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TI II.; I' J !i.';T NAT I "NAI, HAN V "I,'
MAHYSVILLE
! :-1 '!'!!!.: ('1_1UJ~'1' UF COMMON PL~^S
(;1' ('IJr'lHI';FJ.ANlJ COUNTY, PA
I'Ll int i II
vs
NO.
')8 -01>0"/4 CIVIL
KENNETH W. JACKSON
Defendant/"
MOHTGN;I.; FORECLOSURE
crVrL, ACTION - LAW
Please enter judgment in favor of Plaintiff and against
Defendant/s, Kenneth W. Jackson, Apt.101, School House Apartments,
Duncannon, PA 17020 for failure to plead to the Complaint within
twenty days from service thereof. I certify that the Default
Notice required by Rules of Court was sent to the Defendant as
shown on the copy attached hereto. Assess damages as follows:
$43,725.10 together with interest at the per diem rate of $9.11
after October 23, 1998, and all other charges and costs incidental
thereto to the date of Sheriff's Sale and for foreclosure and sale
of the property within described.
To
Prothonotary
February,
\
, 1999
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Attorney for Plaintiff
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THE FIRST NATIONAL BANK OF
MARYSVILLE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
Plaintiff
vs
No. 98-06074 CIVIL
KENNETH W. JACKSON
Defend<lnt/s
MORTGAGE FORECLOSURE
CIVIL ACTION - LAW
To KENNETH W. JACKSON,
Defendant/s
You are hereby notified that on FEBRUARY
the following judgment has been entered
captioned case.
1ST, 1999,
against you in
the above
DEFAULT JUDGMENT IN THE AMOUNT OF $43,725.10 TOGETHER WITH
INTEREST AT THE PER DIEM RATE OF $9.11 AFTER OCTOBER 23, 1998, OTHER
CHARGES AND COSTS INCIDENTAL THERETO TO THE DATE OF SHERIFF'S SALE
AND JUDGMENT AGAINST DEFENDANT AND FOR FORECLOSURE AND SALE OF THE
PROPERTY WITHIN DESCRIBED.
DATE: FEBRUARY /~i-, 1999
/.;/ f1d,~I-1l ~
I Prothonotary
I hereby certify that the name and address of the proper person/s to
receive this notice is;
KENNETH W. JACKSON
APT. 101
SCHOOL HOUSE APARTMENTS
DUNCANNON, PA 17020
FIRST NATIONAl, HANK OF
MAl{ YSV I LLE
cOlJwr ew CO~~M()N PLEAS
CIJMI\,':R!,ANIJ COUNTY, PENNSYLVANIA
Plaintiff
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No. 98-06074 CIVIL
KENNETH W. JACKSON
DeEendant/s
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
Pursuant to Pi!. R.C.p No. 237.1 (a) (2)
To: KENNETH W. JACKSON
DEFENDANT/S
DATE OF NOTICE: December 10, 1998
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 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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
4 TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
Signature
Signature of Plaintiff or Atty.
Address: 13 0 9 BRIDGE STREET
NEW CUMBERLAND, pA 17070
Phone No. (717) 770-0292
I.D. # 07172
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IN TilE COUI{'_LQI:...~:m~'1!'tQJLI'J,!'lI,<;_QI:' CUMBlmr,ANlJ COUNTY. I'I-:NNSYI,VI\N..LlI
c:l I( II, III V IS ION
I'HAECII'E FOH WHIT 0(.' EXECUTION
THE FIHST NATIONAl. BANK OF
MARYSVll.I.E
( ) Confenocd Judgmcnt
(X) Othcr__IlEI:.lIYFl'----'TUQQ11.I~NT,
MORTGAGE FORECLOSURE
vo.
KENNETH W. JACKSON
APT. 101
SCHOOL HOUSE APARTMENTS
DUNCANNON. PA 17020
Defendant
File No. 98 06074 CIVIL
Amount Due $41.642.96
Interest FROM 10/23/98 @ 9.11
per diem
Atty's Comm $2.082.14
Costs Total $43.725.10
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise
out of a retail installment sale, contract, or account based on a
confession of judgment, 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 pursuant 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
following described property of the defendant{s} 319 Second
Street. West Fairview. Pa. 17025
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of
County, for debt, interest and costs, as above, directing
attachment against the above-named qarnishee(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: 7-\' ll\'i. Signature: 0- \ ~\ \,~
Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
Attorney for Plaintiff
(717) 770-0292
ID No. 1t07172
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THE FIRST NAT [(JNAI. HANK OF
MARYSVILLE
IN TH!'; ('( Jin<T OF COMMON PLEAS
(iF ('ij:-lH!-:I<I./\NIJ COUNTY, 1',1
Plaintiff
iF). lJd (Jld.l)'l CIViL
vn.
rI;U!(~'I_;^(;l': FU1~:':CLO:;URE
KENNETH W. JACKSON
CIVIl. ACTroN - LAW
Defendants
NOTICE OF SHERIFF'S SALr. OF Rr.A[, PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE
That the Sheriff's Sale of Real Property (Real Estate) will
be held on June 9, 1999 in the Cumberland County Courthouse,
Carlisle, Pennsylvania at 10:00 A.M. prevailing local time.
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:
319 Second Street
West Fairview, PA 17025
The judgment under or pursuant to which your property is being sold
is docketed to:
98-06074 CIVIL
Cumberland County, pennsylvania
The name(s) of the owner(s) or reputed owner(s) of this property
is:
KENNETH W. JACKSON
APT. 101
SCHOOL HOUSE APARTMENTS
DUNCANNON, PA 17020
A SCHEDULE OF DISTRIBUTION, being a list of the persons
being entitled to receive part of the proceeds of the sale
received and to be disbursed by the Sheriff will be filed by the
Sheriff thlrty (30) days after the sale and distribution of the
proceeds if 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
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Common PleaD of C'lImh'rl<11HI COLlllLy, c'll'Ii.~;I(~, P^
("/1"1) 7.106390.
THIS PAPER [S ^ NOTfCf': OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPEWI"Y.
It: h"" been [''''lied ),',,-"duse t:hf"'f" is d Judgment: d'Jdinst you.
It mClY cause your propert.y to be held, to be sold 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 TillS 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.
Pennsylvania Lawyer Referral Service
Pennsylvania Bar ^"sociation
213 N Front Street
P.O. Box 186
Harrisburg, PA 17108
(800) 692-7375
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the jUdgment if you have a
meri torious 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 Sheriff's Sale you may file a petition with the
Court of Common Pleas of Cumberland 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 Cumberland 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, Cumberland County Courthouse,
Carlisle, PA, before presentation of the petition to the
Court.
Arthur M. Feld
Attorney for Plaintiff
Arthur M. Feld, Esq.
ALL THOSE two (7.) lot,; 01" piec',,; o[ fjl"ound situate in the
Borough of West Fail.vi.,w, County of Cumberland, Stelte of
Pennsylvania, more fully bounded dIld def.jcribf'd d~j follow, to wit:
TRACT 1
BEGINNING at a corner on the East side of Second Street at the
corner of lot now or formerly of Mary E. Rowland; Thence in an
easterly direction along Tract II described herein, 153 feet to a
point at the corner of land now or formerly of M. B. Stewart; THENCE
20 feet 6 inches in a generally northerly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of William Musser in a westerly direction 158
feet to the aforesaid Second Street; THENCE in a southerly
direction along the East side of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge 135 feet; THENCE in a
northwesterly direction by land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract 1
herein described, 153 feet to the East side of aforesaid Second
Street; THENCE by the East side of Second Street, South 116 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 319
Second Street, West Fairview, Cumberland County, Pennsylvania.
EXPECTING therefrom a tract of ground conveyed by Violet B.
Rowland, single wor.\en, by Deed dated September 18, 1956, and
recorded in the Cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order of the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Common
Pleas of Cumberland County, Docket No. 1667 Civil 1986.
BEING the same two tracts of land by Deed dated June 25, 1990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mortgagors herein. Hannah J.
Jackson departed this life on August 24, 1998 whereby title passed
to Kenneth W. Jackson.
Tax Parcel No. 45-17-1044-085
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SEIZED, tdk"ll
KCIlnctll W. Jilckson,
CIVIL.
it! ('X,'r'lll i(Jtl ! () l}l' :;old <I:; ch.'
