Loading...
HomeMy WebLinkAbout01-03769 " . ,'~ Fi'. __;,,-,,,' "_~"'j p~ILBSlDA TAFILE\Gendoc,C1U'\7927 .writrevival Created: 06/13/01 09:33:35 AM ,. Revised: 06j13/0109:41:05AM ~ --..... CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants -# 0/ -37(09 C'v,'1 NO. 94-5702 CIVIL TERM PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Issue a Writ of Revival of Judgment entered to No. 94-5702 of the Court of Conunon Pleas of Cumberland County and index it to the judgment index against Richard A. Coon and Elizabeth K. Coon in the amount of $20,000.00 with interest from October 5, 1994 as set forth in the Transcript Judgment. You are directed to return the Writ of Revival to the undersigned for service. MARTS ON DEARDORFF WILLIAMS & OTTO By ~ \'- Ivo V. Otto,In, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: June i 5 ,2001 , I~ "'i!iltt~~'"'''''=<i_~~.<J!li;o..iiI!i~~,~~l>1i'OO~kh!i,,;,,'':C'~",""O-'1'f~il-.~~~-"" -~~~.__.. ~ - ;;..... l1 Go (") 0 - -0 0 c c s: ,-j \..N ~ S~ ;:gfg c_ c:= - ~..,. -t:: 9.-) "?":"c' ""- -- ~ lJ Z:::..:' . '. .-0-0 C(J ~~~' W .--"..- ~ fj ,,-,.> -;L_ --, i t:: C) --:::i~) ~T :\>-. ~: ,~;;~~ z~. J ,",0 ,.,..,~c ~~j j'n Z "" ~ N r r" :D -< ..\ ~ - ~~" Irlf " 'I i I ~ , J-". - " -. .'~",.k,Jc~i.li.c " G.<iR)LINE NOLAN IN THE COURT OF COMM::lN PLEAS OF vs. RICHARD A. COON and ELIZABETH K. OOON CUMBERLAND COtJNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-3769 CIVIL TERM ~ WRIT OF REVIVAL TO RTrHnRn.a. fYY'll\T ~nn RT T'ZaRRT'J.i K rYY"if\T_ ':!;':!:C\ Hf"\11:'TA7P:rnnk nriut:30 r;;:arl; C!lt::> on 17()1 ~ You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO. g4-'i7W C'IVTL TERM ~ The plaintiff claims that the amount due and unpaid is $ $20,000.00 with interest from Or.toh"r 5. 1994 You are required within twenty (20) days after service of this Writ to file an an$wer or otherwise, plead to this Writ. If you fail to do so, judgment of revival will be entered. Costs $ 514.50 Pd Deffs15.00 Pd Atty $1.00 Co. Due ~~ /t PRO ONOT . Date June 19, 2001 ~- o~ iA)1um.If/f DEPUTY Seal Ivo v. otto. Ill. Esa. : Martl'jon Dea);TIorff Williams & Otto Attorney for the plaintiff Ten East High Street, Carlisle, PA 17013 (717) 243-3341 , " I, -"'" '. F:\FILES\DA TAFILK\Gendoc.CI11\7927 .appelltallce Created: 06113/01 09:33;35 AM 1'~' Revised: o6l13/0109:41:20AM CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants 110/- 3 7ft, 9 Civil NO. 94-5702 CIVIL TERM PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of CAROLINE NOLAN, Plaintiff in the above matter. MARTS ON DEARDORFF WILLIAMS & OTTO BY~~ Ivo V. Otto, III, Esqnire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Dated: June ,15 , 2001 ~iDJilj~f~~~-' <"miI:~~ .,,"__ ~ ~~,=" .1 ~!!~~#J;"'~~"'~#l';!'i-M'IG,tJc1gj~_'1lI~_~"~ . ~~ ~~ ,~ , ]~~\ii;ll~*'ItJ}""-'._... ~ .' C< .. (") C' c: ~= '.- uCC rpn: oo- ze':' :-1+ (j)" '..0 .~ ~... () ~l......' :er:... )> .... ~ ;ZC.;:- ::r.: '---.-";;c:::; pC ":;'-"<..,,) C ,~~)l--q 2:: .,_1 -j N '3-> en ::0 -, -< ~ ~ ., ,,' L'", I , -..:- ~~ ' '- ~ , ..... CERTIFICATE OF SERVICE I, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, Pennsylvania, first class mail, postage prepaid, addressed as follows: Richard A. Coon Elizabeth K. Coon 398 East High Street Carlisle, PA 17013 TSON DEARDORFF WILLIAMS & OTTO By Ivo V. Otto, III, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: June 15 ,2001 .iliIU!~I!~!~i!ilI~~_~~~-",;jj"-lrl'M'~'iii,""I<>",lIo;~<<l"i1!ffiili~f~~iiii__Wli6li~ ''''''''''~~~~'.i7,,,"",,w"-'-'''l':lI11jjljililj( dJ,ID,..", ._,n,. ., . 0 co j-j c: . S- " '-- '\J W 1::: fll('I'" Z:::r. "-:>, ~~.. \.0 ~;,~... "" ZC~: ..,,,- > " c. \...,.: Z ,'V .;:;;-: =< S:J <:1' -< (S tb ..~ - ~ ''','^ ~, 10 ~. "'j" . ~,,~ -"~.'~~~'" ~ ~ _.~--~~ .' , J, ~" JIiJ\ SHERIFF'S RETURN - REGULAR CASE NO: 2001-03769 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOLAN CAROLINE VS COON RICHARD A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon COON RICHARD the DEFENDANT , at 0856:00 HOURS, on the 28th day of June , 2001 at 335 HOLLOWBROOK DR CARLISLE, PA 17013 by handing to RICHARD COOK a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 ?'"~~<~ R. Thomas Kline 06/29/2001 MDW&O Sworn and Subscribed to before By: me this .:lJM day of ~0J.6.u/ A.D. a~~ r thonotary ~-^-' ,~,-~ I ' ~ , ; - - ~ .. \; SHERIFF'S RETURN - REGULAR CASE NO: 2001-03769 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOLAN CAROLINE VS COON RICHARD A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland Cbunty,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon COON ELIZABETH K the DEFENDANT , at 0856:00 HOURS, on the 28th day of June , 2001 at 335 HOLLOWBROOK DR CARLISLE, PA 17013 by handing to RICHARD COON a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r~~"'~~ R. Thomas Kline .06/29/2001 MDW&O Sworn and Subscribed to before By: me this ~3~ day of Q;~' A.D. {2~ rothonotary I~ ,'~ """" ~, ,,' :)'.\. '."',' . , +" f F:\FILES\DATAFILE\Gendoc.cur\7927_writ.1/drg . Created: OS/lS/0209:4S:13AM Revised: 06/11/02 01:32:16 PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue writ of execution in the above matter, (I) directed to the Sheriff of Cumberland County; (2) against Richard A. Coon and Elizabeth K. Coon, Defendants (3) execute against real property owned by Defendants and identified on attached listing Amount due Interest to June 11,2002* Plus Interest from Date of Filing at $2.67 per day Attorney Fees Costs $15,000.00 $ 2,156.18 $ $ 2,000.00 $ * Interest calculated at 6.5% per annum from 10/5/00 to date of filing. B David R. Gallowa J.D. Number 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: June 11,2002 . "'- ,"-- .~- h',^ " '~~",>i. ". , ,i, '; , , . F:\FILES\DATAFILE\Gendoc,cur\7927-writ.1/drg Created: 06106102 11 :40:54 AM Revised: 06fII!0202:I2:47PM 7927,1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO. 1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and LotNo. 