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HomeMy WebLinkAbout01-1204 FX <~.,-~' ~--, ,- '" -'~~- . ~'-,J.';". , ".1i"~' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V AN1A Plaintiff CIVIL ACTION - LAW vs. Defendant ACTION OF MORTGAGE FORECLOSURE 0/- /26Y Ct<:.;ll '-r~ HARRY ADEN HINKLE 'fillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if yon fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Conlplaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 A VISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIa QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 - - --. ~ - ,. " - ~'" i1.LiIIllllWL~:' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE HARRY ADEN HINKLE, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 US.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount ofthe debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 171 02 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff ~- . - _.....~ :-;M~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. Defendant ACTION OF MORTGAGE FORECLOSURE TLb.D/- /.;10'1 &;;J --r ~ HARRY ADEN HINKLE, COMPLAINT IN MQRTGAGE FORECLOSURE 1. Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., herein after referred to as MERS, is the owner of the legal title to the Mortgage subject to the Mortgage to this action and nominee for Homeside Lending, Inc., which is the OWl11er of the entire beneficial interest in the Mortgage, with an address of 8120 Nations Way, Building 100, Jacksonville, Florida 32256. 2. Defendant, HARRY ADEN HINKLE, is an adult individual, whose last known address is 1330 CHURCH STREET, CARLISLE, PENNSYLVANIA 17013. 3. On or about, March 29, 1996 the said Defend!ant executed and delivered a Mortgage Note in the sum of $109,900.00 payable to SIGNET MORTGAGE CORPORATION. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiff also avers that the within Mortgage foreclosure cornplaint is based upon the Mortgage and that the attachment of a copy of the Note is urmecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution ofthe aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office ofthe within County and Commonwealth in Mortgage Book 1311, Page 78 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK and recorded in the aforesaid County in Mortgage Book 594, Page 9 on November 9, 1998. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and . -=~ -'-""-~ ;,;. "-"~ .~ '-~;,jo!i<li~'H,' recorded in the aforesaid County in Mortgage Book 625, Page 212 on September 20, 1999. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 1330 CHURCH STREET, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "A" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on April 1,2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $104,672.90 Interest at $20.07 per day From 03/01/2000 To 03/0112001 (based on contract rate of7.000%) $7,325.55 Accumulated Late Charges $371.17 Late Charges at $34.72 Per month for 12 months $416.64 Escrow Deficit $551.28 Attorney's Fee at 5% of Principal Balance $5,233.65 $118,571.19 **Together with interest at the per diem rate noted above after March 1,2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff s Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgement has been entered upon said Mortgage in any jurisdiction. . .~ .~ " .~ . "-' ,,~.<:; ""~" ""8 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 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 has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($20.07 per diem), together with other charges and costs including escrow advances incidental the toAIle date of Sheriff s Sale and for foreclosure and sale of the property within described. /' ~~_</?"~. BY~~/ ~ quRCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff LD. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) -~...- - " ~' "' .,., ~"" ,-- ~.~ Description TRACT ND. 1 ALL THAT CERTAIN tract OF land situate In Monroe Township, Cumberland County. pennsvlvanla, bounded and described pursuant to a comPass survey bv Tom O. Bletsch. Registered Surveyor. In April, 19S9. as Follows: BEGINNING at a pOint In the center of relocated Pennsvlvanla Highwav Route NO. 174, said point being 500.4 Feet, more or less, Ina SouthwesterJy direct/on along the center of said Road From the Southwestern corner of land now or Formerlv of Percy O. Jumper and Lillian B. Jumper; thence bv land of Ravmond C. Shughart and Cora B. Shughart, his wiFe. South 37 degrees 5 minutes East 164 Feet. more or less to a pOint In the center of Former pennsvlvanla Hlghwav Route NO. 174; thence bv the center OF said Road, South 70 degrees 45 minutes West 105 Feet to a point; thence bV land of Ravmond C. Shughart and cora B. Shughart. his wiFe. North 37 degrees 5 minutes west 131 Feet, more or less. to a point In the center of relocated pennsVlvanla Hlghwav Route No. 174; thence bv the center of said Road, North 52 degrees 55 minutes East 100 Feet to the Place of BEGINNING. CONTAINING .34 