MortJfolql)! :1"1" i:1 lInd.-I' ,JUChJrlH!lIl
!J!-()p"rt y of
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NOTiCE 10 furtill!!' qlV"il II' dll pdrti'!f; ill illLI~l,.~;t dll(J
clailllLlntn. 1\ propof;ed :.;('!JI_'dlll,' (1/ Ili~:tl ibutlCJfl o[ Lhfl pl.()(_..~t~d:; ()f
the abrJV~-' ~dl~ 'IJill be Li 1!~;J liY t}jt. .'--;iJ.,tiff ()f Curnbt~rl(lnd Count.y,
Pennsylvania, on July 9, 1\J()(J, dlHi t.hat difJtribuLic>ll of said
proceeds will be made in ilcconLlllc'" with "aid propo""d "c1E,dule
thirty (30) days after the dill" of ",11" ullle,,,, exceptioll" ,1I"C filed
thereto within tell (10) days lhe~"dfl0r.
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KENNETH \'1. ,IN T::uN
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TilE [,' Ii,ST N;,'i'IONAL BANK Ol' ;.iARYS\!, L.LE, Plaint i [r in Lil' above
captioned action, sets forth as of the daLe the praecipe for Llle
writ uf execution was filed the following information concerning
the real pr'operty located at 319 Second Street, I'lest Fairview,
Cumberland, County, Pennsylvania, 17025 more specifically described
in Exhibit 'IA", attached hereto.
1. Name and address of Owner(s) or reputed owner(s):
Address
reasonably
indicate)
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( if address
ascertained,
be
cannot
please
so
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Kenneth W. Jackson
Apt. 101
School House Apartments
Duncannon, PA 17020
2. Name and address of Defendant (s) in the Judgment:
Address (if address cannot be
reasonably ascertained, please
so indicate)
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Kenneth W. Jackson
Apt. 101
School House Apartments
Duncannon, PA 17020
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3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
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HunJl1(Jil lJ[ ~,;,';;l !...li!".::,....
(JK S. El1oL,1 Drivi,'
Enol<1, PA 1'/O~;~)
PA HounLng Fil1dnc>,~ ^(I'~llCY
HomeownCl-S Elllct-gency M{)~.tq(vV: ^:;:; i ;;tdl1C'. !Jl'()qt'arn
2101 N FranC Scn:"t
PO Box 15530
!!'1:-; i :~bl1!-""L p{-'Tln~':,1"Jl::: . '11 nc r'C,'I,I)
4. Name and addresf3 of tht~ L--l;;l l'..::'c:c)~'ded hnldcr of every mortgage
of i".:L.:urd:
Addt.es:,:; (i f address cannot be
reasoIlably ascertained, please
so indic3t.~)
First National Bank of Marysville
P.O. Box Il
Marysville, pennsylvania 17053-0017
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
5. Name and address of every other person who has any record lien
on the property:
Address (if address cannot be
reasonably ascertained, please
so indicate)
First National Bank of Marysville
P .0. Box B
Marysville, Pennsylvania 17053-0017
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
Borough of West Fairview
98 S. Enola Drive
Enola, Pennsylvania 17025
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NLlrn'~ and add_n:!~;:; uf t ''I'' toy
interest in th.~ pr()p!~J"I'l -lIlt!
the sale:
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P"I'::'Jll
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'.-JII!) 11-1:; ,lIlY recor:d
"'''I b" "[f,,cted by
^d_dl"l~:::; (i I ,lddr"::H C"dnI1ot be
l'(~d~>nll,lbly d:j('I~rtdillC'd, pleClse
f30 indicdl>!)
Tho:;'-~ !llmr>rl in P'lt",lq ~ul: . ,. J,
tl lnd r-) "11- '-1'."---'.
7.
Name and address of every
Ld.::> knowledge who hzw tiny
be a fLeeted by the sale:
othet- person of whom the plaintiff
interest in tht, i..JLUP'..:!l'ty whIch may
Address (if address cannot be
reasonably ascertained, please
so indicate)
Those named in Paragraphs 3, 4 and 5 above and One Mansion
Hill, Inc. 3401 N. Front Street, Harrisburg, Pennsylvania 17110
(fireplace chimney encroachment) Allen B. & Karen E. Ruch at 315
2nd Street, West Fairview, PA successor in title One Mansion Hill,
Inc.
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.
Dated: tin ('IS
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C~'h
Larry D. RelC
Vice President for
The First National Bank of Marysville
Plaintiff
Arthur M. Fold, Esq.
ALL THOSE two (2) 10t:J or piec"" of ground situate in the
Borough of West Fairvio'", County of cumberland, State of
Pennsylvania, mor~ fully bounded and deucribed au follow, to wit:
TRACT 1
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BEGINNING at a corner on the Eaut: aide of Second Street at the I'"
corner of lot now or formerly of Mary E, Rowland; Thence in an
easterly direction along Tract II described herein, 153 feet to a
point at the corner of land now or formerly of M.B. Stewart; THENCE
20 feet 6 inches in a generally nort:herly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of william Musser in a westerly direction 158
feet to the aforesaid Second Street; THENCE in a southerly
direction along the East side of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at: a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge 135 feet; THENCE in a
northwest:erly direction ~v land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract 1
herein desc::-ibed, 153 feet to the East side of aforesaid Second
Street; THENCE by the East: side of Second Street, South 116 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 319
Second Street, West Fairv~ew. Cumberland County, pennsylvania.
EXPECTING therefrom a tract of ground conveyed by Violet B.
Rowland. single women, by Deed dated September 18, 1956, and
recorded in the Cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order of the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Com~on
Pleas of cu~berland County, Docket No. 1667 Civil 1986.
BEING the same two tracts of land by Deed dated June 25, 1990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mort:gagors herein. Hannah J.
Jackson depart:ed this life on August 24, 1998 whereby title passed
to Kenneth W. Jackson.
Tax Parcel No. 45-17-1044-085
EXHIBIT II A"
SEIZED, ::aken in exe-::ution to be ~lOld all the property of
Kenneth W. Jacknon, Mortgagor herein under Judgment No. ~B-OG074
CIVIL.
NOTICE i:> further given to all partie!l in intere!lt and
claimantn. A propo!led schedule of distribution of the proceeds of
the abovf! :>alt! will be filed by the Sheriff of Cumberland County,
pennsyl vania, on July 9, 1999, and that distribut ion of said '
proceeds will be made in accordance with said proposed schedule If..
thirty (30) days after the date of sale unless exceptions are filed J
thereto wi::hin ::en (10) days thereafter.
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TilE FIRST NATIONAL HMJK UF
r~AR YSV I I.I.E
IN TilE COURT OF COMMON PLEAS
(J!i (':n~HEEI.AND COUNTY, PA
Pia in!. i 1 j
NO. ~B OG07~ CIVIL
VB.
MORTGAGE FORECLOSURE
KENNETH W. JACKSON
CIV r I. ACTION - LAW
Defendant/"
AFFIDAVIT OF MAILING
I, Arthur M. Feld, attorney for Plaintiff, do hereby verify
that I have sent the attached notice and affidavit (copies of which
are attached hereto), to the mortgagees, judgment creditors, the
defendants, terre-tenant (s) and others listed below notifying them
of the sheriff sale of real estate in the above captioned action.
Said notice has been sent certified mail, return receipt requested,
on February 1, 1999 to the address listed on the copy attached
hereto.
(1) KENNETH W. JACKSON
(2) FIRST NATIONAL BANK OF MARYSVILLE
(3) PA HOUSING FINANCE AGENCY
(4) BOROUGH OF WEST FAIRVIEW
(5) CUMBERLAND COUNTY TAX CLAIM BUREAU
(6) ONE MANSION HILL, INC.
(7) ALLEN B. AND KAREN E. RUCH
The foregoing information is true and correct the best of my
personal knowledge, information, and belief, and is made subject
tot he penalties of 18 Pa. C. S. Section 4904, relating to unsworn
falsification to authorities.
~l"l\.f~
Arthur M. FeId, Esquire
Attorney for Plaintiff
1309 Bridge Street
New Cumberland, PA 17070-1116
(717) 770-0292
.r.lllll.ll'Y ~;() I 1 lJ lJ<J
Kenneth W. .Jdcb;Oll
Apt. 101
School !lOUl;f' ^pdrtllli'IlLn
DunCallI101l, PA l,/()).O
The FirDt Natioll,tl Ballk uf. r~drY"'1ill"
P.O. Box B
Marysville, PA 11053-0017
Borough of West Fairview
98 S. Enola Drive
Enola, PA 17025
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, PA 17105-5530
Cumberland County Tax Claim Bureau
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
One Mansion Hill, Inc.
3401 N. Front Street
Harrisburg, PA 17110
Allen B. and Karen E. Ruch
315 2nd Str'eet
West Fairview, PA
NOTICE IS HEREBY GIVEN to the Defendant 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 being notified of
the said Sheriff's Sale. .(: ----- Q
By: Arthu~ M. J~~ld -\-<.2Q?