25, Block "B," North 05 degrees West 133 feeHo a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.1, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofIand situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/k!a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14,1998 ~ ' ',', ,'- -" ~ , ' ,,' 'h."';""'"""""' )" , .. and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THA T CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 'feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive; the .place of BEGINNING. BEING Lot No.7 A on the Preliminary and Final Subdivision Plan. of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County RecorderofDeeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, alk/a Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B -,--'---- "'r---'--'- , ~1iid~!liWli:;~>H!.\lfutt1iiAlliill~i;I~iW@I~m.;~I1;i1li&<,""','''',..'''J~0r.h,...;h','"~"'1'=:,~,\-1im'",'rliilil~~;l;\~j;,ili,IlM'lR,,~~Wa\lliIIlMm\l;lilj!ll'!l!dllill'W'-Il!l!'.h' I "-'il.;' ;~) (-) fl:.1 ~ ......... \.^ 1~1 ~ :~ ~ '-'-..J ,,_. ~ "1 () I ?'- (' ~ ....... o ~~-;Ci.:::;:::'kJ"""~ ~ -I~ :---:-t-~ oO&~8od8 'I I I I ~-v : ~~~~:::~F ~ ~ , '- ,~E " :,;4:- ~ I ~ . ... n c :;;~ -uU! m[Tl Z Ti zi;': ~:;X:, ~t:) )>i-) z,:; )>,~ :z :::< ,~-, fif'" ~'~ ~ """""'he' ., ,::> N o "TI ~ 'Tl I":;;;' '-JI") -:-:,iO ;,::)~'" -;:!,~ ;c""'---rt ~O Orn -' J> ~ -0 ;:;;:: W .... Bl b- ~ h . ,. .~ ~ , -~ F:\FILES~ATAFILE\Gendoc.Qlf\7927-alf.lIdrg Created; 06lOSI0210:21:56AM Revised: 06I1110202:11:07PM 7921.1 CAROLINE NOLAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 David R. Galloway, counsel for Caroline Nolen, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located as described in the attached Exhibit: I. Name and address of owner(s) orreputed owner(s): Name Address Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon, Equitable Owners Janet M. Cook, alkJa Janet M. Shambaugh Legal Owner 1940 Reservoir Dr., Carlisle, Pennsylvania 2212 Circle Rd., Carlisle, Pennsylvania 335 Hollow Brook Dr., Carlisle, P A 17013 335 Hollow Brook Dr., Carlisle, PA 17013 2. Name and address of Defendants in the Judgment: Name Address Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Drive, Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Caroline Nolen c/o James Nolen, 4700 E. Reno St., Oklahoma City, OK 73117 4. Name and address of the last record holder of every mortgage of record: Name Address . ~ Cendant Mortgage Corporation Wells Fargo Home Mortgage, Inc. Financial Trust Company Commerce Bank/Harrisburg N.A. GreenPointMortgage Corp. Janet M. Cook, aIkIa Janet M. Shambaugh Legal Owner . , "'~ -- """". ~'. J 6000 Atrium Way, Mt. Laurel, NJ 08054 P.O. Box 2026, Flint, MI 48501-2026 1415 Ritner Highway, Carlisle, PA 17013 Commercial Mortgage Department, 100 Senate Ave., Camp Hill, PA 17011 5032 Parkway Plaza Blvd., Bldg. 8, Charlotte, NC 28217 217 North Middlesex Rd.. Carlisle. P A 17013 5. Name and address of every other person who has any record lien on the property: Address Name None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Janet M. Cook, aIkIa Janet M. Shambaugh Address 217 North Middlesex Rd., Carlisle, P A 17013 7. Name and address of every other person of whom Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address None. ~,- o_~ " "', "I" '" ~ iE, , j.~. I verify the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4909 relating to unsworn falsification to authorities. avid R. Galloway Attorney J.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: June 11, 2002 - - ,',L. "^"" > "-,- ''" ' ~. . iii,;;" ,~, '-< "-" , 'l ..,' ,0/' - F:IFrrEs\DATAFll..E\Gendoc,cur\7927.writ.l/drg Created: 06/0610211:40:54 AM Revised; 06l1I!0202:12:47PM 7927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feetto a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.1, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/kla Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 ~, < ;,,-, -,",."",', , , . ,,' c~^; k.,,,, ',-;', "', 1 ,~ ~it ,., . ' - .. and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No.7 A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/k/a Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B ~~~tlJi!~"8iiIlW~"-.rIi@MikH1'lUi~~~~~li>Jiji;;);l.AF,<l!<:1:;0;;~'J;i,;'1J'~''''''<i.".l;'d,~,*p~~:,-;~'~M:jS'~~i&!l<'liMilW~~~~~~^ o ~;; .<;;. -oi:Z1 men :ZX' zr- q3~:: 2~ <.....~ ~o =0 ..-c ~ "'~","" ,,- ~v."""~'._'" ..~~W"'" . c:: r"--.) '- t-"" ~;;: .~ 1-' ""t' :J!;: ~ -c-;;::; ~'C' :d~ ~~-q ,,,:.-j(~ 7)rn :::. " :13 -< - "" "',' 'J " " ,'.' ~, ~,' ;,q,;" ,j.,;",~, i"~,, '__';; " F:\FILESIDATAFlLE\Gendoc.cur\7927_not.lIdrg Created: OS/24/O~11:15:22AM Revised: 06I11/0~02:ll:54PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4, 2002 in the COMMISSIONER'S HEARlNG ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are 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 the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, P A 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; b. Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; c. RichardA. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle,PA 17013, Equitable Owners; and ". .' :.0,,;:, " _', .';J,'- '''' 1- ~, c. Janet M. Cook, a/k/a Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within 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 Cumberland County, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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. 