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Home My WebLink About99-03582M h • Z I T ,.a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, Vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. TO: DEFENDANT(,) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAOE'RE NST YOU. L AT IFF 1 HEREBY CERTIFY THAT T11I7 ADDRESS OF THE PLAINTIFF IS: 11330 McCormick R.W. Suite 200 Hunt Valley. MD 21031-1026 AND THE DEFENDANT(S): 230 N Crossroads Road Lyke O E R PLAINTIFF C'ER'rIFIC'A'TE OF LOC'A'TION i HERFBY 'F 1!1f 'Y "'Hl r'THE LOC A"HON OF THE REA .S KI'E FC'T8D BY THIS LIEN IS 4 E. Pin 25 ATTO E FOR PLAINTIFF CIVIL DIVISION NO.: C/I - 35$a TYPE OF PLEADING qW ?QfM CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Eastem Savings Bank Plaintiff, COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DURKIN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: qq-358a Vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. AVISO USTED HA SI.nO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dial despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclarnacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME A MAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: qq- 35Qa, Ci;..Sil"err*? V3. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Eastern Savings Bank, FSB, by its attorneys, James, Smith, Durkin & Connelly LLP, files this Complaint in Mortgage Foreclosure as follows: The Plaintiff is Eastern Savings Bank, which has its principal place of business at 11350 McCormick Road, Suite 200, Hunt Valley, Maryland 21031-1026. 2. The Defendants, Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, are adult individuals whose last known address is 230 N. Crossroads Road, Lykens, Pennsylvania 17048. 3. On or about May 2, 1997, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, executed a Note in favor of Plaintiff in the original principal amount of $78,750.00. 4. On or about May 2, 1997, as security for payment of the aforesaid Note, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $78,750.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on May 6, 1997, in Mortgage Book Volume 1380, Page 46. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. On or about July I, 1998, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, deeded the aforementioned mortgaged premises to Defendants, who presently are the record and real owners of the aforesaid mortgaged premises, subject to the Mortgage. 6. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 7. On or about December 10, 1998, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, was mailed Notices of Homeowners' Emergency Mortgage Assistance Act of 1983, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983. A true and correct copy of said Notice is marked Exhibit "B", attached hereto and made a part he-eof. 8. On or about December 10, 1998, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, was mailed a Notice of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. § 101, et seq. A true and correct copy of said Notice is marked Exhibit "C", attached hereto and made a part hereof. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal Interest through 6/9/99 $78,597.16 8 Escrow Advances $ ,910.81 Late Charges $ 553.00 Other Fees and Costs $ 423.49 Attorney's Fees $ 140.00 Title Search and Costs $ 800.00 $ 2.500.0 0 TOTAL $89,924.46 plus interest on the principal sum ($78,597.16) from June 9, 1999, at the rate of $24.56 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $89,924.46, with interest thereon at the rate of $24.56 per diem from June 9, 1999 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises JAMES, SNIj Hl DURKIN & CONNELLY LLP BY: Sc Jt A. Dietterick, Esquire Attrneys for Plaintiff PA I.D. # 55650 P.O. Boa 650 Hershey, PA 17033 (717) 533-3280 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" REI'BRNORIGINALTO: /J,, EF"S/MechanicaburR 5070 Riller Road Suite 115 Mechan.exl.urg, I'A 17055 r)t ul- ret( 1120571%55 '9719B' 6 Pill 12 33 MORTGAGE #1120571755 (ay.c. raw. TNtt tar rot n.e„oaq osy 6w $- 11115 MORTGAGE ("Securityy Instrument") Is given on ........................MAY, 2N1,) 199?...... .' The mortgagor is.OAIj11ARA A. SI'llCRLY _ ......................................._........ ............................................................................("Borrower"). 'I his Security Instrument is given tn.................................. EASTERN SAV INGS RAMC, F'SII "".............................................................................................................................. which is urgalised and existing under lhC laws n(,TItN UN[t; ffATFti OFAIMM A ............. and whose address is ................................ ................................................................................. .......s ...,cuucr. . . ). Borrower owes Witter the principal sum of ... til':?[i'Y I?,ICIIT TIIOG,SAND SEVIiN IIUNDBF.D .. ................ TY .. ..hIs................................... .......... F'1F ANU... .......................N....../.......O IRO .... ............ . IAJlars (U.S. 5....... 7A,750;00 ,,,,, ,,.., .., , ,,• ).•IThis ..) debt is evidenced by Borrower's note ote dated the some date as this Security Instrument Nom"), which provides for monthly payments, with the full debt, If not paid earlier, due and pays.... on ......MAY . ............. .......... This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced underparagraph 7 toprotecl the security of this Security Instrument; and (c) the performance of Borroircr'scovenams and agreements tinder this Security Instrument and the Nate. rot this purppoose, Bormwer does hereby mortgage, grad and convey to Lender the following described property .......... ....... located In ........ Clkml.erland....- ....-................................................................................................... County, Pennsylvania: SEE EXHIBIT "A" ATYACIIED HEREl'O AND MADE A PART IIEREOF which has the address of........... AE; PINE; St; ENOIA ............................... ........... .......... ................. ................... ICMi Pennsylvania .........17025 ............. ("Property Aildress"); ............................. Inne.asl Tornm[En Wrm all the improvements now or hereafter erected on the property, and all eapemems, appurtenances, and fixtures now or hereafter apart of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred m in Ihis Security Instrument as the "Property." I1nRROWER CUvL'NAirm that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Burrower warrants and will defend generally the title In the Properly against all claims and demands, subject to any encumbrances of record. PENNSYLVANIA - Single Family- Fannie MaelFredrOa Mac UNIFORM INSTRUMENT Form 7079 9100 (pas lolypaw) oood380faclt 46 'lolls SvOlar ry INS.BtmMLNI' colnnbines uniform eovcoallls for national use nod nun-11"B"rm cuverild- will- limited vadulfunx by jurfsdicttm. to oursrttme a uniform seclllily insruntcnl covering real property. UNIFUI(M CU V BNAN'I S. lonower ulna I cndur coecoaal and agree as follows; I. payment of Principal and Interest; Prepayment and late Charges. Borrower shall promptly pay when file th principal of and interest nn the dela evidenced lay the Note and any prepayment and late charges tire under the Note. 2. Funds fur Taxes anti Imurance. Subjecl to applicable law ar Io a written waiver by lender, Borrower shall pay Io Lender nn tlm day monthly payments arc Joe under the Note, until the Nnte is pail bi full, u sum ("B'unds") for: (a) Yearly taxes anti assessments which may attain priority ever tills Security Instmmrnt as n Ifen on the Properly; (b) yearly leasehold Puymcll s or ground rents stn tine Properly, if ally: (c) ycntiy Iazanl or pngrny insurance premiums; (J) heady !hand insurance premiums, if army; (c) yearly mortgage insurance premiums, if any; and (f) any sums payable by Burrower m Imder, in accordance with the provisions of paragraph R, fn lieu of the payment of mortgage insurance premiums, These items are called "Cscrow Items." lender may, at any time, collect still hold Funds ht an amount not to exceed ilia maximum amount a leader fur a federally relined mortgage loan may require for Borrower's escrow account under the federal Neal [;state Settlement Procedures Act of 1974 as amended from lime an time, 12 U.S.C. 82601 er seq. ("RBSPA"),unless another law that applies hit the Funds sets a lesser amounl. If sec, Leader may, aI any lime, collect and hold Ponds fn an amount our to exceed the lesser amount, Imder may estimate the a hull of Funds due on the basis of current data and reasonable estimates of expcnJflures of future Escrow Items or otherwise fn accordance with applicable law. 'life I undx shall be held in all fn.uilto nn :whole deposits are insured by a federal agency, in.mmmenhlfty, or entity (Including Imder, it render is such tan first II if Ilia) or In any Federal Ilome IAlan Bank. Lender shall apply the Funds to pay the ENcruw Items. Leader may nut charge Borrower for loading and applying line Funds, annually analyzing the escrow account, or verifying the Escrow Items, utIess Lender pays Ifurruwer interest on the Fonds still applicable law permits lender it, make such u charge. Iluwever, lender may require Borrower hit pay a one-time charge for an independent real estate lax reporting service used by [seder in connection with This Iran, unlessapplicnhle IawprnvlJesolherwia. Unless an agreement is made or applicable low requires interest to he paid, Lender shall nor he required or pay Borrower any interest or earnings on the Funds. Borrower still Icader may agree in writing, however, that interest shall be paid on the Funds. Lender shall give In Borrower, without charge, an normal accounting (,title Funds, showing credits null debits to the Funds and the purpose for which each dchll o Bite Funds was made. The Funds arc pledged as additional security for all sums secured by this Security instrument. lithe 1vnds held by Lender exceed the anuunls permined to be held by applicable law, icnder shall account to Burrower far the excess Virus in accord,mce with the requirements (if applicable law. If the amunnl lit the Funds held by Lender at any lime is not sufficient to pay the Escrow Items when due, lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the salaam necessity it) make up the deficiency. Borrower shall make up the deficiency in no more than twelve monthly payments, at lender's solediscretion, Upm paymenl fn full of all sums secured by this Security Instrument, Lender shelf promptly refund to Borrower any Funds held by Lender. If, under paragraph 21, lender shall acquire or sell the Properly, Lender, prior to the acquisition or sale of the Properly, shall apply any Funds held by Lender or the time of aquisithm or sale as a credil against the sums scctrcd by ibis Security Instrument. 3, Application of Payments. Unless applicable law provides wherwise, all payments received by Imder under paragraphs I and 2 shall he applied: first, In any prepayment charges due under the Note; second, to amnunls payable under paragraph 2; ddal, if) interest due; fourth, to principal due; unit Iasi, (,);toy late charges duc under the Note, 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Puperty which may attain priorhy aver this Security Instrument, and Ien.sehold payments it ground rents, if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on lime directly tit the person owed payment. Sort, wer shall promptly famish to Lender all notices of amounts to be paid underthfsparagmph.If Lkrnawermakes drew payments directly, Ilorrowershall promptly famish to lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees fn writing Io the paymenl of the obligation secured by tine lien to a manner acceptable to lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which fn the Lender's opinion operate In prevent the enforcement of the lien; at be) secures from the holder of the lien :stn agreement satisfactory to lender suMr- dinating the lien to this Security Instrument. If Leader determines that any part of the property is subject to a Ifen which may attain priority over this Security Instrument, Leader may give Borrower a notice identifying the lien Borrower shall satisfy the lien or lake one or more of the actions set faith above within in days of the giving or notice, 5. [[sued or property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Prapeny insured against loss by (ire, hazards included within Ilse term "extended coverage" and any otter hazards, Including floods or flooding, for which Imder requires insurance. -this insurance shall he maintained in the amounts and sTafa rn6 _211w BOGXi38OPACE 47 Form =39 a/ao (pafrloopaaw) for the periods that Itittle r requires. 'I he insurance carrier providing the insufance slmll be chosen by le B suhJecTnder's approval which shall n,, be unrcasnuhly wilbadd. If Borrower fails it) All insurance main hdn coverage desedburrowered shave, Icndcro may, at I surana option, otillr coverage m prince, lender's rights in the PIuperly In accordance with paragraph 7. ce Policies still renewals shall be acceptable To Under and shall include a standard mortgage clause, lender shall have the right w hold the poltefes and renewals. If Lander Inquires, Burrower shall promptly give to Under all receipts of paid premiums and renewal notices. In The event of loss. Borrower shall give prompt notice in th insurance carrier mill Under. Under may make proof of loss if no, made promptly by Borrower. Unless Under and Borrower otherwise agree in writing, Insurance prunxds shall be applied it, restoration or repair of the Property damaged, if The restoration or repair is economically feasible and finder's security is not lessened, If the restoration or repair Is nil economically feasible or Lender's security would be lessened, the Insurance proceeds shall be applied to the sums secured by this Securily Instrument, whither or non then due, with anycacess paid to Borrower. If Borrower abandons the Properly, of does nol answer within 30 days a notice from Under that The insurance carrier has offered to settle a claim, then Under may collect The insurance proceeds. Under may use the proceeds ns repair or resume the Property or In pay sums secured by this Securily Instrument, whether or not then due.'rhe 30-Jay period will begin when the notice is given. Unless Under and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the lute Jane of the monthly payments referred m in paragraphs I and 2 or change the amount or file payments. It wider paragraph 21 the Property is acquired by I.ender, borrower's right m any Insurance politics and proceeds resulting from damage Io [be Property prior to the acquisition shall Pass to Lender to the exit. tit of the sums seemed by this Security Instrument Immediately prior ill the acquisition. 6. Occupancy, Preservation, Maintenance unit Proleclinn or lint Property, Ilorrower's f.oun Application; Leaseholds. Borrower shal I occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of ibis Security Instrument and shall continue to occupy the Property as Ifarrower's principal residence for at least (Inc year after the date of occupancy, unless Under otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which arc beyond Iiormwer's comrul. Borruwer shall not destroy, damage or impair the Property, allow the Property it, de,eftorale, or commit waste on the Property. Bormwer shall he in default if any forfellure action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of,he i'roper,y ortrtlherwise materially impair the lien created by this Security Instrument or lender's security interest. Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in Banter's good faith determination, precludes forfeiture of the Borrower's interest fn the Property or other material impairment of the lien created by this Security Instilment or lender's security interest. Bormwershall also he in default if torrower, during the loan application process, gave materially false or inaccurate information or statements to Under (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, bill not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If Ills Security Instrument is on a leasehold, Bloomer shall comply with all lite provisions of the lease. If Borrower acquires fee title to the Property, the IcasehnW and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of lender's Nights in the Properly. If Borrower fails to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect t cnder's rights in the Property (such as a proceeding in bankruptcy, probate, far condemnation or forfeitum or to enforce laws or regulations), then Under may do and pay fur whatever is necessary to protect tire value of the Property and lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property In make repairs. Although Lender may take action tinder this paragraph 7, Under dues nun have to do so. Any amounts disbursed by lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Icndcr agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rare and shall be payable, with interest, upon notice from Under in Borrower requesting payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by ibis Secondly Instmmenl, Borrower shall pay the premiums required lo maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay lie premiums, required to obtain coverage substantially equivalent or the mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Burmwerof the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Bender each month a sum equal to one-twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to he in effect. Icndcr will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in The amount and for the period that lender requires) Pmvidcd by an insurer approved by lender again becomes available Sreu'PA&3,Nr:W BOON 1380 PACE 48 Form 3032 9190 (par aallpgsr) and Is obtained. Borrower shall pay Ilre Premiums required la mahnain mortgage insurance in ritual, or a provide a loss reserve, ullil the requirement (or mortgage insaru... ends In o"nuanee will, any written agrcemenu between Borrower and Icnder car applicable law. 9. Inspection. Lender or its agent may make reasonable entries n;xro and inspections of the Property. Icndcr shall give Borrower notice at die time of or prior m an inspection specifying reasonable cause for into inspection. Ill. Condemnation. The proceeds of any award or claim fur damages, direct or consequential, 41 connection with any condemnation car other taking of any part of the Property, car for conveyance in lice of amdemnation, are lmrcby assigned and shall he paid to Icnder. In the event of a total taking of the Property, the pnkceds shall he applied m the atimsseamcd by Ibis Security Instrument, whetter or not then life, with any excess paid lu Borrower. In the event of a partial taking of the Property in which the fair market value of The Property immediately before the taking is equal w it greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Icnderolherwise agree in writing, the sums secured by this Security Instrument shall Ire reduced by Ilse amount of Ilre Proceeds mnltplled by the following traction: (a) the total amount of the sums.coned immediately before the taking, divided by (b) lire fair market value of Ibe Property Immediately before the taking. Any balance shall be paid it, Borrower. In the event of a panful taking of the Property in which the fair market value of the Property immediately before die taking is less than the amount of the sums accused im- mediately before, the taking unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise pro. vides, the proceeds shall be applied to the sums orated by This Security Inslmment whether or not the sums are then due. If the Property I. abandoned by Borrower, or if, after notice by Icnder m Borrower that she omdenmor offers to make an award or settle u claim for damages, borrower fails to respond to Icndcr within 3U days after the date the notice is given, lender is authorized in collect and apply the proceeds, at its option, either to restoration or repair of the Property ,it to the sums secured try this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall nil extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By tender Nal a Waiver. Extension of The time for payment or modification of amortization of the sums secured by this Security Instrument granted by tender to any successor in interest of Borrower shall not operate to release the liability of she, original Borrower or Ikrrrower's successors in interest. Lender shall nor in required to commence proceedings against any successor in interest or refuse to extend time for payment or ntherwire modify amonizariun of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Save •o1 Liability; Co-signers, -Pita covenants and agreements of this Security Ins[mment shall bind and benefit the success, rs and assigns of Lender and Borrower, subject to the provisions ofparagraph 17. Bonower'scovenants and agreements Ord In joint and several.Any Borrower who cu-signs ibis Security Inslmment but does not execute the Note: (a) is co-signbtg this Security Instrument only bs mortgage, grant and convey that Borrower's interest in the Property tinder the terms o' this Security Instrument; (b) is nut personally obligated to pay the sums secured by this Security instrument; and (c) tog'. ees that lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument car the Nate without that Borrower's consent. 13. Loan Charges, If the loan secured by This Security Instrument is subject to a law witless sets maximum loan charges, and that law is finally interpreted so that the tdterest orosher luau charges collected or to IV collected in connection with the Ivan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded In Borrower. Icndcr may choose to make this refund by r sb cing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under Be: Note. 14. Notices. Any notice to Borrower provided for in this Security Nstmmem shall be given by delivering it or by mailing it by first class mail unless applicable law requires rise of another method Ilia notice shall he directed to the Property Address or any other address Borrower designates by notice to tender. Any notice In Lender shall he given by first class mail to Lender's address stated retain or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall tie deemed to have been given it, Borrower or lender when given as provided in this paragraph. 15. Governing Law; Severobilily. This Security Instrument shall he governed by federal law and [he law or the jurisdiction in which the Property is located. In the event that any provision or clause of this security Instmmam or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instalment or the Note which can be given effect without the conflicting provision. To [his end the provisions of this Security Instrument and the Nola are declared to be severable. 16. Burrower's Copy. Butrewer shall be4 wit one confirmed copy of the Nom and of this Security Instrument. BOUgj3QOPAGE 49 ST&M PAM14.fln Farm 3039 Grata (orprlol ypaaaQ 17.'1'ramier orlhe Properly or a flenefrcial Imarexl in llorrasrer. If all or any part of The Properly or any interest III II la Fllhl sir Irallsrefrell fur if a beneficial inlayed in Borrower i.s Fuld sir transferred and Ikmnwer is 11,11 a natural person) without Icnder's prior written consent, lender may, at its option, require immediate payment in full of oil sons secured by this Security Instrument. However, this option shall not he exercised by Lender if excmise is prohibited by federal law as of the date of this Security Instnlmeni. If lender exercises ibis upliun, lender shall give Borrower notice of acceleration.'Bm notice shall provide a pound (door less than 70 days from [lie date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay Ihese sums prior to the expiration of Ibis period, lender may invoke any is medies permlunl by this Security Instrument without further notice or demand on Borrower. 18. Borrower's Night to Reinstate. If IAVUSwer meets certain condhinns. Borrower shall have the right to have enforcement of this Security Instrument discontinued at any lime prior to the earlier of: (a) 5 days ((it inch other period as applicable law may specify for reinstatement) be-fun sack of the ]Property pursuers to any power of solo contained in Ihis Security Instrument; or 01) entry of a judgment enforcing this Security Inslrumem 'those conditions are that Ilarnlwer: (a) pays Igniter all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) noes any deraplt orally other Covenants or agreements; (c) pays all cepeuses incurred in enforcing this Security Instrument, including, but our limited to, reasonable allomcys' Ices; and (d) takes such action as leader may reasonably require to assure that the lien of this Security Instrument, tender's rights in the ]Properly and lhsrruwer s obligation to pay the sums seemed by tits Security Instrument shall continue unchanged. Upon reinstatement by Borrower, ibis Security In- strument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. Ilowaver. this right to reinstate shall not apply in The case of acceleration under paragraph 17. 19. sale of Nate; Change or iAmn Servicer. I lie Note (ir a part aI into rest in the Note finger tier with this Security Instrument) may he sold one or more limes without prior notice to Borrower. A sale may result in a change in The entity (known as the "Iran Servicer") That collects monthly payments due under the Note and this Security Instrument. 'rhere also may lie one or more changes of the loan Servicer unrelated to a sale of the Note. If there Is a change of the Iran Services, Borrower will bo given written notice of the change fn accordance with paragraph 14 above and applicable law, ']fie notice will state the name and address of the new Loon Servicer and the address in which payments should be made. ']fie antics: will also ccnafn any other information required by applicable law. 20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release or any Hazardous Substances an or fit the property. Borrower shall not du, nor allow anyone else to do, anything affecting the Property that is in violation of any linvfronmental law. llas preceding two sentences shall nor apply to the presence, use, or storage on the Property of small quantities of (hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the I'mpmty. Borrower shall promptly give tender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the ]Property and any Hazardous Substance or Environmental law of which Ihorowcr has actual knowledge. U Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remedimion of any i hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 20, "]Hazardous Substances" are those substances deffned as toxic or hazardous substances, by Environs menial law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pestchles and herbicides, volatile solvents, materials containing ashcans or formaldehyde and radioactive materials. As used in Ihis paragraph 20, "Environmental law" means federal laws and laws of lhejurhdictiun where the Property fs located that relate to health, safety or environmental protection. NONUNIFORM COVENANIN. Borrower and leader further covenant and agree as follows: 21. Acceleration; Remedies. Icnder shall give notice ill Barmwer prior to acceleration following Dometwer's breach of any covenant or agreement in this Security Instrument (Trot not prior In acceleration under paragraph 17 unless applicable law provides a herwise). Icnder shall notify Harrower of, among other Brings: (a) the default; (b) the action required to cure the defoult; (c) when the default must be cured; and (it) that failure to cure the defa ill asspecifled may result in acceleration of the st unsecured by this Security Instrument, farelosom by judkial proceeding and sale of the Properly. Lender shall farther inform Borrower of Ilse right In reinstate after acceleration and the righltoasserlin the foradgsurepromeding the nnncxkslet ceufudefoull many nlherdefense orllurrowerloacceleratian and Foreclosure. If the default is not cured as specincd, Lender at its option may require Immediate payment In full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Icnder shall he entitled In collect sill expenses incurred in pursuing the remedies provided in this pamgruph 21, Including, hill not limited to, attorneys' fees and crisis of title evidence to the extent permitted by applicable law. x W A PAn.s. NEW Bood39-0 PAGE 50 Form moo a/as, Nalz'•Sollpapn) 22. Release. Upon payment of all $ums secured by this Seel"hy hashumeut, this Security Instrument and the estate conveyed shall termhmte and become void. Attar such iwell rrenco.I ender shall discharge and satisfy Ibis Secmily Instrument. Burrower shall pay any recordation costs. Ixoder may charge Ilnrrower a fee for releasing (his Security Instrunt but only If the fee Is paid ha a third party for services renMred and ilia charging of the fee is permiucd under applicable law, 23. Wallets. borrower, to the extent permined by nPPllcable law, waives and releases any error or defects in pro- ceedings to enforce this Security Instrument, and hereby waives the Iwacfil of any present or haute laws providing for stay of execut fen, extension of Ifine, exemption from xrlxchntent, levy mul role, mid homestead exemption. 24. Reinstatement Period. Borrower's time In reinstate provided hl paragraph IS shall extend to nnc hour prior In Ilia commencement of bidding at a sheriff's sale or other sale pursuant it, [his Security Instmment. 25. 14rrchae Money Mortgage. If any of the dell seemed by 161s Security huhumenl is [cut In Ilurrnwer In eaqufre title to the property, this Security Instrument sball Iw a pamhase money mortgage. 25. Interest Rate Aner Judgment. borrower agrees than Idle haercu rate payable after a judgment is entered on the Note IT hl an action of mortgage foreclosure shall he ilia rata payable from time In Ifine under the Note, 27. Rlderslnlhls Seeurilyfnstmment. If one or more riders are executed by Ilnrrower and recorded together with this Security Instrument, the cuveamus and agreements detach .snub rider shall ire incorporated into and shell amend and supplememdac awmuanuand agrcememsuf tills Security Inmmmenl as i f the rider(s) were apart of thisSecurity Instrument. )(]heck appllcahle hux(mdj ? Adjusmhle Ram Rider ? Cemdnminium Rider ? 1-4 Family Rider ? Graduated Payment hider ? Planned Unit Ihvel(pmma Rider ? Biweekly Payment Rider ? balloon Risher ? Rule Impnwemmn itldcr Other(s) )specify) ? Second f lomc hider ? fly SKINInG Ilt;knw, burrower accepts and agrees to the terms and covenants cmbafned in this Security Instmment and in any rider(s) executed by Ikurower and recorded with it. Witnesses: .......... ..JL ..............(......... .....'?...F. (Seal) BARBARA A, SIVCKEY Ilssrtnwar .......................................................................................(Sea I) -Borrower ........................................................................................ Seal) Aurtnwer Sr&INPA"NFW oooK1380 PACE 51 Farm nano 9190 (Paps BolypepiQ -Borrower CIiRTIFICATB OP RESIDENCE. I, the undersigned subscribing Agent Of the lender named within, do hereby certify that the correct address of the said Lender is WITMSS MY BAND this .??? day of . z K _.__, 19 - f•T,CYG//L??_ Agent or under Name ISpses BNow This One For Aekrmwledi msnq COMMOMWEAL711 OF PMNSYLVANIA, G'6'46.