Attorney for Plaintiff
Attorney I.D. No. 07172
1309 Bridge Street
New Cumberland, PA 17070-1172
THE FIRST NrITIONAL BANK OF
MARYSVILLE
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
Plaintiff
Vs.
NO. 98-06074 CIVIL
KENNETH W. Jr,CKSON
CIVIL ACTION - LAW
Defendant
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
THE FIRST NATIONAL BANK OF MARYSVILLE, Plaintiff in the above
captioned 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 319 Second Street, West Fairview,
Cumberland, County, Pennsylvania, 17025 more specifically described
in Exhibit "A", attached hereto.
1. Name and address of Owner(s) or reputed owner(s) :
Address (if address
reasonably ascertained,
indicate)
cannot
please
be
so
Kenneth W. Jackson
Ane. 101
School House Apartments
Duncannon, PA 17020
2. Name and address of Defendant (s) in the Judgment:
Address (if address cannot be
reasonably ascertained, please
so indicate)
Kenneth W. Jackson
Ane. 101
School House Apartments
Duncannon, PA 17020
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
,.,Lldt'uu'l (if addrcsl.l <':C1nnot be
r'"wonably ascertained, please
<10 lndicate)
Flrst Natlonal Bank of Marysville
P.O. Box B
Marysville, PA 17053'()017
Borough of Weat Fairvluw
90 S. Er.ola Drive
Er.ola, PA 17025
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N Front Street
PO Box 15530
Harrisburg, P~nnsylvani~ l7105-S530
4. Name and address of the last recorded holder of every mortgage
of r",,"ord:
Address (if address cannot be
reasonably ascertained, please
so indicate)
First National Bank of Marysville
P.O. Box B
Marysville, Pennsylvania 17053-0017
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
5. Name and address of every other person who has any record lien
on the property:
Address (if address cannot be
reasonably ascertained, please
so indicate)
First National Bank of Marysville
P.O. Box B
Marysville, Pennsylvania 17053-0017
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
Borough of West Fairview
98 S. Enola Drive
Enola, Pennsylvania 17025
I
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Cumbe~land County Tax Claim Bureau
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
6. Name and address of every othe~ pe~son who has any record
interest in the prope~ty and whose interest may be affected by
the sale:
Address (if address cannot be
reasonably ascertained, please
so indicate)
Those named in Paragraphs 3, 4 and 5 above.
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:
Address (if address cannot be
reasonably ascertained, please
so i.ndicate)
Those named in Paragraphs 3, 4 and 5 above and One Mansion
Hill, Inc. 3401 N. Front Street, Harrisburg, pennsylvania 17110
(fireplace chimney encroachment) Allen B. & Karen E. Ruch at 315
2nd Street, West Fairview, PA successor in title One Mansion Hill,
Inc.
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 unde~stand that false statements herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated: L/n{'tG
~~~
Larry D. Reich
Vice President for
The First National Bank of Marysville
Plaintiff
Arthur M. Feld, Eaq.
ALL THOSE two (2) lots or piecea of ground situate in the
Borough of West Fairview, County of Cumberland, State of
Pennsylvania, more fully bounded and described as follow, to wit:
TRACT 1
BEGINNING at a corner on the East side of Second Street at the
corner of lot now or formerly of Mary E. Rowland; Thence in an
easterly direction along Tract II described herein, ~53 feet to a
point at the corner of land now or formerly of M.B. Stewart; THENCE
20 feet 6 inches in a generally northerly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of william Musser in a westerly direction ~58
feet to the aforesaid S'7cond Street; THENCE in a southerly
direction along the East s~de of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge ~35 feet; THENCE in a
northwesterly direction by land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract ~
herein described, 153 feet to the East side of aforesaid Second
Street; THENCE by the East side of Second Street, South ~~6 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 3~9
Second Street, West Fairview, Cumberland' County, pennsylvania.
EXPEC~ING therefrom a tract of ground conveyed by Violet B.
Rowland, single women, by Deed dated September ~8, ~956, and
recorded in the cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order of the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Common
pleas of Cumberland County, Docket No. ~667 civil ~986.
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BEING the same two tracts of land by Deed dated June 25, ~990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mortgagors herein. Hannah J.
Jackson departed this life on August 24, 1998 whereby title passed
to Kennet:h'W. Jackson.
Tax Parcel No. 45-17-1044-085
EXHIBIT "A"
,
SEIZED, taken in execution to be sold as the property of
Kenneth W. Jackson. Mortgagor herein under Judgment No. 98-06074
CIVIL.
NOTICE is further given to all parties in interest and
claimant5. A proposed schedule of. distribution of the proceeds of
the above sale will be filed by the Sheriff of Cumberland County,
Pennsylvania. on July 9, 1999, and that distribution of said
proceeds will be made in accordance with ::laid proposed schedule
thirty (30) days after the date of sale ~Iless exceptions are filed
thereto within ten (10) days thereafter.
EXHIBIT "A"
'1'111,; I.'! ".';'1' NA'I'!, WAr. HAW: (IF
MAWO;V I r.r.L
I'Llilll if j
I i'J Till'; r "',): ):(1' (iF C'OivW/CJN PLI.:^S
(J!: ('lr~.::I,!':i<./..~;1J ('{JlJ0.'TY, P^
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KI':NNJ.:'I'II vi. .JACKSON
;-;U. (iri {Jl,(J'!.1 ('IVIL
De[t~ncl(lnt/:'i
r~Ol\T(;J\J;r.: F()j~ECrJOSUHE
C IV I r. ACT! ON - LA\'J
.':'1'/,\'1'1-::1,;.:>1'1' Oio' .,-'.~ :):~:<:','
I, Larry D. Reich, Vice President fOl- the Fin;t National Bank
of Mdl i~Jville, Pluiullff, d'-J hereby vel'if'1" thai..-i hClve conducLt:d a
good faith investigation as to the whereilbolltf3 of the ilbove named
Defendilnt (s) who is/are the mortgagor (s), l'I"il1 owner (s) of the
premises known as 319 Second Street, West Fairview, Cumberland
County, Pennsylvania including but not limiting his investigation
to:
(a) actual contact with neighbors
(b) checking with last employer
(c) checking with postal authorities
(d) checking with City Directory ilnd Telephone Book
(e) etc.
and that as a result of this good faith investigation the
whereabouts of the above are:
(1) The last known address for
Kenneth W. Jackson
Apt. 101
School House Apts.
Duncannon, PA 17020
The foregoing information is true and correct to the best of my
personal knowledge, information, and belief, and is made subject
to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn
falsification to authorities.
~~
La . Reich
Vice President for
The First National
Bank of Marysville
Arthur M. Feld, Esq.
ALL THOSE two (2) lots or piece!) of ground situate in the
BorJugh of West Fairview, County of Cumberland, State of
Penr.sylvania, more fully bounded and described as follow, to wit:
TRACT 1
BEGINNING at a corner' on the East: sl.de of Second Street at the
corner of lot now or formerly of Ma~1 E. Rowland; Thence in an
easterly direction along Tract II described herein, 153 feet to a
point: at: the corner of land now or formerly of M.B. Stewart; THENCE
20 feet: 6 inches in a generally northerly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of William Musser in a westerly direction 158
feet to the aforesaid Second Street; THENCE in a southerly
direction along the East side of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge 135 feet; THENCE in a
northwest:erly direction by land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract 1
herein described, 153 feet to the East side of aforesaid Second
Street; THENCE by the East side of Second Street, South 116 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 319
Second Street, West Fairview, Cumberland County, Pennsylvania.
EXPECTING therefrom a tract of ground conveyed by Violet B.
Rowland, single women, by Deed dated September 18, 1956, and
recorded in the Cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order of the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Common
Pleas of Cumberland County, Docket No. 1667 Civil 1986.
BEING the same two tracts of land by Deed dated June 25, 1990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mortgagors herein. Hannah J.
Jackson departed this life on August 24, 1998 whereby title passed
to Kenneth W. Jackson.
Tax Parcel No. 45-17-1044-085
EXHIBiT "A"
SEIZED, taken in exccution to be sold an thc property of
Kcnncth W. Jacknon, Mortgagor hcrein under Judgment No. 98-06074
CIVIL.
NOTICE is further given to all parties in interest and
claimantG. A proposed schedulc of distribution of the proceeds of
thc above Gale will be filed by thc Sheriff of Cumberland County,
Pennsylvania, on July 9, 1999, Clnd that distribution of said
proceeds will be made in accordancc with said proposed schedule
thirty (30) days after the date of sale unless exceptions are filed
thereto wit:hin ten (10) days thereafter.
