HomeMy WebLinkAbout03-0571
BANK ONE, NATIONAL ASSOCIATION, AS
TRUSTEE
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
YS.
ACTION OF MORTGAGE FORECLOSURE
SHEILA M. GROSS
Defendant
i)3 - .5' 71
L'!t'.tiJ
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTlNGTO 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 A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIP ACION. 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 A VENUE
CARLISLE, PA 17013
717-249-3166
BANK ONE, NATIONAL ASSOCIATION, AS
TRUSTEE,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
vs.
Defendant
ACTION OF MORTGAGE FORECLOSURE
?l..t" D3.::r'l/ ~ ~.#'-
SHEILA M. GROSS,
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is BANK ONE, NATIONAL ASSOCIATION, AS TRUSTEE, a national association acting
through its servicing agent, Homecomings Financial Network, Inc., whose address is 9275 SKY PARK
COURT, SUlTE 300, SAN DIEGO, CALIFORNIA 92123.
2. Defendant, SHEILA M. GROSS, is an adult individual whose last known address is 1880 MCCLURES
GAP ROAD, CARLISLE, PENNSYLVANIA 17013.
3. On or about, January 22,2001, the said Defendant executed and delivered a Mortgage Note in the sum
of$61,950.00 payable to HOMECOMINGS FINANCIAL NETWORK, INe., 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 ofthe same, Defendant made, executed, and delivered to original Mortgagee, a certain
real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1665, Page 366 conveying to original Mortgagee the subject
premises. The Mortgage was further assigned to Bank One, National Association, as Trustee and was
sent for recording. Said Mortgage and Assignment are incorporated herein by reference.
5. The land subject to the Mortgage is: 57 WATERSIDE DRIVE, CARLISLE, PENNSYLVANIA 17013
and is more particularly described in Exhibit "B" attached hereto.
6. The said Defendant is the real owner ofthe property.
7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on
October 01, 2002 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE
$60,562.58
Interest at $19.56 per day
From 09/01/2002 To 03/01/2003
(based on contract rate of 11.6250%)
$3,540.36
Late Charges $30.97
From 10/01/2002 to 03/01/2003
$154.85
Attorney's Fee at 5% of Principal Balance
TOTAL
$3,028.13
$67,285.92
**Together with interest at the per diem rate noted above after March 01,2003 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 Sheriffs 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. Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending
to Defendant, by certified and regular mail, a copy of the Combined Act 6/91 Notice. A true and correct
copy ofthe Combined Act 6/91 Notice is attached hereto as Exhibit "C".
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. The Defendant has either failed to meet the time limitations as set forth under the Combined Act 6/91
Notice or has been determined by the Pennsylvania Housing Finance Agency not to qualify for
Mortgage Assistance.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 11.6250% ($19.56 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 tho property within d""riboo. By' -if/ii/Ii}! rJz 1
PURCEg.i, & HALLER
Leon P. Haller, Esquire
Attorney for Plaintiff
J.D. # 15700
1719 N. Front Street
Harrisburg, P A 17102
(717-234-4178)
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Page 33 004
LEGAL DESCRIPTION
ALL THAT CERTAIN three tracts of land situate In lower Frankford Township, Cumberland County,
PennSylvania, bounded and described as follows:
=====~=:=========:========:============~==-===:=======~:==============
TRACT NO.1: BEGINNING at an iron pin and stake at the corner of land of Paul R, Young and
Russell L. Mackey, et al; thence along the line of land of Paul R. Young, crossing a private road and
through an iron pin on the southern side thereof, South 44 degrees 30 minutes West 200 feet. to an
iron pin: thence by the same land and the same course, 35 feet, more or less, to the low water line of
the Conodoguinel Creek; thence by the said low water line, North 75 degrees 39 minutes West, 60
feet to a point on line of tand conveyed or about to be conveyed to Afverta M. Fry; thence by the
latter land, North 44 degrees 30 minutes East, 35 feet, more or less, to an iron pin; thence by the
same land and the same course, 211.29 feet, crossing a private roael, to an iron pin on the line of
land of Russell L Mackey, et al; thence by the latter land, South 65 degrees 18 minutes E,asl, 55,14
feet 10 the Place of BEGINNING, said desCIiption being in accordance with a SUl\Iey thereat by
Roger Sf. Germain & Associates, dated September 26, 1961.
TRACT NO.2: BEGINNING at a slake at line of other land of K. Swartz; thence by said land,
South 44 degrees 30 minutes West, a distance 0'225 feel, more or less, to the low water mark of the
Conodoguinet Creek; thence by the same up the creek, North 52 degrees 15 minutes West. a
distance of 51,5 feet to a point: thence along lands of Chester Fry, North 44 degrees 30 minutes
East, a distance of 231 feet to a stake; thence by the same, South 45 degrees 30 minutes East, a
distance of 50 leet to a stake, the Place of BEGINNING. CONTAINING 0.27 acres, more or less.
TRACT NO, 3; BEGINNING at an iron pin at the corner of land of Chester L. Fry and wife and
Russell L. Mackey, at 81; thence along the line of land aforesaid of Chester L. Fry and wife, crossing
a private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same course, 35 feet, more or less, to the low water line of the Conodogurnel Creek;
thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line of land of
Brinton F. Forney and wife; th~l'lce by the latter land, North 44 degrees 30 minutes East 35 feet,
more or less, to an iron pin; thence by the same land and the same course, crossing a private road
234.38 feet to an iron pin on the line of land of Russelll. Mackey, et al; thence by the latter land,
through an iron pin in the center of said line, South 65 degrees 18 minutes East 110.28 feet to the
Place of BEGINNING; said description being In accordance \\Ilth a survey thereof by Roger St
Germain & Associates, dated September 26, 1961.
BErNG the same premises which Lee E. Grove and laura Grove. by Deed dated and recorded ellen
date herewith granted and conveyed unto Sheila Gross, Mortgagor herein.
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Page 1 of6
Homecomings Finandal
A Gt..fAr CDl")!pt.l:~V
lj,;,cel11l1rr liS. :1)(1:
Cendled t.J~il. Return Receipt Reques~d
04(1IH64&S 1
Sheil" M Gross
57 WSl<rnide Dr
CaTJi~le, I'A 1 'Oi3
Re: Pro[X'rty Addr....."
51 Walaside on"e
Corh.lc. P A 171) I :;
1.0'" Number:
'>l00.164 S& I
A defauJt exist~ undo:r the, Bbove refcrc:ncedMOJtG;\Ge:Decd of 'flUSt lOlln BOlfCc:mml The nction required 10 cure
Ire clefnuh i. tile fl.'Y1'k1nt of nU '.\IIos oue \ll'1Oer t.... l\!!,'rtgllg.-irNeo ('If TI'IIOI Joon ngree_, As Ot'lhe dOle "f
thi. leuer the lOOt] omcunl due i. $ 1.958.99. ThaI sum includes lhe f<1l]"'..-j"S:
, ""ymonts tolalin8: S Uf97.(I5
Late chllrW-"" $ 61.94
(lthert"ecs <I!ld"1[ costs Ni A
iJllHpplied fund,; N/A
Thc 10101 BtO''''nt clue .hown .hlwc is s"I,iccllo funlter iner""so. for AJdil"1l),)lmoolhly ",,~mcnt'. 1.31< charges,
Olll'mey f,,-,... arnh'lt ntb<f fees mt(J CO:ll "'hid, moy b<-c'~ne due. Bfler Ih" dali nflhi" leu,... To obtain an upomc
oft.'" lotal amounl due 10 <urr: this default, conla,.; us at 1.8011.206.2901.
TO CURE TmS DEFAULT, SEND YOllR CASHIER'S CHECK. kfONEY ORDER, OR CERTIFIED
CiiliC).; IN THE AM(ll,JNT OF SO t.9!\ll.99 BY .Ian......' 114. 2110.1 TO THE fOLLO\VL"iG ..\DDRESS
H".I~~"llIlnll' Hn~..dlll,P,O, now 78426 I""'"nlx. AZ SS.162-ll426 Ol{ OVERN,IGUT TO: lot45 W.
Uunl..p A...nu., Suit. ItNll'h...nl", AZ 1l50l1.2f101.
!f the dcl"IIU!t is ""1 ",,,,,d witbin thirty (3(() da).,. d the maili~ of this Idler, the Jender. without furth,.- octice Of
d""""""l wull ""cd.mte tll.> m31llrlty dau l,f the NOlC and W,clare all sum. ""cured by tl.., MI)nfl)1l!.ciDood of
TtuSl 10 be imml'dialdy due lllllI payable, The I""de, Ih<n mt""ds 10 ha\'e lhe pI(""".ty sold at II public
f""edosure ...Ie, Aller .cedeml;olt, II oun"!) of the delimit and ",i".1ala1,,,"t of lhe 101111 will he pem,illed up in
the lime of the sol. by PO)'If1l.l,lht f10Sl due moo,thly f<lymenl. lI1ld "l!wr SUltlS Ihen due urKler lhe 1-:!<:>.t1llPge,'l:JeC<l
ofTrusll<...._ agreemelU a..J~' oOll1l'lyins with aUI.e1m. of ",instatement
)",,\1 ho\'e lhe ri!!hlt" brinp,ll Ct'ur! lICti,,,, 10 """elt Ill<! nnncxi"tenec <,f 0 dcfflUl1 "'My (lIhel defom,e that may
OX"'I 10 prel'cnt .<<de...u"" ..><I ..le of the pr"f>Ol1Y,
TInS NOTICE IS SENl" TO YOUN /1,'1 ATTEJ..!PT TO COLLE(vl' TIlE INDEBTEDNESS REFERRED TO
I'lliRE IN AND ANY INFORMATION OBTAINED FRO"! YOU WILl. Bfi USED H>R. lH..'T P1JRl't.>S5
Sincerely,
Loon l"':mmsdinll V"""rt.mo:II
HUl
HmneccHlllnq:l- HI'lClm::kJI
2111 Nf'tltlt tl(i"t;~1l A'I'f!t'W'e Mille> WXlDCH!I"J'\. T.e~(H 1.~2(U
.fU).206':'~' Hnll'ClOtnil1{f:t..eum
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ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
nns NOTICE IS SENT TO YOU IN AN AT1E.\iPT TO COLLECT nm INDEBTEDNESS REFERRED TO
HEREfN AND ANY INFORMATION OBTAtNEl) mo!\! YOU Wli,L BE USEl) FOR THAT }'1.JRI"OSE
This is an 0[["'411 nnlia that the mnrtll"ll" l1n 'our home is in tler,,>>I!. arnJ Ihe len~ intends 10 ("red,,.", Specific
i.nfllllllilti\1r."a!x>\!tJMJ.1allln!.9f.tl:huld;'lllllUt>rQriill1'IUIl,llKlIIllll;Ih1Q~
The HOvmOW1\13R'S MORTGAGE ASSIST ANCH PROOIL~HI!EMAl'l mav 11<' "hie t(:. help 10 saw: \'~
llilli.1:i!"'i~~<!:m)D.!!.!~~Im!!YJ~,m~mrro_\'rQ.~
~_J.LIjE':~.j:&~.gJll hIt!!'_ roo mWlt MEET '''lTH l\ CONSUMER CREon COtJNSF.UN(,T N3E\JCr ~
30 DAYS OF TH DATE' TIllS NOl1C-:C, 'Ilih tisnotice \\'tlb vol! wllCtH'(lumcet wilh Ihe Col1Jt!lCl ' I 'eru:\',
The name. Ildl,tres:; am! J.'I/lOne number "r (\'l1sUl1lef Credit COOl1S<!litl~ lll!encles ,mille \'001' COIJ1I1V nre !if;Ud at the
ct"U'Lth;~J:'!c!jKJb1!ll;~_an~~q!!~!!Ql1!;".Y!'l\!JTh'L"'!lt~~nn~:!.l'!!!1u.;Ji(m~jn$~jnanc-'1..,"'l!!'n<;YJQHJt~aU:
!:11!1-,:142.,Z3~11..~\'rl(.1!l!L'IltI:UlllJX!Jl"fJ..th~llfiJ,lJl-"'Il!;;lll.(l.l7.Ll1!I!:.lll.i9')'
Thi. Noei", C(lfl!atJl$ Im!"'rIlmll<g81 infamlatioll, If y"u h~"e lItly qU"~j"'l$. rqm:.el'l1:Jtives llt the Con.umer Credil
Coon.<tlmg ,<\ge.JCY moy be ohle 10 hi'll' Ernpla.n it. You m:.1Y also WOllt fa (",.met llIl att,)ltI;!y 1Il YOUI' Ol'<lo. The locll
b&r associal;oo ""'y be able 10 help you lind a lowyer,
LA NOTlFlCACION EN ADJL1\lO ES DE SUMA IMPORTA'\lClA, PUES AFECTA SU DERECnO A
CONTINUAl-: VIVlENDO EN SU CASA. 51 NO COMl'RBNDE EL COl\TL\NIDO DE ESTJ\ N<XI'IflCACION
OBTENGA UNA TRADlJlTION IMMEDIATA\IENTE ILAJl.fANDA ESTA AGENCIA (PENNSYL VANTA
HOUSING FINANCE AGENCY) SIN C,\RGOS j\L NUMERO MENC.IONADO ARRIBA PLlEDES SF.R
ELEGlBlli PARA UN PRESTA'10 {'OR EL. PROGR..~'\1A LlMt,\I)O "IiO!\.fEOWNER'S El>fl'iRGh"NCY
MORTGAGE ASSlST.6oNCE PROGR...:\.\f"' EL CU4L Pl'EDE S.4LVAR SU CAS.4- DE LA PElU)!DA DEL
DERECIlO A RED!l.fIR SU lill'tHErIA
Dme I)ro"",hcr OS. 2002
TO'
ShcilaMGroos
57 WllIerside Dr
C\VIi~l:c. PA 17013
Prnmis.es:
57 Wolctsidc f)ri,,,
Clllhsl".I'A 17'))3
Re, Leon Numher: ()4(~I,'Ii:l4~llI
FROM UQ!1.1~~J!!!~il)tll!!!~1!!
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Page 3 of6
I10MF.QWNERS' E}\[ER("~ENCY MORTGAGE ASSIST ANCEPROGRi\M
VOll MA V m;: F:UGIBLE FOR Fl'\L\.NeIAl. ASSl!>"TAN"CF. \\111(:n C..\N SA n: \'OlIR nOMIC FROM
F"ORF:CI,osnU:,\NI) IUU'V()1.' I.UKE FUTURE MORTG,\GI'I',\Y\U:Nl:S
IF YOU CO~.'lPr.Y \\llll TIlE PRO\lSTONS OF TIlE HOME01.vr-.1'ER'S ITh.ffiRGENCY !\TORTGAGE
ASSITANCE ACT OF 1993 (TITE ";\(,T"), YOU l\'fAY BE EDGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE'
IF YOUR DEl' AFLI IL'\s BEEN CAUsED BY CIRCUMSJANCES
BEY01'll) YOVR C(}Nnw!,.
TF YOU HA VB ,\ REASONi\I:lLE PTWS1'EGT OF BEING ABU': III
PAY YOUR r-.rOR 1\1 AGE PA YMFJ>it'S. AND
IF YOUr-.-iEET CflllER alGlBll..ln' REQI1IREr-.ffiNTS
ESTABUSHFJ) BY THE PK"JKSYl.VANIA HOrSING FIN,.\.."lCE
AGEN"(7Y
n:MI'ORo\R\' ST.-l\' OF f'ORIX~I.OSURE .. Undo, the Act, yo" "'" enlitled t<> a tcmporar}" st.~r of foreclosure
(III Y(I\lr mMil'1g~ lor thinS' (31)) doys liOJl1 tm d.\lr~ of thi~ N,)I k.e Du.tins. rm.1 lime; you 1l:W-"" all'llIll!~ end atlend a
-[""e-Io-f.",," meetinll with one of Lhc CD.......... credil rounsdill8 "ll"""ies list.ed at Lhc end of tlUs Notice. TJ{JS
~IEl1TL"G I\msT oct\1B "1TlUN nJ~ )\WXT JII DAYS u:. :ron 00 NOT .\1'''1 Y FOR F.MERGE"{rr
M.QRIg.h.9K.~~1:?IAi'!t;lLXQ!}.J,1!1;lIJlm.l':IQ.XQ.!.'R.!\:'!"'!l(1]JAGJLIJP_1J;)_QAI.~-,...IHE 1~~I_Q.LIH!~
NQIK'JifAI.!,!!:D~'HQW:rQ(:!:Rfi:YQ~Il{MLlli:Hi,"'()!;Jl!;l",4,1.\!.I",J::X!~!",\IN.~m")iLIQJ~RJN\J)'(lUR
M.Cl:I!J:1JAG.EJ.1'...IQ1.1AIIi
C:ONSI'\U:R CRI':""" CCmNS~:llNC; A<;f:NC:n;S - If you mo.' with "no of Ill< consumer creJn coun.,ehng
"~hCies liSle(j ll\ II>< end .,f1,h.. ,,,,:i<:<', Ih" lenoo may NOTm!" lllC1;nn 9ga''''t you [(If Ihiny' (JIl) day~ ,lI[le, Ih" dm"
01 this '''''''linE' Ih<'."n"mo;s."~<:I.:Ir:c~'!I1>iJ~,!"I!!!~mmt!!~I]""f.,~,,;snaIC4.c,on~.ffi'<!jt~c>:I:J!:I:!!~!u~"~!1cj~sJ"r
IMQ,,'lIIJlIY iIlYi:h.i~hlb~I"mjX(lSJ~"'!;i!I"l!ur,,~t!QrthllIJ~endQrllltsN!.>tl~ 11 I' Ollly ~W'.l' 1(.> $clt~dlll. !."lII"
fa.e-lo-[acc mceling, ll<h-ise your lender imm.edintdv Df}'Olll" intentions.
