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.