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EXHIBIT "A"
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THE FIRST N^T I ()~':/\I, ;J,i\~:;< (iF
MM,YSVI LLE
(", Ii J!(;' ()1-' ('(J:-:il;( )~'; lJLEi\S OF
('t;:.IHj':PLt\:,Jll '.'(dJNTY, PENNSYLV^NI^
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KEto;NETH \~. JACKSON
C 1 V! L ACT lON LAW
f),_, f., ncLlll t
t-;ClRn;,vir-; FOHECLOSURE
NOT ICE
YOU HAVE BEEN SUED IN COURT. IE 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 ilppearance personally or by attorney and filing
in writing with the Court your defenses or objections to the claims
set forth against you. You arB warned that if you fail to do so
the case may proceed without you and a judgment may be entered
against you by the Court without further notice for any money
claimed in the Complaint or for any other claim or relief requested
by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAVIYER 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
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
viente (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Usted debe presentar una apariencia escrita 0 en
persona 0 pOl' abogado y archival' en la corte en forma escrita sus
defensas 0 sus objeciones alas demandas en contra de su persona.
Sea avisado que si usted no se defiende, la corte tomara medidas
y puede entrar una orden contra usted sin previo aviso 0
notificacion y pOl' cualquier queja 0 alivio que es pedido en la
p(~ticiOll d.. d"::ll:',j l. 1.T;:: ..,j !.",.~" ;.,: j..! il::" ) II ;;\1;: pl(Jpj,.(Ltd.'::
r) () t I - ( ); ; (I ( . I -., . i : ' , ,!' I: f I ~ I ';:'. j.
I,LEVE E~:;T/\ l)j':i,~!..r;li/.. j\ Tl:J hH': ,/..'
ABOCADO () :: I ~:!) T 1 i":~;I-: 1-::' 11; ;;!-::-
VAY^ EN JIE!~,(:(ii'ir\ I) !,!J\~'~!< \:.,,, ::T ,.," '~:" ,\ :J\ I)!.'!~'l;:,'\ :'1~':^
SE ENCUENTH^ F~;('i': 1 T!.. /\i~/\.J J i'/.,j,'/\ ,\'-)I-:i" 1 ;:I/d.' i)()~:!lE :;1-: jJlJEDE
AS IS'mNC LA LEi ;,\1,.
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NO 'I'IENE
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CONSEGUIR
('\Inll)"~"!.\ll(l ('(Jlllll Y 1,1'.':;,"'/ ;':"!"!'!dl >~,~!''.'i(>'
Cutlrt ^drnini:-a.I",lt (it
CUrnb"l"!dlHl C\)\l!lLy ('(!lll"t HUU;;!'
Celdic;le, PA 1'/0]
('Il7) 240-6200
THE F I i~~;'I' Nt\T j ONAi, Ht\~;V {Jl.'
M^liY,;V 11.1.1.:
,'( r;:)';' ()!.' (,;)~~:'1()='l I!!,E^S
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1998 -
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{IUJ
KENNETH W. JACKSON
CIVIL ACTION - LAW
Dc, f "nd.lll t /"
MOWfGAGE FORECLOSURE
cor.1PLAINT
1. plaintiff is First National Bank of Marysville, a Pennsylvania
corporation with an address at 101 Lincoln Street, PO Box B,
Marysville, PA 17053.
2.
Kenneth W.
individual
Cumberland
Jackson, a Defendant and Mortgagor, is an adult
with an address of 319 Second Street, West Fairview,
County, Pennsylvania 17025.
3. On or about September 9, 1993, M0rtgagor and Hannah J. Jackson,
his wife (now deceased) executed and delivered a Note in the
sum of $43,800.00, payable to The First National Bank of
Marysville, a copy of which is attached hereto, marked Exhibit
"A" and made a part hereof.
4. Contemporaneously with and at the time of the execution of the
aforesaid Note, in order to secure payment of the same,
Defendant and Hannah J. Jackson made, executed and delivered
to The First National Bank of Marysville, a certain real estate
Mortgage which is recorded in the office of the Recorder of
Deeds of Cumberland County, Pennsylvania in Mortgage Book 1164,
Page 447, conveying the subject premises to Plaintiff, which
mortgage is incorporated herein by reference.
5. The land subject to the Mortgage is situated in the Borough of
West Fairview, Cumberland County, Pennsylvania and is more
particularly described in Exhibit "A" attached hereto and made
a par~ hereof.
6. Mortgagor is the real owner of the land subject to the
Mortgage.
'/. Th.' r::-:'llql'J" i;: ill d"llldt d\l" III ~!." :,1": l~l.tf :11" f';')fI lJ.tqill
!l.t::! lil,'!j 1(> !J,IY mUlllllly in:;I,IJJll:'"I;!": ,': :::~H;'),ll t'll tll.' mOllt.h
I)j :.i,IY, l'j'JH ,Ill(l "<1('11 ;;\11);;"'1\1":ll r:lr':l! il!,/ Ill;;! ,ll1ml'llt::
lll"l",llt"l" ,llld 1.11., f()!!(J'Nillq l!ll)Ullt:~ ,II" li\:.. "ill lh.' r.lrltl()qdq,':
(, Ii
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ll:lP,lill pt"jllCip,11 i. il1i"l":;! III )1)/.:,/''''1
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^l tl)n:.,/':: ('O!J\f1Ii::::j(lll r)':;
Tnt d J ^1I1(Jl1!l1 l>\l'~
::; 't : , . ~ ,1 '/ , "/1)
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$Ij-i, 'l:,!I-I,10
tugl!Uh'r 'Nith inten:st '-It Lll!:! per di"lI\ l.-,-lU.! of $:J.l1 per day
att!!!' Octobc~r 23, 199B, and ot.IH.!r c1ldnll_~;; dnd costn to date of
.s11..~ r iff. ':; Sa I f.~ ,
8, The attot"ney'S fees set forth above arC' in conformity with the
Mot-tgagc documcnts and Pcnnsyl vania law, and wi 11 bc collected
in thc cvcnt of a third party pUtTh,ls'cr Clt Sheriff's Sale. If
tht-~ Mortgage is reinstated prior to the sale, reasonable
attorncy's fecs will be charged that arc ilctually incurred by
Plaintiff.
9. Mortgagor/ s arc not members of the Armcd Forces of the Uni ted
Statcs of America, nor engaged in any way which would bring
them within the Soldiers and Sailors Rclief Act of 1940, as
amended.
10. Notice of intention to foreclose and to accelerate the loan
balance has been given to the Mortgagor in accordance with
Section 403 of Pennsylvania Act No. 6 of 1974, but the
Mortgagor has failed to reinstate the Mortgage in accordance
with the provisions thereof. A copy of the notice is attached
hereto, marked Exhibit "B" and made a part hereof.
11. Plaintiff has complied with the procedures required by
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and Defendant has either failed
to meet the time limitations as set forth therein or have been
determined by the Housing Finance Agency not to qualify for
assist.ance.
1'11l1-:HEF()I(!': , I'll , Ii! I I I 1-" I:. j
Kenneth \'i . .J, I (' k~;()/1 In I I". ,I::: ,I':;'
intJ~n:~;t at th" P"I cil"!:\ t,l! ,- ,
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il,'l "Ilddlll ,
::: ,j ~ , '/:~:, . 1 (j , t o( J' . tilt' 1 wi f 11
1:~"1 e)('I()l)"l ;~~, 1',IJH, (Jtll"!
clla2:~Jf-~H ~lfld c()~;L~; ill('!(!"ll! ,Ii
h"l"!" ! 'I! !j" ddl-,' (d .';iI,'!i I J ';; .l;,\l..
and judgment '::lgaillt;t th.' I)\.t '_'WL/Dl dlld f (II' t.un:~clo~3111'(~ dnd ndl(~ uf
the propcr-ty within cl'=scrib,'d.
Respectfully, Submitted,
Date:
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By:
Arthur M. Feld, Esquire
Attorney 1.0. No. 07172
1309 Bridge Street Suite 5
New Cumberland, PA 17070-1116
(717) 770-0292
TilE F I WiT NilT I ONM, ('F
MMYSV 11.1.1.;
1"( Ji 11,'1' ()I-' ('( )r-1~I!UN 1'1 ll':^.~; OF
", :r';H!';I<I.MJI> "UIINTY, i'ENN.<;YINNJ I iI
Pl.l i III i! :
r;',l.
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KENNETH 1'1. .JilCKSON
(' I V I!. ACT ION - l.ilW
Def'~llcJdIlt /~;
rt,()IiTilGAGE FOEC!.OSlJEE
VER I FI CilTION
r i'1rry n Rp;rh states subject to the penalties of 18 Pa
C.S. Section 4904 relating to unsworn falsification to authorities,
that he/~ is the Spninr viro Pro~id..nt of the Plaintiff in this
matter, that he/she is authorized to make this affidavit on its
behalf and that the facts set forth in the foregoing pleading are
true and correct to the best of his/her knowledge, information and
belief.