AI'PLlCATION FOR 1\I0RTGAC.;).:ASSISTANCE - You. n"'r1~. i. in LIt.fauTt ft'T tht "'a"".., <,'II,'r1h litle,
in this Not,,,,, (s"" r.,lkw.;ng page!< for speciile infonnalioll abomlhc I\3Iure of your defmdt) ffynu ha,.., tried and
lite Ulml>le 1(1 re;;l>lv~ Ihti; rn<"'Tem with the I~Jwel'. you 113,.t the ngllt I,.,. llfll\Jy lOr fUlllllc,el O~I$t.~ (i'{lnllhe
HnmeD"'I""". Emer,!<'ll"Y Mortil"S" As:sista.""" Pt-~. To do so, you must fill Dut, .illfl and file a romplcled
HOO1CO,,"'wr's 5m."'!ll<'l1cy A~si'I(lI""" f'r<)8f'lln Apph1'311011 wIlh 00.' of lhe .;li!slgWIted ellnmm"'r qedi! coulWehll&
811"1'1"'.8 list,,,,' ill lh. ,'11d "fli.is Nt1li(".<, Cmlr ""n>U:lIkT ''I't'{bt OOWl..ling llgl."",;c.. hll't applic:ulicm.. fo. Ihe pruglum
and Ih<)' will a....ist yoo in submilling " complcte appli<:at;')ll to Ihe Pennsylvania Hou.,ing Fimncc l\gmcy \'ou,
owlicellon MUST 00 fll~d or 1'000l1lalked wilh'll lhm)' (30) day. ,'I' your r_-Io.face meebng
UiNIlI(R CX>NTM1T IN Rt:GARnS TO PI:i'"NSn.\',o\NrA U01)!>'NG "NANn". ;\SSISTANCt.
H,)l1lt.'C,)fIlilll!l' Fil1l1l1<.;l1I
271 I NOr1h Hafikdl A.e. Sude 9<.10
Dall.., TeJ<as 752(10;
AI111, L"..~ Mit~I"'" Dip;utmm. Slcrhoni~ CtD\lch
Phone: 1-8(10-206-290 I. Cxt. 15(06
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AU, CORRf'sP'ONI)ENn: REGAROING I'Hf"A ASSISTANCE suorw BE J!ORW,\JUJEI) TO 11m
AHO\ 'f: REFERF:NC[I) AII.DRf:S.'l.
\'OI!"MlJS1' I'IU: YOUR '\PI'UC\TIOC\' l'ROMPTI,l'. 111 Y(m FAIT, TO no so on IF \'01; no NOJ'
FOU,OW TIn: OTIIEf~ TIME l'ERJOl.lS SET FORTIl IN nus I"E'ITER, FOIU:(:U~1rRF: MAl'
I'ROn;l.,]) AGAL\1ST YOUR HO!\fE 1l\1!\1El>l.ATEL \' AJ\1) YOUR AI'PLlCATION ,FOR MOR'I'(;AGE
AS"SIS1ANCE \\1H, Ill: m:I'.'u:o,
AGFXCY A{:TION -- A,,,i1ab!e funds for emcq;cl>l>Y mQrI~ ..""islant:e are '''c}. fimi..,d. They will be illsllurscd
by thi' I\gMC}' 1\Jl;;lcr thc cllgJblllly m~crla Q~bli.hoo by UN lwl The PCIlII'l}'h'llnlll Housing FlIllIll'" /\gl!ll"}' has
Sl:~t)' (6iJ) ililys t" I1llll:c 1I docislOlI elkr Lt recdves )'uur "I'l'tic.t;oo. L~ tI\lIt lime, n" f",.closure rrocc~dm!!"
wi!! be JlUIDlcd Il;!lltio.\t }"l:>U If you h",,, met tho limo roquircmonlll set forth ab,,,"o, y"" will be nmifiod dircclly by
the I'l'llllSyh'ania 1l0Wiing F iIUJnce AgelK1' of ils ru.'l.i.Sl(m un yu.... "I'l'licll1ion.
NOTE: IF YOU ARE C::IlRRF.J\"'TI,\' PROTECTFJ) BY THE FlUNG OF A PETITION IN
BANKRIJPTc\', THE FOU,O\\1NG PART 0.' nus NOTICE IS FOR INFORMATION PURPOSES
OJI\'I, \' Al\1> SHOllI.J) NOT BE CONSTRt"ED A..~ AN ATTEMPT TO COLl,FA:T mr DEBT
(If "00 ban m"d b..nkru~' you "an SWlllPply for E~' Mltrtgl\Il' A"'$llln(~,)
now TO CURE YOFR I\fORT<;AGE DlWAUI,T (Brin!! it UP 10 date).
N.\n JR.' 0 I' Tin: I) 1"'1,'" 1.11 :r - The MORTGAr.;E debl held h)' the 3b(".. londer on lwr propcny 1000at.d 3~,
57Wale""de Drive. e....l;s]". PA 170].'\
IS SER10tJSL Y IN DEF AU"T b<'c'U$<!,
YOU HAVE NOT l\fADE MONTlILY MORTGAGE PAYMEl'i"TS for the t(']klWl~
months and the following amoonts .,." "n... flBSl <h,e'
Ivtonlllll' pII}'''k'll1s frOIl1 ]0.'01/(1210 12qll 'fl2 Maling:
Late C'h.rees:
Oilier fee$ QIId/or 00!;t$ {indu.;l1l1g NSF .hargl!5 and pr(l~tty m.'1:>eCliOl1.~}:
[.ESS: Unapplied Funds:
TOTAL
S 1,897.05
$ 61.9~
N,l;\
NlA
1: 1.958 99
HOW TO ellU: TIlE IlFFAtTLT - You 1I10}' r.ure the d~f'\,ll~ within THlRTI' (.'In) DAYS of Ibe dale "flh,.
N<'liee B\' PA\'L'\1G THE TOTAL AMOUNT DUE TO THE LE!Il1>ER., "VHlGH IS S 1.958.!)lI.PLUS A.'<,'
MORTGAGE PAYM,ENTS AND LATE CHARGES WHICH BECOME DUE DURING '11m THIRTY (311) DAY
PERIOD, P'Wll'ctl(~ mll.l ~ tI1lide either bv ca-;h. CIl''lhiet'" ehoel:. certified d.e<:k t">I m,mev bider mrtd" tm\'ll'bl" end
~q,,,:
lIomeelllnings Pi_ldlll. P.O. Dol: 7842:6 Phot'ldl:, AZ 85;062:-8426 OR OVERl\'1GIIT TO:
2445 W. Dunlap Avenue, Suite 100 Plloenb, AZ 85021-2803.
IF \'01'1)0 NOT CURE TilE DEFAt1J,r - If)'Oll do Ml = the default wilhin TIIIRTY (:KJ) DAYS of tbe dole
\'1' t111~ Notl""', lh~ ~nck-r inltnd. to <urc:i>. I'" ""Ill to ...cd.,...!. th. ...orll......: debt, nu~ me<llt' lhrd the 1;111;1<
oUI'tll'nding balance- llr II... okbl wiIl be .lln.id"ted dUt ,mmediutdl' and you mol' (".. the cham;" 10 ",ry 1.11.< rm>trgJ'lg,e
in monthly install...ents. If full JlfIyment of the 10Ul] amounl pnst due is not made within 'fHIRl'Y (30) DAYS, the
ICllOO[" als,,", ItlIC/)o.l.~ 10 mslruCl.IS ooOITlt.1' ", 8t.10 l<l!;ll! acuon 10 lCr<<:,]0lle ll,"OO y"ur mortgaged I'wpcny,
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IF TIm 1\IORTGi\G}: IS FORF:CUlSEIl I'PON - Tbe m<'l1pg,'tI pml'elty witt be :!;old I'l" the Shenirlo pay olT
lhe m<1rll!"!\<' d<-.bl If t"" l.nder rclen l'our O:lselo it< HlIun,c)', but yeu cure I"" adinqu.",,>' bdore ihe Imder "eains
legal pRJC<:",ling.~ nglliw,( Y'''', you will ~tilI be Je"uire<llo pay lhe ,_ooable ounrney', fees lhol were oetually
iJlcwred. lip \" S5{/.OO, However. if ]eJllll PllXccilin~ lIIe ~UlItca against yon. Yl'U will hal'e to payaJlIe'<lsonable
at:orney's fces "'ctI41!1~' incurred 11)' tile lender. c'"en if they """ecd :!i5IJ,~)I} Ally atloolCy's fe<:>< will be 'l<ldcd In lhe
aml'UI11 )\')\1 owe lllii lender. which may alS0 ,"elude Nher reasonable CiJ1<t.', If V{lU tUft tllf- dd"lIult wllltin tht
nlfRT\'UfIl l),-\\, ~ri"d. .."" ..III no' 1M' "'qllirNIlo !:lD.' nllnm,,\". f....,
K-\.RI.IF..sl' I'OS."'BU: SlIERIF}''S S,\,U: ]),\ 1"E - II is "'-iim.tcd tha\ 'lhe c.rlio51 dalc that sucl1 a Sheriff" s
S1\lc nf tlw m')/tg<1Il",i Pr<'I"'l1y ('<'uld I." 11<']d w,'Uld he "l'f>I'..xlm"ld~' ~h (6) lllo..tI." from lhe da1t or Ihis Noll('t'.
A nollec l,r the !lCtusl ""Ie or the Sherilfs Sal< will he "'-'!Ilk' yoo before lhc S<lk or COllr:$e. the llI11mllll nl:e~cd 10
<:<$re lhe dcfaul'....ill i~ the lO'll.!Cf roo wart i' OlI may' find OlIt at nor lime c~lr ",h"" the n>qaired payment or
actlOll will: he hy CO<ltOOllllg the lender.
HOW TO C(}NT ACT TIfF I,F1\llFR:
Hllmccom".~ Fil1llTleial
2711 N H",kc Jl, Suite ')tat
Dnlln~, TX 752D4
Alln: 1<>&11 Counsclin!;1 Drpmrtmcnt
Phon.' ] gOI) 2n6,29111
I;:rn:cr OF 11W SHFRIH"S SAtE - '1'00 should mh;:c thnta Shc:rilfs Sale will end}'\>lJT ''''l1~hil' of the
monga~d property and }'our right 10 0<.'CUp)'" If yoo ~'rotin"" to Ii"e III the propert}' after lhe Sherin", Salt. a
Inwsuillo ",,,,,we rou and yo"r fumi5hinss lino other belongings ""<tlld be sllUtcd 1>)' Ihe len"'" at ony ti",e
ASSUMPTION O~' MORT(;AG~: - y,ltlllwy be able to '\ell or transfCt YOUt home to 0 buyer Orll'lll1s.fetcc u;'ht,
will "SIll1l< tile marteaB" debt, prnvickd thst all tile outstnndi"l.' pa)'1I1crus, charges and llltomcr's fees 3nd """IS aTe
paid pll()l' to ()I' allbe !-ale and that Ihe v-thcr requij<'tllCt'll5 ,~nhe m()ngafJ,e Me S1i!lsllcd.
YOl1 MAY AlSO HAYf:TH.: RI(;HT:
TO SELL THE PROPERTY TO OBTAIN MONEY reI PAY OFF mE MORTGAGE DEBT OR
10 BORRmV MONEY FROM ANOT!lliR LENDING lNSmUflON TO PAY OFF TIns
DEET,
TO HAVE THIS DEFAULT CFRED BY ANY lHIRDI't\RTY ACTING ON YOUR BEHALF
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TO IL" VE nm MORTGAGB RESTORED TO THE SAME POSITION AS IF NO DI.lFAULr
Hr\D OCCVRRED, IF YOU CURE TIili DEfAU.T. (HOWEVER. YOU DO NOT HAVE nns
RIGHT TO Cl.1kE YOUR DEFAULT MORE THAN THREE TI\!ES IN ANY CALENDAR
YEAR )
TO,"","SEIU TlIBNOJ\'EX!SmNCE OF A DBFAm,r IN ANY FORBCLOSUTm
PROCEEDlNG OR ANY OTIiliR LAWSVIT lNSTITVTED UNDER THE MORTGAGE
nOCI)1\IENTS,
TO llSSERT A,"lY OTHER DIiFE.",,'Sli YOU BELIEVE YOU MAY HitVE TO SUCH AC1K.'N
BY HIE LENDER
TO SEF..K PROTECTION UNTIE!{ TIm FEDERAL Bi\i'\'KRIJPTCY LAW,
Sine"rely.
Lt'l{ln Coun5ClingDt.llQrtm<nt
E!l<'klSUr,,~)
Lr..<;t of Coun~;c~iI"Q;Agt"lk"ie:s
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VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the facts
Contained in the foregoing COMPLAINT in Mortgage Foreclosure are
true and correct to the best of my knowledge, information, and
belief based upon information provided by Plaintiff BANK ONE,
NATIONAL ASSOCIATION, AS TRUSTEE. Said facts contained herein are
made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
Date: February 06, 2003
&
Haller, Esquire
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SHERIFF'S RETURN - REGULAR
CASE NO: 2003-00571 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE NATIONAL ASSOCIATION
VS
GROSS SHEILA M
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
GROSS SHEILA M the
DEFENDANT , at 1815:00 HOURS, on the 24th day of February, 2003
at 57 WATERSIDE DRIVE
CARLISLE, PA 17013
by handing to
SHEILA M GROSS
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
Service
Affidavit
Surcharge
So Answers:
18.00
3.45
.00
10.00
.00
31.45
.r~~
R. Thomas Kline
02/25/2003
PURCELL KRUG HALLER
me this
v--
'7 ---
day of
Sworn and Subscribed to before By:
~ c2.0V-3 A.D.
C L'1L--- 0, YLL, '0.0,..1 II~
nprothonotary ,-(1
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-00571 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK ONE NATIONAL ASSOCIATION
VS
GROSS SHEILA M
KENNETH GOSSERT
I Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
TENANT
the
DEFENDANT
, at 1815:00 HOURS, on the 24th day of February I 2003
at 57 WATERSIDE DRIVE
CARLISLE, PA 17013
by handing to
SHEILA M GROSS
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
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
r~~~~~
R. Thomas Kline
02/25/2003
PURCELL KRUG HALLER
me this 7 tC
day of
Sworn and Subscribed to before By:
~ :2tnJ] A.D.
r+rl- (2 ~J/~~) ~
Prothonotary'
BANK ONE, NATIONAL ASSOCIATION,
AS TRUSTEE,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
NO. 2003 571
IN MORTGAGE FORECLOSURE
VS.
SHEILA M. GROSS,
DEFENDANT
SUPPLEMNETAL
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug &
Haller I sets forth as of the date the praecipe for the writ of execution was
filed, the following information concerning the real property located at 57
WATERSIDE DRIVE, CARLISLE, PA 17013.
1. Name and address of the Owner(s) or Reputed Owner(s):
Sheila M. Gross
57 Waterside Drive
Carlisle, PA 17013
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.
knowledge
sale:
Name and address of every other person of whom the Plaintiff has
who has any interest in the property which may be affected by the
TENANTS IF ANY ...
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
Cynthia J. Naught
31 Bellaire Avenue
Carlisle, PA 17013
Richard H. wix, Attorney
4705 Duke Street
Harrisburg, PA 17109
(In the preceding information, where addresses could not be reasonably
ascertained, the same is indicated.)
I verify that the statements made in this Aff~'_d it are true and correct
to the best of my personal knowledge, information belief. I understand
that false statements herein are made subject to h penalties of 18 PA C.S.
section 4904 relating to unsworn falsification tau. orities.
DATE, July 16, 2003
'1
Haller PA I.D. #15700
I, Krug & Haller
171 North Front Street
Ha risburg, PA 17102
(717) 234-4178
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BANK ONE, NATIONAL ASSOCIATION,
AS TRUSTEE,
PLAINTIFF
VS.
SHEILA M. GROSS,
DEFENDANT
RETURN OF SERVICE
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 571
IN MORTG1~GE FORECLOSURE
I hereby certify that I C In the U.S. Mails at
Harrisburg, pennsyl vania on 0 at I', a true and correct
copy of the Notice of Sale 0 R al E ta e 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:
Sheila M. Gross
57 Waterside Drive
Carlisle, PA 17013
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
Cynthia J. Naught
31 _ll"ire Avenue
earlisl.e, PA 17013
Richal:d H. Wix, Attomey
4705 Ulke Stn!et
Harrist1Jl:g, PA 17109
B~~
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, FA 17102
(717) 234-4178
JOHN W, PURCELL
HOWARD B. KRUG
LEON p, HALLER
JOHN W, PURCELL JR
BRIAN J. TYLER
JILL M. WINEKA
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FORECLOSURE DEPT, FAX (717) 234-1206
JOSEPH NISSLEY (1910-1982}
ANTHONY DiSANTO
OF COUNSEL
HERSHEY
1099 GOVERNOR ROAD
(717)533-3836
NOTICE TO:
Sheila M. Gross
57 Waterside Drive
Carlisle, PA 17013
Cynthia .J. Naught
31 RPlli'lire Avenue
Carl.isl.e. PA 17013
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
Richard H. Wix. JI.ttomey
4705 Duke street
HaIrisblrg. PA 17109
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 that you have an
opportunity to protect your interest, if any~eing notified of
said Sheriff's Sale. ~~~
By: ~_ .<
Leon P. Haller PA I.D.15700
Attorney for plaintiff
BANK ONE, NATIONAL ASSOCIATION,
AS TRUSTEE,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
VS.
SHEILA M. GROSS,
DEFENDANT
CIVIL ACTION - LAW
NO. 2003 571
IN MORTGl,GE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
WEDNESDAY, SEPTEMBER 3, 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:
57 WATERSIDE DRIVE
CARLISLE
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT in the amount
which your property is being
Commonwealth and County to:
of $67,285.92 under or pursuant to
sold is docketed in the within
NO. 2003 571
THE NAME(S} OF THE OWNER(S} OR REPUTED OWNERS of this property
is:
SHEILA M. GROSS
K:\MKFIDOCSICUMBERLAIGROSS,NOS
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) wil1 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 specifical1y 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 attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL those three tracts of land situate in Lower Frankford Township, Cumberland
County, pennsylvania. bounded and described as follows:
TRACT NO.1: BBGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et al; thence along the line of land of Paul R. Young, cro~ing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 mmutes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 75
degrees 39 minutes West. 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey thereofby Roger St. Germain & Associates, dated September 26, 1961.