•??AdJ County s3: On this, the c?Nb day of MAY v? 97 , before me, BARBARA A. SFUCKMY the undersigned officer, personally appeared known to me (or satisfactorily proven) to be the Person(s) whose name(s) is/arc subscribed m the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WlmhsS WIIFREOF, 1 hereunto set my hand and official scat. / My Commission cxpires:A1'7v61N1-'6-K'`(, stress S77RDw PA6.7.1,113W NOTARIAL SEAL JAMES J. BAIBOS, Namy PW91c C m 'uLM'W Nn fy 1999 Booty 1380 PAGE 52 Form N39 9/0 fwa7anPrw.1 Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described an fol lown, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis N. Spangler, said plan being recorded in the Office for Recording of Benda in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side or Pyre Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point In the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyre Street), South Enola, ' Pennsylvania,, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. 8 Pine Street, South 40 degrees 30 minuteB East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes Went 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. .,::,ylvanin SS .,.:roorl:rnd ` . omce for ine Pn:urdinp of 0..", f?I n••rlnnd COU nf' '/ (\?? of s}t d a dny E ,y Reel, er BOux 1380 PACE 53 EXHIBIT "B" ff EASTE[k - Cutpurate Headquarters Etautive Plaza 2 11550 McCormick Road, s Suite 200 SAVINGS BANK Ilunt Vallcy, Maryland 21031 Established 1905 (410)785.2200 Date : December 10, 1998 VIA CERTIFIED MAIL RETURN RECEIPT REOUIFSTED AND VIA REGULAR MAIL Mortgagor : Barbara A. Sheaffer Mailing Address : 4 E. Pine Street Enola, PA 17025 Property Address : 4 E, Pine Street Enola, PA 17025 Re : Loan Number : 1120571755 Premises : 4 E, Pine Street Enola, PA 17025 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE The MORTGAGE Held by -Eastern Savings Bank. fsb. (hereinafter we, us or ours), on your property located at 4 E. Pine Street Enola. PA 17025 IS IN SERIOUS DEFAULT because you have not made the following payments Regular Monthly Payment of $ 764.87 from 0/7/98 to 1[6/98 for (Three (3) ) $_2224.41 Monthly Late Charges of $3.8.24 from 5/7/98 to 12(6/2$ for( Seven (7)) months $ 232.29 Escrow Balance / Deficiency $ 00.00 Property Inspection Report $ 00.00 Bad Check Fees $ DM Other Fees (pre-legal appraisal) $_W 40 TOTAL AMOUNT DUE $ 2526.90 Z 146 218 966 us Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Pikmille(410) 486-8222 • Tommn(410) 29G4300 • Fullermn(410) 661.4412 • N.W. llah,=,04103358.3881 Mr.kr FDIC W 4 . Al I S-. J_ D.: , EASTERN Corporate Curpu Headquaittri ff E n 2 titive Executive Pan 2 ucu SAVINGS BANK 11350 McCormick Road. Suite 200 rah llant valley. Maryland 21031 Established c9os (410)785.2280 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $ 2526..90 . You may cure this default within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $ 2526.9 0, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at : F. A: 7orkv Collection Office Eastern Savings Bank, FSB. 11350 McCormick Rd. EP-2, Suite 200 Hunt Valley, MD 21031 (410) 785 - 2200 Pikerville (410) 486.8222 a Tuwm(410) 2964300 a F.Ilenon(410) 661.4412 a N.W Baltimore (4 to) 358. M8 I a HtShhndtown(410) 327.3623 a Ellicott City(410) 992.8500 MW" FDIC ® - Corporate Hadgoancta EASTEf?IV Executive Plana 2 SAVINGS BANK 11351 McCormick Road, Suite 200 ran Hunt Valley, Maryland 21031 Established 1905 (410) 785.2200 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. IF YOU NEED MORE INFORMATION, CALL THE PENNSYLVANIA HOUSING FINANCE AGENCY AT 1 (800) 342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA; PLIES AFECTA SU DERECHO A CONTINUAR VIVENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Date: December 10. 1998 RE: NAME: Barbara A. Sheaffer PROPERTY ADDRESS: 4 E, Pine Street Enoia, PA 17025 ACCOUNT NUMBER: 1120571755 Pikeville (410) 486.8222 a Towwn(410)296-4300 a Fulltnon(410)661.4412 " N.W Baltimore (410) 3583881 a Hiehhndtown(410) 327.3623 a Ellicott City (410) 792.8500 Aland, FDIC , Suite 200 95 EASTERN - Curyaorc licadquancts Executive Plaza 2 11350 M<Cormick Road, Suite 200 SAVINGS BANKVA, Hunt Valley, Maryland 21031 Established 1905 (410)785.2200 Mail To : Barbara A. Sheaffer 230 N. Crossroads Rd. Lykens, PA 17048 FROM: F. A. Zerwitz Eastern Savings Bank. fsb. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the " ACT"). You may be eligible for the emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time, you must arrange and attend a "face to face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face to face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: F. A. Ze rwitz . EASTER N SAVINGS BANK. FS13. EP-11. SU ITE 200 11350 M C i k RD HUNT V c orm c . ALLEY. MD 21031 1 - (800) - 787 - 8187 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face to face meeting. You should advise the lender immediately of your intentions. Your mortgage is in serious default because you have failed installments of principal and interest, as required, for a perio The total amount of the delinquency is $ 2526.90 . That following: Three (33) regular payments of $ 764.87 fgt through 1/6/98, late charges of $ 232.29 for the months , escrow balance( I deficiency of $ 00.00, bounce checi fees ( appraisal) of $ 00.00. Pikewille (410) 486.9222 " Tunon (410) 296.4300 a Fullerton (110) 661-0412 • NV Wlum"m (110) 358-1881 • 11 Al mtrr POIC Z 068 651 962 US Poslal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for Inlemational Mail /See reverse) IR.mm BARBARA A. STUCKEY / 230 N. CROSSROADS LYKENS, PA 17048 Ir me.e F. EASTE11?1 Corporate Headquarter, 11350 McCormick Executive Road, Suite SAVINGS BANK Nunr Valley, Maryland 21031 Established ig05 (410)785.2200 Your mortgage is also in default for the following reason: n/a If you have tried and are unable to resolve this problem at or after face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within thirty (,3_0) days of your face-to-face meeting It is extremely important that you file your application promptly, If you do not do 0 or if you do not follow the other time ne6gds 5el forth in this I ttar foreclosure may proceed against your home imrrlediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and omnlete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P. 0. Box 8029, Harrisburg, PA 17105. Telephone number (717) 780.3800 or 1 (800) 342-239' (toll free number). (Enclosed also is) (you have already received) (in addition you will receive) another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. (Use this paragraph only if applicable.) Sincerely,n F. A. 1 Collection Officer Act 91 Pikesville(410) 4868222 " Tovson(410)296.4300 • Fallen"n 6110) 6611412 " RW Baltimore (410) 358-3881 • HigMandeown(410) 3273623 • Ellicott Gry(410)992.8500 Menbm rDIC EHF, and HOFFI•IAII . li.l. CLARION COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Washington Street Butler, PA 16001 (412) 282-7812 CLEARFIELD COUNTY Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 (412) 465-2657 FAX H (412) 465-5118 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500.02 Third Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 CLINTON COUNTY Lyconting-Clinton Counties Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 FAX p (717) 322-2197 Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 163 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 6091.30 067 P. 11 31 West Market Street Wilkes-Barre, PA 13702 (717) 821.0837 or 1(300) 922.9537 FAX x (717) 821-1785 Commrission on Economics Opportunity of Luzern County 211.213 South Main Street Wilkes-Barre, PA 18701 (717) 826.0510 or 1(800) 822-0359 FAX N (717) 829-1665 - call before faxing (717) 455.4994 Hazelton Fax k (717) 455.5631 - call before faxing (717) 836-4090 Tunkhanno:k CRAWFORD COUNTY Booker T. Washingtolt Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX N (814) 453.5749 Greater Erie Community Action Committee 18 West Ninth Street Erie, PA 16501 (814) 459-4531 FAX # (814) 456-0161 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX # (814) 898-1243 Shenango Valley Urban League, Inc, 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 111-3? 19'd: 0::-'5FH c- EAR and HOFFFIRI N.J. 60? 53U 9067 F.1'I Financial Services Unlimited 117 West Third Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 FAX H (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX N (717) 243-3948 DAUPHIN COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 FAX N (717) 2324985 DELAWARE COUNTY Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 763.2333 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East DeKalb Pike, Suite 100 King of Prussia, PA 19406 (215) 354-9922 Consumer Credit Counseling Service of Delaware Valley 1211 Chestnut Street, Suitc 400 Philadelphia, PA 19107 (215) 563-5665 FAX N (215) 864-2666 Hispanic Association of Contractors & Enterorises 2921-27 North Fifth Street Philadelphia, PA 19133 (215) 426.8025 FAX H (215) 426-8027 La Casa Del Pueblo 815 West Baltimore Pike Kennett Square, PA 19343 (215) 444-3731 FAX p (215) 444-3178 Media Fellowship House 302 South Jackson Street Media, PA 19063 (215) 565-0846 Philadelphia Council for Community Advancement 100 North 17th Street, Suite 600 Philadelphia, PA 19103 (215) 567-7803 FAX H (215) 963-9941 ELK COUNTY Jolut F. Kennedy Center, Inc. 2021 East 20th Street Eric, PA 16510 (814) 898.0400 FAX p (814) 898-1243 Northern Tier Community Action Corp. 135 West Fourth Street Emporium, PA 15834 (814) 486-1161 FAX N (814) 486-3370 Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX N (814) 453-5749 Greater Erie Community Action Committee 18 West Ninth Street Erie, PA 16501 (814) 459.4581 FAX N (814) 456-0161 IF EASTEI?IV - Corporate Headquarter, Gtnutirt Plug 2 2 Sl1VII \ V J B{?(i) 11350 McCormick Road, Suitt 200 tr° Hunt Yillcy,Maryland 21031 Eslabllshed 1905 (410)7135,2200 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. IF YOU NEED MORE INFORMATION, CALL THE PENNSYLVANIA HOUSING FINANCE AGENCY AT 1 (800) 342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Date: December 10 1998 RE: NAME: PROPERTY ADDRESS: ACCOUNT NUMBER: Barbara A. Sheaffer 4 E, Pine Street Encla, PA 17025 1120571755 Pikeaville(410) 486.8222 a 70awn(410) 2964300 r F"Ilenun(410) 661.1412 a NN Oakimmt(410) 3183881 v PoBhlandtoan(410) 3273623 4 Ellicott City 010) 992.8500 Alt"bee r01C SEASTECorporate ,W1 Headquarters Executive re Plato 2 SAVINGS BANK 11350 McCormick Rout, Suite zoo nn Hunt Valley, Maryland 21031 Established 1905 (410)785.2200 Mail To : Barbara A. Sheaffer 4 E. Pine Street Enola,PA 17025 FROM: F. A Zerwitz Eastern Savings Bank fsb You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the " ACT"). You may be eligible for the emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time, you must arrange and attend a "face to face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face to face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face to face meeting. You should advise the lender immediately of your intentions. Your mortgage is in serious default because you have failec' installments of principal and interest, as required, for a peric The total amount of the delinquency is $ 2526.90. That following: Three (3) regular payments of $ 764.87 for through 1/6/98, _late charges of $ 232.29 for the months , escrow balance( ) / deficiency of $ 00.00 bounce chec' fees appraisal) of $ 00.00. Prkeawile(410) 4868222 a Towson(410) 2064300 a Fullerton WO) 01 66144 1 2 a N,W Baltimore A lot 3583881 a H M,mb,r FDIC Z 146 218 967 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. na rwt use for International mail isee re ./, /I JFEASTERN SAVINGS BANK nh Coemare Ileadquarmn Executive Plan 2 11350 McCormick Road, 5u ce 200 Hum Valley, Maryland 21031 (4101711%.2m Your mortgage is also in default for the following reason: nla If you have tried and are unable to resolve this problem at or after face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or po tmark d within thin yam days of yoi ir face-to-face meetina It is extremely important that you file Your aooli ation oromRtly If you do not oo cr, r f you do not follow the other time p rlod c t forth in this letter, for to AM= your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. ft is extremely important that your aooli aki i accurate nd o pl t resgect The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P. 0. Box 8029, Harrisburg, PA 17105. Telephone number (717) 780-3800 or 1 (800) 342-2397 (toll free number). (Enclosed also is) (you have already received) (in addition you will receive) another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while ou are receiving that assistance. (Use this paragraph only if applicable.) F. Act 91 Piknrille(410) 486.8222 • Towson (410) 296-4300 • Fullrnon(410) 661.1412 • N.W. Billion=(410) 158d891 • E86•hlandtovn N 10) 327 /? k, FDIC 3623 • Ellicott City (410) 792.8500 Min IQ lU 195: 0J: _EPl'I SPEAR and H! IFFIVil I I I. f, CLARION COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Washington Street Butler, PA 16001 (412) 282-7812 CLEARFIELD COUNTY Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX H (814) 539-1688 Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 (412) 465-2657 FAX H (412) 465-5118 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500.02 Third Avenue Post Office Box 278 Duncanville, PA (814) 696-3546 CLINTON COUNTY Lycoming-Clinton Counties Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 FAX # (717) 322-2197 Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 ('717) 342-1072 or 1(800) 922-9537 P.11 31 West Market Street Wilkes-Barre, PA 18702 (717) 821.0837 or 1(800) 922-9537 FAX N (717) 821-1785 Conm»ssion on Economics Opportunity of Luzern County 211.213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 or 1(800) 822-0359 FAX # (717) 829-1665 - call before faxing (717) 455.4994 Hazelton Fax # (717) 455-5631 - call before faxing (717) 836-4090 Tunkhanno:k CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX N (814) 453-5749 Greater Erie Community Action Committee 18 West Ninth Street Erie, PA 16501 (814) 459-4581 FAX k (814) 456-0161 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX N (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pemtsylvania, Inc. 2000 LinglWown Road Harrisburg, PA 17102 (717) 541-1757 10-2:-199Y 0:;:39F1'1 SF'U iP. and HVFFMA11 , H.J. 609 530 91367 P.12 Financial Services Unlimited 117 West Third Street Waynesboro. PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 FAX N (717) 2324985 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX N (717) 243-3948 DAUPHIN COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 FAX k (717) 232-4985 DELAWARE COUNTY Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 763-2333 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East DeKaib Pike, Suite 100 King of Prussia, PA 19406 (215) 354-9922 Consumer Credit Counseling Service of Delaware Valley 1211 Chestnut Street, Suite 400 Philadelphia. PA 19107 ('215) 563-5665 FAX N (215) 864-2666 Hispanic Association of Contractors & Enterprises 2921-27 North Fifth Street Philadelphia, PA 19133 (215) 426-8025 FAX # (215) 426-8027 La Casa Del Pueblo 815 West Baltimore Pike Kennett Square, PA 19348 (215) 444-3731 FAX # (215) 444.3178 Media Fellowship House 302 South Jackson Street Media, PA 19063 (215) 565-0846 Philadelphia Council for Community Advancement 100 North 171h Street, Suite 600 Philadelphia, PA 19103 (215) 567-7803 FAX N (215) 963-9941 ELK COUNTY John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX k (814) 898-1243 Northern Tier Community Action Corp. 135 West Fourth Street Emporium, PA 15834 (814) 486-1161 FAX N (814) 486-3370 Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX N (814) 453-5749 Greater Erie Community Action Committee 18 West Ninth Street Erie, PA 16501 (814) 459-4581 FAX X (814) 456-0161 EXHIBIT "C" Lr MCuqunteHeaJgmrtcn Eaceutive Flux 2 NK 11350 McCormick Auul, Suite 200 r.n Hunt vallcr, Maryland 21031 Established 1905 (410) 785-2200 Date : December 10, 1998 VIA CERTIFIED MAIL RETURN R IPT R 2 T D AND VIA REGULAR MAIL Mortgagor : Barbara A.Sheaffer Mailing Address :230 N. Crossroads Rd. Lykens, PA 17048 Property Address : 4 E, Pine Street Enola, PA 17025 Re: Loan Number : 1120571755 Premises : 4 E, Pine Street Enola, PA 17025 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE The MORT A r held by _En5teru Savings Bank fah. (hereinafter we, us or ours), on your property located at -4-E. Pine Street Fnola. PA 17025 IS IN SERIOUS DEFAULT because you have not made the following payments : Regular Monthly Payment of $ 764.87 from 1017/98 to 1/6/98 for (Three (3) ) $-294-b_1 Monthly Late Charges of $ 38.24 from 517/98 to 12/6/98 for ( Seven (7)) months $ 232.29 Escrow Balance / Deficiency $ 00.00 Property Inspection Report $ 00.00 Bad Check Fees $ 00.00 Other Fees (pre-legal appraisal) $ _MW TOTAL AMOUNT DUE $ 2526.90 Z 068 651 961 US Postal Service Receipt for Certified Mail No Insurance Coverage ProvMed Oo rwt use for Intemetlonal Mao See reverse Isent to BARBARA A. STUCKEY 230 N. CROSSROADS/ POtrnille(410148"222 -Tovwn(410)296.4300 - Fullerton(410)66IA412 • N.W. B,1nmure(4l0)358d881 . High LYKENS, PA 17048 MovM FDIC L L!