Acre, more or less. TRACT NO.1 BEGINNING at a point at the Intersection of the legal right of way of Pennsvlvanla state Route 174 and legal right of way of township road 640; thence along the legal right of way line of said pennsvlvania state Route 174 North 56 degrees 45 minutes East two hl:mdred sixty-Four and seven tv-one one-hundredths 1264.711 feet to a point on said legal right of way; thence bV Lot No. 2 on the Plan of LOts hereinafter mentioned South 37 degrees 5 minutes East seventy Four and seventy-Four one-hundredthS (74.741 feet to a polnton the dedicated rIght of way line of township road 640 as shown on saId Plan of Lots; thence along said dedicated rIght of way line of township road 640 South 70 degrees 45 minutes west two hundred eighty and Forty- six one-hundredths (280.461 feet to a pOint on the legal rIght of way line of township road 640; thence along said legal right of way line of township road 640 North 19 degrees 15 mInutes West sIx and FiFty one-hundredths 16.501 Feet to the point and place of BEGINNING.- !IffY mK1311..". 84 E ~h \b;~ "K' ",,'""'""- - '- ". . . '0;; . COMPANY NAME: M:RIQ\ffi lliCIRNlC ~ SYSIEM3, oc. VERIFICATION . I verify that the statements made in the foregoing Complaint are true and correct. 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 FEbru3ry 26, 2001 ~~'. \;V01 ~\ By Title Leanne Galvin, Vice President -,-,," .t~ '-' ~ .- ~"'- _ ~c -"-",,,,"'~ .&' - ,~l,<, SHERIFF'S RETURN - REGULAR " CASE NO: 2001-01204 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS HINKLE HARRY ADEN CPL. TIMOTHY RIETZ , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HINKLE HARRY ADEN the DEFENDANT , at 0019:59 HOURS, on the 5th day of March , 2001 at 1330 CHURCH STREET CARLISLE, PA 17013 by handing to HARRY A. HINKLE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.72 .00 10.00 .00 31.72 r~~~~~ R. Thomas Kline 03/06/2001 PURCELL, KRUG & HALLER Sworn and Subscribed to before <' By rT~~ Duty S'her' me this A1 ~ day of ~ J-in I A.D. ~ a ~-'-' · ~lf Prothonotary' ........... '" j, r., "- ";IilS~:t~ . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW vs. Defendant ACTION OF MORTGAGE FORECLOSURE 01- 1.JL>Lj CUlL T~ HARRY ADEN HINKLE TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMP'rINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FORTHE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in com"!. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the conrt your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed withou1 you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 A VISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO.PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRlTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARlO, DECIDIR A FAVOR DEL DEMAND ANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 TRUE COPY.FROM RECORD lilT lIlItImOnY wtlefaof, .llItl!e untosetlllf.haIII ...ttw _ .of.sald~isI8..h. '- ~AS;:~dap~~~;j~~ PI_h"~ i-_ <, -,I.' ,- , " -, - '(.&'lk-~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ys. CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE HARRY ADEN HINKLE, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification ofthe said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. pURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff 'P ~-~, "" , " ;. , -~--~-,. "- i . tu iW-~,-~' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. : ACTION OF MORTGAGE FORECLOSURE HARRY ADEN HINKLE, Defendant COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., herein after referred to as MERS, is the owner of the legal title to the Mortgage subject to the Mortgage to this action and nominee for Homeside Lending, Inc., which is the owner of the entire beneficial interest in the Mortgage, with an address of 8120 Nations Way, Building 100, Jacksonville, Florida 32256. 2. Defendant, HARRY ADEN HINKLE, is an adult individual, whose last known address is 1330 CHURCH STREET, CARLISLE, PENNSYLVANIA 17013. 3. On or about, March 29, 1996 the said Defendant executed and delivered a Mortgage Note in the sum of $109,900.00 payable to SIGNET MORTGAGE CORPORATION. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiff also avers that the within Mortgage foreclosure complaint is based upon the Mortgage and that the attaclunent of a copy of the Note is urmecessary pursuant to Rules 1019(h) and Il41(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1311, Page 78 conveying to original Mortgagee the subj ect premises. The Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK and recorded in the aforesaid County in Mortgage Book 594, Page 9 on November 9, 1998. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and '''-,.,,~ "' ,~ ~ < -" ...~,:' . recorded in the aforesaid County in Mortgage Book 625, Page 212 on September 20,1999. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 1330 CHURCH STREET, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "A" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on April 1, 2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $104,672.90 Interest at $20.07 per day From 03/01/2000 To 03/01/2001 (based on contract rate of7.000%) $7,325.55 Accumulated Late Charges $371.17 Late Charges at $34.72 Per month for 12 months $416.64 Escrow Deficit $551.28 Attorney's Fee at 5% of Principal Balance $5,233.65 $118,571.19 **Together with interest at the per diem rate noted above after March 1, 2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. Ifthe Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgement has been entered upon said Mortgage in any jurisdiction. o~ w-~_ , "" >, ; :.. ,',. ~ i'--' '-~", 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pe1IDsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces ofthe United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 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 has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($20.07 per diem), together with other charges and ---, costs including escrow advances incidental ~t6J9,tlie date of Sheriffs Sale and for foreclosure and sale of the property within described. (/:e--:<','/./. ..... //,-/ By'~ / ~ . / - --PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff !.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) , ,. .' "' _...""k,., Description TRACT NO.1 ALL THAT CERTAIN tract of land situate in Monroe TownshIp. cumberland County, pennsylvania, bounded and descrIbed pursuant to a compass survey by Tom o. Bletsch. !?eglstered surveyor, In April, 1959, as foilows: BEGINNING at a point In the center of relocated pennsylvania Highway!?oute No. 174, said point being 500.4 feet, more or less, In a Southwesterly dIrectIon along the center of said !?oad from the Southwestern corner of land now or formerly of Percy o. Jumper and Lllilan B; Jumper; thence by land of Raymond C. shughart and Cora B. Shughart, hIs wife. South 37 degrees 5 minutes East 164 fee~ more or less to a poInt In the center of former Pennsylvania Highway Route No. 174; thence by the center of saId Road, South 70 degrees 45 minutes West 105 feet to a point; thence by land Of Raymond C. shughart and Cora B. Shughart. his wife, North 37 degrees 5 minutes west 131 feet, more or less. to a point In the center of relocated pennsylvanIa Highway !?oute No. 174; thence DY the center of said !?oad. North 52 degrees 55 minutes East 100 feet to the Place of BEGINNING. CONTAINING .34 Acre, more or less. TIlACT NO.1 BEGINNING at a point at the Intersection Of the legal right of way of PennsylvanIa State Route 174 and legal right of way of township road 640; thence along the legal rIght of way line of said pennsylvania State Route 174 North 56 degrees 45 minutes East two hundred slxty.four and seventy-one one-hundredths 1264.711 feet to a point on said legal rIght of way; thence by Lot No. 2 on the Plan Of LOts hereinafter mentIoned south 37 degrees 5 minutes East seventy four and seventy-four one-hundredthS 174.741 feet to a point on the dedIcated right of way ilne of townshIp road 640 as shown on said Plan of Lots; thence along said dedIcated right of way line of township road 640 South 70 degrees 45 minutes west two hundred eIghty and forty- six one-hundredths 12BO.461 feet to a point on the legai right of way ilne of township road 640; thence along said iegal right Of way ilne of township road 640 North 19 degrees 15 minutes west siX and fifty one.hundredths 16.50J feet to the point and place of BEGINNlNG.- flf)1-! !~ny.i3i1rA". 84 K' E~h\bi1 ", 1 " , , ~ ~ ~ . . ~i_~4 " J_._ "'" . j" COMPANY NAME: M:lOO'CE E:rECIKNlC JEISImTICN SYSIEM3. IN:. VERIFICATION > I verify that the statements made in the foregoing Complaint are true and con'ect. 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 FEl::n:u3ry 26, 2001 r-. \jUO!LU~k~{A) By Title Leanne Galvin, Vice President ,,"," ~~~>M,Ql;'l",.!.~&1td,;:tiOlM:;~I4'J,m;llf4lf..!J-i.8ll":;j.lY!,ji~W1;;';-"~'i~"""Jffi:'''''',u,.;:,"-~;L~'iliJj..l,,'-ikli~<iilfib!j;jil!i/lllillllliMill~IiSil~~Wi ~'-.,,> ~'-~J , '11 NV^lJ ~~; 1': H 3d ':'.., ~~ /-;,,: V:] 10. HV EZ II Z DiU AJ!.ioi,J r:/i,:..18i,no IIJlllilfis 3!it ~o ,Wii!~g " ., .'" J ," _. ,__ < _~ ," ~_ _"=_,, __,'"' c' _~,' ,_). ~. .. .Idw'( ~..-"<.,,=., v. , ,~ ", '" __0__ ~" _~ 0 ~ - _.- li..Jli:ldAA';-; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant HARRY ADEN HINKLE for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $20.07 from 3/1/00 to 3/1/01) Accumulated late charges Late charges ($34.72 per month to 3/01) Escrow Deficit 5% Attorney's Commission $104,672.90 $ 7,325.55 $ 371.17 $ 416.64 $ 551. 28 $ 5,233.65 TOTAL $118,571.19** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HAL By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOGS\GUMBERLA\H1NKLE.P -.-. _~;j_~;~JI('!lLlli!iilf;l~!Mi!fi<til.1:1:t\b,";~~~UN"lo'iJ~i,1\j-,;,,;,,<:~.!il1d";:.c~,,;,',*ji;:t"'['~'E",~,-~~_I!itlllll!l_iii!M!I"'" 0,"=- "",;;,;I!ill\lIil -- ~-" . -. =~ - ~', . >"~" -=~ '~'>-"~- ,. -'~" 0 0 0 c: 'T1 ~.;: , ...1 "'UCO c: - i ~ ,1 mr;\ .,- , 2:__ ,t' 2'-- :--J ~~~ f") ~~;<) ,<:C-' "'V 7."