TOGBTHER with a rigbt-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and, assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land of 1(. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGBTHER with a rigbt-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, pennsylvania, bounded and described as follows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same cowses, 35 feet, more or less, to the low water line of the Conodoguinet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 minutes
East 3S feet, more or less, to an iron pin; thence by the same land and the same course, crossing a
private road, 234,38 feet to an iron pin on the line of land of Russell L. Mackey, et &1; thence by
the latter land, through an iron pin in the center of said line, South 6S degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
thereofby Roger St. Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
Re: HC vs. GrosS
Cumberland 9/3/03
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
postage:
One piece of ordinary mail addressed to:
Sheila M. Gross
57 Waterside Drive
Carlisle, PA 17013
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:
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
Re: HC/GROSS
CUMBERLAND SALE 9/3/03
u. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In com liance with postal Service Form 3877
Received from:
purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
postage:
One piece of ordinary mail addressed to:
postmark:
Cynthia J. Naught
31 Bellaire Avenue
Carlisle, PA 17013
u. S. POSTAL SERVICE
CERTIFICATE OF MAILING
liance 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:
Richard H. Wix, Attorney
4705 Duke Street
Harrisburg, PA 17109
postmark:
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Bank One, National Association
As Trustee
VS
.$hedQ M, 6rbSS
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-571 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Leon Haller.
Sheriffs Costs:
Docketing
Poundage
Posting Handbills
Advertising
Mileage
Levy
Surcharge
Postpone Sale
Law Library
Prothonotary
Law Journal
Patriot News
Share of Bills
30.00
30.67
45.00
45.00
8.28
45.00
40,00
20.00
.50
1.00
716.45
543.34
28.90
$1564.14 paid by attorney
12/22/03
Sworn and subscribed to before me
.~-~<~
u;..
This ~ day of JJiH~
; R. Thomas Kline, Sheriff
2003, A.D. \4--- 0 'th"fb", ~ ' 0 - A I
BY J t) ~)(k.J.A.Y,
Prothonotary Real Est& Deputy
j.Jb
ck '!3:L'f9"
11--. 11/6'1"31
r
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 18,25,2003 AUGUST I, 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. III
-0.~
a Marie ~~or I
TO AND SUBSCRIBED before me this
day of AUGUST, 2003
Writ No. 2003-571 Civil
Bank One. National Association.
as Trustee
VS,
Sheila M. Gross
Atty,: Leon p, Haller
ALL those three tracts of land
situate in Lower Frankford Town-
ship, Cumberland County, Pennsyl-
vania, bounded and described as
follows:
'!RACf NO, I: BEGINNING at an
iron pin and stake at the corner of
land of Paul R. Young and Russell
L. Mackey. et al; thence along the
line of land of Paul R. Young. cross-
ing a private road and through an
iron pin on the sout.hern side there-
of. South 44 degrees 30 minutes
West 200 feet to an iron pin: thence
by the same land and the same
course, 35 feet, more or less. to the
low water line of the Conodoguinet
Creek: thence by the said low wa-
ter line, North 75 degrees 39 min-
utes West, 60 feet to a point on line
of land conveyed or about to be con-
veyed to Alverta M. Fry; thence by
the latter land, North 44 degrees
30 minutes East, 35 feet, more or
less, to an iron pin: thence by the
same land the same course, 211.29
feet, crossing a private road to an
iron pin on the line of land of Russell
L. Mackey, et al; thence by the lat-
ter land, South 65 degrees 18 min-
utes East, 55.14 feet to the Place
of BEGINNING said description be-
ing in' accordance with a'survey
thereof by Roger St. Germain &
Associates. dated September 26,
1961.
TOGETHER with a right-or-way
S
I
~-~/ xt7J1d~
Nar~ IJ
LOIS E. SNYDER. NlllaI'y PubUc
CeI1IsIe Floro. C~mt.f,~.arn:l Coorrty
, My Cor~ &;Jl11illlitla"d15. 2005
,
~"- Uu-"" ......~~, ~_ .
of land conveyed or abo~t to be con-
veyed to Alverta M. Fry; thence by
the latter land. North 44 degrees
30 minutes East, 35 feet, more or
less. to an iron pin: thence by the
same land the same course, 211.29
feet. crossing a private road to an
iron pin on the line of land of Russell
L. Mackey, ct al; thence by the Jat-
ter land. South 65 degrees 18 min-
utes East, 55.14 feet to the Place
of BEGINNING said description be-
ing in' accordance with a'survey
thereof by Roger St. Germain &
Associates. dated September 26.
1961.
TOGETHER wlth a rigbt-of-way
for the purpose of ingress and egress
over other lands of the Grantor
herein and other owners to the prop-
erty herein conveyed over a private
road from the public road leading
from Bergner's Bridge to Bloserville
in common with the Grantor. his
heirs and assigns.
SUBJECT to the aforesaid right-
of-way for ingress and egress in fa~
vor of the owner or owners. their
heirs and assigns. of the land to the
West hereof.
TRACT NO, 2: BEGINNING at a
stake at line of other land of K.
Swartz: thence by said land. South
44 degrees 30 minutes West. a dis-
tance of 225 feet more or less. to
the low water mark of the Conodo-
guinet Creek, thence by the same
up the Creek. North 52 degrees 15
minutes West. a distance of 51.5
feet to a point; thence along lands
of Chester Fry, North 44 degrees
30 minutes East a distance of 231
feet to a stake: thence by the same,
South 45 degrees 30 minutes East,
a distance of 50 feet to a stake. the
Place of BEGINNING, CONTAINING
0.27 acres, more or less.
TOGETHER with a right-or-way
for the purpose of ingress and egress
over other lands of the Grantor here-
in to the property herein conveyed.
over a private road from the public
road leading from Bergner's Bridge
to Bloserville in common with the
Grantor, his heirs and assigns, said
right-of-way to be approximately
1609 feet, more or less. Crom the
said public road.
TRACT NO, 3: ALL that certain
tract of land situate in Lower
Frankford Township, Cumberland
County, Pennsylvania. bounded and
described as follows:
BEGINNING at an Iron pin at the
comer of land of Chester L. Fry and
-.--" -
iron pin on the line of land of Russell
L. Mackey, et al; thence by the lat-
ter land, through an iron pin in the
center of said line, South 65 degrees
18 minutes East 110.28 feet to the
Place of BEGINNING: said descrip-
tion being in accordance with a SUf-
vey thereof by Roger St. Germain &
Associates, dated September 26.
1961.
TOGETHER wlth a right-of-way
fOf the purpose of ingress and
egress over other lands of the prior
Grantors herein and other owners
to the property conveyed over a pri-
vate road from the public road lead-
ing from Bergner's Bridge to Blos-
erviIle. in common with the prior
Grantors, their heirs and assigns.
SUBJECT to the aforesatd
right-oC-way for ingress and egress
in favor of the owner or owners,
their heirs and assigns. of the land
to the West hereof.
HAVING THEREON ERECTED A
DWELLING KNOWN AS 57 WATER-
SIDE DRIVE, CARLISLE, PA 17013,
BEING THE SAME PREMiSES
WHICH Lee E. Grove and Laura Mil-
ler Grove by deed dated 1/22/00
and recorded in Deed Book 238
Page 228 granted and conveyed unto
Sheila M. Gross.
TO BE SOLD AS THE PROPER-
lY OF SHEiLA M, GROSS ON JUDG-
MENT NO, 2003 571.
ASSESSMENT: 14-07-0475-004,
r
-~,"
r~' ul ll1e
~~..... V~ ~aId line. South 65 degrees
18 minutes East 110.28 feet to the
Place of BEGINNING: said descrip-
tion being in accordance with a sur-
vey thereof by Roger St. Germain &
Associates, dated September 26.
1961.
TOGETHER with a right-of-way
for the purpose of ingress and
egress over other lands of the prior
Grantors herein and other owners
to the property conveyed over a pri-
vate road from the public road lead-
ing from Bergner's Bridge to B105-
erviIle. in common with the prior
Grantors, their heirs and assigns,
SUBJECT to the aforesaid
right-of-way for ingress and egress
in favor of the owner or owners,
their heirs and assigns. of the land
to the West hereof.
HAVING TIiEREON ERECTED A
DWELLING KNOWN AS 57 WATER-
SIDE DRIVE, CARLISLE. PA 17013,
BEING THE SAME PREMISES
WHICH Lee E. Grove and Laura Mil-
ler Grove by deed dated 1/22/00
and recorded in Deed Book 238
Page 228 granted and conveyed unto
Shella M. Gross.
TO BE SOLD AS TIiE PROPER-
lY OF SHEILA M, GROSS ON JUDG-
MENT NO. 2003 57!.
ASSESSMENT: 14-07-0475-004,
\
\
,
r
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~
Sunday Patriot-News newspapers of general circuiation, printed and pubiished at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were estabiished March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is secureiy attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th
day{s) of August 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
5 ALE #51
.. .,....fJ.~.7.;._~.,.".,.,..,..,.,.
Sworn to bscribed before~e ' 13th day of 3 A.D.
TerryL=~=.vMC Ul4 ~.P-(
CIty Of Hanisburg, Dauphin County NOTA Y PU BLI C
My Commission El<piresJ""'S,2006, My commission expires June 6, 2006
_, Pennsylvania Association Of_
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA, 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr,
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
541.59
1.75
543,34
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.,.,..".................,.......,.......,.,........................
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
CIVIL ACTION LAW
SHEILA M, GROSS,
NO, 03-571 CIVIL
DEFENDANT(S)
MORTGAGE FORECLOSURE
BANKRuPrcY DISMISSAL
UIrED STATES BANKRUPTCY colT
MIDDLE DISTRICT OF PENNSYLVANIA
INRE:
Sheila Mary Gross
CASE NO.: ]-03-04604
CHAPTER 13
Debtor(s)
ORDER DISMISSING CA~E
,tI''\'
NOW, thi~YOfMarch, 2004,
Upon consideration of Trustee's Motion to Dismiss (and hearing if appropriate), and it
having been determined that this case should be dismissed. it is
ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and
it is further
ORDERED that the trustee hereby is discharged from further responsibility in this case, and
it is further
ORDERED that all pending adversary proceedings in this case be and they hereby are
dismissed, and it is further
ORDERED that any outstanding fees are immediately due and payable to the U.S.
Bankruptcy Court.
HARRISBURG, PENNSYL VANIA
COURT:
~
CY JUDGE ,""-
. ,0
,
B
FllED
HARRISBURG
PA
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, .... ..(...
crC'l~, IJ,. ~a;~
\ ,/ \ ;!,. ; ,.'
074585
'--
IN THE COlJRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DlVISION - LAW AT NO, 03-571 CIVIL
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
DEFENDANT(S)
Total Judgment Amount
Interest
Per diem of $ 1 9,56 to sale
date 9/8/2004
Late Charges
$30,97 per month to sale
date 9/8/2004
Escrow Deficit
$67,285,92
$10,363.23
VS,
$526.49
SHEILA M, GROSS,
$2,000,00
TOTAL WRIT $80,175.64
*Plus additional interest, latc charges and other costs
to date of sheriff's sale.
SALE DA TE: Wednesday. September 08. 2004
(PROTHONOTARY'S USE)
Pltf Paid
Deft. Paid
Due Proth/Clerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue Writ of Execution m the above captioned case,
Date: June 7. 2004
Attorney for Plaintdf
1719 North Front Street
Harrisburg, PA ] 7102
(7 17) 234-417R
WRIT OF EXECUTION - MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satIsfy the Judgment, interest and costs in the above captioned case, you are directed to levy upon and
sell the property descrIbed in the attached description known as 57 WATERSIDE DRIVE CARLISLE,
PENNSYLVANIA 17013
Date:
PROTHONOTARY/CLERK CIVIL DIVISION
BY
DEPUTY
...L-"
(,
ALL those three tracts of land situate in Lower Frankford ToWll$hip, Cumberland
County, pennsylvania, bounded and descn"bed as follows:
TRACT NO. 1; BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et al; thence along the line of land .of Paul R. Young, crossing a
private road and through an iron pin on the southern side thereo~ South 44 degrees 30 minutes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 3S feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey. et al; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey thercofby Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-<Jf-way for the pwpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land of 1(. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water D18rll: of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees IS
minutes West, a distance of SI.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 4S degrees
30 minutes East, a distance of SO feet to a stake, the Place of BEGlNNlNG. CONTAINING
0,27 acres, more or less.
TOGETHER with a right-<Jf-way for the puzpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
;TRACT NO.3.. ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at an iron pin at the corner of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a
private road. South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same courses, 35 feet, more or less, to the low water line of the Conodoguinet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 minutes
East 3S feet. more or less, to an iron pin; thence by the same land and the same course, crossing a
private road, 234.38 feet to an iron pin on the line of land of Russell L. Mackey, et al; thence by
the latter land, through an iron pm in the center of said line, South 6S degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
thereof by Roger St. Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571,
ASSESSMENT: 14-07-0475-004
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK ONE NA TlNAL ASSOCIATION, TRUSTEE
N003-571 Civil
CIVIL ACTION - LAW
Plaintiff(s)
From SHEILA M, GROSS, 57 WATERSIDE DRIVE, CARLISLE P A 17013.
(I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 57 WATERSIDE DRIVE, CARLISLE PA 17013 (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) Ifproperty 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 himlher that helshe has been added as a
garnishee and is enjoined as above stated,
Amount Due $67,285.92
L.L.
Interest PER DIEM OF $19.56 TO 9/8/04 = $10,363.23
Atty's Corom % Due prothy $1.00
Atty Paid $1,707.09 Other CostsLATE CHJARGES OF $30.97 PER
MONTH TO 9/8/04 = $526.49: ESCROW DEFICIT = $2,000.00
Plaintiff Paid
Date: JUNE 9, 2004
(Seal)
CURTIS R. LONG
~;"J~ ~/1~ 0
REQUESTING PARTY:
Name LEON P. HALLER, ESQ.
Address: 1709 N. FRONT ST.
HARRISBURG PA 17102
Attorney for: PLAINTIFF
Telephone: (717) 234-4178
Supreme Court ill No, 15700
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
VS
CIVIL ACTION LAW
NO. 03-571 CIVIL
SHEILA M. GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
AFFIDA VlT PURSUANT TO RULE 3129.1
The Plaintiff in the above action. by its attorneys. Purcell. Krug & Haller, sets forth as of the date
the praecipe fot" the writ of exeClltion was filed, the following information concerning the real property
located at 57 WATERSIDE DRIVE CARLISLE, PENNSYL VANIA 17013:
I, Name and address of the Owner(s) or Reputed Owner(s):
SHEILA M, GROSS
57 W A TERSlDE DRIVE
CARLlSLE. PA 17013
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 is a record lien on the
real property to be sold:
Cynthia Naught
31 Bellaire Avenue
Clrlisle, P A J 7013
Richard Wix, Esquire
4705 Duke Street
Harrisburg. PAl 7 [09
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 person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Tenants if any, ,
DOMESTIC RELA nONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle. P A J 70 13
Dorothy L. Mott. Esquire
125 State Street
Harrisburg.PA 17101
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated.)
I vcrify that the statements made in this Affidavit are true and correct to the bes my personal
knowledgc. information and belief. [ understand that false statements herein are e subject to the
penalties of 18 PA C.S, Scction 4904 relating to unsworn falsification to auth e
Leon P. HallerPA LD, #15700
Purcell. Krug & Haller
1719 North Front Street
Harrisburg, PAl 7102
(717) 234-4178
DATE:June 7. 2004
BANK ONE. NATIONAL ASSOCIATION. TRUSTEE.
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYL VANIA
VS.
CIVIL ACTION LAW
NO. 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 08, 2004
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 ofthe 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:
57 WATERSIDE DRIVE
CARLISLE, PENNSYL VANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
wi thin Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
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.
InfoDnatioll 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 Libel1y A venue
Carlisle. PenllSylvania 17013
717-249-3 I 66
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 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 Com1 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 COImnon 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 Com1 of Common Pleas of the within County, The petition must be served on
the attomey 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 Com1house. before a presentation of the petition to the
Com1,
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, P A 17102
(717) 234-4178
ALL those three tracts of land situate in Lower Frankford Township, Cumberland
County, Pennsylvania, bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et al; thence along the line of land of Paul R. Young, crossing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 minutes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 75
degrees 39 minutes West, 60 feet to a point OD line of land conveyed or about to be coDveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minnt..s East, 35 feet, more or
less, to an iron pin; thence by the same land the same cow:se, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey thereof by Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the pwpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land of K. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the pwpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloservi1le in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Franlcford Township,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same courses, 35 feet, more or less, to the low water line of the Conodoguinet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 minutes
East 35 feet, more or less, to an iron pin; thence by the same land and the same course, crossing a
private road, 234.38 feet to an iron pin on the line of land of Russell L. Mackey, et al; thence by
the latter land, through an iron pin in the center of said line, South 65 degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
thereofby Roger St Germain & Associates, dated September 26, 1961.
TOGBTHER with a right-of-way for the pwpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to BIoserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
, ,
'.-,-J
\._-'
",--.,
c
BANK O]\;E, "'ATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION LAW
NO, 03-571 CIVIL
SHEILA M GROSS,
DEFENDANT
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHJl'o.:
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
Dcfendant (s) above namcd 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
before me this ~~,y
or9{t"-C - 2<Y' Y
~~U.(i;/f/~id/-
MARYLAND~~~~~~~ SEAL
Lower Paxton Twp rr, Notary Public
My CommiSSIon ,. "I auphln County
~xp res Aug, 8, 2006
-!j
I'.,
~
REAL ESTATE SALE No. 51
Writ No. 2003-571
Civil Term
Bank One, National
Alec.letlon,
AI TrUltee
VI
Shelll M. Grosl
Atty.: Leon P. HIller
DESCRIPTION
AU. those three tracts of land situate in Lower
Frankford Township, Cumberland County,
Pennsylvania. bounded and described as follows:
TRACI' NO. I: BEGtNNING at an iron pin and
stake at the corner of !and of Paul R. Young and
Russell L. Mackey. et al; thence along the line of
land of Paw R. Young, crossing a private road and ,
.tbrou~anironpinonthesouthernsidethereof,
South 44 degrees 30 minutes West 200 feet to an
iron pin; thence by the same land- and the same
course, 35 feet,more or less, to the low water line
of the Conodoguinet Creek; thence by the said
low-water line, North 75 degrees 39 minutes West,
60 feet to a point on line of land conveyed or
about to be conveyed to Alverta M. Fry; thence by
the latter land, North 44 degrees 30 minutes, East,
35 feet, more or less, to an iron pin; thence by the
..same land the &aIDe course, 211.29 feet, crossing a
private road to an iron pinon the line of land of
Russell L. Mackey, et al; thence by the latter land,
South 65 degrees 18 minutes East, 55.14 feet to
the Place of BEGINNING said description being
in accordance with a survey thereof by RogerSt.