Date: Oct. 13,
,1998
L~r:;:~h D/2i4?
.
II XI'!) Hi\ 1'1' NO IT
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S4 J. SOO. 00
Sf'p t ('mlll"
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1'1'111\';\'1\',1111,1
FOR VAI.\:I: InTFIVFIl. Ih" '"11ipl",ign"d (joinlly "n,j
sevPfally) prol1li'..f' to pay r1\(~ First National Bank of
Marysvillp, a f'f'llflsylvallia Corporatioll. ("Note Hnldt'r"), or
order. the principal slim of Forty Three Thousand Eight
Hundred and 00/100 Dollars ($43,800.00) with interest on the
unpaid principal balance from the date of this Note, unti I
paid, at the ratt' of Eight and fifty hundredths (8.50~,) per
cent per annum. The 1'1' i nc i pal and interest shall be paid on
demand, in the absence of demand, payments shall be made in
240 consecutive monthly installments of Three Hundred Eighty
Dollars and 11/ I 00 ($ 380. II) on the 14tb day of each month,
beginning October 14, 1993. Principal and interest shall be
payable in lawful money of the United States of America, at
the offices of the holder in Marysville, Pennsylvania (or at
such other place as the Not. Holder may designate in
writing). In applying installments under this Note, Note
Holder will apply all amounts received first to all interest
accrued on the date the payment is credited and then to the
unpaid principal balance until the entire indebtedness,
evidenced by this Note, is fully paid, except that any
remaining indebtedness, if not sooner paid, shall be due and
payable on September 14 , 2013.
In the event of a defaul t in the payment of any
installment due on this Note, a default in the performance of
any covenant or condition in the Mortgage securing this Note
or a default in the performance of the obligations imposed by
any Mortgage constituting a lien superior to the Mortgage
securing this Note, the Note Holder upon providing the
undersigned with such notice as required by law, shall have
the right and option to declare the entire unpaid balance of
this within indebtedness due and payable at once and to
foreclose any Mortgage securing this Note. Failure to
exercise this option shall not constitute a waiver of the
right to exercise the same in the event of a subsequent
default.
The Note Holder may require the undersigned to reimburse
Note Holder for any charge the Note Holder has been required
to pay upon the dishonor of the undersigned's check.
The unders i gned may prepay wi thou t pena 1 ty the
indebtedness evidenced hereby in whole or in part at any
time. Any prepayment will be applied to the outstanding
prin~'ipal bnlanc{. aftef payrnC!l\t of all lat~ charges and
interest through the date of such prepayment. AnY!Jrepayment
;EX/;ibi'i
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will not pO'.tpoIII' till' dl!.. d.,(f' of ,\I1\' '.ub,,"qUI'lll 1I1."1l11l~'
installlTll'llf 1l1l1,",'. NIlI.. 11,l/d"r 01111',......].." .&gr,"". Ifl wfltltU:,
In till' 1'''''11 t I I Ill' flflll", IlI'C",. '.,11 ". t II fl' f "r ! I. i', No I" t I)
illl i1ttorrlf'~'.1t law for ,'oll,'cllon. 01 If llli'; d"It! "f all)'
part hPl"f'of h,. coll",,!,.d hy allY attorrH'Y in II'J~,tl prol:"l.ding',
of any kind. Ihl' lJndl'''',II~IlI'(1 '.hilll "I'Imhll!";" Nol., Ilold,'f' for
such reasnnahll' att(jfIH'Y'~; fl'(,',. COUrt (.o.;ts <llld fl'l'~; a~; arl'
actually illl'IJrI'fld by Notl' Holdl'r ill till' 1'01 ll"'! 1011 of allY
part of tht. dpht f'vidf'II"l'd hy thi~; Notl'.
The unders igned has bee" informed and under, tands tha t
credit liff? insurallct-' is not required to obtain r:rt'dit.
Property insurance on the real property described in the
Mortgage may be obtained from anyone you want that is
acceptable to the Lender.
The unders igned and all endorsers., suret j es and
guarantors further consent to any and all extensions of time,
renewals, waivers or modifications which may be granted or
consented to by the Note lIolder hereof as to the time of
payment or any other provision of this Note. Presentment,
notice of dishonor, and protest are hereby waived by all
makers, suretIes, guarantors, and endorsers hereof. This
Note is the joint and several obligation of each maker and
shall be binding upon them and their heirs, successors and
assigns.
The parties agree that they have engaged in this
transaction evidenced by this Note and the Mortgage securing
this Note pursuant to applicable federal, as well as state
law, including the Secondary Mortgage Loan Act, as have been
preempted by appl icable federal law.
This Note is secured by a Mortgage of even date herewith
executed by Kenneth W. Jackson and Hannah J. Jackson, to The
Pirst National Bank of Marysville constItuting a first lien
on real property located in Cumberland County, and duly
filed for record in the Office of the Recorder of Deeds for
said County.
IN WITNESS WHEREOF, each individual has set his hand on
the date first written above.
, / . 0 .
,...,~~ ""';j'.:,...,"~~
Kenneth W. Jackson
JL~^~=l J h~~~
Hannah ckson
.E'IAihil
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I~; IN ~;l HI()IJ~; III f"ldJ:
{or (III' IIUJlltl1s of ~: I'
mulllu/n'/:,IIISI,'
, 1"'1,1,1\1' Vlllllr,n /' "of !I),lIlf,' (h" IIrullfhlv {J,WIIII'fI(\ /II .s
.Tun,' ,uHI
~;; 'J. I I
',,1,. 14, 1998
Latc char~les iJnd other c1wrqes have i.llso accrued (0 this date in the amOLJllt of $364. eo ___' Thc total
amount now ff~qllired to curl~ this ddilUIt, or ill otlwr words, ~wt ciluqht up in your paymcnts, as of the datc of thi~,
letter, isS 1,505.13
You mav Clift! this (IL'lal/lt Lvithin THIRT~' (30) DA YS of till.' datu of tllis lutter, hV flaying (0 liS the above amount
of S 1,505.13 ., pIllS iI/lV additional fl/onthly paYfl/ents i)mllatl.' charyl.' which Inay fall due during thi~
parioc/. Such payment nlLlst he made either by cashi cashier's check, certified check 01 money order, and made al
__'1110 First National Bank of f.13rysville 01 Lincoln St Marysville PA_~Z~___ .
If you do not cure the default within THIRTY (30J DAYS. we imend 10 exercisl! our rigllt to aeeell!ratl! tile
mortgagl.' paYl1wncs. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to payoff the original mortgage in monthly installments. I f full payment of
the amount of default is not made within THIRTY (301 DAYS, we also imend co instwet our attorneys to start a
lawsuit to foreclose your mortgaged property. If tile mortgage is foreclosed your mortgaged property will be sold by
the SlIeriff co payoff tile mortgage debt. If we refer your case to our attorneys. but you cure the default before they
begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
550.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even
if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our
reasonable costs. If you cure tile default witllin tile tllirty day period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still
have the right to cure till! rlefault and prevl!nt till! saIl! at any timl! up to one lIour bl!fore tile SlIeriff's foreclosure sale.
You may do so by paying the total amount of tile unpaid montllly payments pIllS any late or otller cllarges tllen dUI!,
as well as tile reasonable arromey's fees and cosrs connected wirll rile foreclosure sale and perform any o tiler require.
ments under tile morrgage. I t is estimated that the earliest date that such a Sheriff's sale could be held would be
approx imately_ _11-6-9 S d A notice of the date of the Sheriff sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may ~ind out at any time exactly what
the reqlJlfed payment will be by calling us at the following number: _ 957::21.%__. This payment must be in cash.
cashier's check, certified check or money order and made payable to us at the address stnted above,
.10u should realize that a Sherilf's sale will end your ownership of the mortgaged property and your right to remain
in it. If YOll continue to live in Ih!: property after the Sheriff's sale, (J lawsuit could be started to evict you,
You have additional r(ghts to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE
PROPEHTY TO 08TAIN MONEY TO PAY OFF THE MORTGAGE DEBT. OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR
TRANSFEfl THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL
ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE. AND THAT THE OTHER REQUIRE.
MENTS UNDEf1 THE MOIlTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUM
STAI'jCES THIS RIGHT MIGIIT EXIST. YOU HAVF THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
THIRD I'A"l Y ACTI"C; em ','()Ull BEHAIJ ',c)~1 HAVE TilE f1(GIIT TO ASSERT IN THE FORECLOSURE
PROCEEDI.',(;S THE Nor, F\(i;TENCE OF A iJII-,\ULT OR ANY OTHER DE..FE.N SE YOU r....~.Y HAVE TO
ACCELERATION OR FOf1ECLOSURE.