-;;2:} ~8 r:? '~~f~ )>c: ~ --==' 35 .-1 -< ,,"' ,'",-",',.' ""''"'''''''.';'L ,~" -'~~ >.J ~liik-: I MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on MAY 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller FA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 .~- -, -- ~ ", b >!illic.;'., , MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO. 01-1204 HARRY ADEN HINKLE Defendant : CIVIL ACTION LAW : IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: May 21, 2001 TO: HARRY ADEN HINKLE 1330 CHURCH STREET CARLISLE, P A 17013 TIDS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE 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 TillS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 - .' By -... LEON P. HALLER, Attorney for Plaintiff !.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 PURCELL, KRUG & -'.',.. .11 1"''''~lW:l1!'ii'I',-lH~im>aoWi,!!l!JiI1,'iIM<t-W!;;';;j,j;:;;''~.c:t!~Nl?o:k~';;'''',tiiZ''!';;'''''''''f~0lf~'!~1M!Ii~ > -~~ ~^ _.- ~.",,~---~ ~ ", ,,<- .~,-, ",~ ,~"' 1.ilIi~~~i!.!ij~--<' -~ , > "~ ,< ~ > .> 0 D 0 C '"n s:: '- ~-:;:; -0 OJ C !J:lQ' z ~r"i:'D 2-1..: , zc -t-ti"T'l ~2; IV ";-~CJ ~i~:). ~c.' -a r- , p ::<: ~:2(~ zO -C- Orn 5>C f;-? ~ -~ :::> S; .-.1 -< . > ~ ;"~ " .. . , ~ '..-, k, ~__ "'~. ~. '"1.," -J eft" r MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on Q-'" /:< 20-0/ agains you in the the above- $118,571.19 and for the sale and foreclosure of your property located at: 1330 CHURCH STREET, CARLISLE, PA 17013 Dated:C:}w_ /:2. :;2e-o/ r1xrL4' P ~~ ~- PROTHONOTA ' Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Harry Aden Hinkle 1330 Church Street Carlisle, PA 17013 - ~... -'" ,-, _J;"<:;rr,iI."'5,,,,;r- - < . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 1204 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF TOTAL AMOUNT OF JUDGMENT $118,571.19'/ Interest at $20.07 per diem to sale date $ 3,773.16 Late charges at $34.72 per month to sale date $ 173.60 Escrow Deficit $ 2.000.00 TOTAL $124,517.95* VS. HARRY ADEN HINKLE, DEFENDANT *SALE DATE: WEDS.,SEPT. 5, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the case. Date: June 11, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1330 CHURCH STREET, CARLISLE, PA 17013. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY :0)-_;. '-~'~~~l~ML,~;jffl:JEflii-l',iili,*,~k!;-~_~":if,;"j;ift11",'d<Mi;J;1"\!.~['t~"~.,![J".,.~___!lWdIlI!tiWIBiIl8RllMi_~~~ ~~ (}.o ~ '- '- "- i-., <>Q W ~. ~ -.-"~".~-""~~ ~"-~ --. ,~'" ~f ~.,. ~, ,_ ~ ",.. '~,,- -',C" , -~-,~ ~-" >~ ~, _'~~~.H~_ - ',i,'1 !~ Jf>' " ,~ ! ,. 0 a (j C :? -n "DE? '- . n1n-, c:: Z.." Z2: -.,., zi;',' ~ "n (f) _,' r'0 ---.leJ --<2". ~c ::;? '-:.~;~) ~o .;!';;::rJ s;:C; ~ ,;~-(;~ c ~ ~ CD -<: ~ :r- >- .. -- <:> --\1' r~ ::-- "" '"" p ~ ~ 'h ~ ~ \}w , , '0 ~ ~ ~ JY q --- ~ ~ l . . ," . ~~~ . '"' " . .~ . '<' -, - TRACT 1: ~ ALL THAT CERTAIN lot or piece of land situate in Monroe Cumberland County, pennsylvania, bou~ded and de~cribed to a compass survey by Tom O. B~etsch, Reg~stered in April 1959, as follows, to wit: Township, pursuant Surveyor, BEGIHHING at a point in the center of relocated pennsylvania Highway Route No. 174, said point being 500.4 fee~, more or less, in a Southwesterly direction along the center of sa~d Road from the Southwestern corner of land now or formerly of Percy O. Jumper and Lillian B. Jumper;' thence by land of Raym~nd C. Shughart and Cora B. Shughart, his wife, South 37 degrees 5 m~nutes East 164 feet more or less to a point in the center of former pennsylvania Highway Route No. 174; thence by the cen~er of said Road South 70 degrees 45 minutes West 105 feet to a po~nt; thence by l~nd of Raymond C. Shughart and Cora B. Shughart, his wi~e, North 37 degrees 5 minutes West 131 feet, more or less, to a po~nt in the center of relocated pennsylvania Highway Route No. 174; thence by the center of said Road, North 52 degrees 55 minutes East 100 feet to the Place of BEGINNING. CONTAINING .34 Acre, more or less. TRACT 2: ALL THAT CERTAIN parcel of ground situate in the Township of Monroe, County of Cumberland and state of Pennsylvania, more particularly bounded and described as follows, to wit: BEGIHHING at a point at the intersection of the legal right of way of pennsylvania State Route 174 and legal right-of-way of Township Road 640; thence along the legal right-of-way line of said Pennsylvania State Route 174 north 56 degrees 45 minutes east two hundred Sixty-four and seventy-one one-hundredths (264.71) feet to a point on said legal right-of-way; thence by Lot No. 2 on the Plan of Lots hereinafter mentioned south 37 degrees S minutes east seventy-four and seventy-four one-hundredths (74.74) feet to a point on the dedicated right-of-way line of Township Road 640 as shown on said Plan of Lots; thence along said dedicated right-of- way line of Township Road 640 south 70 degrees 45 minutes west two