Germain & Associates, dated September 2~
1961.
TOGETHER with a right-of-way for the purpose
of ingress and egress over other lands of the
Grantor herein and other owners to 'the property
herein conveyed over a private road from the
public road leading from Bergner's Bridge to
Bloserville in common with the Grantor, his heirs
and assigns.
SUBJECT to the a:"oresaid right-of-way for
ingress--and egress in favor of -the owner or
owners, their heirs and assigns, of the land to the
West hereof.
TRACT NO.2: BEGINNING at a stake at line
of other land of K. Swartz; thence by said land,
South 44 degree 30 minutes West, a distance of
225 feet, more or less, to the low water mark of
the Conodoguinet Creek; thence by the same up
the Creek, North 52 degrees 15 minutes West, a
distance of51.5 feet to a point; thence along lands
of Chester Fry, North 44 degrees 30 minutes East,
a distance of 231 feet to astake;thenceby~
same, South 45 degrees 30 minutes East,,'1.
dimnce of 50 feet to - a stake, the Place {)f
BEGINNING, CONTAINING 0,27 acres. more
or1ess. '
TOGETHER with a right-of-way for the pu1'pQIIe
of ingress and egress over other lands of \be
Grantor herein to the property herein conveyed,
over a private road from the public road leading
from Bergner's Bridge to Bloserville in commoo
with the Grantor, his heirs and assigns, said ripl-
of-way to be approximately 1609 feet. more ot ;
less, from the said public road.
TRACT NO, 3: ALL that certain tract of I_
situate in Lower o.Frankford Township,
Cumberland County, Pennsylvania, bounded JDd
described as follows: ."
BEGINNING at an ircn pin at the comer of land
of Chester L. Fry and wife and Russell L.
Mackey, et al; thence along the line of 1ai1d
afOJ<S8id of Chester L, Fry and wif. ero....
, road. South 44 degrees 30 minutes ,.
~feetlDanironpin;thencebythel
.illdthe_counes,l$feet.-or .'.
. lie low ....Iine of the ConodoIui'" .'
lbatce by the said low water line, No: .'
degrees 39 minutes West, 120 feet to the' ..
t.l of Brinton F. Forney and wife; thence by !he
latter land, North 44 degrees 30 minutes, East.' 35
feet, more or less, to an iron PlD; thence by Ihe
same land and the same course, crossing a pr\vate
road,234,38 feet to an iron pin on the line of land
of Russell L Mackey, et at; thence by the tiii
land, through an iron pin in the center of said tine;,
South 65 degrees 18 minutes East, 110.28 feet to
the Place of BEGINNING; said description beipg
in accordance with a survey thereof by Roger St
Gennain & Associ,ates, dated September 26,
1961.
TOGETIIER with a right-of-way for the puijlose
ofingressandegressoverotherlandsof~prior
Grantors herein and other owners to the p~
conveyed ovet a private. road from the pub~_~IOIId'
leading from Bergner',<, Bridge to BloseI'VlUQ, in
common with the pri(~ Grantors, their heifland
assigns.
SUBJECT ID the aforesaid right-of-way' for
ingress and egress i~ favor of the owoeJ::, or
owners, their heirs and assigns, of the land, tp ~
West hereof.
HAVING thereon erected a dwelling knQwn 118
57 Waterside Drive, Carlisle, PA 1701l
BEING the same premises which Lee & Grove
and Laura Miller Grove by deed dated ItZVOO
and recorded in Deed Book 238 Page 228 pmed
and conveyed unto Steila M. Gross. ' , '
TO BE SOLD as the property of Stella lot""'"
on Judgment No. 2003-571.
ASSESSMENT: 14-07-0475.004,
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE.
PLAiNTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
\IS.
CIVIL ACTION LAW
NO. 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby ~ertifY that I have deposited in the U,S, Mails at Harrisburg, Pennsylvania on
1- (~- 0 . a 1rue and correct copy of the Notice of Sale of Real Estate pursuant to P A
R,C.P, 3129, I to the Defendants herein and all lienholders of record by regular first class mail
(Celiificate of Mailing form in compliance with U,S, Postal Form 3817 is attached hereto as evidence),
and also to the Defendants by Celiified Mail, which mailing receipts are attached, Service addresses are
as follows:
SHEILA M, GROSS
57 WATERSIDE DRIVE
CARLISLE, PAl 7013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Cynthia Naught
3 I Bellaire A vcnue
Carlisle, P A 17013
Richard Wix. Esquire
4705 Duke Street
HalTisburg. PAl 7\ 09
Dorothy L. Mott. Esquire
125 State Street
Harrisburg. PAl 71 0 I
B~
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, P A 171 02
(717) 234-4178
LAW OFFICES
I-IO\VAIW B KRll(j
I.EON p, IIALLER
JOliN \V PURCELL m
IIlL M W1NKA
IlRli\:'\ 1 1"\'l..[I,-
:'-II( 'IIOLE ~1_ :'-lTi\U:'t" (r( i(lIUvl.\N
P?~ ~ fJ" Yt~
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TelEPHONE (717) 2J4-417R
FAX (717)234-1206
HERSHEY
(717)533-3S)()
JOSEPH NISSLEY (I910-1'}82)
JOHN W. PURCELL
VALERIE A. (iUNNOF
COUNSEL
SHEILA M, GROSS
57 W A TERSlDE DRIVE
CARLlSLE. PA 17013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanovcr Street
Carlisle. PAl 7013
Cynthia Naught
3 I Bellaire Avenue
Carlisle, P A 170 I 3
Richard Wix. Esquirc
4705 Duke Street
Harrisburg. P A 17 I 09
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, P A 171 01
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or Illore 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 Comlllon PIcas of'the within county on the judgment of the Plaintiff named herein the said real estate
will be exposcd 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 that you have an opportunity to protect your interest. if any. by being notified of
said Sheriffs Sale,
~
Leon p, Haller PA LD, 15700
Attorney for Plaintiff
BANK ONE. NATIONAL ASSOCIATION. TRUSTEE.
PLA1NTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
VS,
C1VIL ACTION LAW
SHEIL^:vI, GROSS.
NO. 03-571 CIVIL
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 08, 2004
TIME:
10:00 O'clock A.M,
LOC A TION: 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 LOCA nON of your property to be sold is:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 03-57l CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
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
disburscd by thc Sheriff (for example, to banks that hold mOlrtgages and municipalities that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of
thc proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by
filing cxceptions to it within ten (10) days of the date it is filed,
Infonnation 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 Illay have legal rights to prevent your property from being taken away, A lawyer can advise
YOll more specifically of thesc 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 Libeliy Avcnue
Carlisle, Pennsylvania 17013
717-249-3166
Lcgal Serviccs. Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
I, 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 thc Sheriffs 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 thc COUli of Common Pleas of the within County, The petition must be served on
the attorney for the crcditor or on the creditor before presentation to the court and a proposed order or
ru1c must be attached to the petition,
If a spccific 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,
PURCELL. KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg. P A ] 71 02
(717) 234-4178
ALL those three tracts of land situate in Lower lprankford Township, Cumberland
County, Pennsylvania, bounded and descn"bed as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et al; thence along the line of land of Paul R. Young, crossing a
private road and through an iron pin on the southern side thl:reot; South 44 degrees 30 minutes
West 200 feet to an iron pin; thence by the same land and the, same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by' the said low water line, North 75
degrees 39 minutes West, 60 feet to a point on line of land (:l)nveyed or about to be conveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, more or
less, to an iron pin; thence by the same land the same comse, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et al;; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey thereofby Roger St. Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other owners to the property hereiIl conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress lIIld egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land of K. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of irlgre5S and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, lrom the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, Pennsylvania, bounded and described as lbllows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same courses, 35 feet, more or less, to the 10", water line of the Conodoguinet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter hand, North 44 degrees 30 minutes
East 35 feet, more or less. to an iron pin; thence by the same land and the same course. crossing a
private road, 234.38 feet to an iron pin on the line of land ofRtlSSell L. Mackey. et 81; thence by
the latter land, through an iron pin in the center of said line, SC)uth 65 degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
thereof by Roger St. Germain & Associates, dated September 26" 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property COllveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and I~gress in fiwor of the owner or
owners. their heirs and assigns, of the land to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
HOMECOMINGS FINANCIAL NETWORK v. SHEILA M, GROSS
Cumberland County Sale 9/8/2004
1I. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
PurcelL Krng & Halkr
1719 North Front Street
Harrisburg, P/\ 1710:2
Postage:
One piece of ordinary 111<lil addressed to:
SHEILA M, GROSS
57 WATERSIDE DRIVE
CARLISLE, P A 170 lJ
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell. Krug & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One pIece of ordinary mail addressed to:
Cynthia Naught
31 Bellaire Avenue
Carlis1c. PAl 7013
Postmark:
2!!1J4 }
//.
li. S. POSTAL SERVICE
CERTIfiCATE OF MAILING
(In compliance with Postal Service Form 3877)
Received hom:
PnrceIt. Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland COUllty Courthollse
13 :"Jorth Hanover Street
Carlisle, P A 171) lJ
Postmark:
~~POsl-~
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" ~2 1A $ 00.900
" . 0004338181 JUL 14 2004
MAILED FROM ZIP CODE 111 02
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received hom:
Purcell. Krug & Haller
1719 North Front Street
Harrisburg. PA 17102
Postage:
One piece of ordinary mail addressed to:
Richard Wix, Esquire
4705 Duke Street
Harrisburg. PAl 7109
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received hom:
PurcelL Krug & Haller
1719 North Front Street
Harrisburg, P ^ 171 02
Postage:
One piece of ordinary mail nddn.:'ssed to:
Dorothy L. Molt, Esquire
125 State Street
Harrisburg. PAl 71 0 I
Postmark:
!Il[1J
II
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$ 00.900
0004338187 JUL 14 2004
MAILED FROM ZIP CODE 17102
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Bank One, National Association, Trustee
VS
Sheila M. Gross
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-571 Civil Term
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on June 22, 2004 at 6;41 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit; Sheila M. Gross, by making known unto Sheila Gross,
personally, at 57 Waterside Drive, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that on
July 14,2004 at 3:18 o'clock P.M" he posted a true copy of the within Real Estate Writ,
Notice, Poster and Description, in the above entitled action, upon the property of Sheila
M, Gross located at 57 Waterside Drive, Carlisle, 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 the within named
defendant, to wit: Sheila M. Gross, by regular mail to her last known address of 57
Waterside Drive, Carlisle, PA 17013, This letter was mailed under the date of July 13,
2004 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per instruction from Attorney Leon Haller.
Sheriff's Costs;
Docketing
Posting Bills
Advertising
Law Library
Prothonotary
Mileage
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Poundage
30,00
45.00
45,00
1.00
7.15
45,00
40,00
697.85
578,65
30.49
30.40
$1,550.54
Sworn and subscribed to before me
So Answ~Js: . f """"
~~"'.. .~-/..;:z
- ~~.~ ~
This JLday of ~ ~..",- /--~
~ .' . 1 ~ R. Thomas Kline, Sheriff
2004, AD. . <<--V Q. ~ ~ I
ro onotary BY VO~ S riu:1::.h
Real Estat Deputy
\.
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irl)v }?>\
Vb '!,'l
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~{;,u
BANK ONE. NATJONALASSOCIATION, TRUSTEE,
PLAI}lTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYL VANIA
VS
CIVIL ACTION LAW
00
~
NO, 03-571 CIVIL
SHEILA M, GROSS.
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of he date
the praecipe for the writ of execution was filed. the following information concerning the real pr perty
located at 57 WATERSIDE DRIVE CARLISLE, PENNSYLVANIA 17013:
J, Name Jnd address of the Owner(s) or Reputed Owner(s):
SHEILA M, GROSS
57 WATERSIDE DRIVE
CARLISLE. P A 17013
2, Name and address of Defendant(s) in the Judgment, if different from that listed, i (1)
above: SAME
3, Name and address of every judgment creditor whose judgment is a record lien 0 the
real property to be sold:
Cynthia Naught
31 Bellaire Avenue
Carlisle. PA 17013
Richard Wix. Esquire
4705 Duke Street
Hanisburg. PA 17109
4. Name and address ofJast recorded holder of every mortgage ofrecord:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
5. Name and address of every other person who has any record lien on the propert
UNKNOWN
6. Name and address of every other person who has any record Interest in the pr ertyand
whose interest may be affected by the sale: UNKNOWN
"
BANK ONE, NATIONAL ASSOCIATION. TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PEN'NSYLV NIA
VS.
CIVIL ACTION LAW
NO. 03-571 CIVIL
SHEILA M GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 08, 2004
nME:
10:00 O'clock AM,
LOCATION: Cumberland County Courthouse
Carlisle, PelU1sy]vania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly onslstmg
of a statement of the measured boundalies of the property. together with a brief mention of the buildings
and any other major improvements erected on the land, (SEE DESCRIPTION ATTACHED)
THE LOCA nON of your propeliy to be sold is:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT lU1der or pursuant to which your propeliy is being sold is docketed n the
within Commonwealth and County to:
No. 03-57] CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
.'
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or gov unental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale receiv d and to be
disbursed by the Sheriff ([ot- example, to banks that hold mortgages and municipalit es that are
owed taxes) will be filed by the Sherif[ of this County thirty (30) days after the sale and di tribution of
the proceeds of sale in accordance with this schedule will. in fact. be made unless someon objects by
filing exceptions to it within ten (10) days of the date it is filed,
InfoTI11ation about the Schedule of Distribution may be obtained from the Sheriff of e 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 F 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 TAKE TO PAY
THE JUDGMENT
You may have legal rights to prevent your property from being taken away, A lawyer 3n advise
you more specifically of these rights, If you wish to exercise your rights, YOU M ST ACT
PROMPTLY.
,>
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. GO T OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU C N GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Libel1y Avenue
Carlisle, PenllSylvania 17013
717-249-3166
Legal Services. Inc
8 Irvine Row
Carlisle. Pennsylvania 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 t 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 ofa legal de ect in the
obligation or the procedure used against you,
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of 1e within
County to set aside the sale for a grossly inadequate price or for other proper cause, Thi 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 p agraphs
must be presented to the Court of Common Pleas of the within County, The petition mnst be erved on
the attomey 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 Admil 'strator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petiti 1 to the
Court.
PURCELL. KRUG & HALLER
Attomeys for Plaintiff
1719 North Front Street
Halrisburg, P A 17102
(717) 234-4178
,
,
ALL those three tracts of land situate in Lower Frankford Township,
County, Pennsylvania, bounded and descn"bed as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of wI R.
Young and Russell L. Mackey, et al; thence along the line of land of Paul R. Young, c ssing a
private road and through an iron pin on the southern side thereo~ South 44 degrees 30 . utes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more riess,
to the low water line of the Conodoguinet Creek; thence by the said low water line, N rth 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conv yed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, ore or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a priva road
to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, So th 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description be g in
accordance with a survey thereof by Roger St. Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private ro from
the public road leading from Bergner's Bridge to Bloserville in common with the Grant . his
heiIs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the own
owners, their heiIs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land of K. Swartz; thence y
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the 1
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees
minutes West, a distance of S1.5 feet to a point; thence along lands of Chester FlY, North
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 4S de
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAlNIN
0.27 acres, more or less.
TOGETHER with a right-of-way for the pwpose of ingress and egress over other land
of the Grantor herein to the property herein conveyed, over a private road from the public ro
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heiIs and assigns
said right-of-way to he approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cwnberland County, Pennsylvania, bounded and descn"bed as follows:
BEGINNING at an iron pin at the comer of land of Chester L. FlY and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. FlY and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same courses, 35 feet, more or less, to the low water line of the Conodogninet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 minutes
..
,
East 35 feet, more or less, to an iron pin; thence by the same land and the same course, cro ing a
private road, 234.38 feet to an iron pin on the line of land of Russell L. Mackey, et al; th by
the latter land, through an iron pin in the center of said line, South 65 degrees 18 minute East
110.28 feet to the Place of BEGINNING; said description being in accordance with a ey
thereofby Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the pUlJlose of ingress and egress over other
of the prior Grantors herein and other owners to the property conveyed over a private road m
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grant rs,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the own or
owners, their heirs and assigns, of the land to the West hereof.
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRI E,
CARLISLE, PA 17D13.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Gr ve
by deed dated 1/22/00 and recorded in Deed Book 238 Page 28
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N003.571 Civil
CIVIL ACTION - LA
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt. interest and costs due BANK ONE NATINAL ASSOCIATION, TRUSTEE
PlaintIff(s)
From SHEILA M. GROSS, 57 WATERSIDE DRIVE, CARLISLE PA 17013.
(I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTA TE
LOCATED AT 57 WATERSIDE DRIVE, CARLISLE PA 17013 (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 fro
paying any debt to or for the account of the defendant (s) and from delivering any property of the defenda
(s) or otherwise disposing thereof;
(3) If property oftbe 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 himlher that helshe has been added as a
garnishee and is enjoined as above stated,
Amount Due $67,285.92
LL.
