE LEMOYNE, PA 17043 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) UNION PLANTERS BANK, NATIONAL ASSOCIATION 7130 GOODLETT FARMS PARKWAY CORDOVA, TN 38018 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 1713 LOCUST STREET NEW CUMBERLAND, PA 17070 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 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 unworn falsification to authorities. February 3, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ?> ?__; c ; C_- LS ? ? __' -y ' . ) . _ . !y',__ \i.?`- ?j ?. . ? r??1 _. J., : J .? 1 •M1? 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 GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY V. Plaintiff, MARY A. WETHERELL Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5878 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ??Zolxk _rA&410? FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c; C_- ? G ;-, ?.?? 7 ? f.?_`?..;. .? ? / J-? ::: i i.Yl _ .. GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY Plaintiff, V. MARY A. WETHERELL Defendant(s). TO: MARY A. WETHERELL 120 HUMMEL AVENUE LEMOYNE, PA 17043 CUMBERLAND COUNTY No. 02-5878 February 3, 2003 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBTAND ANYINFORMATION OBTAINED WILL BE USED FOR THATPURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY. * * Your house (real estate) at, 1713 LOCUST STREET. NEW CUMBERLAND PA 17070, is scheduled to be sold at the Sheriffs Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $91,443.31 obtained by GREENPOINT MORTGAGE FUNDING INC. F/K/A HEADLANDS MORTGAGE COMPANY (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 Sheriffs 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 call: (215) 563-7000. p a y, you may 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See 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 Sheriffs 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 of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd 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 distribution of the money bid for your house will be filed by the Sheriff within 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 (10) 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 DESCRIPTION ALL THAT CERTAIN lot of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Locust Street eighty (80) feet South of the southeast corner of Locust Street and St. Clair Road; thence northeastwardly at right angles of Locust Street and along the southerly line of Lot No. 3, Block C, on the hereinafter mentioned plan, eighty-five and ninety-seven one hundredths (85.97) feet to a point; thence Southeastwardly along a Play Area as shown on said plan, sixty six and fifteen one-hundredths (66.15) feet to a point; thence Southeastwardly along the northerly line of Lots Nos. 12 and 1, Block C, one hundred thirteen and seventy-nine one- hundredths (113.79) feet to a point on the easterly line of Locust Street; thence by the latter line Northwestwardly Sixty (60) feet to the place of beginning. BEING Lot No. 2, Block C on the Plan of lots of Highland Park Extension, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 59. HAVING THEREON erected a single dwelling house known as No. 1713 Locust Street, New Cumberland, Pennsylvania. Tax Parcel #23-0543-246 TITLE TO SAID PREMISES IS VESTED IN Mary A. Wetherell by Deed from Andrea K. Knaub, married dated 7/15/1999, recorded 7/22/1999, in Record Book 204, Page 359. Premises: 1713 LOCUST STREET, NEW CUMBERLAND, PA 17070 c? c.- ; -,, ...,, r ? ., ?:?? < ?_:" , ?. . . ~= _._ - ,__ ? ?. ,,' ; , ?? ? ? ?? ?? 