hundred eighty and forty-six one-hundredths (280.46) feet to a point on the legal right-of-way line of Township Road 640; thence along said legal right-of-way .line of Township Road 640 north 19 degrees 15 minutes west six and fifty-one hundredths (6.50) feet to the point and place of BEGINNING. BEING Lot NO. 1 on Subdivision Plan of Cora B. Shughart which said plan remains of record in the Recorder's Office of Cumberland County in plan Book 22, page 161. PARCEL: 22-28-2401-119 THE DWELLING ERECTED THEREON KNOWN AS 1330 CHURCH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Larry D. 3/29/96 and recorded in Deed Book conveyed unto Harry Aden Hinkle. Shughart et al by deed dated 136 page 1026 granted and TO BE SOLD AS THE PROPERTY OF HARRY ADEN HINKLE ON JUDGMENT NO. 2001 1204. ~~M""~"'l"il~!",Hm"tfe1tlffi1"r';:!jl!Mj1,i.dillj,iiij&\,,,"""~%'iLc,,J;/,-,,iiLlb;/;fh_'lI+'''-''!fu^jlil'.ii:';~-:".-',"j'*'~~t_;lj!ii!d~~iil1lIlOi!..IM~d,.t1~~nlliliil' , - . ~, ~ = ... o C ?~ ""tJ--~ ~tJ:; V!IT~ 2:::[1 ZC, UL ~;;--:'~' :",:C Jo" ;Zq pC" C z: :<! o L c:: ~ "-', -0 ::r.:- ':;) <:) <;0 J~ j~:}i:~ ~ - -v ~; If "" . \, --q ----,-., j-':: ~'=-_:,:g ,.~ "-., '." ,_ "_c' -oJ--",,-- ,-_ " " . ~ .. ef, . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1330 Church Street, Carlisle, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s) : Harry Aden Hinkle 1330 Church Street Carlisle, PA 17013 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of every other person of whom the l' '~~'" Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating 0 unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 11, 2001 ~~t&i~i~iif[<$\t,M,1iM~Mijt:'--"ii1.;\B;t-f,'<f':a,"-~"1!!",",d:nif'!i';;'""'"..!ia)d;".'~"'",*H'!lJlI!l~llltlllMl~""""'"'~---illli!~_~_diiflIIi/jlililil~~-"'~~...~, (") ~ :o~ fl,lf:' ;i:!'J-,i ~t- 05... ;:$-/:;-:;::: ;j:- ~C! ~(-; ~ '--~' ~. :!j . ~-~ - "- F\) ~!' !\J ". .::J '0 ~~J , . C;", -. 9 'I :-~ "::'-" ...;:: i _ ~r-',' ,~'-- ,:-,-r:U ~") ,"---, J:;~:. !"1 5:';;: ~ " t, . , ~ . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1330 CHURCH STREET CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENt under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 1204 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property lS: HARRY ADEN HINKLE . ,., ,~ -"..' ,-, "'It- . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This "'- ~ ,'_'J",_.', .. ,-- -''''--', , petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for' the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 -~ - ."".'---'~-"'-'- J7 . .~, --,< m,","'. .L ,,'. .~ " ;"J~i . TRACT 1: Township, pursuant Surveyor, ALL TRAT CERTAIN lot or piece of land situate in Monroe Cumberland County pennsylvania, bounded and described to a compass su;vey by Tom O. Bietsch, Registered in April 1959, as follows, to wit: BEGIHHING at a point in the center of relocated pennsylvania Highway Route No. 174, said point being 500.4 fee~, more or less, in a Southwesterly direction along the center of sa1d Road from the Southwestern corner of land now or formerly of Percy O. Jumper and Lillian B. Jump~r;' thence by land of Raym~nd C. Shughart and Cora B. Shughart, his wife, South 37 degrees 5 m1nutes East 164 feet more or less to a point in the center of former pennsylvania Highway Route No. 174; thence by the cen~er of said Road South 70 degrees 45 minutes west 105 feet to a p01nt; thence by l~nd of Raymond C. Shughart and Cora B. Shughart, his wi~e, North 37 degrees 5 minutes west 131 fee~, mo;e or less, to a p01n~ in the CElnter of relocated pennsylvan1a H1ghway Route No. 174, thence by the center of said Road, North 52 degrees 55 minutes East 100 feet to the Place of BEGINNING. CONTAINING .34 Acre, more or less. TRACT 2: ALL TRAT CERTAIN parcel of ground situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGIHHING at a point at the intersection of the legal right of way of pennsylvania State Route 174 and legal right-of-way of Township Road 640; thence along the legal right-of-way line of said Pennsylvania State Route 174 north. 56 degrees 45 minutes east two hundred sixty-four and seventy-one one-hundredths (264.71) feet to a point on said legal right-of-way; thence by Lot No. 2 on the Plan of Lots hereinafter mentioned south 37 degrees 5 minutes east seventy-four and seventy-four one-hundredths (74.74) feet to a point on the dedicated right-of-way line of Township Road 640 as shown on said Plan of Lots; thence along said dedicated right-of- way line Of Township Road 640 south 70 degrees 45 minutes west two hundred eighty and forty-six one-hundredths (280.46) feet to a point on the legal right-of-way line of Township Road 640; thence along said legal right-of-way .line of Township Road 640 north 19 degrees 15 minutes west six and fifty-one hundredths (6.50) feet to the point and place of BEGINNING. BEING Lot NO. 1 on Subdivision Plan of Cora B. Shughart which said plan remains of record in the Recorder's Office of Cumberland Co~nty in Plan Book 