Interest PER DIEM OF $19.56 TO 918104 = $10,363.23
Atty's Comm % Due Prothy $1.00
Atty Paid $1,707.09 Other CostsLATE CHJARGES OF $30.97 PER
MONTH TO 918/04 = $526.49: ESCROW DEFICIT = $2,000.00
Plaintiff Paid
Date: JUNE 9, 2004
(Seal)
'].tary
By: \ ~
CURTIS R. LONG
JJ Btt.')1;'
Deputy ,
REQUESTING PARTY:
Name LEON P. HALLER, ESQ.
Address: 1709 N. FRONT ST.
HARRISBURG PA 17102
Attorney for: PLAINTIFF
Telephone: (717) 234-4178
Supreme Court ID No, 15700
Real Estate Sale #52
On June 16, 2004 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Frankford Township, Cumberland County, P A
Known and numbered as 57 Waterside Drive,
Carlisle, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 16, 2004
By: Jr-A, ~\N\" t-1.1
Real E~t;~p;;V
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REAL ESTATE SALE NO. 52
Writ No, 2003-571 Civil
Bank One. National
Association, Trustee
vs.
Sheila M. Gross
Atty,: Leon Haller
ALL those three tracts of land
situate in Lower Frankford Town~
ship. Cumberland County, Pennsyl.
vania, bounded and described as
follows:
TRACT NO.1: BEGINNING at an
iron pin and stake at the corner of
land of Paul R. Young and Russell
L. Mackey, et al; thence along the
line of land of Paul R. Young, cross.
ing a private road and through an
iron pin on the southern side
thereof, South 44 degrees 30 min-
utes West 200 feet to an iron pin;
thence by the same land and the
same course, 35 feet, more or less.
to the low water line of the Cono-
doguinet Creek: thence by the said
low water line, North 75 degrees 39
minutes West, 60 feet to a point on
line ofland conveyed or about to be
conveyed to Alverta M. Fry: thence
by the latter land. North 44 degrees
30 minutes East, 35 feet. more or
less, to an iron pin; thence by the
same land the same course, 211.29
feet. crossing a private road to an
iron pin on the line of land of Russell
L. Mackey, et a1; thence by the lat~
ter land, South 65 degrees 18 m1n~
utes East, 55.14 feet to the Place
of BEGINNING said descrJption be~
iag in accordance with a survey
thereof by Roger St,Germain &
Associates, dated September 26,
1961.
~
TOGETHER with a right-of-way
for the purpose of ingress and
egress over other lands of the
Grantor herein and other owners to
the property herein conveyed over
a private road from the publiC road
leading from Bergner's Bridge to
Bloserville in common with the
Grantor, his heirs and assigns.
SUBJECT to the aforesaid rJght-
of-'WaY for ingress and egress in fa-
vor of the owner or owners, their
heirs and assigns, of the land to the
West hereof.
TRACT NO, 2: BEGINNING at a
stake at line of other land of K.
Swartz; thence by said land, South
44 degrees 30 minutes West, a dis#
-tance of 225 feet, more or less, to
the low water mark of the Conodo~
guinet Creek; thence by the same
up the Creek, North 52 degrees 15
minutes West, a distance of 51.5
feet to a point; thence along lands
of Chester Fry, North 44 degrees
30 minutes East, a distance of 231
feet to a stake; thence by the same,
South 45 degrees 30 minutes East,
a distance of 50 feet to a stake, the
Place of BEGINNING, CONTAINING
0.21 acres, more or less.
TOGETHER with a right-of-way
for tin to the property herein con-
veyed, over a private road from the
public road leading from Bergner's
Bridge to Bloserville in common with
the Grantor, his heirs and assigns,
said right.of-way to be approximately
1609 feet, more or less, from the
said public road.
TRACT NO, 3: ALL that certain
tract of land situate in Lower
Frankford Township, Cumberland
County, Pennsylvania, bounded and
described as follows:
BEGINNING at an iron pin at the
comer of land of Chester L. Fry and
wife and Russell L. Mackey. et a1:
thence along the Hne of land afore-
said of Chester L. Fry and wife,
crossing a private road. South 44
deg:r~es 30 minutes West 211.29
feet to an iron pi ; thence bY -the
same land and same courses,
35 feet, more or ess, to the low
water line of th Conodoguinet
Creek; thence by e said Jow wa.
ter line, North 75 egrees 39 mJn-
utes West 120 fe t to the line to
land of Brinton F. orney and wife:
thence by the latte land, North 44
degrees 30 minut 5 East 35 feet,
more or less, to an ran pin; thence
by the same land and the same
course, crossing private road,
234.38 feet to an ron pin on the
line of land of Rus 11 L. Mackey, et
81; thence by the lat r land, through
an iron pin in the c ier of said line,
South 65 degrees 1 minutes East
110.28 feet to the lace of BEGIN-
NING; said descrip n being in ac-
cordance with a s ey thereof by
Roger St. Germain & Associates,
dated September 2 , 1961.
TOGETHER wi a right-of-way
for the purpose 0 ingress and
egress over other 1 ds of the prior
Grantors herein an other owners
to the property cony ed over a pri-
vate road from the p bUc road lead-
ing from Bergne 's Bridge to
BJoserviIle, in co on with the
prior Grantors, thei heirs and as-
signs.
SUBJECT to the
of~way for ingress
var of the owner or 0
and assigns, of the 1
hereof.
HAVING THEREO
dwelling known as
Drive, Carlisle. PA 1
BEING THE SAM
WHICH Lee E. Gro
Miller Grove by dee
00 and recorded in
Page 228 granted and
Sheila M. Gross,
TO BE SOLD AS e property of
Sheila M. Gross on udgment No,
2003 571.
ASSESSMENT: 14- 7-0475-004,
oresaid rtght-
egress in fa-
ers, their heirs
d to the West
ERECTED a
7 Waterside
013.
PREMlSEES
e and Laura
dated 1/22/
ed Book 238
onveyed unto
.
REAL ESTATE SALE No. 52
Writ No. 2003-571
Civil Term .
Bank One, National Association,
Tl'Uatse
Vs
Sheila M. GI'088
Atty: Leon Hsller
DESCRIPTION
TOGlITIIBR with'. rlgbt-<>f-way for the
purpose <Jf ill8leS' and egress over other lands of
the GrantDr herein to the property herein
conveyed, over a private road from the public road
leading from Bertner', Bridge to B10Ber-rille. in
col!ll!lon with the Grantor, his heirs and assigns.
said righl-<>I-way to be approxilnlllely 1.6091eet,
more or Iess, from the said public ",ad
TRACT NO, r. ALL that cer-tain t!llct of
land ,iltJllle in Lower. Frank/onl Township,
Cumberland County. Penn'ylvania, bounded and
descrit./d as follows: .
BEGINNING at an iron pin at the comer of
tand of Che,ter L, Fry and wile and Ru,sell L,
Mackey, el aI;. thence along lbe lin< 01 land
af~resaid 01 Chesrer L PI)' and wife, cros,ing a.
private road, South 44 degrees 30 minute, West
211.29 1m to an iron pin; then>eby the same
land and the ,amecoUrses, 35 feet, more or I,,~
. to the low WaIer lin< <Jf the Conodoguinet Creek;
~'by.the,aidlclWWal.(line, Nortll 75
degrea.39mimlte!Westl20 tw blthe lin< to
'. '1al1d "tBrlntottP.ForneyalJdlVi1e:.~ by Ill.
1~lind,Noitll44 de&rees 3D ml_ East 35
" lee, more or I,,~ 10 an iron pin; thence by the
, _Ilmd and the ,ame ce..... """,ing . privallo
, .1OOd, 23438 1m to an iron pin on the lin< 01 land
of Russell L, Mackey. et aI; thence by the l.tter
land. throu$b an iron pin in the center 01 said line.
South 65 degree, 18 minulea East 110,28 leet to
the Place 01 BEGINNINO; ,aid description being
in tlCConI-ance with . survey thereol by Roger SI.
Germain & Associates. dated September 26,
1961.
TOGETHER with . rigbt-oI-w,y for the
purpose of ingress and egress over other lands 01
, the prior Grantors herein and other owners 10 the
, property cenveyed over a private road from the
i public road leading from B"'Wler', Bridge to
: Bloserville. in common wIth the priOr Grantors,
: their heln and assigns,
SUBmcr to the aforesaid right-<>f-way for
ingress and egres'. in favor 01 the owner or
, owners, their beln an. as'igns. of the land to the
. West bereol. .
HAVING thereon erected a dwelling known
.. 57Wa",tslde Drive, Carlisle, PA 17013,
BEING the 'ame preml", wbich Lee E,
Grove and Laura 'Miller Grove by deed dated II
22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M, Gross,
TO BE SOlD .. the property of Sbeila M,
Gross on ludgment No, 2003 57L
ASSESSMENT: 14-07-0475-004,
. ALL tho" th!re ttactB of land situate in
Lower Frankford'lbwn-ship, Cumberland County,
PetlllSyl-vania, bounded and described as follows:
TRACT NO, 1: BEGINNING at an Iron pin
and ,take ,t the cerner <Jf land of Paul R. Young
and Ru,,,ll L Mackey. et aI; thence along the line
of land of Paul R, Young. cro,sing . private road
and through an Iron pin on the soutbem Side
thereof, South 44 degree. 30 minutes West 200
leet to an Iron pin; thence by the same land and
the ,,,,.; course. 35 fee~ more or less, to the low
wal<T lin< of the Cotrodoguinet Creek; thence by
the said low ~ line, North 75 degree. 39
minures West, 60 feet. to a point on lin< of tand
conveyed or about to be conveyed to Alverta M.
PI)'; thence by the lalte! land, North 44 depees 30
minute' Bast, 3S feet, mOle or les,. to an !rOll pm;
thence by the same land the same,~ 211.29
fee~ crossing . private road.to an lroIl pin on the
lin< of land 01 R_ll L, Mackey, et aI: thence hy
the latter land, South 6S degrees 18 mlnures East,
S5.141eet to the FIace o111EGINNING said de-
_scription being in accordance with . 'urvey
thereof by Roger St. Gel.main & Associ,"",
dated Sep-tember 26, 1961.
TOGEI1lER with , right-<>f-WlIY for the
purpose of ingres' and egress over other land, of
the Grantor herein and other owners to the
property herein conveyed over . pri",\, ",ad from
the public road leading from Bergner , Bndge ,to
Blo,erville in common Wlth the Grantor, his bellS
and a3signs.
SUBmcr to the aforesaid rigilt-of-w.y 101
ingress and egres' in lavor. of the owner or
owners, their beirsand assign" of the land to the
West hereof,
TRACT NO, 2: BEGINNING at a ,take .t
line of other land 01 K, Swartz: thence by ,aid
land, South 44 degree" 30 minutes West, a
distance of 22S feet, more or less, to the low w.l<T
mark of the Conodoguinet Creek; thence by the
same up the Creek. North 52 degree. IS minures
West., a distance of 51.5 feet to a point; thence
along land, of Chester Fry, North 44 degree, 30
mlnu"" Bast, . di,tance of 231 feet to a ,take;
thence by the same. South 45 de-gre.. 30 minute,
Eas~ a di,tance of 50 feet to a stake. the FIace of
BEGlNNINO, CONTAINING 0,27 acres, more
ortess
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION - LAW AT NO, 03-571 CIVIL
BANK ONE. NATIONAL ASSOCIATION, TRUSTEE.
PLAINTIFF
Total Judgment Amount
Interest
Per diem of$19,56 to sale
date 9/7/2005
Late Charges
$30,97 per month to sale
date 9/7/05
Escrow Deficit
Corporate Advances
VS.
SHEILA M, GROSS.
DEFENDANT(S)
$67.285,92 v""
$15,380,29
$712.31
$4.740.73
$2,71 \.87
TOTAL WRIT $90,831.12
*Plus additional interestl late charges and 0 her costs
to date of sheriffs sale.
SALE DATE: Wednesday, September 07, 2 05
(PROTHONOTARY'S USE)
Pltf, Paid
Deft, Paid
Due Proth/Clerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Date: April 12, 2005
Issue Writ of Execution in the above capt'
'--
Attomey for Plaintiff
1719 North Front Street
Harrisburg. PA 17102
(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 le
sell the property described in the attached description known as 57 WATERSIDE DRIVE, CARLIS
PENNSYLVANIA 17013
Date:
PROTHONOTARY/CLERK CNIL DNIS ON
BY
DEPUTY
upon and
E,
/ M
/.---
ALL those three tracts of land situate in Lower Frankford Township, Cum: land
County, pennsylvania. bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of P ul R.
Young and Russell L. Mackey, et al; thence along the line of land .of Paul R. Young, eros ing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 utes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, No 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conve ed to
Alverta M. Fry; thence by the 1atter land, North 44 degrees 30 minutes East, 35 feet, re or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a priv road
to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, So th 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description g in
accordance with a survey thereof by Roger Sl Germain & Associates, dated September 26 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over 0
of the Grantor herein and other owners to the property herein conveyed over a private ro
the public road leading from Bergner's Bridge to Bloserville in common with the Gran
heirs and.assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the 0 or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stake at line of other land ofK. Swartz;
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to th
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 de
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, No
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 de
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONT
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of ingress and egress over other ands
of the Grantor herein to the property herein conveyed, over a private road from the publi road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs ~
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford To
Cumberland County, Pennsylvania, bounded and descn"bed as follows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wife and R
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, ero
private road, South 44 degrees 30 minutes West 21 1.29 feet to an iron pin; thence by the
land and the same courses, 35 feet, more or less, to the low water line of the Conodo
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 .
,
///
East 3S feet, more or less, to an iron pin; thence by the same land and the same course, em a
private road, 234.38 feet to an iron pin on the line of land of Russell L. Mackey, et a1; then by
the latter 1and, through an iron pm in the center of said line, South 65 degrees 18 minute East
110.28 feet to the Place of BEGINNING; said description being in accordance with a ey
thereof by Roger St Germain & Associates, dated September 26, 1961.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the 0
owners, their heirs and assigns. of the land to the West hereof.
TOGETHER with a right-of-way for the purpose of ingress and egress over other
of the prior Grantors herein and other owners to the property conveyed over a private road m
the public road leading from Bergner's Bridge to Bloserville, in common with the prior tors,
their heirs and assigns.
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller rove
by deed dated 1/22/00 and recorded in Deed Book 238 pag 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
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BANK ONE, NATIONAL ASSOCIATION, TRUSTEE.
PLAINTIFF
IN THE COURT OF COMMON PLEA
CUMBERLAND COUNTY, PENNSY VANIA
VS,
CIVIL ACTION LAW
SHEILA M, GROSS.
NO, 03-571 CML
DEFENDANT(S)
MORTGAGE FORECLOSURE
BANKRIJPI'CY DISMISSAL
.
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
Sheila Mary Gross
CHAPTER 13
CASE NO.: 1 :04-bk-05427
Debtor(s)
ORDER DISMISSING CASE
NOW, at Harrisburg, in said District,
Upon consideration ofTrustee's Certificate of Default (and hearing if appropriat ),
and it having been determined that this case should be dismissed, it is
ORDERED that the case of the above-named deblor(s) be and it hereby is
dismissed and it is further
ORDERED that the trustee hereby is discharged from further responsibility in t is
case, and it is further
ORDERED that all pending adversary proceedings in this case be and they her by
are dismissed. and it is further
ORDERED that any outstanding fees are immediately due and payable to the ,8,
Bankruptcy Court,
BY THE COURT,
?1~~~:: 9-
Date: March 30. 2005
This electronic order is signed and filed on the same date,
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BANK ONE. NATIONAL ASSOCIATION, TRUSTEE.
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVAN
VS,
CIVIL ACTION LAW
NO. 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said Commonwealth and Co ty,
LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states th t 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 SUbSCri~
before me this li!day
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LEO
[1--.--- NOTARIAL SEAL --I
MARYLAND K. FERRETTI, Notary Public I
Lowe: Paxto,n Twp., Dauphin County
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BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V AN
VS,
CIVIL ACTION LAW
NO, 03-571 CIVIL
SHEILA M, GROSS.
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as
the praecipe for the writ of execution was filed, the following information concerning the real
located at 57 WATERSIDE DRIVE CARLISLE, PENNSYLVANIA 17013:
1, Name and address ofthe Owner(s) or Reputed Owner(s):
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, PA 17013
the date
operty
2, Name and address ofDefendant(s) in the Judgment, if different from that listed, n (1)
above: SAME
3, Name and address of every judgment creditor whose judgment is a record lien the
real property to be sold:
Cynthia Naught
31 Bellaire Avenue
Carlisle, P A 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, PAl 7109
4. Name and address oflast recorded holder of every mortgage ofrecord:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
5, Name and address of every other person who has any record lien on the propert
UNKNOWN
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6, Name and address of every other person who has any record interest in the pro erty and
whose interest may be affected by the sale: UNKNOWN
.
7. Name and address of every other person of whom the Plaintiff has knowledg who has
any interest in the property which may be affected by the sale:
Tenants if any . . ,
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, P A 17013
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PAl 710 I
Tenant/Occupant
57 Waterside Drive
Carlisle, P A 17013
(In the preceding information, where addresses could not be reasonably ascertained, th same is
indicated, )
I verify that the statements made in this Affidavit are true and correct to the best of m personal
knowledge, information and belief. I understand that false statements herein are e subj ct to the
penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authori' ,
Leo ,Haller PA LD, #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PAl 71 02
(717) 234-4178
DATE:ApriI12,200S
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BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV A A
VS,
CIVIL ACTION LAW
NO, 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
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TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
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DATE:
Wednesday, September 07, 2005
:2.
TIME:
10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
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THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly onsisting
of a statement of the measured boundaries of the property, together with a brief mention of the uildings
and any other major improvements erected on the land, (SEE DESCRIPTION A TT ACHED)
THE LOCATION of your property to be sold is:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed n the
within Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
~
,
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or gove ental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale receive and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalitie that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and dist 'bution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone bjects 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 th 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
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 an advise
you more specifically of these rights. If you wish to exercise your rights, YOU MU TACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU C
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
R
GET
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 'udgment
against you. You may also file a petition with the same Court if you are aware of a legal de ct 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 e within
County to set aside the sale for a grossly inadequate price or for other proper cause, Thi 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 p agraphs
must be presented to the Court of Common Pleas of the within County. The petition must be erved on
the attorney for the creditor or on the creditor before presentation to the court and a propose order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Admi istrator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petiti n to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
"
/'
---
ALL those three tracts of land situate in Lower Frankford ToWIl$bip, land
County, Pennsylvania, bounded and descnbed as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land ofP R.