II VOl! /'1 'lll! dell/II/r rill' 'fl/,/(/I' LviIi IJr' II'.' I/I'rI to till! s,nn/,' /;'I\I(I()II ilS il (1o.dufault hac{ occurr d. However,
YOLJar\~I;(}t . ~!llpd Ie. thl~;':'II,' ','CtJll:YO(J! Ij"l;u 'T1l111' Ihill1 tl1r(,{~::IT"~sil1anY,cil19nd<p YI~(jr)
I I /2 f/ I//.!}.- :;.~/ .-/ ../
~--{ /I;], - '.) H. . l/c( ,/. $
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1I11~ dalll of II
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11'111'1 I', S
,!','I Illlil+'I! 1(1 IIII';I!.III'1I1III"
Illllllli! ,J!
~ fill 111,1, 1/1:" {II', l/r",/'II! i{lt i '1/1,' I, "~,'I), f 1.\ 'I.', ,1/ UII' '/'1:" ,/ 'fl, I/,',','r" "JV f),IV"lt/ fo U~' fhf,' aho'le ,111101/'
ul S 1,505.13 lilli', ",', ,1,,'f','/lI'I,/i "'11,..,'/1,\ 11'Il'iI,""l', IlIlf /,,11' ,fl./lf/I> l'.'llw!l "'.lV (ill due eluflny fl'
!JI!/JIHI ~;ljdl Ild','fll"I)! IIIlI'il !)J' 111.111.. "llIl"! !)',' ! d'.!l, 1.01;111/"('" 1,1;,'iJ. I "llll",d dll]ck or rJHHlI!y Grdf!r, and madl)
The i"in;. N,"1f."lonz1! l~lnk ,)' ~".-lri'~'Jillt. ~ql Linl";ol:l :;f r"lr"y:.villp. PA 17W)~~
II you diJ rill! Ulr,~ r/r,,' c/"/,\..i! ,:.,dll!! Tlil"T'{ I.'W: ()/\'r':;, '.'.'r' IfI{I'flll {u r!H,'(r:r:W! (J(lr ((:r/;'( (0 accelera(e ~I
II/(I(fy,/fft' IJaV"II'llfs. 1 hIs rm:;ln~; ",;tl VJI1,11evl~r IS m.'J11 Hj lHI tIll' l)fHllllill .lfl\OUllt borrowed will be considered (1.
Hlll11cdliltl!ly dnd you 1l1dY Ic}$l~ thl! Il1dllCI: to pa'l off HlI! oriqindl I!HHtlJii<jl' In lJ10llthly installnwnts, If full payment (
Ille amollnt of defalllt is 110t rTlillh.. within THIHTY (30l D^YS, ('H' also "f/ffJf/d ({) instruct (Jur attorneys to SWrt
I;nvsu;f to fOf(.'(.'/nsl.' VOIIf IIwrfga!JI'c/ !JrlIfJ/'rtV. If till' fll(}rtY;Jf/f} is fflT/'r:lused vn/Jr mortgaged property will be sold I
tll/.' SlInritl (() fJdV oft thf.' f!/Of!(PY/' ril'ht, If \'il~ IIdf)r your CilS~~ to our ,lttorlleys, hut you cure the default before thl
bt~Uill leqal procet!dllHjS a~Jairlst you, 'lOll ,",,.ill strll h;JVI~ to PilY thu rt!asolltlhll: attorney's fees, actually incurred, up !
550.00, However, If leqal procel!dil1q:. iHl) started aqaillsl you, YUU wJlll1ilVC' to pay the reasonable attorney's fees (:'JI
if they are over S50.0Q, Any attorlll!y's fees will tw addl!d to wf1utever you owe us, which [".lay also include Ol
reasonable costs, II VOU Cllre t!lt! (/t'f,'I/t!t I,~.'ithi" tile thirty day !Juri()(J, VOU will flnt /)e required to payattornfJY's fees
We may iJlso Slit: YIlU Iwrsoflillly io! tjll~ urlpaid prHlclpdllwjiHlClJ lHlcJ all utlwr sums due under t:,e mortgage,
If you have not cun~d thl~ dl'fiHill ':Jltlll!l ItH~ tlll1 t'y' day IH!riod and fOff!r.loSlJrfl proceedings h.::.;p begun, you Sf
have tilL' r;yhtfu Clift' (111' df.'lalllf (/f/(IIJfI!Vl.'flt till.' s.:Jll.' at aI/V tilll/.' II!J to OIlL' hOllr !Jufare the Sheriff's foreclosure sa.
You may du so hV !)l/Vi/lY tllf! total df.'IfJIlf/t of tile IIlIIJiJ/d f1)unthlv {JiJYflIL'fltS OlliS any late or o(har charges then (1/,
as lvefl .IS till.' f/';JsuuaIJ/I' ,ltlol1lt.'V\ ,1"1.','." ,I/ir/.' 11.','1'0; C/Jllflt.'I'tl!ri '.':itll thl.' IO".'I:I()slIft.' sail.' and perform any other req/ll';
fllL'lIts under fllf.' {fl(}rtya[Jl.'. II IS 1!~;IlIlldlltd Il1dl IlH~ hlrlit:st ri,lt!] lhdt slIch il ShfHiff's sale could be held would
i1pPIO><.irl\;ltely ^' !)(\IICI~ of till: dilt,! of tlw Slwriff 'liJlf! willlw $I.~llt to you before the sale, Of COlIf',
tlll~ iHllOUllt rWI:cJt!d III \:llrt~ IIH~ (jI'LllJll 1,":;11 :'lC'+'<I$1' thl_: IqrHlt.t ,'0\1 wait. You mil',! find out at any time exactly w~:
1111) n'qllln!d pdyr11f:ll! ~,.ilIIH~ li'{ CiIIIIlHjIJ'; "I ,lll' f,lIl()"V:IHll1undH'f' Sl57-2i l..Hi This paymen~ must be in Cil',
C<l~;11I'~r',; check. 1:1'1,;1" ,!:h'cl, (JlIII'II"', I,j..,. ,IIHi tl:.I(jI' ill'.,dll" III :15 ;j! Ihi' ,idd',!sS swtecJ above.
1'1)\1 "lHJuld It'dll/" 11,.1: ,I Stlt~rllf\ ;.11.> ':,1" 'lid ',IOUI 1)~\'r)l~r';:I,!) fd tht) rnortq,lq.!!] property cHId your rigllt to rer
If: If If V(Jlf COil! 1.1'.1" iI' I;':" II II1,~ :'1;1;) 1 r, d: 11~r [II" ~-,t:111 II j'; ,d'"' ,I laws'lit ,;1)'::11 lll~ started In evict YOLl.
'( ()ll havl: ,l{JdiIIIJlU' II'qll;" tfJ l\t:ltl :I'!J1"I: ('1111 i11:t~rt~~il II: Iii,' iJ'f)Il\~ltV Yi)11 HAVE 1HE RIGHT TO SELL T~
I'II()I'EHT), TlJ l)l, ,,\1:" l,llh'JI'( :', i',,, 11;'1 I!IL i,)()HI';:,C;[ {JEll I, tJf1 TO BORROW MUNEy FR:,
ANOillEII I.lf'J{llr'''1 Ir.SlITi'i:r,': 1',11':,),,11 f TillS Inl';JiOU ~MY H,WE HIE RIGHT TO SELL (
Illi\;';S!'[1' Till i'I",I'! fIT'" 'liJll,":: : i "i"- :',II)I~I(;:,II! II) A IJlliEH Oil TRANSFEREE WHOW'
I\SSU~,.H- 110- ",/lCJf.:T,;;,CI[", [)f-gl !;iil)\i!)ill 1il,\! AL! lil; OUISTAi'jDINCj PAYMENTS, CHARGES A~
l\lICH,:'Jt Y'S r-!-I:I~ /d",II ::l)SP) :,;;~ ;':, PI~:()I.' ("Cl Of1;\r THl~. SALE, I\f'.iD THAT THE OTHER REOU1H
MENIS lj;'HJLr\ !Ia; :\d;f~ll;!\I,: "I\f ",..\IIS!I.!) '.:UI\Jli\Cl IJS TO ur:TEi~fv1INE UNDER WHATCIRCI
';r,\:.('1 ~~ THI(~ j,'II;l.: .,~i(ii!l <,I '1i\\/f- Trlf 11!1,f11 TO H,\VE TfllS DEFAULT CURED BY Ar
I" :',\HI',," '1" ".,\ ,I. IWii' I 1<: ':'i'ln I~J TIfE EOI,ECLOSU'
I)i~( 'l:: ,",!\~(i:-; Iii .\111 : .J,', (): il! q H\j~':'F YOU ~.'~^Y HA\'E
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STATE (>1' I'F:'\l\'S\'I.\'\!':I\.
