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HomeMy WebLinkAbout03-0810IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, VS. SHARON K. BRYAN, Plaintiff, Defendants. CIVIL DIVISION COMPLAINT IN MORTGAGE FORECLOSURE Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 COMPLAINT IN MORTGAGE FORECLOSURE 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 THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the Commonwealth of Pennsylvania, having a principal place of business located at 150 Allegheny Center Mall, Pittsburgh, PA 15212. 2. The Defendant(s) is/are individuals with a last known mailing address of 68 East Main Street, Newville, PA 17241. The property address is 68 East Main Street, Newville, PA 17241 and is the subject of this action. 3. On the 29th day of December, 2000, in consideration of a loan of Seventy-One Thousand, Nine Hundred and No/100 ($71,900.00) Dollars made by First Franklin Financial Corporation, a DE corporation, to Defendant(s), the said Defendant(s) executed and delivered to First Franklin Financial Corporation, a DE corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s) and First Franklin Financial Corporation, as mortgagee, which mortgage was recorded on the 2nd day of January, 2001, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1661, page 372. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. 4. The premises secured by the mortgage are: (See Exhibit "A" attached hereto.) 5. Subsequent thereto, First Franklin Financial Corporation, a DE corporation, assigned to the Plaintiff, National City Home Loan Services, Inc., the said mortgage, that assignment being recorded in the Office of the Recorder of Deeds of Cumberland County and the said assignment is incorporated herein by reference. 6. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attorney's fees." 7. Since November 1, 2002, the mortgage has been in default by mason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 8. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the mortgagor(s). 9. The amount due on said mortgage is itemized on the attached schedule. 10. Plaintiff does hereby release the personal representative, heir and/or devisee of the mortgagor(s) from liability for the debt secured by the mortgage. demands judgment for the amount ($81,026.96) with interest and costs. WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff due of Eighty-One Thousand, Twenty-Six and 96/100 Dollars Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. Louis P. Vitti, Esquire Attorney for Plaintiff Bryah, Sharon K. Unpaid Principal Balance SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Interest ~ 9.5000% from 10/01/02 through 2/28/2003 (Plus $18.4951 per day afier 2/28/2003 ) Late charges through 2/20/2003 0 months ~ 30.23 Accumulated beforehand (Plus $30.23 Attorney's fee on the 17th day of each month after 2/20/2003 ) Escrow deficit (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) 71,060.31 2,774.27 190.15 3,553.02 3,449.21 BALANCE DUE 817026.96 EXHIBIT A - LEGAL DESCRIPTION 68 E MAIN STREET NEWVILLE, PA. 17241 ALL THAT CERTAIN tract of land with the buildings and improvements thereon erected situate in the Borough of Newville, Cumberland County, Pennsylvania, more particularly bounded and described as follows; BEGINNING AT THE CURB LINE ON East Main Street on a line with the West side of a brick pillar; thence Westwardly 50 feet to Parsons Alley; thence by said alley Southwardly 180 feet to Church or Glebe Alley; thence Eastwardly on the alley 48 feet to a comer; thence Northwardly by property now or formerly of Daniel H. Heller in a straight line to the curb, the Place of BEGINNING. HAVING THEREON ERECTED a dwelling house known and numbered as 68 East Main Street. BEING THE SAME PROPERTY which Kathryn S. Woodbum, widow, by Deed dated April 2, 1977 in the Office of the Recorder of Deeds in and for Cumberland Cotinty, Pennsylvania in Record Book E Volume 27, page 96, granted and conveyed unto Glenn B. Heckendorn and Earlene D. Heckendom, husband and wife. Glenn E. Heckendom died May 18, 1998, thus vesting the entire title in Earlene D. Heckendom, widow. AND BEING the same premises which Earlene D. Heckendom, by her deed dated and recorded even date herewith in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, granted and conveyed unto Sharon Bryan, Mortgagor herein. ,~ EXHIBIT' ', VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Loui(P. Vitti