Young and Russell L. Mackey, et aI; thence along the line of land 'of Paul R. Young, c ing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 utes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, N 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conve ed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, re or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a privat road
to an iron pin on the line of land of Russell L. Mackey, et aI; thence by the latter land, So th 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description be g in
accordance with a survey thereof by Roger S1. Germain &. AssociUes, dated September 26, 961.
TOGETHER with a right-of-way for the pwpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private ro from
the public road leading from Bergner's Bridge to Bloserville in common with the Grant ,his
heiIs and. assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the own or
ownm, their heirs and assigns. of the land to the West hereof.
TRACT NO.1: BEGINNING at a stake at line of other land of K. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the w
water IIllIrlc of the Conodoguinet Creek; thence by the same up the Creek, North 52 de 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 de
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. com
0.27 acres, more or less.
TOGETHER with a right-of-way for the pwpose of ingress and egress over other 1
of the Grantor herein to the property herein conveyed, over a private road from the public ~ ad
leading from Bergner's Bridge to BlosetVille in common with the Grantor, his heirs md assi ,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford To
Cumberland County, Pennsylvania, bounded and descnbed as follows:
,
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wife and Russ U
L. Mackey, et aI; thence along the line of land aforesaid of Chester L. Fry and wife, crossin a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the e
land and the same courses, 35 feet, mote or less, to the low water line of the CoDodo .
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the
to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30'
//
/
,
East 3S feet, more or less, to an iron pin; thence by the same land and the same course, ero' a
private road. 234.38 feet to an iron pin on the line ofland of Russell L. Mackey, et al; then by
the latter land, through an iron pin in the center of said line, South 6S degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a ey
thereofby Roger St. Germain &. Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other
of the prior Grantors herein IlDd other owners to the property conveyed over a private road
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Gran:
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the own
owners, their heirs IlDd assigns, of the land to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE D VB,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller G ove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-571 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt. interest and costs due BANK ONE, NATIONAL ASSOCIATION, TRUST
Plaintiff(s)
From SHEILA M. GROSS, 57 WATERSIDE DRIVE, CARLISLE PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 57 WATERSIDE DRIVE, CARLISLE PA 17013 (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 fr
paying any debt to or for the account of the defendant (s) and from delivering any property of the defend nt
(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 a a
garnishee and is enjoined as above stated.
Amount Due 67,285.92
LL
Interest TO 9/7/05 @ $19.56 per diem ~ $15,380.29
Atty's Comm % Due Prothy $1.00
Atty Paid 3,261.63
Other CostsLATE CHARGE S $30.07/MONT
TO 9/7/05 = $712.31: ESCROW DEFICIT = $4,740.73: CORPORATE ADVANCES ~ $2,711.87
Plaintiff Paid
Date: APRIL 15, 2005
(Seal)
CURTIS R. LONG
Prothonqt ry
By: \ U-
REQUESTING PARTY:
Name LEON P. HALLER, ESQ.
Address: 1719 N. FRONT ST.
HARRISBURG PA 17102
Attorney for: PLAINTIFF
Telephone: (717) 234-4178
Supreme Court ID No, 15700
BANK ONE. NATIONAL ASSOCIATION. TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
VS,
CIVIL ACTION LAW
NO, 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I have deposited in the D,S, Mails at Harrisburg, Pennsylvania on
v-/9-{)5"' , 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 D.S, Postal Form 3817 is attached hereto as evidence),
and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are
as follows:
SHEILA M, GROSS
57 WATERSIDE DRIVE
CARLISLE, P A 17013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, P A 17013
Cynthia Naught
31 Bellaire Avenue
Carlisle, P A 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PA 17101
Tenant/Occupant
57 Waterside Drive
Carlisle, P A 17013
By
~-~
PURCE~KRDG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
HOWARD B. KRUG
LEON P. HALLER
JOHN W, PURCELL JR.
JILLM. WrNKA
BRIAN], TYLER
NICHOLE M. STALEY O'GORMAN
f?JJ~ ~ &' ~~
\7\9 NORTH FRONT S1REET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FAX (717) 234-1206
HERSHEY
(717)533-3.836
JOSEPH NISSLEY (1910-1982)
JOHN W. PURCELL
VALERIE A. GUNNOF
COUNSEL
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, P A 17013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, P A 17013
Cynthia Naught
31 BeUaire Avenue
Carlisle, P A 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
Dorothy L. Mott, Esquire
125 State Street
Harrisburg,PA 17101
Tenant/Occupant
57 Waterside Drive
Carlisle, PA 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto,
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 that you have an opportunity to protect your interest, if any, by bei otified of
said Sheriff's Sale,
By:
=
L . HallerPALD.15700
ttomey for Plaintiff
BANK ONE, NATIONAL ASSOCIATION. TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
VS,
CIVIL ACTION LAW
NO, 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 07, 2005
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 ofthe buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your propelty is being sold is docketed in the
within Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
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 filct, 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, Pennsylvania 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 a 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 Sheriffs 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 Connty. 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.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PAl 7102
(717) 234-4178
/
/ .---
ALL those three tracts of land situate in LoWla- Frankford Township, Cumberland
County, Pennsylvania. bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et aI; tbenco along the line: of land 'of Paul R. Young, cro~ a
private road and through an iron pin on the southern side thereot: South 44 degrees 30 mmutes
West. 200 feet to an iron pin; thence by the same land and lhe same course, 3S feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 7S
degrees 39 minutes West, 60 feet to a point on line of landl conveyed or about to be conveyed to
Alverta M. Fry; thence by the latter 1and, North 44 degrees 30 mnmtes East, 3S feet, more or
less, to an iron pin; thence by the same land the same COUll;e, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et aI; thence by the latter 1and, South 6S
degrees 18 minutes East, S5.l4 feet to the Place of BE.GINNING said description being in
accordance with a survey thereof by Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose <If ingress and egress over other 1ands
of the Grantor herein and other owners to the property hm,in conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress Imd egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof:
TRACT NO.1: BBGlNNING at a stake at line of other land of K. Swartz; thence by
said 1and, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water mark of the Conodoguinet Creek:; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester FlY, North 44
degrees 30 minutes East, a t1;.qAnt'~ of231 feet to a stake; thl~ by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place ,)f BEGlNNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over II private road from the public road
leading from Bergner's Bridge to B10secville in common with. the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, Pennsylvania, bounded and descn"bed as follows:
BEGINNING at an iron pin at the comer of land of C1Jestcr L. FlY and wife and Russell
L. Mackey, et aI; thence along the line of land aforesaid of Chester L. FlY and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
land and the same counes, 35 feet, more or less, to the lo", water line of the Conodoguinet
Creelc; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to tbe line
to land of Brinton F. Fomey and wife; thence by the latter bl!ld, North 44 degrees 30 minnte<'
/'
East 3S feet, more or less, to an iron pin; tbeacc by the same land and the same course, crossing a
private road, 234.38 feet to an iron pin on the line of land l)fRussell L. Mackey, et at; thence by
the latter 1and. through an iron pin in the center of said JiJ:le, South 65 degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said descriptioll being in accordance with a survey
thereofby Roger St. Germain & Associates, daied Septembc:r 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of1he land to the West hereoL
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
7lo1.lJ 3'IJ], 't6If6 b'l25 i:!"I72
TO: SHEILA M, GROSS
57 WATERSIDE DRIVE
CARLISLE, PA 17013
SENDER:
REFERENCE:
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Rerum Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
.
~
HOMECOMINGS FINANCIAL NETWORK v, SHEILA M, GROSS
Cumberland County Sale 9/7/2005
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
IIn comoliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One piece of ordinary mail addressed to:
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE. PA 17013
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comoliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One piece of ordinary mail addressed to:
Cynthia Naught
31 Bellaire Avenue
Carlisle, PA 17013
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comnliance with Postal Service Form 3877)
."
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PAl 71 02
Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Postmark:
.
I ~~~fSPQs-~
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"""HV8o..r",,~
02 IA
. 00043538)1 $ 00.900
~ MAflED FROM Z"PR 19 2005
IPCODE 17102
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comuliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comuliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, P A 171 0 1
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comuliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One piece of ordinary mail addressed to:
Tenant/Occupant
57 Waterside Drive
Carlisle, P A 17013
Postmark:
1
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Bank One, National Association,
Trustee
VS
Sheila M. Gross
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No, 2003-571 Civil Term
Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law,
states that on May 25,2005 at 6:00 o'clock PM, he served a true copy of the within Real
Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon
the within named defendant, to wit: Sheila M. Gross, by making known unto Sheila M.
Gross, personally, at 57 Waterside Drive, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Richard Smith, Deputy Sheriff, who being duly sworn according to law, states
that on July 12,2005 at 6:40 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Sheila M, Gross, located at 57 Waterside Drive, Carlisle, 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 the within named
defendant, to wit: Sheila M. Gross, by regular mail to her last known address of 57
Waterside Drive, Carlisle, PA 17013. This letter was mailed under the date of July 01,
2005 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Leon Haller.
Sheriffs Costs:
Docketing
Poundage
Posting Handbills
Advertising
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
30,00
35,91
45.00
45.00
1.00
7.20
12.34
45,00
40,00
Law Journal
Patriot News
Share of Bills
Postpone Sale
899.00
632.72
18.20
20.00
$1831.37
Sworn and subscribed to before me
So Answers
/~~//-.,
R. Thomas Kline, Sheriff
BY I HI 11/ s~tl
Rea~
2005, A.D.
4. lfO J
}, LIt5.;.2~J
~u,
BANK ONE, NATIONAL ASSOCIATION, TRUS:EE.
PLAINTIFF
VS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION LAW
i
NO, 03-571 CIVIL
SHEILA M, GROSS.
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
~!.
6'
AFFIDAVIT PURSUANT TO RULE 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 57 WATERSIDE DRIVE CARLISLE, PENNSYL VANIA 17013:
1. Name and address of the Owner(s) or Reputed Owner(s):
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, P A 17013
2. Name and address ofDefendant(s) in the Judgment, if different from that listed, in (1)
above: SAME
3, Name and address of every judgment creditor whose judgment is a record lien on the
(-") ,....,.
real property to be sold: c-" g ~
_n ('fl
v
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Cynthia Naught
31 Bellaire Avenue
Carlisle, P A 17013
="..
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Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
('."
C::l
U1
4, Name and address oflast recorded holder of every mortgage ofrecord:
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
.'
"
---
ALL those three tracts of land situate in Lower Frankford Township, Cumberland
Cotmty, Pennsylvania, bounded and descnbed as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et al; thence along the line of land 'of Paul R. Young, crossing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 minutes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey thereof by Roger St Germain & Associate!, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs andassigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof.
TRACT NO.1: BEGINNING at a stake at line of other land of K. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water m.azk of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along 1ands of Chester Fry, North 44
degrees 30 minutes East, a distance of231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, Pennsylvania, bounded and descnbed as follows:
BEGINNING at an iron pin at the corner of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of !and aforesaid of Chester L. Fry and wife, crossing a
private road, South 44 degrees 30 minutes West 211.29 feet to an iron pin; thence by the same
!and and the same courses, 35 feet, more or less, to the low water line of the Cooodoguinet
Creek; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Fomey and wife; thence by the latter land, North 44 degrees 30 minutes
)
/-
,./"
East 35 feet. more or less, to an iron pin; th= by the same land and the same course, crossing a
private road. 234.38 feet to an iron pin on the line ofland of Russell L. Mackey, et 21; thence by
the latter land, through an iron pin in the center of said line, South 65 degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
thereofby Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the pUrpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-571 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt. interest and costs due BANK ONE, NATIONAL ASSOCIATION, TRUSTEE
Plaintiff(s)
From SHEILAM.GROSS, 57WATERSIDEDRIVE,CARLISLE PA 17013
(I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 57 WATERSIDE DRIVE, CARLISLE PA 17013 (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 issned; (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) Ifproperty 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 67,285.92
LL
Interest TO 9/7/05 @ $19.56 per diem ~ $15,380.29
Atty's Comm % Due Prothy $1.00
Ally Paid 3,261.63 Other CostsLATE CHARGE S $30.07/MONTH
TO 9/7/05 = $712.31: ESCROW DEFICIT = $4,740.73: CORPORATE ADVANCES = $2,711.87
Plaintiff Paid
Date: APRIL 15, 2005
CURTIS R. LONG
(Seal)
By:
Deputy ,
REQUESTING PARTY:
Name LEON P. HALLER. ESQ.
Address: 1719 N. FRONT ST.
HARRISBURG PA 17102
Attorney for: PLAINTIFF
Telephone: (717) 234-4178
Supreme Court ID No, 15700
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), p, L,1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
V1Z:
July 15, 22, 29, 2005
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.
Lisa
SWORN
29
AND SUBSCRIBE before me this
day of Julv. 2005
NOTAR SEAL
LOIS E. SNYDER. Nolary Pul,lic
Carnsle Boro. Cumberland County
MV Commission Expires Marth 5. 2009
REAL ESTATE SALE NO. 36
Writ No. 2003-571 Civil
Bank One, National
Association, Trustee
VS,
Sheila M. Gross
Atty.: Leon P. Haller
ALL those three tracts of land
situate in Lower Frankford Town~
ship. Cumberland County. Pennsyl-
vania, bounded and described as
follows:
TRACT NO, I: BEGINNING at an
iron pin and stake at the corner of
land of Paul R. Young and Russell
L. Mackey, et al; thence along the
line of land of Paul R Young. cross-
ing a private road and through an
iron pin on the southem side thereof
South 44 degrees 30 minutes West
200 feet to an iron pin; thence by
the same land and the same course,
35 feet. more or less. to the low
water line of the Conodoguinet
Creek; thence by the said low v:a-
teT lIne, North 75 degrees 39 miIl~
utes West, 60 feet to a po1nt on line
of land conveyed or about to be con-
veyed to Alverta M. Fry; thence by
the latter land, North 44 degrees
30 minutes East, 35 feet, more or
less, to an iron pin: thence by the
same land the same course, 211.29
feet, crossing a private road to an
iron pin on the line of land of Russell
L. Mackey, et al; thence by the lat-
ter land, Soulh 65 degrees 18 min-
utes East, 55.14 feet to the Place
of BEGINNING said description be-
ing in accordance with a survey
thereof by Roger St. Germain & As-
socJates, dated September 26, 196!.
TOGETI-IER with a right-of-way
for the purpose of ingress and
egress over other lands of the
Grantor herein and other owners to
the property herein conveyed over
a private road from the public road
leading from Bergner's Bridge to
Bloserville in common with the
Grantor, his heirs and assigns.
SUBJECT to the aforesaid right-
of-way for ingress and egress in fa-
vor of the owner or owners, their
heIrs and assigns, of the land to the
West hereof.
TRACT NO, 2: BEGINNING at a
stake at line of other land of K.
Swartz: thence by said land, South
44 degrees 30 minutes West, a dis-
tance of 225 feet, more or less, to
the low water mark of the Conodo-
guinet Creek; thence by the same
up the Creek, North 52 degrees 15
minutes West, a distance of 51.5
feet to a point: thence along lands
of Chester Fry, North 44 degrees
30 minutes East, a distance of 231
feet to a stake: thence by the same,
South 45 degrees 30 minutes East,
a distance of 50 feet to a stake, the
Place of BEGll'INING. CONTAINING
0.27 acres, rlore or less.
TOGETHER With a right-oE-way
for the purpose of ingress and
egress over other lands of the
Grantor herein to the property
herein conveyed, over a private road
from the pubHc road leading from
Bergner's Bridge to Bloserville in
common with the Grantor, his heirs
and assigns, said right-of~way to be
approximately 1609 feet, more or
less, from the said pubHc road.
TRACT NO.3: ALL that certain
tract of land situate in Lower Frank-
ford Township, Cumberland Coun-
ty, Pennsylvania, bounded and de-
scribed as foHows;
BEGINNING at an iron pin at the
comer of land of Chester L. Fry and
wife and Russell L. Mackey, et al;
thence along the line of land afore-
said of Chester L. Fry and wife,
crossing a private road, South 44
degrees 30 minutes West 211.29
feet to an iron pin; thence by the
same land and the same courses,
35 feet, more or less, to the Jaw
water line of the Conodoguinet
Creek; thence by the said low wa-
ter Hne, North 75 degrees 39 min-
utes West 120 feet to the line to
land of Brinton F. Forney and wife:
thence by the latter land, North 44
degrees 30 minutes East 35 feet,
more or less, to an iron pin; thence
by the same land and the same
course, crossing a private road,
234.38 feet to an iron pin on the
line of land of Russf>J1 L. Mackey, et
a1; thence by the latter land. through
an iron pin in the center of said line,
South 65 degrees 18 minutes East
110.28 feet to the Place of BEGIN-
NING; said descIiption being in ac-
cordance with a survey thereof by
Roger St. Germain & Associates,
dated September 26, 1961.
TOGETHER with a right-of-way
for the purpose of ingress and
egress over other lands of the prior
Grantors herein and other ov.mers
to the property conveyed over a pri~
vate road from the public road lead-
ing from Bergner's Bridge to
BloseIY111e, in common with the pri-
or Grantors, their heirs and assigns.
SUBJECT to the aforesaid right-
of-way for inp;ress and egress in fa-
vor of the owner or owners, their
heirs and assigns, of the land to the
West hereof.
HAVING THEREON ERECTED A
DWELLrNG KNOWN AS 57 WATER-
SroE DRIVE, CARLISLE. PA 17013.
BEING THE SAME PREMISES
WHICH Lee E. Grove and Laura
Miller Grove by deed dated 1/22/
00 and recorded in Deed Book 238
Pag:e 228 granted and conveyed unto
Sheila M. Gross.