22, page 161. PARCEL: 22-28-2401-119 THE DWELLING ERECTED THEREON KNOWN AS 1330 CHURCH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Larry b. 3/29/96 and recorded in Deed Book conveyed unto Harry Aden Hinkle. Shughart et al by deed dated 136 page 1026 granted and TO BE SOLD AS THE PROPERTY OF HARRY ADEN HINKLE ON JUDGMENT NO. 2001 1204. " ~_. ... . L '"'" ""~,- 'il'~l~'" Mortgage Electronic Registration Systems, Inc VS Harry Aden Hinkle In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1204 Civil Term R. Thomas Kline, Sheriff, who being dilly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon Haller. Sheriff's Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 30.00 15.00 .50 1.00 25.66 10.40 15.00 15.00 1.73 11.89 333.60 116.66 $606.44 paidjby attorney 8/3 ]/01 Sworn and subscribed to before me This 1 W day of ~n::./.. , 2001, A.D. Q'f'""" &' 7h~;~./, A1fP1 So Answers' rgz:fA'<p~ . R. Thomas Kline, Sheriff Prothonotary ~- BY Re. Estate Deputy I. ~il ck.. 33 SY'f iB....., J/t.lf7 . , .)~ , , . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 1204 HARRY ADEN HINKLE, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1330 CHURCH STREET CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 1204 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: HARRY ADEN HINKLE _, _'_o,j _1. - -~ ., I A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This "'. ~" _'I'..J._'" "W---"J petition MUST BE FILED BEFORE THS SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for'the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 - -. '.',.' 'j1 ....'Jllll!~n. TRACT 1: Township, pursuant Surveyor, ALL TRAT CERTAIN lot or' piece of land situate in Monroe Cumberland County, pennsylvania, bounded and described to a compass survey by Tom O. Bietsch, Registered in April 1959, as follows, to wit: BEGIHHING at a point in the center of relocated pennsylvania Highway Route NO. 174, said point being 500.4 fee~, more or less, in a southwesterly direction along the center of sa1d Road from the southwestern corner of land now or formerly of Percy O. Jumper and Lillian B. Jumper;' thence by land of Raymond C. shughart and Cora B. Shughart, his wife, south 37 degrees 5 minutes East 164 feet more or less to a point in the center of former pennsylvania Highway Route No. 174; thence by the cen~er of said Road South 70 degrees 45 minutes West 105 feet to a p01nt; thence by l~nd of Raymond C. Shughart and Cora B. Shughart, his wi~e, North 37 degrees 5 minutes West 131 feet, more or less, to a p01nt in the center of relocated pennsylvania Highway Route No. 174; thence by the center of said Road, North 52 degrees 55 minutes East 100 feet to the Place of BEGINNING. CONTAINING .34 Acre, more or less. TRACT 2: ALL THAT CERTAIN parcel of ground situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGIHHING at a point at the intersection of the legal right of way of Pennsylvania State Route 174 and legal right-of-way of Township Road 640; thence along the legal right-of-way line of said pennsylvania State Route 174 north 56 degrees 45 minutes east two hundred sixty-four and seventy-one one-hundredths (264.71) feet to a point on said legal right~of-way; thence by Lot No. 2 on the Plan of Lots hereinafter mentioned south 37 degrees 5 minutes east seventy-four and seventy-four one-hundredths (74.74) feet to a point on the dedicated right-of-way line of Township Road 640 as shown on said Plan of Lots; thence along said dedicated right-of- way line of Township Road 640 south 70 degrees 45 minutes west two hundred eighty and forty-six one-hundredths (280.46) feet to a point on the legal right-of-way line of Township Road 640; thence along said legal right-of-way "line of Township Road 640 north 19 degrees 15 minutes west six and fifty-one hundredths (6.50) feet to the point and place of BEGINNING. BEING Lot NO. 1 on Subdivision Plan of Cora B. Shughart which said plan remains of record in the Recorder's Office of Cumberland County in Plan Book 22, Page 161. PARCEL: 22-28-2401-119 THE DWELLING ERECTED THEREON KNOWN AS 1330 CHURCH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Larry D. 3/29/96 and recorded in Deed Book conveyed unto Harry Aden Hinkle. Shughart et al by deed dated 136 page 1026 granted and TO BE SOLD AS THE PROPERTY OF HARRY ADEN HINKLE ON JUDGMENT NO. 2001 1204. ~ WRIT OF EXECUTION and/or ATTACHMENT , _, ,'- ,,' ,," :i :"", ',";, ~ t~ '~'i ~~-'~l COMMONy'l~ALJ:H0F'PENNSYLV),\NrAr' ,} , , NO. COUNTY OF CUMBERLAND) . 01-1204 CIVILJO! TERM CIVIL ACTION - LAW TO THE SH~RIFF OF r.rrnhPrl ann COUNTY Tosatlsfy the debt, interest and costs due Mortgage Electronic Registration Systems. Inc. PLAINTIFF(S) from HArry Anpn HinklA 1310 Chllrch Street. Carlisle. Pa. 