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 Telephone (717) 249-3166 R. Thomas Kline, Sheriff ... F:\FILESIDAT AFlLE\GeQdoe,cur\7927-writ. J/drg Created: 06/06/(J211:40:S4AM Revim: 06l11f()202:12:41PM 7927,1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feetto a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place ofBEGlNNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERT AlN piece or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/kIa Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14,1998 ", "'~ ".1,1 I '" ",~ t'" and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place ofBEGlNNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, alk/a Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUlT ABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B c ~~~~~Jil:.kII~~"lOOliii.I~1<t\lil>l'IJlli~~,;/i-j>1MI~il!l"""~!E"'~'io;';'i;Ai''''~:0';-3il".!"'.";.E~,,;;,,;~'(;'~W'iiI&r~~I!WIilj~l!W~~1 "''''''~~' ,~,~.. ..,,~~,~~ ~ _, ,~ ,~,~.W~_*<~_" ~,__<~"_ .~~~ '" ~~~~ -~ ~A" '~ .ru ~ ~ it ", n c::> ,.'-" c "'" ~""' .'n 3';: r_ ",..1 -ocr:; c:: [t1rr: :i~ -1'1 Z"TI c- zt'" ---=;t'""] ~~{ ''1 ~CJ -0 (~;(--' --r-""Tl ec-.. :1t: ~]~~ LC< >c:: 'i! -7 ~ .- :~ ::0 -< /!l J~ ' - ~.' ~ . . '..'" .;.,," c~'L " :") , .1iI.... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANTA) COUNTY OF CUMBERLAND) NO 01-3769 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAROLINE NOLAN, Plaintiff (s) Fro11lRICHARD A. COON AND ELIZABETH K. COON, 1940 RESERVOffiDR., CARLISLE, PA, 2212 CIRCLE RD., CARLISLE, P A, AND 335 HOLLOW BROOK DR., CARLISLE, P A (I) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a narned garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,000.00 L.L. $.50 Interest TO JUNE 11, 2002 (INTEREST CALCULATED AT 6.5% PER ANNUM FROM 10/5/00 TO DATE OF FILING) - $2.67 PER DAY - $2,156.18 Atty's Comm % Due Prothy $1.00 Atty Paid $103.10 Plaintiff Paid Date: JUNE 11, 2002 Other Costs $2,000. ATTY'S FEES CURTIS R. LONG Prothonotary, Civil Division '-...l!y: 0rn- p P 71;~n~)~ REQVESTINGPARTY: Name DAVID R GALLOWAY, ESQUIRE Address: MARTSON DEARDORFF WILLIAMS & OTTO TEN EAST IDGH STREET CARLISLE, P A 17013-3093 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ill No. 87326 - " "J .' ,;, 5 Caroline Nolan VS Richard A. Coon and Elizabeth K. Coon In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3769 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney David Galloway. Sheriff s Costs: Docketing Surcharge Law Library Prothonotary Mileage Levy Advertising Posting Handbills Share of Bills Poundage Law Journal Patriot News Certified Mail 30.00 50.00 .50 1.00 13.80 45.00 45.00 45.00 25.20 300.00 270.05 171.35 14.23 $1011.13 paid by attorney 08/28/02 Sworn and subscribed to before me This '16; day of ~ 2002, A.D. ~a~,~ Prothonotary ~p ~, r ~r~ c.(I R. Thomas Kline, Sheriff BY ,--Jo~ Jw.-Jj, Real E te Deputy {,SO tfu3hml /} j.2 9,797 ICe..-.. t ~..... cr'- ~ ~~ ~ ~ ,- ,~ ' 'e_. e,';J.) - ,-,,> ','C F:\FILES\DAT AFli'm\Gendoo,cur\7927-aff, J/drg Created: 06lOS/0210;21:56AM ReviseoJ: 06/11/02 02:11:07 PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 David R. Galloway, counsel for Caroline Nolen, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located as described in the attached Exhibit: 1. Name and address of owner(s) or reputed owner(s): Address 1940 Reservoir Dr., Carlisle, Peunsylvania 2212 Circle Rd., Carlisle, Pennsylvania 335 Hollow Brook Dr., Carlisle, PA 17013 Name Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon, Equitable Owners Janet M. Cook, alk/a Janet M. Shambaugh 335 Hollow Brook Dr., Carlisle, PA 17013 Legal Owner 2. Name and address of Defendants in the Judgment: Name Address Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Drive, Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Caroline Nolen Address c/o James Nolen, 4700 E. Reno St., Oklahoma City, OK 73117 4. Name and address ofthe last record holder of every mortgage of record: Name Address ,-- c.', ",,-" , ~-',,, -,..' c,,~ v,_' '. l '.- >,:,.. L_~ "'1i< t Cendant Mortgage Corporation Wens Fargo Home Mortgage, Inc. Financial Trust Company Commerce Bank/Harrisburg N.A. GreenPoint Mortgage Corp. 6000 Atrium Way, Mt. Laurel, NJ 08054 P.O. Box 2026, Flint, MI 48501-2026 1415 Ritner Highway, Carlisle, PA 17013 Commercial Mortgage Department, 100 Senate Ave., Camp Hill, PA 17011 5032 Parkway Plaza Blvd., Bldg. 8, Charlotte, NC 28217 217 North Middlesex Rd., Carlisle, PA 17013 Janet M. Cook, a/k/a Janet M. Shambaugh Legal Owner 5. Name and address of every other person who has any record lien on the property: Name Address None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Nanle Janet M. Cook, a/k/a Janet M. Shambaugh Address 217 North Middlesex Rd., Carlisle, P A 17013 7. Name and address of every other person of whom Plaintiff has knowledge who has any interest in the property which may be affected by the sale: ~ Address None. , ~ " ~ . ~, " - , '''_~'" )", ' ,;;die ""-1',i> '. ,1 ~ Oil' . I verifY the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4909 relating to unsworn falsification to authorities. MARTSON DEARDORFF WILLIAMS & OTTO Date: June 11,2002 By Davi R. Attorne .D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff '. _:,; ':J;" l. F:\FlLES\DA T AFlLE\Gendoc,cu[\7927~writ,lldrg Created: 06I06I0211:40:S4AM Revised: 06l1110202:J2:47PM 7927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cwnberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East ISO feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cwnberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cwnberland County at Carlisle, Pennsylvania, in Deed Book "W," Volwne 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cwnberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cwnberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/kIa Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14,1998 .