4i _\ 'pocket for Case: " + GetCaseNoo + " (" + DktTypeExpand(m.gsDktType) + ") Page 1 of 2 Bankruptcy Docket Report 102-02902 (Harrisburg) WETHERELL, MARY A Docket items entered between 01/01/1931 and 02/03/2003 Filing No. Docket Entry View Date document 05/28/02 1 VOLUNTARY PETITION under Chapter 7, Matrix and all Schedules/Statements None [EOD 05/28/02] [AG] 06/25/02 2 MOTION for relief from stay Re: Banc One Acceptance Corp. (Fee paid, Receipt None #583814, $75.00) [Disposed] [EOD 06/25/02] [KZ] CERTIFICATE OF NON-CONCURRENCE [EOD 06/25/02] [KZ] 06/25/02 3 ORDER that answers aredue on 07/15/02 Re: Item # 2. [EOD 06/25/02] [KZ] None 06/28/02 4 CERTIFICATE OF MAILING of notice of 341 meeting. [EOD 06/28/02] [AUT] Doc * PDE 3 pages) 07/01/02 5 CERTIFICATE of service Re: Item # 3. [EOD 07/02/02] [KZ] Doc #5 PDF 1 Page) 07/11/02 6 MOTION for relief from stay Re: Union Planters Mortgage (Fee paid, Receipt Doc #6 PDF_(3 #584346,$75.00) [Disposed] [EOD 07/11/02] [KZ] pages) CERTIFICATE OF NON-CONCURRENCE [EOD 07/11/02] [KZ] 07/11/02 7 ORDER that answers aredue on 07/31/02 Re: Item # 6. [EOD 07/11/02] [KZ] Doc 47 PDF...(1 Rage_.) 07/16/02 8 CERTIFICATE of service Re: Item # 7. [EOD 07/16/02] [SP] None 07/18/02 9 CERTIFICATE OF DEFAULT Re: Item # 4. [EOD 07/18/02] [KZ] None ENTERED IN ERROR (Related to wrong docket entry) [EOD 07/18/02] [KZ] CERTIFICATE OF DEFAULT Re: Item # 2. [EOD 07/18/02] [KZ] 07/18/02 10 ORDER granting relief from stay Re: Item # 2. [EOD 07/18/02] [KZ] None 07/24/02 11 MOTION for relief from stay Re: Greenpoint Mortgage Corporation as Sevicer for Doc #11 PDF (4 the Mortgagee of Record (Fee paid, Receipt #584786, $75.00) [Disposed] [EOD pages.) 07/24/02] [KZ] CERTIFICATE OF CONCURRENCE of Counsel for Debtor [EOD 07/24/02] CERTIFICATE OF NON-CONCURRENCE of the Trustee [EOD 07/24/02] [KZ] 07/24/02 12 ORDER that answers aredue on 08/13/02 Re: Item # 11. [EOD 07/24/02] [KZ] D_oc #12 WF_11 page.) 07/26/02 13 341 meeting held. [EOD 07/29/02] [DP] None 07/30/02 14 FINAL REPORT of Trustee in No Asset Case [EOD 07/31/021 [DP] None 08/02/02 15 CERTIFICATE of service Re: Item # 12. [EOD 08/05/021 [DS] None 08/05/02 16 CERTIFICATE OF DEFAULT Re: Item # 6. [EOD 08/06/02] [KZ] None 08/07/02 17 ORDER granting relief from stay Re: Item # 6. [EOD 08/07/02] [KZ] None 08/29/02 18 MOTION for default judgment Re: Item # 11. [Disposed] [EOD 08/29/02] [KZ] None http://pacer.p amb.uscourts. gov/cgi-binlfoxweb. exe/npacerInPacer?ExecThis=docket&puid=(... 2/3/2003 Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 2 of 2 08/29/02 19 ORDER granting default judgment Re: Item # 18. [EOD 08/29/02] [KZ] ORDER granting relief from stay Re: Item # 11. [EOD 08/29/02] [KZ] None 09/30/02 20 DISCHARGE of Debtor(s). Certificate of Mailing. entered on 09/26/2002. Doc #20 PDF?3 Certificate of Mailing. [EOD 09/30/02] [AUT] . . a es 10/04/02 21 FINAL Decree. Certificate of Service. entered on 10/01/2002. Certificate of Doc #21 PDF (2 Mailing. [EOD 10/04/02] [AUT] a es Printed: 02/03/03 11:07:59 PACER Service Center Transaction Receipt 02/03/2003 11:07:59 PACER Login: fp0039 Client Code: Description: Docket rCase Namber: 111 2002-02902 Billable Pages: u Cost: 110.14 Need help? Try the PACER User's Guide Pacer Service Center http://pacer.pamb. uscourts. gov/cgi-binlfoxweb. exe/npacerInPacer?ExecThis=docket&puid=(... 2/3/2003 CJ ?= ;"; n _ -i'[ ??s-i _ -? __ ,( _ .. ' -? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY ) CIVIL ACTION vs. MARY A. WETHERELL CIVIL DIVISION NO. 02-5878 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for GREENPOINT MORTGAGE FUNDING, INC. F/K/A HEADLANDS MORTGAGE COMPANY hereby verify that on 2/4/03 & 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 82003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff a ,cr, ti l '?J s ? roy w z to ?. W N .