TO BE SOLD AS THE PROP-
ERTY OF SHEILA M, GROSS ON
JUDGMENT NO, 2003 57!.
ASSESSMENT: 14-07-0475-004,
, .
. '
.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No, 587. Approved May 16. 1929
Commonwealth of Pennsylvania. County of Dauphin} os
Joseph A. Dennison. being duly sworn according to law. deposes and says:
That he is the Assistant Controller of The Patriot News Co" a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania. with its principal office and place of business at 812 to 818 Market
Street. in the City of Harrisburg. County of Dauphin. State of Pennsylvania, owner ami 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 19th and 26th day(s) of July and the 2nd
day(s) of August 2005, 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 lias 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,
COpy
S ALE #36
Sworn to an
PUBLICATION
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE. PA, 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO,
For publishing the notice or publication attached
hereto on the above stated dates
632.72
REAL ESTATE SALE No. 36
Writ No. 2003-571
Civil Term
Benk One, N8IIonel _18IIon,
Tru8le8
Va
Shelle M. Gross
Ally: Laon P. Haller
DESCRIPTION
TOGETHER witb a right-of-~y for the
purpose of ingress and egress overotber 1aalk of
the Grantor herein to dJe proptlfy herein
con~eyed, over a ~vate road from. the public road
leading from .8ergner'.s Bridge to Bloserville in
CO.~OD with !he Grantor, his heirs and assigns,
s&d right-of~way to be approximately 1609 feet,
more or less, from the said public road.
.~NO.3:~thatcertain.tractOfland
SItuate m Lower Frankfurd Township, Cumberland
COIlllly. Peonsyl""" bounded and _bed "
follows:
BEGINNING"'at an iron pin at the comer ofland
of Chester L Fry "'" will: and Russell L, Mackey,
et a1; I:bence along the liue of land aforesaid of
Che&er L Fry and will:. crossing a priWle road,
South 44 degrees 30 minutes West 211.29 feet to
an iron pin; thence by the same land and the same
courses, 35 feet, more or less. to the low water line
of die ~()fJ()joguinetCreel; dreoce by die said low
w.ater line, North 75 degrees 39 minUtes West 120
feet to the line to land of Brinton F. Forney and
wife; thence by the latter land. North 44 ;egre."
3? minutes East 35 feet, more or less, to 811, iron
pm; thence by the same IaJ1d and the same course,
crouinga privale road, 234.38 feet to an iron pin
on !be line of Ian<l 01 R_n L Mickey, et aJ;
thencebytbe latter land, Ihrough an iron pin in the
center of said line, South 65 degrees 18 minutes
East 110.28 feet to the Place of BEGINNING;
said description being in accordance with a survey
lbereof by Roger St. Germain & Associates, dated
~26, 1961.
TOGETHER wilh a right-of-way for the
purpose of ingress and egress over other lands of
the prior Grantors Mrein and other owners to the
property conveyelover a private road from the
public road 1eadi:Dg from Bergner's Bridge to
BIosemUe, in cmnznon with the prior Grantors,
lheirheirs andassigns.:.
SUBJECf to the aforesaid right-<lf-way for
ingress and egress in favor of the owner or owners,
their heirs and assigns. of the land to the West
bereof,
HAVING thereon erected a dwelling known as
57 W_llri"". Carlisle,PA 11013.
BEING TIlE SAME preIlIi.es which Lee E.
Grove and Laura Miller Grove by deed dated 1/211
00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sbei1a M. Gross.
TO BE SOLD " !be propeny of Sheila M.
Gross on Judgement No. 2003 571.
ASSF.'lSMENr. 1W7-0475.004,
ALLtbosethree tracts of land situate in Lower
Frankfonl ToWll.!bi;: Cumberland' Coonty,
Permsy1van1a. bounded and described " follow",
TRACI' NO., 1:' BEGINNING at an iron pin
and slake at _ of Ian<l of Paul R, Young
andRussollL, Mai:key, ct aJ; thence aJong \he line
of 1aDd of Paul R.Young, crossing a !XivareJ'OOd
and through lID iron pin 011 the soutbem side
_, Sonlb 44 degrees 30 minutes West 200
feet to an iron pin; tbencebytho same land and
Ihe same course, 3Sfeet, more or less, to the low
water line 01 the conodogIrinet Ct<ek; the"" by
the said low warer\ine.Nolth75 deglees 19
minutes west, 60 feet to a po.inf on line of land
conveyed or about to be conveyed to Alverta M.
Fry; thence by \he _land, Nolth 44 degrees 30
JDinures East, 3S feet, more or less, to an iron pin;
tbence by the same land the same course, 211.29
feet,crossingaprivateroadtoaaironpmontbe
line oIIandolRussoll L Mai:key, et aJ; thence by
!be \atter land, SOUIb 65 degrees 18 minutes East,
55.\4 feet to \he PIao: 01 BEGINNING said de-
scription being in accordance with. a. survey
_by Roger St GennaJn I< Associates. dated
September 26, 1961.
1UGE1HER witb a right-of-way for the
purpose olingtess andegJOSS over oIber Jands 01
me OnDtor herein and other owners to the
property herein .iOnveyed over a priv~ ~ from
the public road 1eading from Bergner s Bodge to
Bloservme inoommon with tbeGraDtor, his,heirs
and"';-
siiitr...e -- ."., ..
.................-.-
tIlIltllein......., of..1oslI \0"'"
....'
1'IlACI' NO, 2: BEGINNlNG at a stake at line
of_laodofR SW8tlZ; thence by said land.
South 44 degrees 30 minultS West, a distance of
225 feet, more or less, to !he low water mark of
theCouodoguUtetCreek;thenceby<lre-up
the Creek. Nolth 52 degrees 15 minutes W....'
distarM:eof51.5feetroapoint;l:beocealooglands
of Cltester Fry, Nolth 44 degrees 30 minutes East,
a ~~e_ of 231_ ~.~_~_~~; ~_bJ_~
.
....
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO, 03-571 CIVIL
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
DEFENDANT(S)
Total Judgment Amount
Interest
Per diemof$19.56 to sale
date 9/612006
Late Charges
$30,97 per month to sale
date 9/6/2006
Escrow Deficit
Corporale Advances
$67,285,92
$22,271.75
VS.
$712.31
SHEILA M. GROSS,
$6,591.60
$9,030,54
TOTAL WRIT $105,892.12
.Plus additional interest, late charges and other costs
to date of sheriff's sale.
SALE DATE: Wednesday, September 07, 2005
(PROTHONOTARY'S USE)
Pltf. Paid
Deft, Paid
Due ProthlClerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION. MORTGAGE FORECLOSURE
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue Writ of Execution in the above captioned ca
Date: May 30, 2006
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(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 57 WATERSIDE DRIVE, CARLISLE,
PENNSYLVANIA 17013
C 1L DIVISION
Date:
PROTHO
BY
DEPUTY
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ALL those tbreo tracts of land situate in Lower Frankford To~, Cumberland
County, PemJSylVlllIia, bounded and described as follows:
TlUCT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Maclcey, et al; thence along the line of land .of Paul R. Young, crossing a
private road and through IIIl iron pin on the southern side thereof: So1Ith 44 degrees 30. minutes
West 200 teet to IIIl iron pin; thence by the same land end the same coursc:, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line. North 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; 1hence by the latter land, North 44 degrees 30. mnmt..a East, 35 feet, more or
less, to an iron pin; thence by the same land the same COUISe, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et al; thllDCO by the latter lend, South 65
degrees 18 minutes East, 55.14 teet to the Place of BEGINNING said description being in
accordance with a survey thercofby Roger SL Germain &~, dated September 26, 1961.
TOGETHER with a right-of-way for the pUlpOSll of ingress end egress over other lands
of the Grantor herein and other OWlll!lrS to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs andassigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners. their heirs and assigns, of the land to the West hereof
11l.4CT NO.2: BEGINNING at a stake at line of other land of Ie. Swartz; thence by
said lend, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water mark of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees IS
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester FlY. North 44
degrees 30. minutes East, a distance of 231 feet to a stake; thence by the same. South 45 degrees
30. minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0..27 acres, more or less.
TOGETHER with a right-of-way for the pwpose of ingress end egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 teet. more or less, from the said public road.
11l.4CT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, PcmnsylVlllIia, bounded end described as follows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry md wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry BDd wife. crossing a
private road, South 44 degrees 30. mm"boa West 211.29 feet to. an iron pin; thence by the same
land and the SIUI1ll courses, 35 teet. more or less, to the low water Jino of the Conodoguinet
Creelc; thence by the said low water line. North 75 degrees 39 '1'm,!fes West 120. feet to the line
to land of Brinton F. Forney and wife; thence by the1atter land, North 44 degrees 30. ";innt~
.
w . /~
,v
East 35 feet. more or less, to an iron pin; tbeoco by the same land 8Dd the same coune, crossing a
privatoroad. 234.38 feet to an irol?-pin on tho 1ino oflandofRusseIlL. Mackey, etal; thoDCc by
the latter land, through an iron pin in tho center of said line, South 65 degrees 18 minutes East
110.28 feet to tho P1aco of BEGINNING; said description being in accorcIaDce with a survey
thereofby Rogel" St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the piIlpose of ingress and egress over other \ands
of tho prior Grantors herein and other owners to tho property conveyed over a privato road from
tho public road l....nmg from Bergner's Bridge to Bloserville, in common with tho prior Grantors,
their heirs and assigns.
SUBJECTto tho aforesaid right-of-way for ingress and egress in favor of the owner or
owners, theirheim and assigns, of the \and to1he West hereot
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 23B Page 22B
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-571 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
Plaintiff (s)
From SHEILA M. GROSS
(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 gamishee(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 hirnlher that he/she has been added as a
garnishee and is enjoined as above stated,
Amount Due $67,285.92
L.L.
Interest $22,271.75 - PER DIEM OF $19.56 TO SALE DATE 9/6/06
Ally's Cornm % Due Prothy $1.00
Ally Paid $5118.00 Other Costs LATE CHARGES $30.97 PER
MONTH TO SALE DATE 9/6/06 - $712.31 -- ESCROW DEFICIT - $6,591.60 - CORPORATE
ADVANCES - $9,030.54
~
Plaintiff Paid
Date: MAY 31, 2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name LEON P. HALLER, ESQUIRE
Address: 1719 NORTII FRONT STREET
HARRISBURG, PA 17102
Attorney for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ill No, 15700
VS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
NO. 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT
IN MORTGAGE FORECLOSURE
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
before me thi~ day
of
20 d
(,
NOTARIAL SEAL
MARYLAND K, FERRml, Notaty Public
Lower Paxton Twp" Dauphin County
My Commission Expires Aug. 8, 2006
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BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
VS,
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION LAW
NO, 03.571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 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 57 WATERSIDE DRIVE CARLISLE, PENNSYL VANIA 17013:
1. Name and address of the Owner(s) or Reputed Owner(s):
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, PAl 7013
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 is a record lien on the
real property to be sold:
Cynthia Naught
3 I Bellaire Avenue
Carlisle, PA 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 171 09
4. Name and address oflast 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
..4
.
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:
Tenants if any .. .
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, P A 17013
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, P A 1710 1
Tenant/Occupant
57 Waterside Drive
Carlisle, PA 17013
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated.)
I verify that the statements made in this Affidavit are true and correct to the best of
knowledge, information and belief. I understand that false statements herein are ma s
penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authoritie
personal
. ect to the
er PA LD. #15700
, Krug & Haller
19 North Front Street
Harrisburg, P A 17102
(717) 234-4178
DATE:May 30, 2006
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BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO, 03-571 CNIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 06, 2006
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:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
,
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, Pennsylvania 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 a 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 Sheriffs 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.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
.
/
"
---
ALL those three tracts of land situate in Lower Frankford To~, Cumberland
County, Pennsylvania, bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin and stakft at the comer of land of Paul R.
Young and Russell L. Mackey. et al; thence along the line of land .of Paul R. Young, crossing a
private road and through an iron pin on the southern side thereof, South 44 degrees 30 minutes
West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line, North 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; thence by the 1atter land, North 44 degrees 30 mn",t_ East, 35 feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et at; thence by the latter 1and, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accoIdance with a survey thcreofby Roger SL Germain & As~, dated September 26, 1961.
TOGETHER with a right-of-way for the pUIpOse of ingress and egress over other 1ands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloservi1le in common with the Grantor, his
heiIs andassigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
OWDClll, their heirs and assigns, of the land to the West hereof.
TRACT NO.2: BEGINNING at a stakft at line of other land ofK. Swartz; thence by
said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low
water IDlIIk of the Conodoguinet Creek; thence by the same up the Creek, North S2 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 mnllltes East, a tliC!t<mt'-e of 231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the public road
leading from Bergner's Bridge to B1oservil1e in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACT NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cambcr1and County, Pc:nnsylvania, bounded and descn"bed as follows:
BEGINNING at an iron pin at the comer of land of Chester L. Fry and wifo and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chest<< L. Fry and wife, crossing a
private road, South 44 degrees 30 mnmt", West 211.29 feet to an iron pin; thence by the same
land and the same courses, 35 feet, more or less, to the low wafet line of the Conodoguinet
Creek; thence by the said low water 1ine, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Forney and wife; thence by the latter Imd, North 44 degrees 30 "';inntes
,
/,,/
,
East 35 feet. more or less. to an iron pin; tbeDce by tho same land IIDd tho samo courso, crossing a
privato road, 234.38 feet to an iron pin on the liDl: of18Dd ofRussoIl L. Mackey, ot at; thoncc by
tho 1attc:r laud, through an iron pii1 in tho conter of said Iino, South 65 dogreos 18 minutes East
110.28 foot to tho Place of BEGINNING; said description being in accordance with a survey
thoreofby Rogol' St. Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and ogress over other 1ands
of tho prior GrantoI$ horein and 01her owners to tho property conveyed over a private road from
tho public road loading from Bergnor's Bridge to Bloscrville, in common wi1h the prior Grantors,
thoir heirs and assigns.
SUBJBC1' to tho aiorosaid right-of-way for ingress and egress in favor of the owner or
ownC1'S, lhcir heirs and assigns, of tho land to tho west hereof.
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
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BANK ONE, NATIONAL ASSOCIATION, lRUSTEE,
PLAINTIFF
SHEILA M, GROSS,
VS.
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO, 03-571 CIVIL
IN MORTGAGE FORECLOSURE
RELIEF FRCM STAY
,
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UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
INRE:
SHEILA MARY GROSS
Debtors
BANKONE, NATIONAL ASSOCIATION, AS
TRUSTEE
BANKRUPTCY NO. I :05-bk-05676
Movant
CHAPTER 13
vs.
SHEILA MARY GROSS and
CHARLES J. DEHART, III, Esquire, Trustee
Respondents
ENTRY OF ORDER MODIFYING STAY TO PERMIT
THE FORECLOSURE OF LIEN UPON REAL ESTATE OF DEBTOR
AND NOW, it appearing that a Notice of Default was served upon debtors and their counsel on
, and that no response has been received by SHEILA M. GROSS, Respondent, it is hereby
ORDERED that the stay imposed by ~362 (a) of the Bankruptcy Code be, and hereby is,
modified to permit the BankOne, National Association, As Trustee, to proceed to foreclosure on its
mortgage recorded in Cumberland County, Pennsylvania, as described in its Motion on file herein.
By the Com1,
Jj~/~~!;
This electronic order is signed and filed on the same date.
Dated: April 3, 2006
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
VS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION LAW
NO, 03-571 CML
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on
~b DOL , a true and correct copy of the Notice of Sale of Real Estate pursuant to P A
RC.P. 3129,1 to the Defendants herein and all lienholders of record by regular first class mail
(Certificate of Mailing fonn in compliance with U.S. Postal Fonn 3817 is attached hereto as evidence),
and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are
as follows:
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, P A 17013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Cynthia Naught '
31 Bellaire Avenue
Carlisle, P A 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PA 17101
Tenant/Occupant
57 Waterside Drive
Carlisle, PA 17013
By
P , KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
HOWARD B. KRUG
LEON p, HALLER
JOID'f W. PURCELL JR.
JILLM. WINKA
BRIAN J. TYLER
NICHOLE M. STALEY Q'GORMAN
f?P~~!J~
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FAX (717) 234-\206
HERSHEY
(717)533.3836
JOSEPH NISSLEY (1910-1982)
JOHN W. PURCELL
V ALERlE A. GUNNOF
COUNSEL
SHEILA M. GROSS
57 WATERSIDE DRNE
CARLISLE, PA 17013
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle,PA 17013
Cynthia Naught
31 Bellaire Avenue
Carlisle, P A 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 171 09
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PA 17101
Tenant/Occupant
57 Waterside Drive
Carlisle, P A 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
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 that you have an opportunity to protect your interest, if any, by bein I d of
said Sheriff's Sale.
By: ~
Leon P. Haller PA I.D.15700
Attorney for Plaintiff
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
CIVIL ACfION LAW
NO. 03-571 CIVIL
SHEILA M, GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 06, 2006
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:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
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, Pennsylvania 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 a 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 Sheriffs 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.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, P A 17102
(717) 234-4178
/"
.~.
ALL those three 1I8cts of land situato in Lower Frankfotd ToWJ!Sbip, Cumberland
County, pennsylVllDia, bounded and described as follows:
TIlACT NO.1: BEGINNING at an iron pin and stake at tba corner of land of Paul R.
Y olUlg md Russell L. Mackey, et a1; thence along the line of land 'of Paul R. Young, crossing a
private road md through an iron pin on the southern side thereo~ South 44 degrees 30 minutes
West 200 feet to an iron pill; thence by the same 1and and tba lIIII1lC course, 35 feet, more or less,
to the low water line of tba Conodoguinet Creek; thence by tba said low water line, North 75
degrees 39 minuteS West, 60 feet to a point on line of land oonveyed or about to be conveyed to
Alverta M. Fry; thence by the latter land, North 44 degrees 30 m;""t.., East. 35 feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey, et a1; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accotdance with a survey thereofby Roger SL Germain & Assoc:iatcI, dated September 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other OwneIS to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs andassigns.