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell r.AVY lIpon ann RA]] thA property nescribed in the attached description known as 1110 Chllrr.h StrAet. CArllR]e. Pa. 17013 (2) You are also directed to attach the property 01 the delendant(s) not levied upon in the possession of GARNISHEE(S) as follows' and fo notijy fhe garnishee(s) that: (a) an aftachment has been issued; (b) the garnishee(s) is/are 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 thereot; (3) II 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. LL. $0.')0 to sale date % Due Prothy 1 00 Late!:harges at $34.72 per month to sale date Otner Costs 171 r;o Escrow Deficit $2,000.00 Atty Paid Plaintiff Paid 103.72 Date: ,111nA 12. 2001 Curtis R. Lonq Prothonotary. Civil Division by q-<fL~ () ~ Deputy REOUESTING PARTY: Name Leon P. Haller Address: 171 q Nort-h Front St-rAet Harrisburq, Pa. 17102 Attorney for: p1"inr; ff Telephone: (717) ?14-417R Supreme Court ID No. 15700 TRUE COpy FROf1l1 RECOt1D In T astimony whereof. I here unto S!lt illY hand and the ~ of said ~ Car!l!dG, Pa. This /.2 ~ ~y ,..-...- ~I (,7'/' ad, Af"~ Prothonotar~ - ~ -- .-, .'~, -..- ~il:ci!!'..JIl~{k~~_"~ml.,jil_11lt;.ol:ilt1~I~':41'''''*';SA,,",,i,,-"~_~",:,t'''~I'So,";",;t'i_',"?;;~l,",-",.,;;C;"'-,,"~;,",Miii~~iillJ.1Ui!~'!!iIIlf!Iffi!a!iM~~r !ll!11B1dd,'f:ll~1lLM!lI1lWIlli;!~1IJ -~ iJ U REAL ESTATE SALE No. LJ 9 . i !'I ;Ij ,I 1",1 II 'I :1 . e c:a evil c:::::::a C5i> (iii;J un j LLN. j ~ l;l 00 I the snentt levied u~on the OetenO.C1l' interest in the real property coituatlJO in tf/fill/Loe.{~ Cumberland County, Pa., knowl'llmbered as: 1330 ChWu:,.L!Jkud .f~ and more fully"""' nn Exhibit "A" filed wit~ this writ and by this reference incoroorated herein. Oate:~ll(l.JOOJ By: CJ~ ~ /. . ,,' \\3(\ ., 1(' 11" ,\" 1\ \ ,,,,.! .: "', "\ ".1 ' , ,', .' \ \1.\\\ , \1 \ "to t, t. . ~_t\ r- \\). ,-.,"\~ ,0,: \-"'-'.~':'-\:l:lll ,"",r,. _. \' If' ...,1\ ).l."\'''~ ~u..! oj " ~~\\\3\\" . , . r: "'~ , . . . I ~ ~."!, : PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, ofthe County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: JULY 20, 27,2001 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 rnatter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r ~Orw'----- Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 27 day of JULY. 2001 ~; 'A~ -~< k.JotLA / LOIS E. SNYDER, Notary PubIlc Carli.reBoro, CUmbeiland County My ColllIIlJIIIIon ExpiIs Man:h 5, 2005 ;",.-",,,-~- - ::""",,-" '._J;,.'- , A " THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 I.b..e Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Pa1riot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 24th day(s} of July 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time. place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Pa1riot-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 ijMiSCellaneous Book "M", Volume 14, Page 317. k PUBLICATION ............................. 'Ji...................................... COPY ~ ~. yclA Notarial Seal S ALE #49 Terry L. Ruosell, Nota Hemsburg. Dauphin MyCOI11II1isslonElCpiresJuna . NARY PUBLIC Member. PennsylVania Associallon Of Nltan.. My commission expires June 6, 2002 .' CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s} $ To1al $ 115.16 1.50 116.66 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... , ,~ !;i ,I , , il ! 'I II ! 1 !i I! 11 ii Ii " ;'1 ji !! I ~M;/j~l\!l&"'i('i1!.\l~"-;",;;tU;N<I'&;;1",ci.,':,idl\ii'''i:r,'li!1ikJ'~.'i,;''''L,;J:i1'4~.!:r,;,"',,";;"'N;',-, ,:q",%,,,,,,;,;r,,"~,,,,,,,y~~~~lll'~~_~lB;M~,,iill~&titi:~lltfjf;J.\Ili II ',', ',{>;,'~ -,<!,l..;O~'- : ~ ~. ~~ _ d,r. _,_~", __,_~_,' 'd',,_ >_ .-, - ,~. ~, ~ , em' ., REAL EsTATE SALE NO. 49 Writ No. 2001-1204 Civil Mortgage Electronic Registration Systems Inc. vs. Hany Aden Hinkle Atty.: Leon P. Haller TRACT 1: ALL THAT CERTAIN lot or piece of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described pursuant to a compass SUlVe1J by Tom O. Bietsch. Registered Surveyor. in April 1959. as follows, to Wit: BEGINNING at a point in the cen- ter of relocated Pennsylvania High- way Route No. 174. said point being 50004 leet. more or less. in a South- westerly direction along the center of said Road from the Southwest~ ern corner of land now or formerly of Percy O. Jumper and LilliancB. Jumper; thence by land of Raymond C. Shughart and Cora B. Shughart, his wife. South 37 degrees 5 min- utes East 164 feet. more or less to a point in the center of former Penn- sylVania Highway Route No. 174: thence by the center of said Road. South 70 degrees 45 minutes West 105 feet to a point; thence by land of Raymond C. Shughart and Cora B. Shughart, his wife. North 37 de- grees 5 minutes West 131 feet, more or less. to a point in the cen- ter of relocated Pennsylvania High- way Route No. 174: thence by the center of said Road, North 52 de- grees 55 minutes East 100 feet to the Place .of BEGINNING. CONTAINING .34 Acre. more or less. TRACT 2: ALL THAT CERTAIN parcel of ground situate in the Township of , Monroe. Connty of CwnberIand ~d '--State ofPennsylva.nia. more.