% TUP CurpurEeHtivePl s2 aecure Plm 2 B11350 McCormick Road, Suite 200 Hunt Valley, Maryland 21031 Established 19os (410) 7854200 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is S 2526.90 . You may cure this dcl:wlt within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $ 2526.90, plus any additional montldy payments and late charges which may fill due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and inade at Eastern Savings Batik, FSD. 11350 McCormick Rd. EP-2, Suite 200 }lust Valley, MD 21031 / (410) 785 - 2200 F. A. Zefwitz Collection Officer Nkerville(410)486.8222 • To-=(410)276.4300 • Fullerton 1410) 661.4412 a N.W. er1imorc(410) 358-3881 • (4 10) 327-3623 • Ellicott Cry (410)992-8500 Mande, FDIC !^'1 VERIFICATION G._C. KulIkOWSki hereby states that he Is the_ Assistant Vice President- of -Eastern Savings Bank fsb mortgage servicing agent for plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsification to authorities. Kw G. C. Kulikowski Assistant Vice President Date: -May 10. 1999 C?j u:?? r 1 L , v Vv ? CST j SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-03582 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EASTERN SAVINGS BANK FSB VS. STUCKEY BARBARA A ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: STUCKEY BARBARA A N/K/A SHEAFFER BARBARA A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania. to serve the within NOT. COMPLAINT IN MORT. FORE On July 28th, 1999 , this office was in receipt of the attached return from DAUPHIN County, Pennsylvania. Sheriff's Costs: So answer 7777 Docketing 18.00 Out of County 9.00 Surcharge 8.00 40m ine, S e i DEP. DAUPHIN CO 47.75 $8a?.15 JAMES,1SMITH, DURKIN & CONNELL 07/287999 Sworn and subscribed to before me this )9 *1 day of 19q-9_ A.D. a- "--Pro nonocary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-03582 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EASTERN SAVINGS BANK FSB VS. STUCKEY BARBARA A ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: SHEAFFER BRYAN J but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania. to serve the within NOT. & COMPLAINT IN MORT FORE On July 28th 1999 , this office was in receipt of the attached return from DAUPHIN County, Pennsylvania. Sheriff's Costs: So anew Docketing 6.00 Out of County .00 X' Surcharge 8.00 mas in eri U JAMES, SMITH, DURKIN & CONNELL Sworn and subscribed to before me this ?9 -ft- day of 199 A.D. 'Pro o a Of E Phi#f Mary Jane Snyder Reed Estate lkluty William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 far: (717) 255.2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania EASTERN SAVINGS BANK FSB vs County of Dauphin SHEAFFER BRYAN J Sheriff's Return No. 1232-T - - -1999 OTHER COUNTY NO. 99-3582 Ralph G. McAllister Chief Ikputy Michael W. Rinehart Assistant Chief Deputy AND NOW: July 9, 1999 at 12:10PM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon SHEAFFER BRYAN J by personally handing to DEFT 1 true attested copy(ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at 230 N CROSSROADS ROAD LYKENS, PA 17098-0000 Sworn and subscribed to before me this 9TH da of JULY, 1999 PROTHONOTARY So Answers, ?l xl°, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $47.75 PD C6/21/1999 RCPT NO 125157 NM/TW (1?£ftre ofePxiff Marv Jane Snyder Reel Fstute Deputy ?? William T. Tully f Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)255.2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania , EASTERN SAVINGS BANK FSB County of Dauphin SHEAFFER BRYAN J g Sheriff's Return No. 1232-T - - -1999 OTHER COUNTY NO. 99-3582 Ralph C. McAllister Cltiel• Ikputy Michael W. Rinehart Assistatu Chief Deputy AND NOW: July 1, 1999 at 1:55AM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon STUCKEY BARBARA A N/K/A by personally handing SHEAFFER BARBARA A to DEFT 1 true attested Copy(ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at DAUPHIN COUNTY COURTHOUSE HARRISBURG, PA 00000-0000 Sworn and subscribed to So Answers,, before me this 9TH day, of JULY, 1999 Sheriff of Dauphin County, Pa. / PROTHONOTARY By 6?" I Deputy Sheriff Sheriff's Costs: $47.75 PD 06/21/1999 RCPT NO 125157 DM In The Court of Common Pleas of Cumberland County, Pennsylvania Eastern Savings Bank, FSB VS. Barbara A. Stuckey n/k/a Barbara A. Sheaf fer No. 99 3582 Civil Now, June 15 1939 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff 7 Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to _ a and made known to Sworn and subscribed before me this _ day of , 19 19_, at o'clock M. served the copy of the original So answers, the contents thereof. Sheriff of County, PA COSTS SERVICE _ MILEAGE _ AFFIDAVIT In The Court of Common Pleas of Cumberland County, Pennsylvania Eastern Savings ?3ank, FSB Bryan J. Sheaffer No. 9g 3589 civil Now, June 15 1999 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. op, Sheriff Curnbeiland County, PA Affidavit of Service Now, within upon at by handing to _ a and made known to So answers, Sheriff of copy of the original Sworn and subscribed before me this _ day of 19, 19_, at o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff. vs. CIVIL DIVISION No.: 99-3582 CIVIL ISSUE NUMBER: TYPE OF PLEADING: BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. 1 Hereby certify that the last known address of Defendant(s) is/are: 230 N. Crossroads Road Lyke ,P S tt . Dietterick, Esquire PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF: Eastern Savings Bank Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 Attorney for Plaintiff JAMES, SMITH, DURKIN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. CIVIL DIVISION NO.: 99-3582 Civil PRAECIPF FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, in the amount of $91,572.78 which is itemized as follows: Principal $78,597.16 Interest through 8/13/99 $ 8,482.65 Escrow Advances $ 553.00 Late Charges $ 499.97 Other Fees and Costs $ 140.00 Attorney's Fees $ 800.00 Title Search and Costs $ 2.500.00 / TOTAL $91,572.78 '/ plus interest on the principal sum ($78,597.16) from August 13, 1999, at the rate of $24.56 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged JAMES, By: -? r Scott A. Die erick. Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717)533-3280 CONNELLY LLP AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTFI OF PENNSYLVANIA COUNTY OF DAUPFIIN SS: Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendants are not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. 4R Scott A. Dietterick, Esquire Sworn to and subscribed before me thisL 9 day of «?+ '1999. i ??i(L ICEQ YCCcd? Notary Public My Commission Expires: EAL Y PINlIN: OINITY, PA NE 9 9003 aail IN THE COURT OF CONINION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION EASTERN SAVINGS BANK, PSB, Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. TO: Bryan J. Sheaffer 230 N. Crossroads Road Lykens, PA 17048 DATE OF NOTICE: July 30, 1999 NO.: 99-3582 Civil 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 MAY BE ENTERED AGAINST YOU WITHOUT A HEARING. AND YOU MAY LOSE YOUR PROPERTY °OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 219-3166 IN THE COURT OF COtiIMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, CIVIL DIVISION VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AVISO IMPORTANTE A. Bryan J. Sheaffer FECHA DEL AVISO: July 30, 1999 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENDS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FL-CHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE OCUMENTO ARUATV AYA0 LLAME LA DFICINA ABAJO INDICIADA P 4 AQUE LE O N NO PUEDE PAGAR UNO. INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 DATE: FIRST CLASS U.S. MAIL. POSTAGE PREPAID JAMES, IITH, DURKIN & CONNf t? iY BY: ? r v Cott . Dietterick. Esquire PA I.D. 455650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN -THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, vs. BARBARA A. STUCKEY n/k,`a 3ARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. IMPORTANT NOTICE TO: Barbara A. Stuckey n/k/a Barbara A. Sheaffer 230 N. Crossroads Road Lykens, PA 17045 DATE OF NOTICE: Julv 30, 1999 NO.: 99-3532 Civil YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT I\ HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Countv Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAF FER and BRYAN J. SHEAFFER. Defendants. AVISO EMPORTANTE A. Barbara A. Stuckey n/k/a Barbara A. Sheaffer FECHA DEL AVISO: Julv30, 1999 CIVIL DIVISION NO.: 99-3532 Civil USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TO.-MAR LA ACCION REQUERIDA EN ESTE CASO. A MENDS QUE USTED TOME ACCION DENTRO DE LOS PROXINIOS DIEZ (10) DIAS DE LA FECHA DE ESTE A VISO. SE PUEDE DICTAR L11 FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PER-DER SU PROPIEDAD Y OTROS DERECHOS 1MPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATANIENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 DATE: 0 FIRST CLASS U.S. ,MAIL, POSTAGE PREPAID JAMES, SMITH. DURKIN & CONNEL Y BY : Scot A. Dietterick, Esquire PA LD. X55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717)533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION P!aintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF ORDER DECREE OR JUDGMENT TO: Barbara A. Stuckey n/k/a Barbara A. Sheaffer ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XXX) Thejudgment is as follows: $91,572.78 plus interest on the principal sum ($78,597.16) from August 13, 1999, at the rate of $24.56 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFF.R and BRYAN J. SHEAFFER, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Bryan J. Sheaffer ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on _ 7 ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: $91,572.78 plus interest on the principal sum ($78,597.16) from August 13, 1999, at the rate of $24.56 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. -?r 71 GAL Dep Q\ Jx?s r- r: ? rX Her; r L ?y LL) ?. l.l1L f.rj u- 01 .V.] 0 0? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. CIVIL DIVISION NO.: 99-3582 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, 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 Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens, PA 17048 BRYAN J. SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens, PA 17048 BRYAN J. SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff EAST PENNSBORO TOWNSHIP 98 S. Enola Drive Enola, PA 17025 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Amended 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. §4904 relating to unswom falsification to authorities. JAMES, SMITH DURKIN & CONNELLY LLP DATED: -J )gy. 4!co?t?D?i?btterick. Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 } C) ? LL,1 ?: 5 r i r i7 .y rJ : . _ ,7 Cr u. N ?_- L; [3. I uJ CYN U c;% R IN THE COM OF COMMON PLEAS OF CUMBERLAND COL MY, PENNSYLVANIA CIVIL DIVISION Eastern SAvings Bank, FSB, File No. 99-3582 Civil Plaintiff Amount Due $91,572.78 V. ro Barbara A. Stuckey n/k/a Barbara A. Sheaf fer Interest to ate of sale $4,469.92 and Bryan J. Sheaffer, : Atty's Comm Defendants TO THE PROTHONOTARY OF THE SAID COURT: Costs The undersigned hereby certifies that the below does not arise out of a retail installrmnt sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECIMON Issue writ of execution in the above metter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Attached Exhibit "A" PRAECIPE FOR ATTACHmENr EXECVI'ION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached e bit- DATE: 3C? Signature: /' !!.(?Y i• Print Name: Scot A. Dietterick, ESq. Address: P.O. Box 650 Hershey, pA 17033 Attorney for: Plaintiff Telephone: (717) 533-3280 Suprame Court ID No.: 55650 Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of Eaec Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spanglar, said plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or leas; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. B Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes Nest 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. ? r . m v U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, CIVIL DIVISION NO.: 99-3582 Civil vs. BARBARA A. STUCKEYn/k/a BARBARA A. SHEAFFER and BRYAN J.SHEAFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, 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 Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens, PA 17048 BRYAN J. SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens. PA 17048 BRYAN J.SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, I-SB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal kn ,wledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. JAMES, SMI DU & CONNELLY LLP DATED: cS ?,0 Rq BY: \ Sc tt . Dietterick, squire . Pa. L #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ?n it cam. _ c)s. - lu \ J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J.SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey n/k/a Barbara A. Sheaffer 230 N. Crossroads Road Lykens, PA 17048 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 8, 1999, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH} DURKIN & CONNELLY LLP DATED:L/' J 'Al ? BY: S 7 c ttt . Dietterick, Esquire Pa. LD. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND REGULAR U.S. MAIL Legal Description ALL THOSE T140 certain Pieces or parcels of land situated in the Township of East Penneboro, County of Cumberland and State of Pennsylvania. more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spanglar, said plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2. Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on Sot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, Said point being 27 feet in a Northeasterly direction from the center lire of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degreea 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine street. ?_ ,n s- \i ?' 1: [ ?j: u t _ ?'J j r ..? C!. ? ? i:- l? <" 'J .`. ?? U n U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer 230 N. Crossroads Road Lykens, PA 17048 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 8, 1999, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 tares), will be filed by the Sheriff 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square. 