Dated: February 20, 2003 SHERIFF'S RETURN - REGULAR CASE NO: 2003-00810 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY HOME LOAN SERVIC VS BRYAN SHARON K BRYAN WARD , , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BRYAN SHARON K the DEFENDANT at 10 LAFAYETTE STREET NEWVILLE, PA 17241 , at 1940:00 HOURS, on the 10th day of March , 2003 by handing to TIFFANY BLAIN, DAUGHTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this f 7~ day of So Answers: R. Thomas Kline 03/11/2003 LOUIS VITTI By: fDepu~ ShY'ri f f NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Sharon K. Bryan 10 Lafayette Street Newville, PA 17241 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 3, 2003 at 10:00 A.M., the following described real estate, of which Sharon K. Bryan are owners or reputed owners: Newville Boro, Cumberland Cty & Cmwlth of PA. HET a dwg k/a 68 East Main Street, Newville, PA 17241. Parcel No. 27-20-1756-094. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Home Loan Services, Inc., et al vs. Sharon K. Bryan at No. 03-810 Civil Term in the amount of $81,859.23. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is flied in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgrnent against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. 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 NOTICE AND THE WRIT OF EXECUTION 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Louis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, SHARON K. BRYAN, Plaintiff, VS. Defendant. NO. 03-810 CIVIL TERM LEGAL DESCRIPTION ALL that certain tract of land with the buildings and improvements thereon erected situated in the Borough of Newville, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at the curb line on East Main Street on a line with the West side of a brick pillar; thence Westwardly 50 feet to Parsons Alley; thence by said alley Southwardly 180 feet to Church or Glebe Alley; thence Eastwardly on the alley 48 feet to a comer; thence Northwardly by property now or formerly of Daniel H. Heller in a straight line to the curb, the place of beginning. HAVING thereon erected a dwelling house known and numbered as 68 East Main Street, Newville, PA 17241. PARCEL NO. 27-20-1756-094. BEING the same premises which Earlene D. Heckendom by deed dated 12/29/2000 and recorded on 01/02/2001 in Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 237, page 61, granted and conveyed unto Sharon K. Bryan. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, VS. SHARON K. BRYAN, Defendant. NO. 03-810 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 National City Home Loan Services, Inc., et al, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 68 East Main Street, Newville, PA 17241. 1. Name and address of Owner(s) or Reputed Owner(s): Name: Sharon K. Bryan Name: Address (Please indicate if this cannot be reasonably ascertained) 10 Lafayette Street Newville, PA 17241 Name and address of Defendant(s) in the judgment: Address (Please indicate if this cannot be reasonably ascertained) Same as No. 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Dennis W. Hancock Jenn D. Hancock Address (Please indicate if this cannot be reasonably ascertained) 204 West Main Street Walnut Bottom, pA 17256 Waypoint Bank P.O. Box 1711 Name First Franklin Financial Corp. Name None 235 North Second Street Harrisburg, PA 17105 4. Name and address of the last recorded holder of every mortgage of record: Address (Please indicate if this cannot be reasonably ascertained) 512 City Boulevard Waycross, GA 31501 5. Name and address of every other person who has any record lien on the property: Address (Please indicate if this cannot be reasonably ascertained) 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) None 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tax Collector of Newville Borough Newville Water & Sewage Authority Commonwealth of PA -DPW Clerk of Courts Criminal/Civil Division Address (Please indicate if this cannot be reasonably ascertained) 108 West Street Newville, PA 17241 4 West Street Newville, PA 17241 P.O. Box 8016 Harrisburg, PA 17105 One Courthouse Square Carlisle, PA 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse Court of Common Pleas of Cumberland County Domestic Relations Division Bureau of Compliance Tenant/Occupant One Courthouse Square Carlisle, PA 17013 P.O. Box 320 Carlisle, PA 17013 Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough 68 East Main Street Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. April 14, 2003 Date Louis P. Vitti, Esquire Attorney for Plaintiff SWORN TO and subscribed before me this 14th day of April, 2003. of'aw Pubhc Ld~S ~ EV,,~aEUST~, No'r,,av ~,u~c CITY OF PITTSBURGH, ALLEGHENY COU g COMMISSION EXRRES OCTOBER 17, 200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03=810 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY HOME LOAN SERVICES, INC., ASSIGNEE OF FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff (s) From SHARON K. BRYAN, 68 EAST MAIN STREET, NEWVILLE, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $81,859.23 L.L. $.50 Interest --- $2,626.30 Atty's Comm % Due Prothy $1.00 Atty Paid $118.28 Other Costs Plaintiff Paid Date: APRIL 17, 2003 (Seal) REQUESTING PARTY: Name LOUIS P. VITTI, ESQUIRE Address: LOUIS P. VITTI & ASSOC., P.C. 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 CURTIS R. LONG Prothonotyy ~ ,.. Deputy Supreme Court ID No. 3810 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, SHARON K. BRYAN, Plaintiff, VS. Defendant. NO. 03-810 CIVIL TERM LEGAL DESCRIPTION ALL that certain tract of land with the buildings and improvements thereon erected situated in the Borough of Newville, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at the curb line on East Main Street on a line with the West side of a brick pillar; thence Westwardly 50 feet to Parsons Alley; thence by said alley Southwardly 180 feet to Church or Glebe Alley; thence Eastwardly on the alley 48 feet to a comer; thence Northwardly by property now or formerly of Daniel H. Heller in a straight line to the curb, the place of beginning. HAVING thereon erected a dwelling house known and numbered as 68 East Main Street, Newville, PA 17241. PARCEL NO. 27-20-1756-094. BEING the same premises which Earlene D. Heckendom by deed dated 12/29/2000 and recorded on 01/02/2001 in Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 237, page 61, granted and conveyed unto Sharon K. Bryan. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, SHARON K. BRYAN, Plaintiff, VS. Defendant. NO. 03-810 CIVIL TERM AFFIDAVIT I, Louis P. Vitti, hereby certify that as representative of National City Home Loan Services, Inc., et al am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. Louis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 14th day of April, 2003. ~blic ~' NOTARIAL SEAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, CIVIL DIVISION NO. 03-810 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS VS. SHARON K. BRYAN, Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, VS. SHARON K. BRYAN, Defendant. NO. 03-810 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $81,859.23 Interest 04/15/03-09/03/03 2,626,30 Total $84:485.53 The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate Newville Boro, Cumberland Cty & Cmwlth of PA. HET a dwg k/a 68 East Main Street, Newville, PA 17241. Parcel No. 27-20-1756-094. Attorney for Plaintiff IN THE COURT OF COMPDN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF ~CXJTION Caption: : : National City Home Loan Set,rices, Inc., et al, : : Sharon K. Bryan, ( ) Confessed Judgment ( ) Other File No. 03-810 Civil Term : Interest : Atty's Co~n : Costs $81~859.23 2,626.30 TO THE PROTHO~ARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retm~ l installment sale, contract, or account based on a confession of jud~nent, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property purst~_nt to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the roi!owing described property of the defendant(s) See attached legal description. pR~WCTPE FOR A~T~ EXELTTfTON Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four' copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee( s ). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: April 14~ 2003 Signature:~~ Print Name: Address: A~torney for: Te!eghone: Louis P. Vitti 916 Fifth Avenue Pittsburgh, PA 15219 Plaintiff (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., · assignee of FIRST FRANKLIN FINANCIAL · CORPORATION, · NO. SHARON K. BRYAN, Plaintiff, Defendant. 03-810 CIVIL TERM LEGAL DESCRIPTION ALL that certain tract of land with the buildings and improvements thereon erected situated in the Borough of Newville, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at the curb line on East Main Street on a line with the West side ora brick pillar; thence Westwardly 50 feet to Parsons Alley; thence by said alley Southwardly ! 