- "' "' ,;" '."' .L"-.. :'6-1 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THA T CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No.7 A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/kJa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS TIIE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 2 1-05-043 1-050B ,_"ill...... ~ ~~~ r:::g ~ '---'- ~ ~,~ 1: ,,"- I'" ~ , .,~' ~,"', . F:\FILBS\DATAFD.E\Gendoc,c:ur\7927-not l/drg Created;OS~Il:IS:22AM Revised; O6JlI10202:11:S4PM 7927.) CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. RICHARD A. COON and ELIZABETH K. COON, Defendants . . NO. 01-3769 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4, 2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are 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 the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, P A 17013 THE JUDGMENT under or pursuantto which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OwNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; b. Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; c. Richard A. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, P A 17013, Equitable Owners; and ~ ''III ...... ~ "',- " """"', ~~- " ~.",' -.I,',,; .;;' ,i~. c. Janet M. Cook, a/kJa Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within 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 Cumberland County, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (7i 7) 240-6100. THIS PAPER IS A NOTICE OF TIIE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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. 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 TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R. Thomas Kline, Sheriff _.. - ~ .' . ~ .-'^' ""i-".,, '- ,-,'. ~, l-i--."'~' .;j; F:\FILES\DAT AFlLB\Gcndoe.cur\7917-wrill/dti CreaIed: 0&'D6I&211:40:54AM Ravired: 06/11102 02:12:47 PM 7921.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West I 50 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thenceby said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feetto a point atIine of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book II, Page 5 1, and being improved with a dwelling known as I 940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS TIlE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT TIlE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THA T CERTAIN piece or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No.6 I on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/kIa Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 ,~,~ "" 'ok" ._,"~, '"i', ~; and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the westem dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/kJa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999lii1d recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Peunsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431.050B . ,.- , -" ^" ^~", , ," , ~ J,,~~ ,:,' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3769 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAROLINE NOLAN, Plaintiff (s) From RICHARD A. COON AND ELIZABETH K. COON, 1940 RESERVOIR DR., CARLISLE, P A, 2212 CIRCLE RD., CARLISLE, P A, AND 335 HOLLOW BROOK DR., CARLISLE, P A (1) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,000.00 L.L. $.50 Interest TO JUNE 11,2002 (INTEREST CALCULATED AT 6.5% PER ANNUM FROM 10/5/00 TO DATE OF FILING) - $2.67 PER DAY - $2,156.18 Ally's Conun % Due Prothy $1.00 Other Costs $2,000. ATTY'S FEES Ally Paid $103.10 Plaintiff Paid Date: JUNE 11, 2002 CURTIS R. LONG Prothonotary, Civil Division ~: ~ (V,. g 2. /i;~-'Y~Df'&- REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: MARTSON DEARDORFF WILLIAMS & OTTO TEN EAST HIGH STREET CARLISLE, PA 17013-3093 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ill No. 87326 ~,""" '^"'_;";'h"~,~lM,;",8',<,,'&'''\'i--;-K''',-{,.i,";,;'"'''_';'b''';_,!;""",,,,",,,,~;~,....%h[;j_':ij,..MbllM,rlll1!!wl~~iiIlitffi 1llJOO;, Real Estate Sale # 80 On June 18, 2002 the sherifflevied upon the defendant's interest in the real property situated in North Middleton Township and Middlesex Township, Cumberland County, P A known and numbered as 1940 Reservoir Drive, Carlisle; 2212 Circle Road, Carlisle; and 335 Hollow Brook Drive, Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 18, 2002 By: J6olt.[ Jvtvi~ Real Estate Deputy 11;lr,!,'! ,-'; I ( , , I: I '''L,~ .-"'l lltl_.! ~IIW' L f;I~1 ,~-!tl'li( :!!'~!i~j;:,',< :f,!:) 'J .~ ",:,;,j,:d) ..,.""", , "."", ~.. "~~ --~,'--~'" ," =, ,,'-.,,'-~~ ~ "'~ .'\ ~" ,~ .'. ,1 ',,,,".-,, ~ ,L " - ~ '\~ . . " 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and...I!!l! Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established 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 exactiy as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd of July 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy SALE#80 Notana! Seal TefTY L Russell. NotarY. Public City Of Hamsburg, Dauphin CounIY My Commission Expires June 6, 2006. Member,pennsylvaniaAssodationOfNotanes My commission expires June 6, 2006 . CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 . Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 169.60 1.75 171.35 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.................................................................... HI:ALcSTATCSl\:!:E.NO..ao. __W.rJt No. 2001-3769 ,~~"r:~'-' ~-i:J Civil Term - --CarolIne Nolan - -~ =vs'''~- RJciliardX Coon an.d Elizabeth K. Coon 'jF 'AttY: David Galloway J1ESC&!IDON ,~CT NO:ul: 1940 ,~~serVoii Drive; Carlisle, . .~l'e<m,yh",~ 1101~ ..: ~ . . ,,~_'lliAT1_C.IDITAIN).ract of, land ,with the lJ~~~.v_eJl.0l. tnhereo~ 8ected situate in North ~Q1eto!1 J:1'.NDsbjP'; Cumgerian? qlUOty, !p~}v~nIa,;:Qounded and described as foRows: fBEGlNNING at a pain! on the~wesiem lure of $;ReseIYOid~ri'le and at the northern ~lirie ~ of Lot ,~NQ.3~..B1Ock.. ''B,,'' as shown ,on the_ hc"reinafter - <'OnelmonecrPlim - ofThtS; lJience by the-latter, ~ rsbUth SS'degrees Wesf 150 feet to a pomnntlie' '€P.