4th Floor Carlisle. Pennsylvania 17013 ('717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED: BY: Sco t A. ietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND REGULAR U.S. MAIL Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western hall of Lot No. 51 in the Plan of lots laid out by Francis H. Spangler, said plan being recorded in the office for Recording of Deed, in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyre Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. S1; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastetn line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 45 degrees 30 minutes West 20 feet to a point, thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. - I Ll u ? J ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil VS. ISSUE NO.: BARBARA A. STUCKEY n/k/a TYPE OF PLEADING: BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. Pa.R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT(S)/OWNER(S) AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: Eastern Savings Bank, FSB, Plaintiff COUNSEL OF RECORD FOR TI4IS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DURKIN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. Pa.R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE OF DEFENDANT(SUOWNER(S) AND OTHER PARTIES OF INTEREST 1, Scott A. Dietterick, Esquire, attorney for Eastern Savings Bank, FSB, Plaintiff, being duly sworn according to law depose and make the following Affidavit regarding service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant(s)/Owner(s) and Other Parties of Interest as follows: Defendants, Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, are the record owners of the real property. 2. On or about September I, 1999, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via Certified Mail, Return Receipt Requested, at her last known address, being 230 N. Crossroads Road, Lykens, Pennsylvania 17048. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about September 1, 1999, Defendant, Bryan J. Sheaffer was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via Certified Mail, Return Receipt Requested, at his last known address, being 230 N. Crossroads Road, Lykens, Pennsylvania 17048. A true and correct copy of said Notice and Return of Service are marked Exhibit "B", attached hereto and made a part hereof. 4. On or about September 17, 1999, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to Rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. Truc and correct copies of said Notices and Certificates of Mailing are marked Exhibit "C", attached hereto and made a part hereof. Finally, the undersigned deposes and says that Defendant(s)/Owner(s) and all Other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa. R.C.P. 3129.2. Dated: q Sworn to and subscribed before me this doJ14I day of t 1t& 1999. Notary Public MY COMMISSION EXPIRES: JAMES, S, AITH, DURKIN & CONNEL Y LLP BY: Scott A. iettenc , Es Pa. I.D. # 5650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 NOTARIAL SEAL MICHELLE ELLIOTT, NOTARY PUBLIC HUMMELSTOWN, DAUPHIN COUNTY, PA NY COMMISSION EXPIRES JUNE 9, 2005 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey n/k/a Barbara A. Sheaffer 230 N. Crossroads Road Lykens, PA 17048 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 8, 1999, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured bcu,.1'',.ries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date mast be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH4 DURKIN & CONNELLY LLP DATED: BY: r ? Scott A Utetterick, Esquire Pa. I.D) #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED AND REGULAR U.S. MAIL Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis N. Spangler, said plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2. Page 2. BEGINNING at a point on the Southern side of Pync Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Erola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeantern line of Pine Street, North 49 degrees 3o minutes East 20 feet to a point; thence along premises known as No. a pine street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. SENDER: • Complete Items I end's, 21ar inklah nal services N complete 'toms 3.4a, and ah. 4r • Print your name qad address all the reverau of ties form so that w L" card to yyou • anon Ihgl form to the front of the mnilpleco, or en the hack d spar 2 ppeennil. The R l d • lefum ecer Rw on the mm'dir Iminw the anal .t. aThe' Receipt will show to to whom the nNCla as Jellveredm tlellvenedred. 0 3., A ticle Addressed to. n r 5. R/ey(glved By: (Print Ala `?rR ?tiQa 6. Smnallrw• /dddm<mn nr 4nar.n I also wish to receive the following services (for an an'.turn this extra fee) runer.ot 1 .? Addressee's Address u • numbs,. 2. ? Restricted Delivery ? ?r the date Consult postmaster for fee. g 4a. Article Number S y l 4b. Service Type ? Registered P} Certiliotl ? Express Mail ? insured c ? Return Receipt for Merchandise ? COD 7. Date of Delivery 3 9. Addressee's Address Only it requested m and tae is paid) m > PS Form 3811, December 1994 U6? 102595-gee 0229 Domestic Return Receipt Z 589 881 ''94 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Dn nN n<a 1nr Intornen.. 1 I,,.. ,c..,. ...,_._. u a a Ca C M LL N a. Sen11o, ? Jp ?l zt.lu -r _S ?r ( +, .?? Street a Number ? Post 01(Ite, tale, S ZIP C04e ` '?:t h? 17 t J(?yyl ostage $ comfort Fee Special Delivery Fee Restricted Delivery Fee Actum ecelptserving to "8 Date ois d, l turn e It 1 s?iEpe $ set rk or Date ? Q?` `„ i ( lep EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/kJa BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer 230 N. Crossroads Road Lykens, PA 17048 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 8, 1999, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3532 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you mast 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. DATED: VIA CERTIFIED MAIL JAMES, SMITH, DURKIN & CONNELLY LLP .1 /! BY: ? ? r/1 l Scott A. Diett cre k, Esquire Pa. I.D. 455650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717)533-3280 RETURN RECEIPT REQUESTED AND REGULAR U.S. MAIL Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Penneboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described an follows, to wit: LOT NU. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spanglar, said plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern aide of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. RAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No, a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. s d SENDER: V • Complete items 1 a here 2 for additional services'. `m •Complete items 3, 4a. and 41b. • Print your ante and address on the reverse of this form so that we can return this Color ou m • Attach Ilus form Is the front of the reallplece, or on the back it space does not y ponml. m • rile 47emm et will o me mmlple the article number. G • The nehurn Receipt will show show t to whole fire article was s delivered add the dale erect eraU delivered 0 3. Article Addressed to: 4a. Article a c 4b. Sema I also wish to receive the followirig services (lot an extra fee): 1. ? Addressee's Address 2. ? Restricted Delivery m Consult postmaster for fee. EL mber u E.'. j 1L, ..I ) C {.11 r) c U d':i Arr ? Registered ? Express Mail ,j ? Return Receipt for Merchandise 7. Date of live 5. Re vetl By: (Pont Name) B. Addressee's Address (Only and fee is paid) 6. Signal :(Addressee or Agee ,%/Jft1?? Certified ? Insured ? COD 0 requested ,Tr c 9 0 X T " PS Form 3811, December 1994 1025e59eBe229 Domestic Return Z 5119 881 793 ?\? 1: /1 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. N an m Q O O: A LL 4 ' r. 'ILI sent to 1 Steel pl Nymper Post QQlITice, state. & ZIP Ced ?1 ' t e I 7 ??? c i i t U i 1 Postage's $ Certified Fee (?(f Special Delivery Fee Restricted Delivery Fee Relum Receipt Showing to j Whom & Date Dela red ,e(mo ir?m W WV, l Q Q Datt1, ox OT P a r„r $ r P ayQ r ?iY to i z 1f e i EXHIBIT "C" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. PURSUANT TO Pa R C P 3129(61 TO: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 8, 1999 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheafter are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale oF. 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLY,LLP l Dated: v?- gy; Scott A. i, tterick, Esquire PA ID #55 50 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spangler, said plan being recorded in the office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. S1, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Stole, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes soelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 1S feet wide alleys thence along said alley South 49 degrees 30 minutes Nest 20 feet to a point; thence through the center of a partition wail separating the Premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 12S feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine street. w" run I GESTIC AND INTFRNATIONACMAII. DOES N, eROVIDE FOR INSURANCE-POS TMASTER Received From NO POSTAGE NECESSARY :. SF POSTAGE PREPAE) BY P.O. BOX M 1i{?71 HERSHEY, PENNSYbVAMA 17833-0650'+ •+'???;', o . One Piece of ordln.,y mall eddleeeed M LP ilk I') C? %Ct.? (ICtf?? l j? P11 r )uj `) PS Form 3817, Mar. 1989 +r-I' • ._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa R C P 3129(b) TO: Cumberland County Domestic Relations Office Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 8, 1999 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of. 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on ajudgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. Dated: i JAMES, SMITH, DURKIN & CONNELLY LLP Bv: Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Flershev. PA 17033 (717) 533-3280 -? Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania. more particularly bounded and described as follows, to wit, LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid Out by Francis H. Spanglar, maid plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot go. 51; thence in a Northerly direction along the line running through the cancer of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyre Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction team the center line of an alley; thence along the southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the plate of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. L' `?6..4/. ? Iv U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, GOES NO' PROVIDE FOR INSURANCE-POSTMASTER Received From: NO POSTAGE NECESSARY Jf POSTAGE PREPAID BY URKIN ONNELLY LLP rn RIM 650 HERSHEY, PENNSYLVANIA 1703341650 One pleco of ordinary mall addreued lo: 1 C.r. lY 11 cu (lc, ''??r plc ?ir i. r" a EASTERN SAVINGS BANK, FSB, VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL DIVISION NO.: 99-3582 Civil BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. PURSUANT TO Pa.R.C.P. 3129(b) TO: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 8, 1999 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of. 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLY,LLP Dated: By: Scott A. Di tterick, Esquire PA ID #5565n Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsbaro, County of Cumberland and state of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spanglar, said plan being recorded in the office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected an lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. $1; thence in a Northerly direction along the line running through the center of the partition ,all of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyre Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. U.S. POSTAL SERVICE CERTIFICATE F MAIL MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N( PROVIDE FOR INSURANCE-POSTMASTER IS7 RecalVee Flom: NO POSTAGE NECESSARY POSTAGE PREPAID BY PM, Smaii, NNELLYLLP PO Box ISM _ HERSHEY, PENNSYLVANIA 170334)650 Ona place of erElrtary mall addressed to: PS Form 3917, Mar. 1999 14 ` ? r S F J - 7 rl N ?'? 1(L 14 71 ) 4 a? U IN THE COURT OF COMMM PLEAS OF CUMBERLAND OOUMy PENNSYLVANIA CIVIL DIVISION Eastern Savings Bank, FSB, • File No. 99-3582 Civil Plaintiff, • Amount Due $91,572.78 V. : Interest 6'cm 8/13/99 $19,694.30 . Atty's Come Barbara A. Stuckey, n/k/a Barbara A. Sheaffer Costs and Bryan J. Sheaffer, Costs Defend. TO THE PROTHONOTARY OF THE SAIDants COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act. 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRADCIPE FOR EXECUTION _ REissuE Issue writ of execution in the above matter to the Sheriff of Cumberland county, for debt, interest and costs upon the following described property of the defendant(s) See attached Exhibit "A" PRAECIPE FOR A7TAcmW EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhib t. DATE: 11/16/00 Signature: Print Name; Scot A. Dietterick, Esquire Address: P. O. Box 650 Hershey, PA 17033 Attorney for: Plaintiff Telephone: (717) 533-3280 Supreme Court ID No.: 55650 I Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. SPanglar, said plan being recorded in the office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western halt of a 2 1/2 story double frame dwelling house known an No. 3 East Pine Street (also known as Pyne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes Spelled Pynel Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. B Pine Street. South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as 110. 4 Pine Street. ? • v ?? ?. ? ` ? ? w ; ?- 2 ?1 ?4 ? ? r V _. i ^^ 'V .? _ O 1' ;'u ? ? o ? 7 0 Li C3 ? d ? ? V 1 ry _ ? _ Z? n ?.. r h n• ti V ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, CIVIL DIVISION NO.: 99-3582 Civil VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, Plaintiff in the above action, sets forth as of the date the Praecipe for the Reissued Writ of Execution was filed the following information concerning the real property located Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER 4 East Pine Street Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Clarmont Rd. Carlisle, PA 17013 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX Cumberland County Courthouse CLAIM BUREAU One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 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. §4904 relating to unworn falsification to authorities. JAMES, SMAU CONNELLY LLP DATED:_ J I6 ?Q BY: Scot . Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ?l? - -._ `, ' cal C1. J __ 'mil ? 1 ca C..i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED: BY: Scott Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spangler, said plan being recorded in the Office for Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or leas; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or lens, to a point in the running through the center on Lot No. 51; thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 3/2 story double frame dwelling house known as No., 3 East Pine Street (also known as PYne Street), South Enola, Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. s Pine Street, South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as 1:0. 4 Pine Street. e ?': ?j) ; L ? ? ? I ) ('• ? 1 ?.-i '1 li 7 ;J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S ALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED:. BY: Scott . Dietterick, Esquire Pa. I.D.#55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE I Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO, 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spangler, said plan being recorded in the Office for Recording at needs in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line running through the center of the partition wall of the double frame dwelling house erected an lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or lees; thence in a Southerly direction 125 feet co a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51: thence in a Northerly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as Pyne Street), South Encla, ' Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. B Pine Street. South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 4 Pine Street. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, 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 Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens, PA 17048 BRYAN J. SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 230 N. Crossroads Road BARBARA A. SHEAFFER Lykens, PA 17048 BRYAN J. SHEAFFER 230 N. Crossroads Road Lykens, PA 17048 3. Name and Address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff EAST PENNSBORO TOWNSHIP 98 S. Enola Drive Enola, PA 17025 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Amended 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. §4904 relating to unworn falsification to authorities. I JAMES, S` T - D CONNELLY LLP DATED: ?Z 1 Q? BY: Sco A. Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 * ?? C i ; (? Vie- ''Sr I .< ? ?? r ..i' '' • I'? `-' ?I Fn 1? ?` -- (_ ?. ILLI , ?.1 Ir o :'r. U ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EP STERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil VS. ISSUE NO.: BARBARA A. STUCKEY n/k/a TYPE OF PLEADING: BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Pa.R.C.P. RULE 3129.2(C) Defendants. AFFIDAVIT OF SERVICE OF DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: Eastern Savings Bank, FSB, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DURKIN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL. DIVISION Plaintiff, NO.: 99-3582 Civil VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. Pa.R.C.P. RULE 3129.2fc1 AFFIDAVIT OF SERVICE OF DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST I, Scott A. Dietterick, Esquire, attorney for Eastern Savings Bank, FSB, Plaintiff, being duly swom according to law depose and make the following Affidavit regarding service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendants/Owners and Other Parties of Interest as follows: Defendants, Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer are the record owners of the real property. 2. On or about December 6, 2000, Defendant, Bryan J. Sheaffer, was served with Plaintiffs Amended Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via certified mail, return receipt requested, at his last known address, being c/o Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania 17013. A true and correct copy of said Notice and Return Receipt are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about December 5, 2000, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, was served with Plaintiffs Amended Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via certified mail, return receipt requested, at the address of the mortgaged premises, being 4 East Pine Street, Enola, Pennsylvania 17025. A true and correct copy of said Notice and Return Receipt are marked Exhibit "B", attached hereto and made a part hereof. 4. On or about December 13, 2000, Plaintiff's counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiff s Affidavit Pursuant to Rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "C", attached hereto and made a part hereof. Finally, the undersigned deposes and says that Defendants/Owners and all Other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa. R.C.P. 3129.2. Dated: Sworn to and subscribed before me this ?kday of . 2000. Notary Public MY CONMSSION EXPIRES: NOTARIAL SEAL MICHELLE ELLIOTT. NOTARY PUBLIC HUMMELSTOWN, DAUPHIN COUNTY, PA MY COMMISSION EXPIRES JUNE 9, k03 JAMES, BY: Scott Pa. I.D. Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY LLP EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 3 and 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717)240.6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED: 7? BY: Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE a Legal Cescription .} ALL THOSE TWO certain pieces or parcels of land situated in the township of East pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 9e--/NG the western half of Lot No. 51 in she Plan of lots 1a4'_ out by Francis S. Spangler, said plan being recorded in the OL' Lor Recording oC Oeeds is and for Cumberland County, Pennsylvania, in Plan Book 2. Page 2. 9EGINN:NG at a Point on the Southern side of Pyne Street in the line running th:oug the center Of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or less; thence in a Southerly di:ecticn 125 feet to a 15 Lott alley; thence along said alley in ar. easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direccaen along the line running through the center of the partition, wal: of the aforementioned dwelling house, 125 Lee. to the Place of Beginning. HAVING thereon erected the Heste:r. half of a 2 1/2 story double Pram shelling house known, as No., 3 East Pine St:eet dal so known- as pyre Street) South Pennsylvania, and also a cement block garage. LOT N0. 2 BEGTNNING at a point on the Southeastern line of Easy-?_nticn tp:dmeyescenter line J of Streec, said point beinc 27 feet in n lineasceriy an alley; thence along aw.e Southeaa to rn lire of Pine Street, North 49 degrees 30 No, a Pine Streec, thence along premises known as minutes East 20 feet to a point; South 40 d thwestern line of a 15 degrees l0 minutes East 125 feet to a point on the Nor feet wide egr e ; tneaeealor.5 said alley $Outh 49 decrees 30 minutes Kest 20 Leec to a t 4 point; thence ch:ough• ehe center of a pall wall separating the Premises Of Pine Street, North 40 degrees 30 minutes Kea. 125 f to a Point, . e P. BEGINNING . ed a two and are-half story frame dwel_ing known as No. a Pine HAVING thereon erect street. ? ro,myn ? s ? I A . ? ; ? CenanrJ Flc ? , l?(:) 1. ? RnlnrH Ilr I ?y- I6nporin l enl lie O ResIr ClNJ rl1 yf,. O IFnJO•sem< I R I II OO TateI PPNIn9, 6 re.N ) d-o m IPIa rt'a Nan f' }K In r `U6 Vis I?E1-l' Ilnl, . j ? f? 0 r!t `r.7 a ? ¦ Complete Items 1, 2, and 3. Also to item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. I. Anicle Addromed to: &L 0,, 1 1 Sf\-4 ; L, A. Received by fPlease Print Cfeady) B. Date Of livery C C. LY Signature L `-?t30 x ? Agent D. Is tlelivery address tlid ` E3 Addresses _ If YES, enter deliver dd U yes y a ress below: 13 No t L ice Type I`O r1LR: LIS- enifiM Mail ? Extras Mall egistered ? Return Receipt for Marchandlsa 1 2 sured Mail ? C.O.D. J icted Delivery'/ (Extra Fee) 2. AA", eNumber (Copy ? Yes )rom servic q ?ldp D811 3unn ??? PS Form 3811, Juty 1999 Domestic Return Receipt f 102595-00-M-0952 r EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 3 and 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED: P ! Y't BY: Scott 4. Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE . `a .: Legal Oescriptien .? ALL THOSE TWO certain pieces or parcels of land "'ousted in the Towrah'P of East Pennaboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT 110. 1 BEING the western half of lot No. 51 in the Plan of lets laid out by Francis H. Spangler, said plan being recorded in the Office for Recording of Deeds in and far Cumberland County, Pernsylvania, in Plan Sock 1, Page 1. BEGINNING ac a point on the Southern side of Pyne Stree: in the line running through the cancer of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street ir. a Westerly direction 20 feet more or less; chance in a Southerly direction 125 feet to a 1S fact alley; thencc along said alley in an easterly direction 10 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction. along the line running through the center of the partition wall of the aforementioned dwelling house, 125 fact to the Place of Begi=ing. HAVING thereon erected the Western half cf a 2 1/2 starry double frame dwelling house known 16 No. 3 East Pine Street (also knc•.o as P}-e Street', South Erola, ' Pennsylvania, and also a cement black garage. LOT NC. 2 BEGINN:NG at a print oa the Southeastern lire of East Pine (sometimes spelled Pyne) Street, said point being 27 feet in a Northeasterly direcceian from the center line of an alley; thence along t.e Souchean-trn line of Pine Street, North 49 degrees 30 minutes East 20 feet an a pc'ncr thence along premises known as No. a Pine Street, South 40 degrees 30 minutes East 125 fear to a point on the Ncrchwestern line of a 15 feet wide alley; thence alone said alley South 49 decrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the Premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 !at- to a point, the place o: BEGINNING. HAVING thereon created a two and one-half story frame dwelling known as No. 4 Pine Street. I ti T` '' Pnsleg» Ln CM2pd Fun -a/ 1 Return Rec»rPl Fx» Entlersdmern H.a t Fr . C3 Restr¢t»d . O n»bverv F!.r IEndorsemenl Hxqunnp C3 U Tdrel Paetaee 8 Fesa ?J' m NPb } Nemsln aset T p_. %11."° c'a- ¦ Complete Items 1, 2, and 3. Also c Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece or on the front If space permits. 1. Article Addressed to: G O Agent D. Is delivery adtlress tliRerent Iro tem 17 Addressee U Yes It YES, enter delivery address below: ? No 3. Service Type 'Cirri fled Mail ? Express Mail Registered ? Return Receipt 'or M ? Insured Mail ? C.0 0. emhandise 4. Restrimed Delivery? (Extra Feat ? Yes 4 ®1 EXHIBIT "C" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintil& VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Cumberland County Domestic Relations Office Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on March 7, 2001 at 10:00 a.m., the following described real estate which Leigh R. Fogelsanger is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: Lot Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLV LLP Dated: 4 } J I Scott A. Diftterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Legal Cescript'_an .? ALL THOSE TWO certain pieces or pa: eels of land situated in the TOwnshSP of East Pennabaro, County of Cumbe:lard and 3caca of pern,sylvsnia, =.-a particularly hounded and described as !allows, to wit: LOT. NO. 1 BELNG the western half of Let No. 5. in the plat of lots laid nut by Francis H. Spanglar, said plan being recorded in the Cffice for Recording of Deeds and for Cumber-and County, Pennsylvania, in Plan Rock 2. Page 2• BEGINNING at a point an the Southern Aide of Pyne Street in the line tanning thro•lich the cents: of the partition wall of the double frame dwelli rg house treated on 10[ No. 51, extending along Pyre Street in a Nestelely direct t 20 feet more or less; thence in a southerly d!raeticn 125 fast to a 15 fact alley; thence along said alley '_t an easterly direction 20 feet, more or 'less, ca a paint in the running through the center or. Lot No, 51; thence in a Nc aherly direction a5cne :ha line ranrirg the tough ohs center of the partition wall of the of oramentiared duelling house, 125 feet to the Place of Beg'-nni-g. liAVINO eheraan erected the Western half of a 2 i/2 sto ri dott5ouc!rme haEnc aeldwliag house It.... as NO..3 East Pine street (also kno•r._ as Pyne Street) , pannsy'-Dania, and also a celesta black garage. LOT NO. 2 BEGINIIING ac a point on the Southeastern lire of East P!te (sometimes spelled P•'ce) Street, said point being 2T feet in a No:::neasrerly directicn from the canter line of an alley; thence along t.-ha southeactern lire of Fine street, North 49 degrees JO minutes East 20 fact to a point: thence along Premises k,-,cwn as Na. a Pine street. s East u5 feat to a pc!t: an the Ncrthwestern line of a 15 South 40 degrees 20 minutes wide all<y; theaoa along said alley south 49 degrees 30 rutas West Z0 feet co a point; thence through the center o! a partition •_all.-separating the premises 7 and 4 Pine Street, Nereh 40 degrees 30 minutes West 125 co a paint, the prate of BEGINNING. P.AVL`IG chorea:. exec tad a two and story !=are dwel'ing known as No. 4 Pine Street, Received From: i p 1 ;"" .' :?'-' •liS'i:1t2'i PC, i _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff VS. BARBARA A. STUCKEY n/W BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.RC P 312M TO: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on March 7, 2001 at 10:00 a.m., the following described real estate which Leigh R. Fogelsanger is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of Lot Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A'). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, Sb(ITH, DURKIN & Dated: Z ' Z Q? CONNELL LLP By. / /F Scott A. D 'ck, Esquire PA E)#55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717)533-3280 a: Legal Description .? UL THOSE TWO eer:aic pieces or parcels of land situated in the Township of East Pen:zebora, County at Cumberland and State of Peansyivani a, mots parC'_culaay bounded and described as £allowa, to wit: LCT N0. 1 BEING the western half of Lot No. 51 in the PFla.. of lc es laid cue by Francis H. Sparglar, said plan being recorded in the Office £e. pec:rding Of Deeds in and Co: Cumberland County, Pennsylvania, in Plan Hock 2. Page 2. BEG INNING At a point on t.`.e Scuthert side o47yre. Street in the line running through the cancer of the partition wall Of the double frame dwelling house erected or. !cc No. 51, extending along pyre Street in a Westerly dixec-itr. 20 feet More or less; thence in a southerly dixectian 125 feet to a 15 *Oct alley; thence along said alley is ar. easterly direction 20 felt, more or less, to a point `n- CSine nu,-.ncngh chtou 4yche_nter 5• or. Let No. 5:; thence in a No: -he:ly direct _c r. along Center of the partition wall of the afcr,,,ntioaed dweil:ng house, •135 felt Cs the Place of eeCiDning. HAVING thereon erected the Nester.: ha_f of a 2 1/2 stc.-y double frame dwelling house known as No. ,3 East Pine Street (also i=". as Pyre Street), South Enola, Pennsylvania, and also a Cement block garage. LOT No. 2 HEGIMNING at a point on the 50utheasc rn line of East Pce-csofetweses?elled Lino of St=etc, said point bdnc 27 feet in a Northeasterly - North 49 degrees 30 an alley; thence along the Sou rheas Leta line of P^isest known as No. s Pine Stree-, minutes East 20 feet cc a point; thence along p Scuth 40 decrees 30 minutes Eas- 125 feet to a point on the Northwestern line of a 15 es feet t4 a fee- wide alley; thence along said alley South 49 de separating 4nucmap West 20 3 and pein:; thence through. the cent--r of a p fee- ?t, the puce of Fiae Street. North 40 degrees 30 menutes Nest 12s _ to a po=• BEGINNING. HAVING cheream erected a two a_d one-half story frame dwelling known as No. 4 Pine Street. . POS_TAISERVICE CERTIFICATE O MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT E FOR INSURANCE-POSPROVIp MASTER _ Received From: W, 0 piece of er barY mod eJdreFeetl lo: M ?? , /??? ??? / D L . 4 ,? I . . , ? a 0 I "10 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on March 7, 2001 at 10:00 am., the following described real estate which Leigh R. Fogelsanger is the owner or reputed owner and on which you may hold alien or have an interest which could be affected by the sale of. Lot Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A'). . The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, Vs. BARBARA A. STUCKEY nWa BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. N0.99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be tiled at the Office of the Sheriff before above We date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLYtLLP Dated: 1 f I ?la? Scott A. Die#erick, E PAID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Legal CeacripCi°n ,? ALL TH05E TWO certain pieces or parcels of 'and aicua:ed in the %wnahiP of Ease Pennahoro, County of Cumba:land and S- ace oC Pennsylvania. more Particularly bounded wit: described as follows, to LOT N0. 