80 feet to Church or Glebe Alley; thence Eastwardly on the alley 48 feet to a comer; thence Northwardly by property now or formerly of Daniel H. Heller in a straight line to the curb, the place of beginning. HAVING thereon erected a dwelling house known and numbered as 68 East Main Street, Newville, PA 17241. PARCEL NO. 27-20-1756-09~,. BEING the same premises which Earlene D. Heckendom by deed dated 12/29/2000 and recorded on 01/02/2001 in Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 237, page 61, granted and conveyed unto Sharon K. Bryan. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, SHARON K. BRYAN, Plaintiff, VS. Defendant. NO. 03-810 CIVIL TERM AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the Defendants' last known address is 68 East Main Street, Newville, PA 17241. Louis P. Vitti, Esquire SWORN TO and subscribed before me this 14th day of April, 2003. NOTARIAL 8F.N. LOIS A. EVANGEU8TA, NOTARY PUBLIC CITY OF PffTSBURGH, AU.EGHENY COUNTY MYCOM~SlON EXPIRES OCTOBER 17, 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLrNTY, PENNSYLVANIA NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, CIVIL DIVISION NO. 03-810 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- MILITARY SERVICE VS. SHARON K. BRYAN, Defendants. Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, VS. SHARON K. BRYAN, Defendant. NO. 03-810 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO: PROTHONOTARy OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of $81,859.23, in favor of the National City Home Loan Services, Inc., et al, Plaintiff in the above-captioned action, against the Defendants, Sharon K. Bryan and assess Plaintiffs damages as follows and/or as calculated in the Complaint: Unpaid Principal Balance Interest from 10/01/02-04/14/03 (Plus $18.4951 per day after 04/14/03) $71,060.31 3,606.54 Late charges (Plus $30.23 per month from 02/20/03-09/03/03 $181.38) Attorney's fee Escrow Deficit (Plus any additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) 190.15 3,553.03 Total Amount Due ~ The real estate, which is the subject matter of the Complaint, is situate in Newville Boro, Cumberland Cty & Cmwlth of PA. HET a dwg k/a 68 East Main Street, Newville, PA 17241. Parcel No. 27-20-1756-094. Louis P. Vitti, Esquir~-~ Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, VS. SHARON K. BRYAN, Defendant. : NO. 03-810 CIVIL TERM CERTIFICATION OF MAILING I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on April 1, 2003, giving ten (10) day notice that judgment would be entered should no action be taken. LOUIS P. VITTI & ASSOCIATES, P.C. SWORN to and subscribed before me this 14th day of April, 2003. BY: Louis P. Vitti, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of · FIRST FRANKLIN FINANCIAL CORPORATION, . SHARON K. BRYAN, VS. Plaintiff, · ; .- Defendant. · NO. 03-810 CIVIL TERM IMPORTANT NOTICE TO: Sharon K. Bryan 10 Lafayette Street Newville, PA 17241 Date of Notice: April 1, 2003 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LO VITTI CITES, P.C~ BY: uis P. ~itti, Esquire"' ~f/~/~ Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 ** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** AFFIDAVIT OF NON-MILITARY STATUS TO THE BEST OF MY KNOWLEDGE AND BELIEF, Sharon K Bryan IS NOT NOW, NOR HAS BEEN IN THE LAST 90 DAYS, A PERSON IN THE MILITARY SERVICE OF THE UNITED STATES AS THAT TERM IS DEFINED IN THE SOLDIERS AND SAILORS CIVIL RELIEF ACT OF 1940. ALSO, TO THE BEST OF MY KNOWLEDGE AND BELIEF, THE AFORE SAID PERSON(S) OWN(S) THE REAL ESTATE AT: 10 Lafayette St Newville, PA 17241 MORTGAGE LOAN 1004009672 HELD OR SERVICED BY NATIONAL CITY HOME LOAN SERVICES. Ta'ryn/T', (J~d~e a r-y- --A FORECLOSURE SPECIALIS~ STATE OF PENNSYLVANIA, CITY/COUNTY OF ALLEGHENY I, , A NOTARY PUBLIC IN AND FOR THE JURISDICTION AFORESAID DO HEREBY CERTIFY THAT Taryn L. McCreary OF THE FORECLOSURE DEPARTMENT OF NATIONAL CITY HOME LOAN SERVICES, WHOSE NAME AS SUCH SIGNED TO THE FOREGOING INSTRUMENT HAS ACKNOWLEDGED THE SAME BEFORE ME. GIVEN UNDER MY HAND NOTARY PUBLIC MY COMMISSION EXPIRES: FC130/TM1 Notarial Seal Gall A. Walter, Notary Public City Of Piltsburgh, Allegheny Counly MY Commission ExCres Apr. 2, 2006 IV~-~ber, Pennsylvania Association Of Nolaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, CIVIL DIVISION NO. 03-810 CIVIL TERM, AFFIDAVIT OF SERVICE Plaintiff, VS. SHARON K. BRYAN, Defendant. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY HOME LOAN SERVICES, INC., assignee of FIRST FRANKLIN FINANCIAL CORPORATION, Plaintiff, VS. SHARON K. BRYAN, Defendant. NO. 03-810 CIVIL TERM AFFIDAVIT OF SERVICE I, Audra J. Hunger, do hereby certify that a Notice of Sale was mailed and served upon all lien holders by Certificate of Mailing for service in the above-captioned case on April 21, 2003, advising them of the Sheriffs sale of the property at 68 East Main Street, Newville, PA 17241, on September 3, 2003. SWORN to and subscribed before me this 24th day of July, 2003. LOUIS P. VITTI & ASSOCIATES, P.C. "~udra~J. Hun) r~'-~' CERTIFICATE OF MAILING Louis P. Vltti & Associates, P.C. 916 Fifth Avenue. Pittsbureh. PA 15219 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S. POSTAL SERVICE CERTIFICATE OF MAILING Louis P. Vittl & Associates. P.C. 916 Fifth Avenue, Pittsburah. PA 15219 Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, PA 17013 PS Form 3817, January 2001 A J/Bryan/9-3-03 US. POSTAL SERVICE CERTIFICATE OF MAILING Louis P. Vittl & Associates. P.C. 916 Fifth Avenue. Pittsbureh. PA 15219 Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR OOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSU PJ~N CE-POSTMASTER Louis P. Vittl & Associates. P.C. 916 Fifth Avenue. Pittsburoh. PA 15219 Tenant/Occupant 68 East Main Street Newville, PA 17241 PS Form 3817, January 2001 AJ'/Bryan~9-3-03 A Af US. POSTAL SERVICE CERTIFICATE OF MAILING MAy aE USED FOR DOMESTIC AND INTERNATIONAL MAiL~ DOES NOT PROVIDE FOR INSURANCE.POSTMASTER Louis P. Vitti & Associates. P.C. 916 Fifth Avenue. Plttsburqh. PA 1521~) Tax Collector of Newville Borough 108 West Street Newville, PA 17241 PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S. POSTAL SERVICE CERTIFICATE OF MAILING Louis P. Vltti & Associates, P.C. 916 Fifth Avenue. Plftsburqh, PA 1521.3 Newville Water & Sewage Authority 4 West Street Newville, PA 17241 PS Form 3817, January 2001 A J/Bryan/9-3-03 US POSTAL SERVICE CERTIFICATE OF MAILING Louis P. Vlffi & Associates, P.C. 916 Fifth Avenue. Piftsburqh, PA 1521q Commonwealth of PA - DPW P.O. Box 8016 Harrisburg, PA 17105 PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S POSTAL SERVICE CERTIFICATE OF MAILING LOUIs P. Vittl & Associates. P.C. 916 Fifth Avenue, Pittsburqh, PA 1521q Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 PS Form 3817, January 2001 A J/Bryan/9-3-03 pc fe pc P( fe ^f Affix US. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND ~NTERNATIONAL MA~L, DOES NOT PROVIDE FOR INSURANCE.POSTMASTER .Louis p. Vitfi & Associates. P.C. _916 Fifth Avenue, Pittsburqh, PA 1521q Dennis W. Hancock 204 West Main Street Walnut Bottom, PA 17256 PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S. POSTAL SERVICE CERTIFICATE OF MAILING .Lou s P. Vitti & Associates, P.C. 916 Fifth Avenue. Ptttsburclh, PA 15219 Jenn Hancock 204 West Main Street Walnut Bottom, PA 17256 PS Form 3817, January2001 A J/Bryan/9-3-03 U.S. POSTAL SERVICE CERTIFICATE OF MAILING Louis p. Vitti & Associates, P.C. 916 Fifth Avenue, PIttsbur~lh, PA 1521q Waypoint Bank 235 North Second Street P.O. Box 1711 Harrisburg, PA 17105 PS Form 3817, January 2001 A J/Bryan/9-3-03 U.S, POSTAL SERVICE CERTIFICATE OF MAILING MAy BE USED FOR DOMESTIC ANO iNTERNATIONAL MAIL, DOES NOT ,, PROVIDE FOR INSURANCE.POSTMASTER Louis P. Vitti & Associates, P.C. _ 916 Fifth Avenue, PIttsburqh, PA 1521q First Franklin Financial Corp. 512 City Boulevard Waycross, GA 31501 PS Form 3817, January2001 A J/Bryan/9-3-03 Af COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND j~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which National City Home Loan Serv is the grantee the same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ Execution issued on the 17th day of April, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 810, at the suit of National city Home Loan serv Inc against Sharon K Bryan is duly recorded in Sheriff's Deed Book No. 259, Page 1811. IN TESTIMONY WHEREOF, I have hereunto set my hand ~/F--~ day of , A.D. 2003 (r~ ~/tj ~ ~ orderofDeeds and seal of said office this National City Home Loan Services Inc., assignee of First Franklin Financial Corporation VS Sharon K. Bryan In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-810 Civil Term Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on June 16, 2003 at 10:42 o'clock AM, 