~.. O ? Oo J O? Vc .A a ? o a IT IT T 9 w? a R r ?y 0 wqq?m ? a can ?- ?. o. Q ?I N ? ? O O 0 gig 0 0• ? a ?- ..,y w ? ? 7 N ao.?s n o ? b ti -111-1-1i D C'f z C a o? a ? a ? a rn 00 ? r oC/) n r y r ? a Co n r ? Z o b W b a J O J O a ?`s?PtES PosT4 4'O 1 PITNEY now,, r2 '.a $ 00.900 OOJ43UU477 cG?y ? FrgtLEC? FROFdI ZIP„^,p£' g . O tl A m o>z A a F fD ? A rn C ?+ a b ? ?a?nl-d o?c? o° a 0 z °,am VI n1 ., a Ibo1" tv r b ?zb r W .a. vi y hh 0 0 <7 c-3 (D C_ C,) -TI ° -a C C - _r1 .1 G - y !` `- --3 ; 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 Federal Home Loan Mtg Corp 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 5th day of Feb, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 5878, at the suit of Greenpoint Mtg Funding Inc against Marv A Wetherell is duly recorded in Sheriff's Deed Book No. 257, Page 4750. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A.D.2003 . y 3 day of Recordd'i- of Deeds RacoMa? of Deed, CunOaMtl MY?WM?etMFhlMOr ' dJr?-a Greenpoint Mortgage Funding, Inc. f1k/a In The Court of Common Pleas of Headlands Mortgage Company Cumberland County, Pennsylvania VS Writ No. 2002-5878 Civil Term Mary A. Wetherell Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on February 14, 2003 at 4:20 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: Mary A. Wetherell, by making known unto Mary A. Wetherell, personally, at 120 Hummel Ave., Lemoyne, 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 07, 2003 at 6:14 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 Mary A. Wetherell located at 1713 Locust Street, New Cumberland, 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: Mary A. Wetherell, by regular mail to her last known address of 120 Hummel Ave., Lemoyne, PA 17043. 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 Federal Home Loan Mortgage Association. It being the highest bid and best price received for the same, Federal Home Loan Mortgage Association of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna, VA 22183-5000, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $765.57. Sheriffs Costs Docketing $30.00 Poundage 15.01 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Certified Mail Levy 15.00 Surcharge 20.00 Law Journal 274.70 Patriot News 225.85 Share of Bills 25.24 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 765.57 Sworn and subscribed to before me So Answers: This 9 day of R. Thomas Kline, Sheriff 2003, A.D. c Q J?.,, p Protonotary )II ? ? BY ? Cs'?"(V VLL??}'\ Real Estate Deputy 30 v 0-k" 41339 Real Estate Sale # 29 On February 12, 2003 the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA known and numbered as 1713 Locust Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 12, 2003 By: Jody , Real Estate Deputy C;M v? EFD 3. ? THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 ........................ ........... .... ....................... COPY is 1 t day of ay 20A.D. Not cal SALE #29 Terry L. Russell, Notary Public REAL ESTATE SALE No. 29 City Of Harrisburg, Dauphin Coun ?? 