1 halfof L°= No. 51 in. the plan. cf lc ca laid cue by F. .Cis H. BEING angl ar, the western ar. being recorded in the Cffiee CC: Eet"rding of :),td, in and for Sp B Cumberland County, pennsvLvania, in P_an oor. 2. ?nge BEGINNING at a Point cr. the Souther side Of pyne Street ir. the line running Chrnugh ect the tenter of the pa.rD ^ci$e :a C l in! a thCSde.byedS nett cne20 fe romoreaor leas Rtl encNa. 51, e,--ndi.:g along 15 !oat alley: thence 310r, ninc said a1; through ey the in casenter in r d'--net ciao 1:5 feat to a a souther y ens Ceely direction 20 !eat, mare or less, to a paint in the rua or. Lot No. re thence in a vs.-hot ly diraci n al cng t::e in. running through the 725 fee- to the cer of the partition wall of :he of c:emeationed dvea_:ng hous enter e, Place of Beginning. P.?nawnGathereon eret Pir.eh u2 l/2 s No 5aeete (alhasol%nof Of pyneaSir! e1 ,?bsouth Enola, ing house Pennsylvania, aml also a cer?ent block garage. LOT N0. 2 BEGINNING ac a point on the Soucheastere line of East Pine (scmetimas sot'-led Pyne) Sereee, said poi re Leong 21 feet in a NorcheaacerlY dira",son from the dater lire of ttN an a11eY; thence along the southeastern line of Pins stretwn as'NC.98 Pene degrees co a Point; thence along Pre - _ ,rthwesezn minutes East 20 fee 1d•ocnes`70NmiautestWest 20 fee ca co a Sou ch, 40 d-Braes 30 minutes East 725ll fea-south 49 fee, wide alley; thence n1ocS said aey ! seParat' n" the Premises 7 and 4 chr"ugh the Can-er o! a parti "son wal - the place of Point; Street, theses Nerth 40 degrees 30 minutes West 125 feat co a Prin Fine s, eE^^>INt1ING. p.AVIL^7G the:ea^^. erecCad a two and One-half story frame dweline 'rnown as No. a Pine street. 4 •. CE CEI'Elmv,---' DOES NOT )..t'?lol el S. POSTAL Ay BE USED FOR DOMESTIC ATMASTERNATIONAI MA IOVIDEFOBINSURANCE -POS Received Flpm'' ??;'. .11} l1Y` i ...... .. .30 of'gwy mail Eastern Savings Bank, FSB VS Barbara A. Stuckey, n/k/a Barbara A. Shcaffer And Bryan J. Sheaffer In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-3582 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing 30.00 Poundage 17.31 Posting Bills 30.00 Advertising 30.00 Law Library County 1.00 Levy 30.00 Postpone Sale 20.00 Surcharge 30.00 Certified mail 1.10 Mileage 18.60 Law Journal 377.00 Patriot News 272.28 Share of Bills 2153 $ 882.82 Sworn and subscribed to before me Prothonotary paid by attorney This V 4? day of a- 1 2001, A.D., 06-11-01 R. Thomas Kline, Sheriff BYQnnLu Ln De uty Sheriff (A cis, 3,2OG/ hiw, // 31.17 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. CIVIL DIVISION NO.: 99-3582 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, Plaintiff in the above action, sets forth as of the date the Praecipe for the Reissued Writ of Execution was filed the following information concerning the real property located Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Clarmont Rd. Carlisle, PA 17013 J 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 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. §4904 relating to unswom falsification to authorities. JAMES, SMIT AckE NNEL LY LLP DATED: 11116100 BY: Sco . Dietterisquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY nWa BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 3 and 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP f , DATED: BY: Scott A. Dietterick, Esquire Pa. I.D.#55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE Legal Description .? ALL THOSE TIN) certain pieces or parcels of land situated in the T-owr-ahip of Eaat Pennsborc. County of Cumberland and State of Pennsylvania, mare Particularly hounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spangler, said plan being recorded in the Office for Recording o: Deeds in and for Cumberland County, Pentsvivania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Fyne street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more or leas; thence in a Southerly direction 125 feet to a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. 51; thence in a Northerly direction, along the line running through the center of the partition wall of the aforementioned dwelling house, 125 Lett to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No., 3 East Pine Street (also knc'wn Ls Pyne Street), South Enola, Pennsylvania, and also a cement block garaee, LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine Isomecimes spelled Pyne) Street, said point being 21 feet in a Northeasterly direction from the center line of an alley; thence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a Point; thence along premises known as No. a Pine Street. South 40 degrees 30 minutes East 125 feet to a point on the Northwestern line of a 1S feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 . to a point, the pace of BEGINNING. HAVING the-eon erected a two and one-half story frame dwelling known as No. 4 Pine Street. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 7, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 3 and 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DURKIN & CONNELLY LLP DATED: ! ?, I d l17? BY: I Sc'6tt *. Dietterick, Es Pa. I. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE . j a, Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: LOT NO. 1 BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis S. Spangler, said plan being recorded in the Office far Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2. Page 2. BEGINNING at a point on the Southern side of Pyle Street in the line rinning through the center of the partition wall of the double frame dwelling house erected an lot No. 51, extending along pyne Street in a Plesterly direction 20 feet more or less; thence in a Southerly direction 125 feet co a 15 foot alley; thence along said alley in an easterly direction 20 feet, more or less, to a point in the -inning through the center on Lot No. 51; thence in a Northerly direction along the line -unning through the center of the partition wall of the aforementioned dwtiling house, 125 feet to the Place of Beginning, HAVING thereon erected the Western half of a 2 1/2 starry double frame dwelling house known in Np. 3 East Pine Street (also know as Pyne Street), South Enola, ' Pennsylvania, and also a cement block garage. LOT NO. 2 BEGINNING at a point on the Southeastern line of East Pine (sometimes spelled Pyle) Street, said point being 27 feet in a No,.-heasterly direction from the center line of an alley; :hence along the Southeastern line of Pine Street, North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. 8 Pine Street, South 40 degrees 30 minutes East 125 feet to a point an the Northwestern line of a 15 feet wide alley; thence s'_ong said alley South 49 degrees 30 minutes west 20 feet to a point; thence through the center of a partition wall separating the premises 3 and 4 Pine Street, Porch 40 degrtea 30 minutes West 125 feet to a point, the place o£ BEGINNING. HAVING thereca erected a two and one-half story frame dwelling known as 110. 4 Pine Street. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3582 CIVIL TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF „m t and COUNTY: To satisfy the debt, interest and costs due Eastern Savings Bank FSB from Barbara A. Stuckey, n/k/a Barbara A. Sheaffer 9 East Pine Street, Enola, PA 17025 and Bryan J. Sheaffer c/o Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell see Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to not#y.the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to cr.for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachment isfound inthepossession ofanyoneother than a named garnishee, you are directed to notify hirn,herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,572.78 from 8 13 99 to date of sale Interest X19 694_'in Arty's Comm Arty Paid $1128.68 Plaintiff Paid Date: November 21, 2000 REQUESTING PARTY: Name Scott A D' ette Esq. Address: P.O-Box 650 Hershshey. PA 17033 Attorney for: _P1 ai nti ff Telephone: 5.43-12R0 Supreme Court ID No. 55650 L.L. Due Prothy_ Other Costs Curtis R. Lon Prothonotary, Civil Division ?., o mn V Deputy ,oered as: ?y 0:1•.f _ anu ueo on Exhibit "A" filed MCI f this writ and by this reference incorporated herein. ? 'late:4 ^A-a- 9?2 BY Cs'? f?: ContiMortgage Corporation VS Debra E. McNaney James L. McNaney In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-5715 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 14.33 Posting Bills 15.00 Advertising 15.00 Law Library County 1.00 Levy 15.00 Postpone Sale 20.00 Surcharge 30.00 Certified mail 1.39 Mileage 12.30 Law Journal 288.65 Patriot News 262.95 Share of Bills 25.23 $730.85 pd by atty. 06-07-01 Sworn and subscribed to before me This 2 4 C-day of tc 2001,A.D. 1 T' Prot onotary R. Thomas Kline, Sheriff BY '"' Deputy-Sheriff ck.3JQ1v R"-. J1307 Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff ContiMortgage Corporation One ContiPark 338 South Warminster Road Hatboro, PA 19040-3430 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW VS. Debra E. McNaney 38 Bayberry Drive Mechanisburg, PA 17055 and James L. McNaney 38 Bayberry Drive Mechanisburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Term No. 99-5715 Civil Defendants ................................... ........ .. . ... . ....... . .. . .. . . . . . ....... . ..... . ......... . . . ..... . . . . . . . :a . .... . ...... AFFIDAVIT PURSUANT TO RULE 3129.1 ContiMortgage Corporation, Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 38 Bayberry Dr., Mechanicsburg, PA, 17055: 1. Name and address of Owners or Reputed Owners: James L. McNaney 38 Bayberry Drive Mechanisburg PA 17055 Debra E. McNaney 38 Bayberry Drive Mechanisburg PA 17055 2. Name and address of Defendants in the judgment: Date Service Code 1 a Debra E. McNaney 1 38 Bayberry Drive Mechanisburg PA 17055 James L. McNaney 1 38 Bayberry Drive Mechanisburg PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Date Service Code Name an a ress o the last recor e o er o every mor gage VL LCGVLCI: Date Service Code Commercial Credit Corporation 3 6520 Carlisle Pike Suite 155 Mechanicsburg PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Date Service Code 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. I IDate IService Code I 2 W Court of Common Pleas of 3 Cumberland County Family Court Div. One Courthouse Square Carlisle PA 17013-3387 Child Support Enforcement Agency I 13 PO Box 320 Carlisle PA 17013 Commonwealth of PA Dept. of I Welfare PO Box 2675 Harrisburg PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 12/22/00 Plaintiff 3 Comroe Hing LLP Identification No.: 25694 By: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff ContiMortgage Corporation One ContiPark 338 South Warminster Road Hatboro, PA 19040-3430 Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Debra E. McNaney 38 Bayberry Drive Term Mechanisburg, PA 17055 No. 99-5715 Civil James L. McNaney 38 Bayberry Drive Mechanisburg, PA 17055 Defendants ............................................................. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Debra E. McNaney, James L. McNaney Your property at 38 Bayberry Dr., Mechanicsburg, PA, 17055 in CUMBERLAND County; Pennsylvania is scheduled to be sold at Sheriff's Sale on June 6, 2001, at 10:00 AM, in CUMBERLAND County to enforce the Court Judgment of $136,991.98 as of January 10, 2000 plus interest to date of sale of $18,504.07 obtained by ContiMortgage Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Comroe Hing LLP, attorneys for the Plaintiff, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: (215)568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney). 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling the Sheriff of Cumberlaad County at 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of Cumberland County at 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days of 2 the Sale date. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exemptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also. have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPS R TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET HELP. Legal Services, Inc 7 N. Hanover St. Carlisle, PA 17013 or Court Adminsitrator, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 or 717-243-9400 THIS IS A PROCESS THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU OR ANYONE ELSE WILL BE USED TO THAT END. 3 E ?1 p o0 w 0 ° u C O W r b W U U W •? N O ld 41 L L. 6l tio rr .. v v to lJ .R. C Wv? 0 • 5 C F. 'p M N 'O C v O O A g H > O 0 u O U ?C u U o° it. ?' vw C 00b Lev C C v u 7? .9 ti - Y N t%i > W b v cts y. 3 00 5 3 5 v a ei O o A g b v Cp .9 O q u bC C Q\ O o N •5 N ap y q O w O, .v o >a OCR hm> vQ?M PO L) cn y b y w h C N w p Y p .? u b } H ?; g ?,g c u v Y a M C v n, z IS z ,v ej (7, 00 .. r, v, :t ter noE a o Ca t av y o ys y .5 o q .,E C t? '?-• w U v 3 to A o ;.. L a - } U C 7 C d v 41 7O. O u C C .C. Cq 1 bU o ryvq.0-0 2 ..0 to [i. °•H .. - Q O m N vi p N •? 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WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-5715 CIVIL TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF _ CumSert and COUNTY: To satisfy the debt, interest and costs due ContiMortgage Corporation - -- .. 1-1 from nohra F Mr __ and T r uc T -McNanay, 78 Ravherr_y- Drive Marhair`Ghrrrar PA--r_ (1) You are directed to levy upon the properly of the defendant(s) and to sell See legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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 thereof; (3) If property of the defendant(s) not leviedupon an subject to attachment isfound in the Possessionof anyoneother 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 -01 Interest from 1/10/00 o 6/6%01 @ 10.25$ L.L. $18p504-07 Due Prothy Atty's Comm % Other Costs Ally Paid $805.71 Plaintiff Paid Date: January 9 2001 REQUESTING PARTY: Curtis R. Long Prothonotary, Division by-?LLQrn ?- Deputy Name David B. Canrce Es Address: 1700 Market Street, Suite 1400 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215-568-0400 Supreme Court ID No. 25694 REAL ESTATE SALE NO - an the sheriff IWled upon the defenciani., interest in the real property situated In Cumberland County, Pa., known and numbered as: and more fu!; r;oed on Exhiblt "A" filed wits this writ and by this referena- )orated herein. ty: io, w,a 5t Z s N°? , dlIy3H6 3M1 i0 3?I?d0 a rD i-lr IN THE COURT OF CC MM PLEAS OF CLFMERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Eastern Savings Bank, FSB File No. 99-3582 Plaintiff Amount Due v. - 11572.78 Barbara A. Stuckey, n/k/a Interestfmn8/l3/99to 20,728.64 Barbara A. Sheaffer and Bryan J. Sheaffer : Atty's Comm Defendants Costs TO THE PROTr10NOTARy OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. REISSUED PRAECIPE FDR EXECUTION Re- Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Exhibit "A" attached. PRAECIPE FOR ATTACI*gW E)ECLfi'ION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) s a lis pendens against real estate of the defendant(s) described in the attached exhi DATE: 'T bo Q Signature: Print Name: ScoXtDietterrick, Esquire James, Smit , Dur in & Connelly, LLP Address:_ P 0 Box 650, Hershey PA 17033 Attorney for: Plaintiff Telephone:_ (717) 533-3280 Supreme Court ID No.: 5565O Legal 0es=aption ,i ALL THOSE TWO cart+Sn pieces or Parcel' of and dat¦ced in the Township Of East Pennsbora, County of Cumber:and and State of Pennsylvaria, mare particula.ly hounded and described as fellows, to wit: LOT NO. I Parcel #09-16-1050-055 BEING the western half of Lot No. 5: in the plan of lots :aid out by Francis N. Spang'_ar, said Plan being recorded in the Of_"' for Retarding of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyne Street in the line n:.7ning throug the center of the partition all cf :he double frame dwe'll'ing house erected on lot No. 51, extending along Pyne Street in a Westerly di=et:icn 20 feet more cc less; :hence in a southerly direction 125 feet cc a 15 foot a'_ley; chance along said alley in an easterly direction 20 feet, more cr less, to a poi rt in the tvnring through the center on Lot No. 51; thaneit in a Northerly dire^ icn a:cng the line running through the center of the partition wall of the a f=rtmentioned dwelling house, 125 feet to the Place of Beginning. HAVING thereon erected the Western half of a 2 1/2 star+ double Crame dwelling house known as No. 3 East Pine Street jai so Xncwn as Pyne Street), South cnala, Pennsylvania, and also a cemeoc black garage. LOT NO. 2 Parcel #09-16-1050-054 9EGINNING at a point on the southeaster.