C()[ij\:T\' OF C['\IBI'.IU,.\:\11
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Rrrordr:ruf
I)('l',h ill ,11111 fllr,;,id <:tlUIlI~ alld \t;lll dlt 11I-ll'll\ ('("rlir) lhill lilt, ShnifC.... Il,'rd in \\hkh
Vi t.....; 1 \;; It I H: Inl\ III \II! '\ ~'. \' i I 1(.
h Iht, grantee
tlu' \allll' havjng- ",'{'n \old 10 ..aid gr;lIllt'(. on thl"
!Illl
.. _ __ da)' of
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. A. Il.. I!l
~ '; I
, Illldt'r and hy virtue o( a writ.._
1:-;1
1'~'('('lIt i Otl
_ j,..ued fill t1H' _
h'IJI'll:lf'V
day of n ____n__n_'ou_ ,_
Civi I
~)0
- .\. n.. I~I _ _. oul of lilt, Court of COllllllan PJea'i of said enuuly:t'i of
_ Term, 19_,_~~___
G07'1
Number __h_ ______. _ _, at the suit (,( _.
Fi I'st :\;11.1 Iblll.:; or \bl'~'s\'i! If'
- - - . - - - --_.. -- - -.. -- - - - - ----- - - --- - - -- -- ----- ---- - ---
__ _ again..,
f\('i1IH'1 II W ,J:wks()1l
.------ ------------------______________ i...
2():l ;,[il.
duly recorded in Shcriff's Deed Book No. _. . _ ,. _______, Page _ __ ____ _____.
It\ 'J'ESTI~I(l:-;\, WHEREOF, I have hereunto
~Cl my hand and s{'al uf said office this _ ~?_(L_h_ day
'i ! 7c
of -----h--rzr~- ~---..----.-.---- A. 0.,19___;;____
/ . I 1 ,I ,
, J'..,-" (/. ;1rI-~_~.J-o'7
----.---------.-~----~--~~~;r".----
",/-'-/-;; Recorder of Deed.
Recorder of Deeds, Cumberland County, Carlisle, PA
My CommissIon Explfes fhe first Monday 01 Jan. 2002
The Firsl Natillnal Ban" III ~I,ny" ilk
.\'s-
Kennclh W, J''''''''"1
JlIlhl' ( 'llllrl Ill' ('0111111011 Ph.'as tlf
('n",""r1a.,,1 (""I1I1Y. I'ennsyllania
Dalid ":. McKinney. Ikpnty Sherili'. \\hollL'ing dill:. "'11m aL'l'<lnling tlllaw. says on
t\larL'h .11. 1')1)') al 2:2(, o'cloL''' 1'.1'.1. 1ST. he /"lstL'd a l'Opy III rl'al J-:sI'i1e \\'ril NotiL'e
I'lIsler and Ilcscriplion in the aho,l' enlilkd aL'tion on the prllpcrty 01 Kcnnclh W.
Jackson located at .11 ') Sl'eond Slreet. Wesl lainiew. Cllmherland ('Ollllly. Pennsylvania.
ael'<lrding to law.
R. Thomas Kline. Sheri If. who being dilly sworn ael'<lrding to law. says he served the
above Real Estate Writ Notice Poster and Deseriplion in the abow entitled aelion in the
f(lllowing manner: The SherilTmailed a noliee of the pendency oflhe action by Certified
Mail Relurn Reeeipl Requested. Restricted Deliwry. Dcliver To Addressee Only to the
above named defendant 10 wil: Kennelh W. Jackson to his last known address Apt 101
Schoolllousc Apartmcnts. Duncan non. Pcnnsylvania. This Iettcr was mailed undcr the
date of March 30, 1999 and rcceivcd by Kcnneth Jackson on April I. 1999 the relurn
receipt card signcd by Kennclh Jackson.
R. Thomas Kline. Sheriff who bcing duly sworn aecording to law, says he made
diligent search and inquiry for the within named defendant: Kenneth Jackson. but was
unable to locate him in his bailiwick. lie therel(lI'e deputized the Sheriff of Perry County
to serve the above Real Estate Writ Notice Posler and Description according to law.
PERRY COUNTY RETURN: And now April 14. 1999: Served the within name
Kenneth Jackson the defendant named herein. personally at his place of residence in
Duncannon BolO Perry County. PA on April 14. 1999 at 10:49 o'c1ock AM by handing to
Kenneth Jackson. an adult member offamily I true and attested copy of the within Writ
Notice of Sale & Description and made known to him the contents thercoi'.
So answer: Carl E. Nace, Deputy Sheriff
R. Thomas Kline, Sheriff, who bcing duly sworn according to law, says hc served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency ofthc action by regular mail to the within named
defendant to wit: Kenneth Jackson to his last known address. Apt 101 School House
Apartments, Duncannon, Pennsylvania. This lelter was mailed under the date of April 16,
1999 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says that after due
and legal notice had been given according to law. exposed the within described premises
at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on June 9,1999 at !O:OO A.M/E.D.S.T, and sold the same for the sum of$
1.00 to The First national Bank of Marysville. ! O! Lincoln Street, P.O. Box B.
Marysville, Its successors and assigns. It being the highest bid and best price received for
the same The First national bank of Marysville, being the buyer in this execution paid to
SheriffR. Thomas Kline, the sum of$ $ 1.246.25, it being Sheriffs Costs.
Sheriffs COSlS:
Docketing
Poundage
Posting Bills
30.00
24.44
30.00
1\' j ( I! ": ~; : {.. I' j, II ":;:; (', I r I J It ) t 1). .
f",I::(Jll.ll.]y ,l:;("'r-f .lilll.(j, !)!I',I:;I!
:;(j llld i ('.il ,,)
Fir";;t Ndl.irHldl H'lrlK ()f r'1.ity:;vil].'
11.0. Box B
r'1dry:;villl', P^ l'l()l)~ (J()l'/
liOZ"Ullgtl (J[ West I:ail"vil~w
98 S. Enol~ Drive
Enol~, PA 1'7025
Address (if address cannot be
reasonably ascertained, please
so indicate)
PA Housing Finance Agency
Homeowners Emergency Mortgage Assist~nce Program
2101 N Front Street
PO Box 15530
Hurrisbllrg, P.;nn:,yl'/~llli I 1710c; C;C;I,r)
4. Name and address of the l~st: recorded holder of every mortgage
o E rt~cord:
First National Bank of Marysville
P . O. Box B
Marysville, Pennsylvania 17053-001'7
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
5. Name and address of every other person who has any record lien
on the property:
Address (if address cannot be
reasonably ascertained, please
so indicate)
First National Bank of Marysville
P.O. Box B
Marysville, Pennsylvania 17053-0017
PA Housing Finance Agency
Homeowners Emergency Mortgage Assistance Program
2101 N. Front Street
P.O. Box 15530
Harrisburg, Pennsylvania 17105-5530
Borough of West Fuirview
98 S. Enola Drive
Enola, Pennsylvania 17025
".
~"
Arthur M. Fe ld, E::>q.
ALL THOSE two (2) lot!J or piece::> of ground situate in the
Borough of West Fairview, County of Cumberland, State of
Pennnylvania, more fully bounded and de::>cribed aD follow, to wit:
TRACT 1
BEGINNING at a corner on the East side of Second Street at the
corner of lot now or formerly of Mary E. Rowland; Thence in an
easterly direction along Tract II described herein, 153 feet to a
point at the corner of land now or formerly of M.B. Stewart; THEllCE
20 feet 6 inches in a generally northerly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of William Musser in a westerly direction 158
feet to the aforesaid Second Street; THENCE in a southerly
direction along the East side of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge 135 feet; THENCE in a
northwesterly direction by land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract 1
herein described, 153 feet to the East side of aforesaid Second
Street; THENCE by the East side of Second Street, South 116 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 319
Second Street, West Fairview, CUmberland County, Pennsylvania.
EXPECTING therefrom a tract of ground conveyed by Violet B.
Rowland, single women, by Deed dated September 18, 1956, and
recorded in the cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order of the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Com~on
Pleas of Cumberland County, Docket No. 1667 Civil 1986.
BEING the same two tracts of land by Deed dated June 25, 1990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mortgagors herein. Hannah J.
Jackson departed this life on August 24, 1998 whereby title passed
to Kenneth W. Jackson.