-Mrticu- larly bonnded and described as fol- lows. to wit: . BEGINNING at a point at the Ul- , tersection of fue legal :right of way ~ of Pennsylvania State Route 174 and legal right-of-way of Township Road 640; thence along the legal right-of- way line of said Pennsylvania. State Route 174 north 56 degrees 45 min- utes east two hundred sixty-four and seventy-one one-hundredths (264- .71) feet to a point on said legal right- of-way; thence by Lot No. 2 on the Plan of Lots hereinafter mentioned South 37 degrees 5 minutes east seventy-four and seventy-four one- hundredths (74.74) feet to a point on the dedicated right-or-way line of Township Road 640 as shown on said Plan of Lots; thence along said dedicated right-of-way line of Town- ship Road 640 south 70 degrees 45 minutes west two hundred eighty and foIiy-six one-hundredths (280- .46) feet to a point on the legal right- of-way line of T01iVI1Ship Road 640; thence along said legal right-or-way line of Township Road 640 north 19 degrees 15 minutes west six and IIfty-one hundredths (6.50) feet to the point and place of BEGINNING. BEING Lot NO. 1 on SubdMsion Plan of Cora B. Shughart which said plan remains of reCOrd in the Re- corder's Office of Cumberland Coun- ty in Plan Book 22. Page 161. PARCEL: 22.28-2401_119. THE DWELLING ERECTED THEREON KNOWN AS 1330 CHURCH STREET. CARLISLE, PA BEING THE SAME PREMISES WHlCH Larry D. Shughart et at by deed dated 3/29/96 and recorded in Deed Book 136 page 1026 grant- ed and conveyed unto Harry Aden Hinkle._ TO BE SOLD AS THE PROP- ER1Y OF HARRY ADEN HlNKLE ON JUDGMENT NO. 2001 1204. I L REAL ESTATE SALE No. 49 -- . Writ No. 2001.1204 Civil Terl')l Mortgage Electronic Registration Systems, Inc. , ... .-.'\IS .. Harry Aden Hinkle Atty: Leon P. Haller ,-- DESCRIP110N ~TRACT 1:- ALL THAT CERTAIN lot ,or piece of land :.itua~ in Monro~ To\\'nshl~. Climbcr[:1nd Cuunty. Pennsylvama, boundl.:d _n and d,:-;,cribt:d purSuant to a eompu!>s SUl"':Y 0\1 10m 0--:- Bkl~ch. Registered Surveyor. m ~jwil 1959, a" follow,';. tQ_~i.t_:__~ __'n_ _ _ . ~~gEGl}...rN1N:tf ::iC a_J!Qint _in th~ c~nt~r _ 01 ;: reioc~!ed ~nll~ylva.ma HiSh.way. .Ro.ut.l: No. -_.:174._ ~aid poi!lLb~i.M._5~,~ ~~~tl morc_o: _. ~ less. In a ~ollthwe_~..9m::ctl0111iIQ!l.g_tbJ,:__ - center. of &;Jid-_Road Trom the Sou.thw(:~tcm comer- OJ land now oI formerly 01 Pl.lrey O. ~lvlfipcr a-nil Ullian_--:B-, Jumper; thence by ~and Of Raymond C. Shughart and Cora B. -=oS.llU,ghart. hb wife. :_Sout~ ~7 deprees 5 ':;-~rrirn'u.tcs__Ea....t _L64 feet, _myre or les~ to.a ~])Olnnilthe-:cc.nfer _orformcr Pennsylvama ~J:lfghway Route No~ 174; thence by the 'ce-ntcr of-&aid Road., South 70 degrees 45 ~-minule.s-Wcst 105 f..::et to a point; thence by land .of RaYn:l.oJl(j .C'----'Sh~ghart and C~ra B. '=:'Sllu-@1aft. liis -wift.<. N.orth 37 degree:. 5 mltlUtes West 131 f~l. more Of k:ss, t~ . a :":"- .ro-inffn the -ceritcr-of1\:loc<lted Pennsylvama ~_Highway Route No.. 174: thence by tilt: -career of ~aid Road, North 52 degrees 55. '--' minutes. Ea~t 100 feet to the Place .01 ./lEGlN:-IING. ._ . ~CONtAINING .34 Acre. mare-.or les~. . tRACT 2: ALL Tlj@"' CERTAIN parc.e1 .oJ ~~grQuno~ shuat~~ -hiJh~tow'!y?hJQ_l2f t\1Q~rQ~~_ -~--"COUhlY ------or Cu_ffi@,,-~nd. and Sf.UI.: _ .of r; .Pcnns\'lvaniii:- more particularly boun{]oo - ;:mJaescrilkdasfoJ~._!Q.!~!.\;.:-"n ~~ ._, ~E(.,)'N~fJN()" at ~ !2Q.int <It the mter:'.eC'I_~n "- or _thcJl.lgaJ __dgbt_-of-wuy of. Pe1\nsyJ\'!1l1Ia. ~Si-aiC- Route 174 and legal right-Qf.way .01 - Township Road 640: the-nee along t~c- legal . right-of-way line .of sai? Penn:,yl~am~>S~~~e I~R(iU1e 174 nQrth 56 d.ct!Ces 45 _mm!ltes t:lli>t ~Jw_9.-,bundrl;~_ _si.MYo:~J_ anQ._ ._~t?veQ~y~onc ~- one~fiii.n(b:c.d_trudl61..?.1) fed tQ a pomt o~ --.:said legal right-of-way; thence by Lot ~o. _ on the f'la[l_nOf IAts hereinafter mcntlOned . 'south "37 degrees 5 m!l]-Ules east seventy- "--four- aM :seventy-lOur .one hund~ths <:::...(14.74) feet t.o a point .on. thp dedicated ~ri'^'ht-of.way line .of TownshIp Road 640 a1> ~ _ ~hcQWQ on said ~lan_Q[ Lots: thcn~e along_ . sma- dedicated tight-(lf-way 1me .of - Township. Rood 640 south 70 dl.lgrcC5 45 . minuj~ west two hun-dred dghty and fon;y. ~~'--:-ione hundredths (280"'+6) feet t9 a pOl~j on the legal right-of-way I.me of T~wn~blp ____Roaa. 640: thence along ~ld legal nght-of- ,way J_in_(' of TQ~v1}ship' Roa4 640 north 1_9__ ..::.....de~ecs _ t5 rni_l1.!lI~S_~c:sc,..ix_ ~d.fiftY-tJ!1t;_ --=---- hundredths (6.50) feet to th~ pomt and place -==--6fBEGINNING._ --=_, _ _ ._,_ _.- --:=B:EI.NG":r:or~o. - Con $ubdivisi9E.. P~an yf ~k'QlJ) t>:--shughaff\,-,nlfll ~i~.J?lan remam" -=:-'Ql iecoret i1i -tbe Recorder s Office _ ~[ _ ~i:l~l)g CQ.unty j!l.Pt!n__i~K~~~ge_ W'A"R,tEL_; 22-28-2401-119, ..q.,-~-'f..~'.- -riJ1l.'__Q.wt11ling crc~tc.9 ~herc_c:!D__k.!l_o\~-'lli .'T33lrCnurch Streel. Carh~k, P~. "__,.,, Bmc. th~ ~amt:_ prc.'!1iscs whIch., Larry D. .strnih..:n:t ct al .by dec_d ~at~d ~/-:~,!6 ~~ '_ -r:e:~_c.1l--'ll Deed Book 1.,6 ~u~c I O~ ~nre'd nnd canveycd unto Harry Atkn . Hmklc. d' .TO"BE SOl.D <.lS the property of Harry A 1,,:11 . _ffinlJe on Judgment No. 1001 12.04.