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: Sharon K. Bryan, by making known unto Sharon Bryan, personally, at 10 Lafayette Street, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Shmmon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2003 at 2:01 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 Sharon K. Bryan located at 68 East Main Street, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Sharon K. Bryan, by regular mail to her last known address of 10 Lafayette Street, Newville, PA 17241. This letter was mailed under the date of July 3, 2003 and never returned to the SherifPs 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 3, 2003 at I0:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Louis P. Vitti for National City Home Loan Services. It being the highest bid and best price received for the same, National City Home Loan Services of 150 Allegheny Center, Pittsburgh, PA 15212, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $662.19. Sheriffs Costs: Docketing $30.00 Poundage 12.98 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 16.56 Levy 15.00 Surcharge 20.00 Law Journal 214.25 Patriot News 188.50 Share of Bills Distribution of Proceeds Sheriffs Deed 28.90 25.00 39.50 $ 662.19 Sworn and subscribed to before me Tiffs I~- day of (2~)e~t~. 2003, A.D.(~/~.. /~ )~k~, ~/~ 'Ptothonotary R. Thomas Kline, Sheriff Real Esta~j~ Deputy Real Estate Sale # 04 On April 29, 2003 the sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA known and numbered as 68 East Main Street, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: April 29, 2003 By: Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mamh 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice er publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) ef 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 ara 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. PU BLICATION coP,/ s;;'/; ;; cr, bed bo' 'e Te~7 L. Russell, N(~31~ Pul3iic City Of Har~ourg, Dau0hin C~u~y N OT,~'RY PUBLIC My ~ Expires June 6, 2{~6 Member. Pen~y~vanta~O~N~arie~ Y commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., br. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total 186.75 1.75 188.50 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. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 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 ESTA'I'E SALE NO. 4 Writ No. 2003-810 Civil National City Home Loan Services. Inc., assignee of First Franklin Financial Corporation VS. Sharon K. Bryan At[y.: Louis P. vita LEGAL DESCRIPTION ALL that certain tract of land with the buildings and improvements thereon erected situated in the Bor ough of Newvllle, Cumberland County, Pennsylvania. more par ticularly bounded and described as follows: BEGINNING at the curb line on East Main Street on a line with the West side of a brick pillar: thence Westwardly 50 feet to Parsons Al- ley; thence by said alley South- wardly 180 feet to Church or Glebe Alley; thence Eastwardly on the al- ley 48 feet to a comer; thence North- wardly by property now or formerly of Daniel H. Heller in a straight line to the curb. the place of beginning. HAVING thereon erected a dwell- lng house known and numbered as 68 East Main Street. Newvllle. PA 17241. PARCEL NO, 27-20-1756-094. BEING the same premises which Earlene D. Heekendorn by deed dated 12/29/2000 and recorded on 01/02/2001 in Cumberland County. Permsylvanla~ Recorder of Deeds Of flee in Deed Book Volume 237. page 61, granted and conveyed unto Shar- on K. Bryan. SWORN TO AND SUBSCRIBED before me this 1 day of AUGUST, 2003 ALL that certain tract of land with ough of Newvllle, Cumberland tieularly bounded m~d described as follows: BEGINNING at lhe curb line on East Main Street on a Fmc with the West side of a brick pillar: thence Westwardly 50 feet to Parsons Al- ley: thence by said alley South- wardly 180 feet to Church or Glebe Alley: thence Eastwardly on the al- wardly by propert~j now or formerly of Daniel H. Heller in a straight line to the curb. the place of beginning~ HAViNG thereon erected a dwell- lng house t~mwn and numbered as 68 East Main Street. Newvllle, PA 17241. PARCEL NO. 27-20-1756-094. BEING the salne prea~laes which Earlene D. Heckendorn by deed dated 12/29/2000 and recorded on 01 / 02,/2001 in Cumberland County, Pennsylvania. Recorder of Deeds Of- flee in Deed Book Volume 237, page 61. granted and conveyed unto Shar- on K. Bryan.