~oL~~lf-o, 26l,81ock ''11''_O!L~g. FJ~ Lllien~,by sma Lot No. 26, Block "B," and l<lt ~~ 25, Blrn;k "B," North 05'degrees West ,13'3 fteefio.a'poil);t at Ime of 101 No.6, Block "B"; :nneDce by the same,' &orth lS"degrees East fSO I!;.Wapaint"on the western line of Reservoir m~i__then~ by the same, SOl.i!!l!l~.Aegrees~ ~-=.&:.t1? ~f-no,rtb~m line of.1o~ No.~, _Block "'-- <<:' on sald Pian, the Place of BEGINNING, :~ BElN'"G-Lots"'Nos. 4 and S' on the'Plan No. ~:Bl'cid "'11,", of Noll Manor, ,as recOrdea in the ~ce,ofthe'"Recofder ,orD"eeds for 'Cumberland ~C01iiity in Plati Boofll, Page - 5!, an4 being !improved with" a dwelling knO'Ml ,as, 1940 '~oir D~'{e~ Car'lsle,_P,e!!ris.y~vinia, ,~ - ~.J!NG ~--t~,property which" Vkto~a Siar i:B_~~,r, sU1gl~_ man, by deed dat,ed- March 31, W.,andrec,?rdedMarch 31,.1989, i~ the OffLce- (~rL of O-eeds in andJQr CU_ll1berland Carlisle,__ Penns"ylvanfa. b~g Book" , e 33, Page 252, grimted and COnveyed lo.-SicharrtA. Coon and Elizabeth Karen Coon, ,:liP.~and and wife, , _ _ ~TOBg'SOLD.as the property ofRic~A. Coon :~(rEli1.abeat K. Coon onjudgment entered at the ,~ve number and term. ~P~CCh29.l6-1Q94.131,. .. ., ~cr_J~~2 2: 2212 Circle Roil, Carlisle, 1'li"'1lfi11013.. ...... -- - - TItAT:CEItrAIN: piece, or~ei of land il.u~,ir) !-f"~~ Mid~J::I~n T~1}>b.ip,]:um~r1and ~lun.~.-.",. P\O,'eIlP.wv~., ]C!un~.ed 8l1~,~e~~ as _ 7f51J~s OWl.:, - - - - ~ - iiID&o!..LQt No, 62 00- the Plan rr"ereek View - ~6is, Section 'c," as reCo11lelfln fue Office of ~beReccirdeJ'~OfDwli for CiimbCrlanJl 'cmmly in - Plan Book 25, Page 49; containing go feet along ~-Jlie._Hest.aloog Circle Road; c01Jtaining 145 feet ~ ~0!1g ~!..orth._a.LOEg}.ot~~~ on saioPlan; j ~,'co~ri1g90-reeta1Ot]g1lie"Eai;fi.lOQgr:ofNo.. 73-- .. on said Plan; the containing 145 feet along the ~ -South along Lot No. 61 on said Plan of Creek ,~Y~ew Heights. _ , ' -= BEING the same premises which Erik NDrdberg, Executor of the Estate of the Late Judith Nordberg Egger, fi1?a Judith 0, Nordberg, and Frank C, - Egger, Widower, by deed dated December 14 ~ 199~ and recorded in the Office of the Recocde; 'Qf Deeds in and' for Cumberland County Pennsylvania, in Deed Book 191, Page 441: ,~ted and ~nveyed unto Richard A. Coon and Elizabeth Karen Coon, hm.band and wife. .TO BE'SOL~as the property of Richard A. Coon andElizabethl~ Coon onjudgmententered at the above number and term, TAX PARCEL NO,: 29-16-1094-342. ~cr NC?-~: 335 Honow Brook Drive. Carlisle, ~sylvanla17013. - &Tffi.\T_~TA1N 'piece or parcel of land' , ~l~aqfe~x Town.ship, "f!ll'lis1c, t 3~@!OOaand Co~nty, Pennsylvatlla, bounded and -aescnDetf as foHows to wit - --'8EGINNlNG at an iron pin located on the-western -aeaJcated right-of-way line of HoIlow Brook Diive, said iron pin being located on the dividing '='-lirie 5etween Lots 6A and} A on the hereinafter -mentioned SubdMsIOlCPIan; them;~ along the ~~dedicated right- of-way line of Hollow :-:JkROk Drive, South 29- degrees 32 minutes 26 ~as-west;'-3-3o:2Treet'to an icon-pill; thence: :HQttlL21aegrees, <+7 minutes 30 seconds West, _ -S38Jneet to an iron pfu located on !he ::af'vfwng line betw~een Lot Nos, 6A and 7 A on the _ ~afietmentkinea ~Subi:ifvisiOi1 Plan; tbence --along said, dividing line, South 60 degrees 27 ,-minutes 31 seconds East, 420.15 feet to an iron ~pmon the western deaicated right-of-way line of- - Hollow BCQOk DJive, the l?lace of BEGINNING. -aEING Lot No, 7A on the Preliminary and Final -Sii6alvisfon Plan of LO,6755 acres for John M, "Knaub,_ said Plan, being recorded in the =Cumberland County"Reccrder of Deeds Office in -,Plan Book47., Page 100, -BEING improved with a dwelling house known as , - 335Hollow Brook Drive, Carlisle, I\ND BE~G !he same "property which Janet M. ~COOk, aJkh. Janet M, Shambaugh, by Articles of Agrei:"""t.dated April 16, 1999 and recorded August"23, 1999, in the Office of the Recorder of -, Deeds in and for Cumberland County at Carlisle, -= PCnnsylvania, in Miscellaneous Book 622, Page ~ 1090, granted and _conv:ey,ed equitable title unto - "'RichardA'. Coon ana Elizabeth K. Coon, husband ~dwjre. -- --- - -TO BE SOLD as the equitable interest of Richard ~Ai:,CQQ~ -and, ~zabeth K. Coon on judgment ~~1[ereaatlIieaoove 1lJ,\moeTliffd-ierm. '~ --- .cTAX PAKCEr~Q~rl'~94Jl;]>P~=~_~ I . _"" , h~"'" . ,-~ . . ", -,' ;~ '~"'n . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. G!!lJ)1A Roger M. Morgenthal, Editor " SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 "'"",~',, NOT. . LOIS E. SNYDER, Nolary PublIc CaIIIsIe BollI, ClInIIerIand CacIlIY My ComIDs8k.1 ExpII8I Man:h 6, 2006 ;:':'Y~.t!:- ~ -"""li>"''''-','~'L1-'',i:",!;1-\,ii!,j'''"'''',(~!IlIli~'!i:''~I",iillhbk\t,,i'''';;A;sl1l~bl,w.~~."~" ''-"''~~-',,''>I&ltl~"iliiiiliilllllllj~ REAL ESTATE SALE NO. 80 along the South along Lot No. 61 on said Plan of Creek View Heights, BEING the same premises which Erik Nordberg. Executor of the Es- tate of the Late Judith Nordberg Egger, f(k(a Judith O. Nordberg, and Frank C. Egger. Widower. by deed dated December 14, 1998 and recorded in the Office of the Re- corder of Deeds in and for Cum- berland County. Pennsylvania. in Deed Book 191. Page 441. granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon. husband and wife, TO BE SOLD AS THE PROPER- TY OF RICHARD A. COON AND ELiZABETH K. COON ON JUDG- MENT ENTERED AT TIlE ABOVE NUMBER AND TERM. TAX PARCEL NO.: 29-16-1094- 342. TRACT NO.3: 335 Hollow Brook Drive. Carlisle. Pennsylvania 17013. ALL TIIAT CERTAIN piece or par- cel of land situate in Middlesex Township. Carlisle, Cumberland County, Pennsylvania. bonnded and described as follows to wit: BEGINNiNG at an iron pin lo- cated on the western dedicated Writ No. 2001-3769 Civll Caroline Nolan vs. Richard A Coon and Elizabeth K. Coon Atty.: David Galloway LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive. Carlisle. Pennsylvania 17013. ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North lVliddleton Township. Cumberland County. Pennsylvania. bounded and de- scribed as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No.3. Block "B," as shown on the herein- after mentioned Plan of Lots; thence by the latter. South 85 degrees West 150 feet to a point in the middle of Lot No, 26. Block "B." on said Plan: thence by said Lot No. 26. Block "B,. and Lot No. 25, Block "B," North 05 degrees "Vest l33 feel. l0 a point at line of Lot No.6, Block "B~" thence by the same, North 85 de- grees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 de- grees East 133 feet to the northern line of Lot No, 3, Block "B," on said Plan. the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.!. Block "B," of Noll Manor. as recorded in the OffIce of the Recorder of Deeds for Cumber- land County in Plan Book 1 1. Page 51. and being improved with a dwelling known as 1940 Reservoir Drive. Carlisle. Pennsylvania, BEING the same property which Victoria Star Burger. single woman. by deed dated March 31. 1989, and recorded March 31. 1989. in the Office of the Recorder of Deeds in and for Cumberland County at Car- lisle, Pennsylvania. in Deed Book 'W." Volume 33. Page 252, granted i a;nd conveyed to Richard A. Coon andl Elizabeth Karen Coon. husband and wife. TO BE SOLD AS THE PROP- SlIlt"Y OF RiCHARD A coornJ,~ EJJ,ilZABETIl K, COON ON JUDG- MENT ENTERED AT TIlE ABOVE NUMBER AND TERM. TAX PARCEL: 29-16-1094-131. right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7A on the hereinafter men- tioned Subdivision Plan; thence along the western dedicated right- of-way line of Hollow Brook Drive. South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West. 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned SubdMsion Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East. 420.15 feet to an iron pin on the western dedicated right-ot-way line of Hol- low Brook Drive. the Place of BE- GINNING. BEING Lot No. 7 A on the Pre- Iiminarj a..."1d Final Subdivision Pla.."1 of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a(k(a Janet M. Shamhaugh. by Articles of Agree- ment dated April 16, 1999 and re- corded August 23, 1999, in the Of- fice of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania. in Miscellaneous Book 622, Page 1090, granted and con. veyed eqUitable title unto Richard A. Coon and Elizabeth K Coon. hus- band and wife, TO BE SOLD AS THE EQUI- TABLE INTEREST OF RiCHARD A COON AND ELlZABETIl K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. TAX PARCEL NO.: 21-05-0431- 050B. !ITJfL TRACT NO.2: 2212 Circle Road Carlisle. Pennsylvania 17013. ' ALL THAT CERTAIN piece or par- cel ofland situate in North Middleton Township. Cumberland County, Pennsylvania. bounded and de~ scribed as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C." as recorded in the Office of the Re- corder of Deeds for- Cumberland County In Plan Book 25, Page 49; conta.LJing 90 feet along the Wes'~ along Circle Road: containing 14E; fe~:t alon~ the North along LD t No 6,..-1 on s31d Plan: containing 90 fee-,~ along the East along Lot No. 73 OIL __, _", said Plan: ai.td con.-.-:amrrl~ 145 iee'~ """c~,l~MA-J 1.1 ^1~_!!ilJl.",,llnl!4.1J",.MJ,,,J,, n' "'.. ,!lIIL... ~ '."". ,J. !...., .,.,._.. _ w - - o''"~~~ " - ., '.~ "-~, '. "~ ,_ >.f , . ;,j="~,,,,J, F:\FILES\DA T AFILE\Gendoc.cur\7927_praecipejudgment . . CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants REVN AL OF JUDGMENT DOCKET NO. 01-3769 CIVIL TERM PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants in the amount of $20,000.00, plus interest and costs, for failure to plead to Writ of Revival issued on June 19, 2001. I do hereby certifY that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to the Defendants on December 12, 2001, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON DEARDORFF WILLIAMS & OTTO BYI'~~~ LD. No. 27763 Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Plaintiff ~ @b (Q) (8) .~~ ' . ~, - -' ,,~~~ . . F:\FILESIDA T AFILE\Gendoc.cur\7927.defaull CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A COON and ELIZABETH K COON, Defendants NO. 01-3769 CIVIL TERM TO: RICHARD A. COON and ELIZABETH K COON Defendants , DATE OF NOTICE: December 12, 2001 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 THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIDS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARDORFF WILLIAMS & OTTO ~.~v:s- By Ivo V. Otto, III I..D. No. 27763 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff - , > ~'~" ~o "i ~"',- "'" ."Ii; CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS Cill1BERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants REVIVAL OF mDGMENT DOCKET NO. 01-3769 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA : ss COUNTY OF Cill1BERLAND Ivo V. Otto, III, Esquire, being duly sworn accordingly to law, deposes and says that he is an employee of MARTS ON DEARDORFF WILLIAMS & OTTO, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of Default against the Defendants was mailed to them on December 12, 2001, by certified mail, return receipt requested (copies of the return receipts are attached hereto). ~I Ivo V. Otto, ill, Esquire Sworn to and ~bscribed before this ~ day of February, 2002. :4J.n h (l __) (I )J.dM Notary Public U NOTARIAL SEAL BARBARAS. WILDAY, Notary Public Carlisle Boro.. Cumberland County Mv Commission Expires Feb. 18, 2002 - . ^, - r- ru 0=> 0=> 0=> 0=> -D 0=> c ru cD FT1 0=> .... FT1 r- Postage $ Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Requimd) Total Postage & Fees $ 0=> 0=> 0=> r- ---.....