SUBJECT to the aforesaid right-of-way for ingress and egn:ss in mor of the owner or
ownelS, their heirs and assigns, of the land to the West hereof:
TRACT NO.2: BEGINNING at a stake at line of other land of K. Swartz; thence by
said 1and, South 44 degrees 30 minutes West, a distance of 22S feet, more or less, to the low
water marlc of the Conodoguinet Creek; theDce by the same up the Credc, North 52 degrees IS
min'...... West, a dicw.ee of 51.5 feet to a point; thence along lands of Chester Fry, North 44
degrees 30 mirJutes East, a dilZhmt'.e of 231 feet to a stake; thence by the same, South 4S degrees
30 m;"ntH East, a distance of SO feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGBTHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road ftom the public road
leading from Bergner's Bridge to Bloscrvi1le in r.ommO/l with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, ftom tba Slid public road.
TRACT NO.3: ALL that certain tract of land situate in Lower FrlIIIkford Township,
Cumberland Coumy, PeD!ISYlvania, bounded and described as follows:
BBGINNlNG at an iron pin at the comer of land of Chester L. Fry and wife and R.usseI1
L. Mackey, ct a1; thence along the line of 1and afoRsaid of ~ L. Fry and wife, crossing a
private road, South 44 degrees 30 m;"ntes West 211.29 feet to an iron pin; the.oce by the same
land and the same courses, 35 feet, more or less, to the low water line of the Conodoguinet
Creek; thence by the said low water line, North 7S degrees 39 ~ West 120 feet to the line
to land of Brinton F. Fomey and wife; tbeDce by the latter land, North 44 degrees 30. "';;"ntes
/.
./
.
East 35 feet, more or leu, to an iron pin; theoce by the same land llIld the ssme coune, crossing a
private road. 234.38 feet to an iron pin on the line of land of Russell L. Mackey, et a1; theDcc by
the latter land, through an iron piD in the center of said line, South 6S degrees 18 minutes Bast
110.28 feet to the Place of BEGINNING; said description being in accorcIanco with a survey
thereofby Rogel'SL Germain &: Associstes, dated Septemb<< 26, 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the prior Grantors herein and other ownen to the p.lOperty conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville, in common with the prior Grantors,
their heirs and assigns.
SUBJBCTto the aforesaid right-of-way for ingress aud egress in mor of the owner or
owners, their heirs and assigns, oftba!aDd to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
1JWJ JIII10 ..... ... ...~
10: SHEILA M. GROSS
57WATERSIDEDRlVE
CARLISLE, PA 17013
leNDER:
NOS 09/06/06
REFERENCE: HC VS. GROSS
FomI3800 Janus 2005
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Receipt for
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HOMECOMINGS FINANCIAL NETWORK v. SHEILA M. GROSS
Cumberland County Sale 9/6/2006
.
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comnliance with Postal Service Form 3877)
Received from:
Purcell, Krog & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, PA 17013
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comnliance with Postal Service Form 3877)
Received from:
Purcell, Krog & Haller
1719 North Front Street
Harrisburg, P A 171 02
Postage:
One piece of ordinary mail addressed to:
Cynthia Naught
31 Bellaire Avenue
Carlisle, P A 17013
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comnllance with Postal Service Form 3877)
Received from:
Purcell, Krog & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Postmark:
.' Qt>-t-~"%-~.:=:=I.
It ft.':";;,"? -
. ~ "ItV' ____ PITNEY IIO\NES
. 02 1A $ 00.950
. . 0004353871 JUN 02 2006
MAILED fROM Z/PCODE 17102
.
.
.
U. S. POSTAL SERVICE
CERTIFlCATE OF MAILING
(In comullance with Postal Service Form 3877\
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, P A 17102
Postage:
One piece of ordinary mail addressed to:
Richard Wix, Esquire
4705 Duke Street
Harrisburg, P A 17109
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comuli.nce with Postal Service Form 3877\
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PA 17101
Postmark:
V. S. POSTAL SERVICE
CERTIFlCATE OF MAILING
(In comull.nce with Post.1 Service Form 3877\
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Tenant/Occupant
57 Waterside Drive
Carlisle, P A 17013
Postmark:
. . !;)<#"\tSPO&,.~
II ft(t.~~...::::-
~ """'" _ P1TfU'tBOWES
. . 02 1A $ 00.950
0004353811 JUN02 2006
MAILED FROM ZIPGODE 11102
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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 Sheriffs Deed in which Bank One B A Tr is the grantee the same having been sold to said grantee
on the 6th day of Sept A.D., 2006, under and by virtue of a writ Execution issued on the 31 st day of
Mav, A.D., 2006, out ofthe Court of Common Pleas of said County as of Civil Term, 2003 Number
571, at the suit of Bank One B A Tr against Sheila M Gross is duly recorded in Deed Book No. 276,
Page 4453.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
.J..1
day of
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RIcoldIr DeedI, C~lIlnd ~, CIdIIIII. PA corder of Deeds
..., Ct!l1.tl"'1I EJpIIIt.. FiIIt MoIdIIrCII_2DIO
,
Bank One, National Association, Trustee
VS
Sheila M. Gross
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-571 Civil Term
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states
that on June 23,2006 at 12:15 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: Sheila M. Gross, by making known to Sheila M. Grosee, personally, at
57 Waterside Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the
same time handing to her personally the said true and correct copy ofthe same.
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states
that on June 23, 2006 at 12:15 o'clock P.M., he posted a true copy of the within Real
state Writ, Notice, Poster and Description, in the above entitled action, upon the property
of Sheila M. Gross located at 57 Waterside Drive, Carlisle, Pennsylvania 17013
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 ofthe pendency of the action to the within named
defendant, to wit: Sheila M. Gross, by regular mail to her last known address of 57
Waterside Drive, Carlisle, Pennsylvania 17013. This letter was mailed under the date of
June 26, 2006 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 September 06, 2006 at 10:00 o'clock A.M. He sold the same
for the sum of$I.00 to Attorney Leon Haller for Bank One, National Association, as
Trustee. It being the highest bid and best price received for the same, Bank One,
National Association, as Trustee of9350 Waxie Way, Suite 300, San Diego, CA 92123,
being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$I,838.25.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Prothonotary
Mileage
Levy
Surcharge
$30.00
36.04
45.00
45.00
30.00
10.00
1.00
4.40
45.00
40.00
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
905.00
563.00
19.31
25.00
39.50 ()
$1,838.25 v" I 0 / O~ I 0(, '---r
So ~w~
~~~~~~
R. Thomas Kline, Sheriff
~
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DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LA W ~
NO. 03-571 CIVIL '6 0 ~
IN MORTGAGE FORECLOSURE ~~
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
VS.
SHEILA M. GROSS,
AFFIDAVIT PURSUANT TO RULE 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 57 WATERSIDE DRIVE CARLISLE, PENNSYLVANIA 17013:
1. Name and address ofthe Owner(s) or Reputed Owner(s):
SHEILA M. GROSS
57 WATERSIDE DRIVE
CARLISLE, PA 17013
2. Name and address ofDefendant(s) in the Judgment, ifdifferent from that listed. in (1)
above: SAME
3. Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Cynthia Naught
31 Bellaire Avenue
Carlisle, PA 17013
Richard Wix, Esquire
4705 Duke Street
Harrisburg, PAl 71 09
4. Name and address oflast recorded holder of every mortgage of record:
PLAINTIFF HEREIN (AND ANY OTImRS 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
4-1/
I
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:
Tenants if any . . .
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, PAl 71 0 1
Tenant/Occupant
57 Waterside Drive
Carlisle, PA 17013
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated. )
I verify that the statements made in this Affidavit are true and correct to the best of
knowledge, information and belief I understand that false statements herein are ma s
penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authoritie .
er P A J.D. #15700
, Krug & Haller
19 North Front Street
Harrisburg, P A 17102
(717) 234-4178
DATE:May 30, 2006
.~
...
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
PLAINTIFF
NO. 03-571 CIVIL
SHEILA M. GROSS,
DEFENDANT(S)
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE:
Wednesday, September 06, 2006
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:
57 WATERSIDE DRIVE
CARLISLE, PENNSYLVANIA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 03-571 CIVIL
JUDGMENT AMOUNT $67,285.92
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
SHEILA M. GROSS
.-
.
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 ofthe 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, Pennsylvania 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 a 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 Sheriffs 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.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PAl 71 02
(717) 234-4178
,.
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~~
ALL those three tracts of land situate in Lower Frankford To~. Cumberland
County. Pennsylvania, bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin and stake at the comer of land of Paul R.
Young and Russell L. Mackey, et 81; thence along the line of land 'of Paul R. Young, crossing a
private road and through an iron pin on the southern side thereot: South 44 degrees 30 minutes
Wefrt 200 feet to an iron pin; thence by the same land and the same course. 35 feet, more or less,
to the low water line of the Conodoguinet Creek; thence by the said low water line. North 75
degrees 39 minutes West, 60 feet to a point on line of land conveyed or about to be conveyed to
Alverta M. Fry; thence by the latter laud, North 44 degrees 30 minutes East, 35 feet, more or
less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road
to an iron pin on the line of land of Russell L. Mackey. et at; thence by the latter land, South 65
degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in
accordance with a survey tbercofby Roger St Germain & As~e!. dated September 26. 1961.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein and other owners to the property herein conveyed over a private road from
the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his
heirs and.assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners, their heirs and assigns, of the land to the West hereof:
TRACT NO.1: BEGINNING at a stake at line of other land of K.. Swartz; thence by
said land, South 44 degrees 30 minutes West. a. distance of 225 feet, more or less, to the low
water JD8Ik of the Conodoguinet Creek; thence by the same up the Creek, North 52 degrees 15
minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry t North 44
degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 degrees
30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTAINING
0.27 acres, more or less.
TOGETHER with a right-of-way for the purpose of ingress and egress over other lands
of the Grantor herein to the property herein conveyed, over a private road from the p~blic road
leading from Bergner's Bridge to B10serviUe in common with the Grantor, his heirs and assigns,
said right-of-way to be approximately 1609 feet, more or less, from the said public road.
TRACl' NO.3: ALL that certain tract of land situate in Lower Frankford Township,
Cumberland County, Pennsylvania, bounded and descnOed as follows:
BEGINNING at an iron pin at the comec of land of Chester L. Fry and wife and Russell
L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a
private ~ South 44 degrees 30 mmlltes West 211.29 feet to SID. iron pin; thence by the same
land and the same courses, 35 ~ more or less, to the low water line of the Conodoguinet
Creek; theDce by the said low water line, North 75 degrees 39 minutes West 120 feet to the line
to land of Brinton F. Fomey and wife; thence by the latter lan~ North 44 degrees 30. ~mnt~
/,,/
./
"
Bast 3S feet, more or less. to an iron pin; theoce by the same land and the same course, crossing a
private road, 234.38 feet to an iro~ pin on the line of land of Russell L. Mackey. et a1; thence by
the latter land, through an iron pin in the center of said line, South 65 degrees 18 minutes East
110.28 feet to the Place of BEGINNING; said description being in accordance with a survey
tbereofby Roger St Germain & Associates, dated September 26, 1961.
TOGETHER with a right-of-way for the pUrpose of ingress and egress over other lands
of the prior Grantors herein and other owners to the property conveyed over a private road from
the public road leading from Bergner's Bridge to BlosemJ.le, in common with the prior Grantors,
their heirs and assigns.
SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or
owners. their heirs and assigns, of the land to the West hereof:
HAVING THEREON ERECTED A DWELLING KNOWN AS 57 WATERSIDE DRIVE,
CARLISLE, PA 17013.
BEING THE SAME PREMISEES WHICH Lee E. Grove and Laura Miller Grove
by deed dated 1/22/00 and recorded in Deed Book 238 Page 228
granted and conveyed unto Sheila M. Gross.
TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT
NO. 2003 571.
ASSESSMENT: 14-07-0475-004
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-571 Civil
CNIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK ONE, NATIONAL ASSOCIATION, TRUSTEE,
Plaintiff (s)
From SHEILA M. GROSS
(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) Ifproperty 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 $67,285.92
L.L.
Interest $22,271.75 - PER DIEM OF $19.56 TO SALE DATE 9/6/06
Atty's Comm % Due Prothy $1.00
Atty Paid $5118.00 Other Costs LATE CHARGES $30.97 PER
MONTH TO SALE DATE 9/6/06 - $712.31 - ESCROW DEFICIT - $6,591.60 - CORPORATE
ADVANCES - $9,030.54
Plaintiff Paid
Date: MAY 31, 2006
~
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name LEON P. HALLER, ESQUIRE
Address: 1719 NORTH FRONT STREET
HARRISBURG, PA 17102
Attorney for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ill No. 15700
Real Estate Sale # 79
On June 06, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Frankford Township, Cumberland County, PA
Known and numbered as 57 Waterside Drive,
Carlisle, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 06, 2006
By:
JO(lfi~fJ,
Real EState Sergeant
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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 Assistant 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
smce;
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 in the 19th and 26th day(s) of July and the
2nd day(s) of August 2006. 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
S ALE #79
.
'.
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
July 21, July 28, and August 4,2006
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.
TO AND SUBSCRIBED before me this
day of August. 2006
SWO
4
~:~~~JA/
r NOTARIAr'SEAL I
I LOIS E. SNYDER, Notary Public !
I Carlisle Boro.. Cumberland Countv I
f' My Commission Expires March 5, 200R I
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REAL ESTATE SALE NO. 79
Writ No. 2003-571 Civil
Bank One, National
Association, Trustee
vs.
Sheila M. Gross
Atty.: Leon P. Haller
ALL those three tracts of land
situate in Lower Frankford Town-
ship, Cumberland County, Pennsyl-
vania, bounded and described as
follows:
TRACT NO.1: BEGINNING at an
iron pin and stake at the comer of
land of Paul R. Young and Russell
L. Mackey, et al; thence along the
line of land of Paul R. Young, cross-
ing a private road and through an
iron pin on the southem side thereof
South 44 degrees 30 minutes West
200 feet to an iron pin; thence by
the same land and the same course,
35 feet, more or less, to the low
water line of the Conodoguinet
Creek; thence by the said low wa-
ter line, North 75 degrees 39 min-
utes West, 60 feet to a point on line
ofland conveyed or about to be con-
veyed to Alverta M. Fry; thence by
the latter land, North 44 degrees
30 minutes East, 35 feet, more or
less, to an iron pin; thence by the
same land the same course, 211.29
feet, crossing a private road to an
iron pin on the line ofland of Russell
L. Mackey. et al; thence by the lat-
ter land, South 65 degrees 18 min-
utes East, 55.14 feet to the Place
of BEGINNING said description be-
ing In accordance with a survey
thereof by Roger St. Germain &
Associates, dated September 26,
1961.
TOGETHER with a right-of-way
for the purpose of Ingress and
egress over other lands of the
Grantor herein and other owners to
the property herein conveyed over
a private road from the public road
leading from Bergner's Bridge to
BloservlIle in common with the
Grantor, his heirs and assigns.
SUBJECT to the aforesaid right-
of-way for ingress and egress in fa-
vor of the owner or owners, their
heirs and assigns, of the land to the
West hereof.
TRACT NO.2: BEGINNING at a
stake at line of other land of K.
Swartz; thence by said land, South
44 degrees 30 minutes West, a dis-
tance of 225 feet, more or less, to
the low water mark of the Cono-
doguinet Creek; thence by the same
up the Creek, North 52 degrees 15
minutes West, a distance of 51.5
feet to a point; thence along lands
of Chester Fry, North 44 degrees
30 minutes East, a distance of 231
feet to a stake; thence by the same,
South 45 degrees 30 minutes East,
a distance of 50 feet to a stake, the
PI",,,,, of BEGINNING. CONTAINING
TOGE'IHER with a right-of-way
for the purpose of ingress and
egress over other lands of the
Grantor herein to the property
herein conveyed, over a private road
from the public road leading from
Bergner's Bridge to Bloserville In
common with the Grantor, his heirs
and assigns, said right-of-way to be
approximately 1609 feet, more or
less, from the said public road.
TRACT NO.3: ALL that certain
tract of land situate In Lower
Frankford Township, Cumberland
County, Pennsylvania, bounded and
described as follows:
BEGINNING at an iron pin at the
comer of land of Chester L. Fry and
wife and Russell L. Mackey, et al;
thence along the line of land afore-
said of Chester L. Fry and wife,
crossing a private road, South 44
degrees 30 minutes West 211.29
feet to an iron pin; thence by the
same land and the same cour&es,
35 feet, more or less, to the low
water line of the Conodoguinet
Creek; thence by the said low wa-
ter line, North 75 degrees 39 min-
utes West 120 feet to the line to
land of Brinton F. Fomey and wife;
thence by the latter land, North 44
degrees 30 minutes East 35 feet,
more or less, to an iron pin; thence
by the same land and the same
course, crossing a private road,
234.38 feet to an iron pin on the
line of land of Russell L. Mackey, et
al; thence by the latter land, through
an iron pin in the center of said line,
South 65 degrees 18 minutes East
110.28 feet to the Place of BEGIN-
NING; said description being in ac-
cordance with a survey thereof by
Roger St. Germain & Associates,
dated September 26, 1961.
TOGE'IHER with a right-of-way
for the purpose of ingress and
egress over other lands of the prior
Grantors herein and other owners
to the property conveyed over a pri-
vate road from the public road lead-
ing from Bergner's Bridge to
Bloserville, in common with the
prior Grantors, their heirs and as-
signs.
SUBJECT to the aforesaid right-
of-way for ingress and egress in fa-
vor of the owner or owners, their
heirs and assigns, of the land to the
West hereof.
HAVING THEREON ERECTED A
DWELUNG KNOWN AS: 57 Water-
side Drive, Carlisle, PA 17013.
BEING THE SAME PREMISEES
WHICH Lee E. Grove and Laura
Miller Grove by deed dated 1/22/
00 and recorded in Deed Book 238
Page 228 granted and conveyed unto
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