Tax Parcel No. 45-17-1044-085
EXHIBIT llA"
SEIZED, taken in execution to be sold as the property of
Kenneth W. ,;,H:k:Jon, Mortgagor herein under Judgment No. 98 -06074
CIVIL.
NOTICE 1:1 further given to all parties in interest and
claimants. A propo!led schedule of distrl.bution of the proceeds of
the above 'Jal" wlll b., filed by the Sheriff of Cumberland County,
Pennsyl vallL.l, on July 9, 1999, and that distribution of said
proceeds wi 11 be made in accordance with said proposed schedule
thirty (30) dayn after the date of sale unless exceptions are filed
thereto Wl.thln ten (10) days thereafter.
EXHIBIT "A"
THE FIRST N^TION^L fl/\NK OF
M^RYSVILLE
IU TilE COtJHT (lI-' ('()M~:oN PLE^S
(.IF ('IJr-1BFFLl\N[l {'lilJNTY, P^
Pldintiff
v:; .
W;. 'JIl (){JU"/.J ('1\'11,
KENNETIl 1'1. J^CKSON
:-11 )i-:T(~AI;I': FOI<l';("!,O;;llI!I':
Df~[endants
CIVIL ^CTION LNI
NOTICE OF SHERIFF'S 8M,E OF RE^L PROPERTY PURSU^NT TO
PENNSYLVANIA RULE OF crvr L PROCEDURE 3129.1
TAKE NOTICE
That the Sheriff's Sale of Heal Property (Real Estate) will
be held on June 9, 1999 in the Cumberland County Courthouse,
Carlisle, Pennsylvania at 10:00 A.M. prevailing local time.
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:
319 Second Street
West Fairview, PA 17025
The jUdgment under or pursuant to which your property is being sold
is docketed to:
98-06074 CIVIL
Cumberland County, Pennsylvania
The name(s) of the owner(s) or reputed owner(s) of this property
is:
KENNETH W. JACKSON
APT. 101
SCHOOL HOUSE APARTMENTS
DUNCfuVNON, PA 17020
A SCHEDULE OF DISTRIBUTION, being a list of the persons
being entitled to receive part of the proceeds of the sale
received and to be disbursed by the Sheriff will be filed by the
Sheriff thirty (30) days after the sale and distribution of the
proceeds if 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 rle,J~1 of Cumberland COIlOLY, Carl i:.lp, Pl>..
('117) 7.40G]'10.
TII I S PAPER I S A NOT I CE OF THE T Ir1E ,\Nfl PL,\C,': OF THE SALE OF
YOUR PROPERTY.
It has been issued beCaUGf! there i~; ,} lJlldeJrn"Ilt. rFJd 1l1rjl you.
It may causc your propcrty to b'c h.,ld, to b,~ sold (~l- takr,n 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 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.
Pennsylvania Lawyer Referral Service
Pennsylvania Bar Association
213 N Front Street
P.O. Box 186
Harrisburg, PA 17108
(800) 692-7375
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the judgment if you have a
meri torious 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 Sheriff's Sale you may file a petition with the
Court of Common Pleas of Cumberland 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 Cumberland 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, Cumberland County Courthouse,
Carlisle, PA, before presentation of the petition to the
Court.
Arthur M. Feld
Attorney for Plaintiff
Arthur M. Feld, Esq.
ALL THOSE two (2) lots or piec',,; of ground ,;it\lilte in the
Borough of West Fairview, County of Cumberland, Stilte of
Pennsylvania, more fully bounded ilnd described ilS f0llow, to wit:
TRACT 1
BEGINNING ilt il corner on the East side of Second Street at the
corner of lot now or formerly of Mary E. Rowland; Thence in an
easterly direction along Tract II described herein, 153 feet to a
point at the corner of land now or formerly of M.B. Stewart; THENCE
20 feet 6 inches in a generally northerly direction to the corner
of a lot now or formerly of William Musser; THENCE by said line of
lot now or formerly of William Musser in a westerly direction 158
feet to the aforesaid Second Street; THENCE in a southerly
direction along the East side of aforesaid Second Street, 20 feet,
to the place of the BEGINNING.
TRACT 2
BEGINNING at a corner of the East side of Second Street at the
corner of lot now or formerly of Mary J. Cargill; THENCE by said
line now or formerly of Mary J. Cargill of lot in an eastwardly
direction to the top of the ridge 135 feet; THENCE in a
northwesterly direction by land now or formerly of M.B. Stewart,
123 and 1/2 feet; THENCE in a westerly direction along Tract 1
herein described, 153 feet to the East side of aforesaid Second
Street; THENCE by the East side of Second Street, South 116 feet
and 8 inches, to the place of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 319
Second Street, West Fairview, Cumberland County, Pennsylvania.
EXPECTING therefrom a tract of ground conveyed by Violet B.
Rowland, single women, by Deed dated September 18, 1956, and
recorded in the Cumberland County Courthouse, Recorder of Deeds
office in Deed Book "K", Volume 17, Page 576, to Albert R. Shaffner
and Dorothy R. Shaffner, husband and wife.
AND subject to the Order o~ the Judge George E. Hoffer, dated
March 16, 1988, in a settlement of an action in the Court of Common
Pleas of Cumberland County, Docket No. 1667 Civil 1986.
BEING the same two tracts of land by Deed dated June 25, 1990,
and recorded in the Recorder of Deeds in and for Cumberland County
in Deed Book Q34, Page 944, on July 5, 1990, conveyed to Kenneth
W. Jackson and Hannah J. Jackson, mortgagors herein. Hannah J.
Jackson departed this life on August 24, 1998 whereby title passed
to Kenneth W. Jackson.
Tax Parcel No. 45-17-1044-085
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYI VANIA)
COUNTY OF CUMBERLAND)
~,O '(l{ W/.\ CIVIL m: 'I'''/'(II
CIVil AC liON LAW
TO THE SHEf1IFF OF ('lIn,,,'/, I,m"
COIJNIY
To satIsfy tho debl. interest and co~,ts due Till' I.'j (!;, ~~-II j( Ifl.11 IJ~ UtI-'. of ~'~lry~;\' i I J p
PLAINTIFf(S)
'rom Kenneth W. .Irlck:-;nn, ^I,t. Ill] ~;('/1(){J! Ilflll::l' ,\r"lrl m'll' ~;, IlIlll(',lnrH1n, 1'1\ 171l)()
DEFENDANT(S)
(1) You are directed to levy upon llle property 01 tile delend,lnt(s) and to t.ell Jl~1 :;ccond :;trcct. __
J'J.est Fairview, "^ 17()2S
See I.('']o} [)(>script ion_
(2) You are also dlfecled 10 attach the property ollhe defendant!s) not levied upon in the possession 01 __~
. GARNISHEE(S) as lollows:
and to notify tile garnishee(s) that: (a) an attachmenf has been issued: (b) tile garnishee(s) is/are enfoined from paying any
debt to or for Ihe account of the delendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof:
(3) "property ofthedefendant{s) not levied upon an subject to attachment is found inthe possession 01 anyone otller
tllan a named garnishee. you are directed to nofify himlherthat he/she has heen added as a garnishee and is enjoined as above
stated.
Amount Due
$41,642.96
L.L. $.50
Interest hOD' 1 n/?3/q8__(L9_1Lpel:~diem__ Due Prothy _u____._$LOO
Atty's Comm _-S2,Jl.B2_1!L__ % _~__________ Olher Costs
Atty Paid Sl05.92
Plaintift Paid
Date:
Februar2__~99
~.~!tis R. JDnq
Prothonotary, Civil ~ivision
bL_'-~_r_~Q 771rr; 2 ') 6[, J
( Deputy
REQUESTING PARTY:
Name Arthur M. Feld, Eso.
Address: 1 'J09 firi dgfLSb:eet___
New Cumberland, PA 17070
Attorney lor: Pl A; nt-i ff
Telephone: 71 7-770-0292
Supreme Court ID No. 07172
REAL ESTATE SALE f'Jo./)
()n F~ ~. I 'Iq 1 the sheriff levied upon the defendaow
Interest in the real property situaied in jJ,~ ( t/I!.df &.(..~
Cumh"rl-~" r', ..'.. 'h L-no"'r -,,-/ ~ 'rn~M'~ 3":>/9 0 "I.J.-. J
II.J<) ~I".!,:".,,,:, i:l.. p. ':"""'.,," u"':"'J.>j..J~~~
4kd;:;/ "....w "".1 ,'~~";' '(",.,, "'''",-,::,,;., "n r:'-'I"t,:t "A" fjh:i \'Ii;""
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this writ and by II-lis r8~crence inGCrj)Oriled herein.
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