----.._____Hnn..nn__h__._. nn__... ... m ." "iii C Complete items 1 and/or 2 for additional services. CIl Complete items 3, 4a, and 4b, f [J Print your name and address on the reverse of this form so thai we can return this ~ card to you. ! Cl Attach this fOfm to the front of the mailpiece, or on the back if space does not CD permit. '5 CJ Write 'Return Receipt Requested" on the mailpiece below the article number. c [] The Retum Receipt will show 10 whom the article was deHvered and the date o delivered. 'U 3. Article Addressed to: ~ a. E o u SENDER: I also wish to rece\ve the 1o\1ow- ing services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery Ms.. F,1 i .,,,,,,,,t-11 K_ Coon 335 Hollow Brook Drive Carlisle, PA 17013 48. Article Number 7000 0600 0027 7310 3820^ "4b. Service Type ./ o Registered Ef Certified o Express Mail 0 Insured o Return Receipt tor MerchandIse 0 COD 7, Date of Delivery /2-1l.-J- () B_ Addressee's Address (Only if requested and fee ;s paid) ictAAj (;~/V ~ ~ " ,. .!! PS Form 3811, December 1994 102595-99-B-0223 Domestic Retum Receipt ~~t!; .. u '1: .. II) - Q. "ii u .. a: c $ 'i a: '" c u; " .2 " o ... ". C m f' ,:'~ ... m " ';; ~ !: ! m :5 c o " m ... -''8.:- , E o " UJ UJ IIJ lr C II . I '""~~~ ?"- m '" m o .-'I m I"- Postage $ Certified Fee I"- nJ o o Return Receipt Fee lEndorsemem Requlred) Restricted Delivery Fee (Endorsement Required) ,0 o ...D o o o . 0 I"- Total Postage & Fees $ Rscip1ent'$ Name hlease Print Clearly) (to be c~~,bY mallery, ,"/' -~i':-W~fr~~~t~~~~~~;;::::::_~::::::~~.::::~::::::::::::: -CiiY~irf~~, FA 17013 SENDER: I also wish to receive the follow- ing services (for an extra fee): C Complete "ems 1 and/or 2 for additional services. Complete items 3, 4a, and 4b. C Print your name and address on the reverse of this form so that we can return this card to you. o Attach this fORTI to the front of the mailpisce, or on the back if space does not permit. o Write "Return Receipt Requesterr on the mailpiece below the ~e number, o The Return Receipt wUl show to whGm the amcle was deliveJ~\ne dale delivered. ;- 3. Article Addressed to: ~;' 4a. Article Number Mr. Richard A. Coon 7000 0600 0027 7310 3837 335 Hollow Brook Drive Carlisle, FA 17013. 1. 0 Addressee's Address 2. D Restricted Delivery 4b. Service Type o Registered o Express Mail o Retum Receipt for Merchandise g{ertified o Insured DCOD $ ,g, .!!! 7. Date of Deliv 1-- 1'-/ - 0 8. Addressee's Address (Only if requested and fee ;5 pa;d) PS Farm 3&U. O""",,,ber 1994 102595-99-8-0223 I)omestie Return'Receipt ~'~I' .. u '> Ii; rn is. il .. II: c ~ " 1; II: '" 0:: 0; " .2 " o >- ". C .. ~ ... ,~-~~ -~._.~ ~~ ,'" ~""H, CERTIFICATE OF SERVICE I, Jacqueline A Decker, an authorized agent of Marts on Deardorff Williams & Otto, hereby certity that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Richard A Coon 335 Hollowbrook Drive Carlisle, PA 17013 Ms. Elizabeth K. Coon 335 Hollowbrook Drive Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO .Y~dflJ<2f14,l c line A Decker Te ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 14, 2002 ~~~itililli~JimliiIWillml!liU!~i1!lt~i>li!:"->.ilr"iiB!;'" '"'j,,'J.:!;'''''''',tJ>;ijl['~_FI~_ ~""'>J!LIf_~illiilUl$ltl!1Rilitr ~ ~^ -' "~"~ r~ ;,,-,;:! ;;','","0 ~ 7i ~ ~ c --0 ~; & ;;-~~r -"1 f - "~l ;~_.:.. '..,--' D; "/F f- ...... (.I;} ~- '. )l..l () Ff} j"'::- -..J ~ -c: t _L <6 ~ S>C:c' :.-) , ~~ ~ L, ;,==-J ru -~I :.n ~;:" ~~ _D ~ -< ....1 -< p:: ---..( ;1Ct)I""m'-'''~''_~,'''''''''M',"'''',.~, __m, "',~,~,~',~",","<" ,==,,~,,"",~~ .,~,,~",'.~"N"""'.' ,~" ,~",'" ~,~__" ~N" IiIi&t:. [ .,.,""""-- ~ -" -^~. F:\FlLESIDATAFlLE\Gendoc.cur\79271_aff,l/n]m Created: 07/08/0202:]5:46JfM Revised; 07/09/02 02:40:]2 PM 7927.] " .. CAROLINE NOLAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 01-3769 CIVIL TERM CNIL ACTION-LAW RICHARD A. COON and ELIZABETH K. COON, Defendants AFFIDAVIT I, David R. Galloway, Esquire, counsel for the above-named Plaintiff, hereby certify that written notice the sale of real property together with legal descriptions of all tracks, was served upon the following: I) Janet M. Cook, aIkIa Janet M. Shambaugh; 2) Cendant Mortgage Corporation; 3) Wells Fargo Home Mortgage, Inc.; 4) Financial Trust Company; 5) Commerce Bank/Harrisburg N.A.; 6) GreenPoint Mortgage Corp.; 7) Richard A. Coon and Elizabeth K. Coon By regular mail at the addresses set forth in the Affidavit, with the return address of the Plaintiff appearing thereon. There is attached hereto and marked as Exhibit "A," Certificates of Mailing, U.S. Postal Service Form 3817, confirming mailing of each of said persons or entities. A copy of the Notice of Sale together with all legal descriptions, which wa served upon each of the persons or entities named above is attached hereto and marke By SWOl11 n and sui:j:t~et;efore me this 32- day of , 2002. . NOrARIAI. SEAL BARBARA S. WILDAY, Notary PWI'<: Carll8le BolO., Cumberlalld eoUl'lly My CommIsslon Expires Feb. 18, 2006 . . ~ ~'"......... ~~ ~ .J~liuwhi:ioll~~~i"'~II,.....:...,...;..~..i__... " . , ~" , ct ~l. '''~ Cll ;:!:. ~. () 0 bJ I-' ;:!: f . CERTIFICATE OF MAILING ." rt tD , 0 llJ u.s. POSTAL ,SERVICE i, 0 ~ . '1 '1 MAY BEUSED,FqR DOMESTIC AND INTERNATIONAL MAil, DOES N:PT _ ~ 3 u e, I-' t'l rt l ,PROVIDE FOR INSURANCE POSTMASTER ... ' _,-..'''' '" 't"' g ,.... llJ In '" llJ ~ In In O' ~ ~ ~ rr rt ~ I-' rt ::s ~ Received F,rom: :" '1 0 tD "Marts6n Deardorff Williams tD ,.... ~ a. - ::c 0 ~ I-' ~ 5" ,.... tD ~ '1 < ~ .0 llJ 10 East High Street rt 3 ::r a ~ .0 CD ~ JJ !!, ..... (fl 0 '" . -..J rt '1. Carlisle, PA 17013 Q. CD '<: III Q. 0 '1 HI 0 ; ..... III HI 00 () = W tD :€ One piece of ordinary mail addressed to: 0 0 . rt Q. Ul j ~ ,.... Ms. Janet M. Cook/Ms'. .1>0 ..... ..... ,.... 217 N. Middlesex Road ~ rt ,.... Carlisle, 17013 0 II> PA ::s ~ .""~~. l' 0 Or- PS Form 3817, Mar. 1989 . U,S.GPO: 1991-0-282-4041251 Ill- zZ .----- ._,---~ 010) .... U.S. POSTAL SERV C CERTIFIC TE OF MAILING MAY BE USED,FOa:;DOMESnc!, ,NI) IN"mINATIONAL MAil, DOES NOT PROVIDE FOR -INSURANCE-POSTMASTER Received From: Martson Deardorff williams & otto 10 East High Street . If, Carlisle, PA 17013 if. -. ~_... One piece of ordinary mail addressed to: Commerce Bank/Harrisburg, N.A. ." 