1NrH No. 2002-5878 My Commission Expires June 6, 2006 NO RY PUBLIC Civil Term Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 Gr"Pion' t Mortgage Funding, Inc. FIVJ8 Headlands Mortgage Company CUMBERLAND COUNTY SHERIFFS OFFICE vs CUMBERLAND COUNTY COURTHOUSE Ma Arty: A. Fran!'': Federman erellderman CARLISLE, PA. 17013 DESCRIPTION ALL THAT CERTAIN lot of land situate in the Borough of New Cumberland, County of Statement of Advertising Costs Cumberland and State of Pennsylvania, more particularly bounded and described as follows: To THE PATRIOT-NEWS CO., Dr. BEGINNING at a point on the easterly line of For publishing the notice or publication attached Locust Street eighty (80) feet South of the southeast comer of Locust Street and St. Clair hereto on the above stated dates $ 224.10 Road; thence nouheastwardly at right angles of Probating same Notary Fee(s) $ 1 .75 Locust Street and along the southerly line of Lot Total $ 225.85 No. 3, Block C, on the hereinafter mentioned plan, eighty-five and ninety-seven one- hundredths (85.97) feet to a point; thence Southeastwardly along a Play Area as shown on publisher's Receipt for Advertising Cost said plan, sixty-six and fifteen one-hundredths 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. (66.15) teet to a point; thence Southeastwardly along the northerly line of Lots Nos. 12 and I, By.................................................................... Block C, one hundred thirteen and seventy-nine one-hundredths (113.79) feet to a point on the easterly line of Locust Street; thence by the latter line Northwestwardly Sixty (60) feet to the place of BEGINNING. BEING Lot No.2, Block C on the Plan of Lots Tate Parcel #23-0543-246. TITLE To SAID of Highland Park Extension, said Plan being PR E4 is vested in Mary A. Wetherell by recorded in the Cumberland County Recorder of Dad flow Antes IC Knaub, married, dared " Deeds Office in Plan Book 5, Page 59. 15/1999, recorded 7122/1999, in Record Book HAVING THEREON erected a single dwelling 204. Page 359. house known as No. 1':13 Locust Street,, New PREMISES: 1713 Locust Street. New Cumberland, Pennsylvania. Cumberland. PA 17070. 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 was established January 2, 1952, and designated by the local courts as the official et al aforesaid, 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 true. REAL ESTATE SALE NO. 29 Writ No. 2002-5878 Civil Greenpoint Mortgage Funding, Inc., f/k/a Headlands Mortgage Company vs. Mary A. Wetherell Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of land situate in the Borough of New Cum- berland, County of Cumberland and State of Pennsylvania, more particu- larly bounded and described as fol- lows: BEGINNING at a point on the east- erly line of Locust Street eighty (80) feet South of the southeast corner of Locust Street and St. Clair Road: thence northeastwardly at right angles of Locust Street and along the southerly line of Lot No. 3, Block C, on the hereinafter mentioned plan, eighty-five and ninety-seven one hundredths (85.97) feet to a 2- Marie ( Editor SWORN TO AND SUBSCRIBED before me this -9 day of MAY 2003 LC s point; thence Southeastwardly along a Play Area as shown on said plan, sixty six and fifteen one-hundredths (66.15) feet to a point; thence South- eastwardly along the northerly line of Lots Nos. 12 and 1, Block C, one hundred thirteen and seventy-nine one-hundredths (113.79) feet to a point on the easterly line of Locust Street; thence by the latter line Northwestwardly Sixty (60) feet to the place of beginning. BEING 1.ot No, 2. Block C on the plan of lots of Highland Park Exten- sion, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 59. HAVING THEREON erected a sin- gle dwelling house known as No. 1713 Locust Street, New Cumber- land, Pennsylvania. Tax Parcel #23-0543-246. TITLE TO SAID PREMISES IS VESTED IN Mary A. Wetherell by Deed from Andrea K. Knaub, mar- ried dated 7/15/1999, recorded 7/ 22/1999, in Record Book 204, Page 359. Premises: 1713 LOCUST STREET, NEW CUMBERLAND, PA 17070.