'Jli:. Commecial Mortgage Department OJ :;: 0 () ..... ;:!: :0 " "l 'tl . ~?(!'l ..... . tD , llJ 0 llJ n 100 Senate Avenue 0 . i 3 ,.... 9 ..... u '1 '1 ~ sg:" if I-' e ..... t'l rt me '" '" In g ,...- r.: In Q. dcn~ Camp Hill, PA 17011 '" g' ~ In 0 ~ :u2lr- ~ "l lil rt ::s 0 ..... ;:!: >< llJ 0 ,~ z-nUJ PS Form 3817, Mar. 1989 a. ",om ..... .2 - ::c 0 e:o s: " ~- N . .... tD :00- ~ 0 0 < ~ .0 llJ "on .1>0 IV 3 ::r a ~fi U.s. POSTAL SERVICE CERTIFICATE OF MAILING ~ 00 <l' ::c !!, m", co Ul 0 ..... (fl 0 I.... MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT co 0 .~ . -..J rt '1 ..- PROVIDE FOR INSURANCE-POSTMASTER co Q. on ..... Q. 0 '1 HI ",,,n I Ii ..... tD HI gzm Received From: '" ;:!: . W tD 0:11 0 g . rt :;: l:;z.... Q. Martson '" R .... ~~ ii Deardorff Williams & otto Cl\ rt ..... , . .0 ..... zn 10 High Street I JJ ,...- ":l> East ! ~ :too! , tD ~m , - In " Carlisle, PA 17013 \ ~ ..... ,., ~... ::s One piece of ordinary mail addressed to: 0 ;=5: ;':l> Green Point Mortgage Corporation 0- Ill!: / zZ 5032 Parkway ,Plaza Bllld., Bldg. 8 010) .... Charlotte, NC 28217 i II PS Form 3817. Mar. 1989 . U,S.GPo: 1991.0.282-404/25~ " Exhibit "A" , " en ... 0 [ Q '" ..., ;.:~ '" g: 3 0> ..., ..." 0> ... lJ1 . .. ... ... < . .. I-' 0 .... ..... .. . ~ ..... :>:: ~o ..... .. ~ .. 0 f-l."" '" 0 3 :' I-' .... n~ .... ::l ~ ;;: CD .... ~ CD .. ~ O>~ t:J " >,; ...< CD - 0..3 '"d 0> CO it> b:I . it> ... CD ... it>= 0.. CO 0 . l!. 0 >- ~ .. >- ... ....., ",a ....., ..." 0 0= 0 ..." >- 1::1 ol!. >- ..., ... ::t~ ..., "" ..... ..... <I .... CD. .... * .... c ~ '" " '" " ~ ~ .. "! ,6 '" jj .. ~ ;. f ~ !i! Z06!6i Z INnOWij , o. '60 lOr [lOll , ijd'31S'Jlllr.J i a~ij , 3~ijlSO 's'n r . \~ ~ \ III "",>.1 ...... " . . ~ " ~ ~ [::.!) (8) c' ~ , L~-: - ';t" F:\FILES\DAT AFII.E\Oendoc.cur't7927-not.lldfB . Created: OSI2AlO2IJ:lS:22,AM Revi&ed: 06I1110202:ll:S4PM 7927.1 " '. CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIViL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVlL TERM (") 0 0 ~ N "TJ C- -; ;:R OJ c:: 52rn z _1'-I"liJJ '7"1 Z~;:: u"':"1h'1 ~~ ,,(;Q r~) !.. ~O " . -:.~ (.J ~8 :::ll: ;5:8 z:0 >c: w drn ~ ~ -< NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4, 2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are 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 the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, PA 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; Richard A. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, P A 17013, Equitable Owners; and b. c. Exhbibit "B" ~ 'M. '., " c. Janet M. Cook, aJkJa Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or goveroment 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 within 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 (I 0) 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 Cumberland County, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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. 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 Telephone (717) 249-3166 R. Thomas Kline, Sheriff - , ~J F;\FILES\PATAFILE\Oeadtlc.cur\7927.wriL IfdrJ CrataI: (JCf/OCW111:40:J4AM l' . &mad: 1J6l1110202:12:47PM 1927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West ISO feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the westem line of Reservoir Drive; thence by the same, South OS degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.1, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A, COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, f/kIa Judith 0, Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 , ~.' ~, j ':'-, ".c. , 'i', ." , , and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No.7 A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/kIa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999lii1d recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B ".,t, ;; ~< ~,~< ^ M, , CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Mactson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Affidavit was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. and Mrs, Richard A, Coon 335 Hollow Brook Drive Carlisle, PA 17013 MARTS ON DEARDORFF WILLIAMS & OTTO By N;'{~0t.~ r~.If- Ten East High Street Carlisle,PA 17013 (717) 243-3341 Dated: July 9, 2002 ~~~iilti.l~Ji':m~i{!IiIID~&imW,~~~j;ilidiH""""","",'~,"":,,,,'''''~J~hl!1,j","#~.til'JI1Jmi"'I1Hi!lrj.f.I~t~ltli~~lilill'- '~'-Wll!IIIIIilIlIl , o c: ~-~ ~O \~ f--;-" ~) ~:.' c:: ...:) ~s L~" :2 ~"..~ . --'"~~ ".~. ~,--~ " ~ ~- - ~.~ ( \1 -,I -~ I..!.) ~" .~ ~:-? '_fl f~S '61-1 - - " F:\FILES\DA T AFILE\Gendoc.cur\7927 -pra I/drg Created: 0712'5/02 09:45:52 PM Revised: 08/06/02 08:38:54 AM 7927.1 , , " CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01-3769 CNIL TERM CNIL ACTION-LAW RICHARD A. COON and ELIZABETH K. COON, Defendants PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment entered in the above captioned case satisfied and released. ~1~(DE By ( DaVId R. Galloway LD. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 6, 2002 ~ ,~ ~.~-;- CERTIFICATE OF SERVICE I, David R. Galloway, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy of the foregoing Praecipe to Settle and Discontinue was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Dr. Carlisle, P A 17013 David R. Gall a Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: August 6, 2002 .~lf~;j~b~.~~~_l€I;r.t<i;j~&fi;':S-h;1),;:;"";_,,,,~~,"Hi'I.~a:~'flf'-"_~~;[jtllJlIil"--' ~" ""'lIillilV-= C's Q> .~M' ,,~~_ ~, ~ ~_'_'" ~oe_'~ _ ~ ,~-~ '''~ ~-"" ~~~,- -~,~ ^ ~ I~~ . 0 0 0 c: r.....,) -n :;;;: ;Do "'QUi c= :r;,:r m-rT"~ G? Z:x; zr- I d~ 9~. 01 ...L. ~C " ?j~ Pc ::J: Z " --0 )>C (jGl Z s;: --< -< (.0 :D -c ,~ ~,~~-".