-. line of East Pine (sometimes spelled P•ynel Street, said point being 27 _fact in a Northeasterly dire=:icn from the renter line a_" an alley; thence along the Southeastern line of Pine Street, North 45 degrees 30 minutes East 20 fret to a point; thence along premises known as No. a Pine Street, South 40 degrees 20 minutes East 125 fee: to a petnt on the Northwestern line of a :3 feet wide alley; tnenee slang said alley South 49 degrees 30 minutes Nest 20 feet to a point; thence through the cancer of a partition all separating the premises 3 and 4 Pine Scarce. North 40 degrees 3C minutes west 125 feet :a a paint, the place of BEGINNING. HAVING thereon treated a two and one-half stcri frame dwelling )inown RS No. 4 Pine Street. S ... n " :' d 11 J U.J I) t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. CIVIL DIVISION NO.: 99-3582 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Eastem Savings Bank, FSB, Plaintiff in the above action, sets forth as of the date the Praecipe for the Reissued Writ of Execution was filed the following information concerning the real property located Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER 4 East Pine Street Enola, PA 17025 BRYAN J.SHEAFFER c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Clarmont Rd. Carlisle, PA 17013 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola, PA 17025 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record-lien on the property: CUMBERLAND COUNTY TAX Cumberland County Courthouse CLAIM BUREAU One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 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. §4904 relating to unswom falsification to authorities. JAMES, SMIT l & CONNELLY LLP DATED: ? /30/?) BY: Scot A rick, squire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 2 I C l cr. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) wiil be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKF, 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE• 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, QURKIN & CONNELLY LLP DATED: 3O OJ BY: Scott A Di6tterick, Es Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE Legal Description ALL THOSE TWO certain pi ace! c: Parcels of land sit-ace^. in the :rwrahiP of tax' Pennsbaro, Ccurty of Cumberland and State of 2ennsylvsnia, more pa::itulaay bounded and described as fellows, to wit; LOT NO. I Parcel #09-16-1050-055 . of 7ett!3 in and for BEING t Spanglaze as deplanabeing rewr?efl inl:heLOC_!aa for Recd:diag cut Cunbe rl snd County, Pennsylvania, in Plan Book 2, Page 2. is the line mining through BEGINNING at a Print on the Southern side If Pyne Street the center of the partition wall of the douhle framedveilfng house _eca'less nelot No. ence 51, extending along Pyne ..c: etc jr, a Ile ste.-ly direot+_cn 30 fie in a southerly d__ectdon 125 _eet to a 1_ _cot alley; thencealong said all thin ante_ easterly d:rec=inn 20 fee:, mote me less, to a point in the e or. Lot Nr. 51; then-! in a No:the:ly d_:ec_ion alcng the- line running through the cents.- of the partition wall of the afcreme^ti:red d..+e'_!ing house, 125 feet to the Place of stair-ning. HAV2NG thereon erected the Nesrer.: half of a 2 1/2 s__.+ frame dwelling house known as No., 3 Eant Pine Street (alsc kncva as Pyre Street), South EECIa. Pennsylvania, and also a cenent block garage. LOT NG. 2 Parcel #09-16-1050-054 BEGINNM;G at a Pr`_nt on tw.e Southeastern line of East Pine (sonetCnes spelled Pyne) Street, said Point being 27 fee: in a Ncrtneaste=ly direction from thec:ntt- line of i+_ thence along the Sou:'reattern lire of Pine Smmeet, North 49 yegrets 30 an a•y; minutes Ease 20 see tr a point: thence al: rig Premises rn:wn as No. 5 'rtne street. South 40 degrees 30 ace along gas- 125 fee: to a de e: :ce l.o.-thwestttn lire of a 15 eet wide alley; tht thrice said allay South 4 49 9 derrees 7C mtru tea Nest 20 !e_t to a point; thence thrcagh the .-inert of a eartitien well sep a: g the p:errses 3 and 4 ? Of Pine street, North 43 deg_tee 3C minutes Nest 124 fete tc a pcint, the ;-ace o_ BEGINNING. d a two and cnt-half at:ry !Came dwt"_ing known as No. 4 Pine p•AVINC therein e.___-_ Street. > r3 Q ?' G r- lLl_.? C i RR4 ;a c? O J J W '' CY C/1 - %.! an U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, Vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, gRKIN & CONNELLY LLP DATED: S?7 D? BY: , &1?9 Scott A. ietterick, Esquire Pa. I.D.#55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE r a V • ?'? Legal Oescei7ticn •? ALL THOS, T:VO cer:aia r'_eces or par_el¦ of land sit-need in the Township Of Ease Pennsbore, County of Cuau'er'_and and ,:ate Of Pennsylvania, more pa:cioularly bounded and des:ribed as follows, to wi LCT ND. 1 Parcel #09-16-1050-055. aa H. BEING :he was:era half of Lot No. SS is the 'l an of lots laid cut by Fran Spanglar, said Plan being recorded in the office for Recording of moods in and for Cumberland County, Puns}4vania, da plan Book 2. Page 2. BEGINNING ac a point on :he Southern side of Pyne Street in the lino running :hroucn the center of the Par-i:ion wall of the double frame dwelling house erected on 10C No. 51, utsading along ?yne Street in a files ro in. a southerly d:reetion 123 feet ily direction 20 feet mare cc less; chance t . to a 1s foot alley; -non- along s through the y inter e ns tarty der c_tcn 20 feet, morecr less, to a point in t.._ Ha. s1; thenck in a No:-herly direr-'an a.cnc the line inning -n=ocgh the cn Lac - :eater Of the Par_" mn wz 11 of the arc remec-t... ? dwelling house, L's f__ to the Plats of Begir:ing• HAVING therein erected ::_ Western of a 1 1/2 s-°y dc.=1a frame dwelling house Rncwn as No., 2 Eaoc pine street (2-'so k-Ic" zs pyne street), South E:.o'_a, Pennsylvania, and also a canon- block Sa:ace. LcT 110. 2 Parcel #09-16-1050-054 3EG i!417iNG ac a pt iat on the Sou-hen Y. e:n line of East ?ine Iscmedmes sae'_led P;•nel _ direcica from the tort-er line if t _ NGr:n eaa-oily Strtec, said pc 4..t ?,e4 e 21 feet in n an alley: thence sic .g the Sou-contain .er.e of Pine Street, Nc::h C$ degrees Jc minutes East 20 !etc to a point, _nen__ z_an, r__m!ses Y. awn as No. a Pine Street. the Ncr-hw-stern 12no of a 1s South s: degrees 70 minutes East 125 fait tc a point on feet wide Alloy; "come along said a_!ey Soucn 93 decraes IC menu-es _ . ises J and 4 point; thence Obrough one center of a Wes- wall s_tpaocaat-noig nt, the -.,-a _.a -^.•place of Pine street, NO=-,-. S0 degrees 30 menu-ees s Wes- 12g !its • 2 BEU MMIG. HAVING therein e_ccted a two and cne-half s-crl frame dwelling known as No. c Pine street. r rn tr. " r' u d r ?:i- - 1 P?l 111 PA h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, NO.: 99-3582 Civil vs. ISSUE NO.: BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. TYPE OF PLEADING: Pa.R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: Eastern Savings Bank, FSB, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DURKTN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION VS. Plaintiff, BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil Pa.R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE OF DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST I, Scott A. Dietterick, Esquire, attorney for Eastern Savings Bank, FSB, Plaintiff, being duly swom according to law depose and make the following Affidavit regarding service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendants/Owners and Other Parties of Interest as follows: 1. Defendants, Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, are the record owners of the real property. 2. On or about September 6, 2001, Defendant, Barbara A. Stuckey n/k/a Barbara A. Sheaffer, was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via certified mail, return receipt requested, at the address of the mortgaged premises, being 4 East Pine Street, Enola, Pennsylvania 17025. A true and correct copy of said Notice and Return Receipt are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about August 31, 2001, Defendant, Bryan J. Sheaffer, was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, via certified mail, return receipt requested, at his last known address, being c/o Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania 17013. A true and correct copy of said Notice and Return Receipt are marked Exhibit "B", attached hereto and made a part hereof 4. On or about September 17, 2001, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to Rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "C", attached hereto and made a part hereof. Finally, the undersigned deposes and says that Defendants/Owners and all Other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa. R.C.P. 3129.2. Dated: ( 4 JAMES, BY: Scott A Pa. I.D. Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY LLP Sworn to and subscribed before me this 12/ day of A C`, 2001. Notary Public MY COMMISSION EXPIRES: NOTARIAL SEAL MICHELLE ELLIOTT, NOTARY PUBLIC HUMMELSTOWN, DAUPHIN COUNTY, PA uv COUM!ssION FxP!9F9 JUNF 9 2003 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Shcriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")- The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99.3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2 After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH,PgRKIN & CONNELLY LLP DATED: 3 -330 BY: VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE Scott A. Dietierick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ! a I') Legal Oesc_ipcion ALL THCSS TWO certain Pieces or Parcels of land sit.-aced in the Township of East Pennshoro, County of Cumberland and State cf Pennsylvania, ewre Particularly Scunded and described as follows, to wit: LOT NO. 1 Parcel #09-16-1050-055. BE2N'+ the western half of Lot No. 5L in the Plan of lots '.Aid out by Francis H. Spangles, said plan being =ecocded in the Off'_te for Eazz-1 ng cf Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1. PASe 2. BEGINNING at a Paint on the Southern side of Pyoe Streec in the line running through the center of the Pari -Ion wall of the double frame dwelling house erected en lot No. 51, e.:tending along Pyne Street in a Westerly directicn 20 feet more or less; thenct in a Southerly directicn 125 :get to a 1! foot alley; :nenoe along said aliv/ in an easterly direction 20 feet, more or less, to a point in the running through the center on Lot No. S , thenck in a Northerly direction aeon= the line running through the canter of the parcicien wall of the afcrtmeat.oned dwelling hcust, I'S feet to the Plate of Eegirning. HAVING cherttn gre=ed the Westerr, half of a 2 L/2 etcrf =oublt frame dwelling house known as No.. 7 -East Pine Street (also Yrc•wn as Pyne Street), S=uch Encla, Pennsylvania, and also a named bltck garage. LOT NO. 2 Parcel #09-16-1050-054 BEGINNING at a PC' - on the Southeastern line of --as'- Pine (scmec!mes s-elled Pynel 5trxc, said Pt =c being 21 feet in a Norc:easterly dcreC_ita from the center 14ne of an alley; Chance a'_ang the Saut`,easttrn line of P.ne street, Nor-.^. 49 de?rots 70 minutes East 20 feet w a Point; thence along Premises Y_v,n as No. a P,r,t St_e_t, or. the Ncrthwestecn line of a 1 South 40 dalle 7. tts East :=5 feet tt a point =• Nest 20 f__ to a t wide alley; ; Crtoracs along said alley Soon 4? decrees 70 m.nute^. 'c Point; thence through the center of a part, Lon wall separsttng ant Prem. ses 2 and 4 Pine Sereec, vcrt.*. 40 deg_eas 30 minutes West 125 •__ co a point, the pact c_ BEGIMING. 4 P,r.e ••- Y.^.cwn as Nc. Y:,VING thereto groomed a two and enrhalf ar r, frame t+___i-? Street. 2 • Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the beck of the mallpiece, or on the front If apace permits. n1. Article _AddresseLdlto: // Cna(a, ???na.s' PS Form 3811, idly 1999 Received by (P/ease Print Cleady) I B. C. Slggaturs -? ? Agent x l?I./ .,O Adtlre D. Is delivery address different ftoffxem 17 ? Yes II YES, enter delivery address below: O No 3. Service Type KCenieed Mall ? Express Mall ? Registered 0 Return Receipt for Merchandile ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes ?},Iu,Ir??n?,tr?,IliIIIIII!ItI!IIn?,I? Domestic Return Receipt to! M1 ? S fig M1 . ? L POStdgo $ ??h ..d CecJ?ad Fee a Bourn Receipt Fen rl IEndorsement Required) p Endorsement nt Required) (Endorsement Regmmdl O Total Postage a Fees L M1 ..o s i t ? c ?. r (I rPoBO+? ef ?r , le Apt // 99. o ttl O M1 Cne Sfald, ZII'?J ?? /--yln?u 102595-MM-0952 EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, • CIVIL DIVISION Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO VT VAATTA rr.r .-. ..? Bryan J. Sheaffer c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT °A')- The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Tetra THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, 9URKIN & CONNELLY LLP DATED: 3P t?1 BY: Scott M Di6tterick, Es Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE UL IHOS° T-40 mrcua FCeceS c: Parcel' Of land an cua:eC in the Cewnahip of Ebou P ennahoro, County of Cuw`e::asi Pad sc.a to c! Panasylvar.:a, mc:e pa:ctculaay hounded and des Gibed as £cllews, to .4 C: LOT NG. I Parcel #09-16-1050-055 .h , -4 lots ?aid out by F:ar.:es H. BEING she western hhal£'of Lot No' 51 he CC!: ce for P.eco: dta? eC Dseds to and fee 5panglar, Said plan e_n5 =ac in in Plan Sock 7. PnSe 2. ..^s;? '+ania, Cvmberlaod County, Per. BEGINNING ac a point on the Scu Chern side of e'rtae me e decve'n ah- lice cced on lotcNo' the cease: of the parttsien wall of the dcutle Crlii rg .`.hose 51, -,tending along Pyre Stc a?t -nt' ?1p a; .cotda Icy; thence along sa d aliey in an in a Sov C:nerly d:reac:on a . e as te:ly tt.ectior. 20 !at. , Here or less. to point Cr. taerural n? eh:cu?n the center d+<thllS Li nc ne hcusrve, nni?a tC ee :3 so the or, Loc No. 51; cheat! in a No: tnerly d^ca:ien z:crc center o! the paceicicn wall c! t.,e a__._meacicn a_ ' place of Eeginciag. ... ng house ING thereon erected the Nesterr. half of a 2 1/2 s.t-+ d-.`-Sothane :a., };.W3:.^.own as No., 3 East Pine s__e _ 1a1 sc Y-arc. zs 7;ne SCrzec), South Sne_z P ennsyivari a, and a'_so a Gene..^.c blot; ga:ate. LOS No. 2 Parcel 409-16-1050-054 .• East Iscme rimes s?e:led PF el 3EGIAH.iNG at a pccac on the Southeastern line of di.' ___a_. .._n the _•nter line Of S crrc, sa_.. po-.at b2_n5 21 in a Nor- l.^.easteriy St: Set Nc Scut:eascerr. ..' 45 deorees ]G an at 1.y; ehe..^.ce aicne e`.e :m of Pc e ._ce r_e .z see h_.osm as Nc. B -rt ae Str<`-a minutes East 2e eec to a co nt; ch.<nce z _ o ctat oa e.`e Ncrthw<stera L-ne o '. 'Ce t , t5 45 deg>ess 30 miru]ea West 20 !•_e"_ cc a South SO deS:aes 70 mdautea Easc 125 a if eec wide e11 ey; t'CC_.e aleag sa_d a_'•7 S wall seearaoa.^•o the ?rem_ses 3and 4 ! z cartit.on - poinC; thence Ch: occh She ce .e_ c, _.t c: a pciat, the plate t_ p;ra Street. ,4 0 deSr:eS 30 mcouc<s Nest 12S £ ESGI!•C7iNG. • at eed a two and cre•tzl! atc r'i !ra...e dWt l:nS k-t"'a as :70. a Pine ?LAVING theranc -- Etreec. 3 U.S. Po6tal Service CERTIFIED MAIL REC EIPT' .(6?rmosflc M if Only; No Insurance Coverage Pmvidod) ' r r ' r S. c 137 1 n - _ Po.h r 'rn G N I rte: I11 .u IlJ Jfl l t~11 / _ I' `.. ?? 0 ? ?n.u d.f U.I rvrun IC'nJOrorxnnnl nenm em - C O T.I.I P..u%ge 8 Fee. / Nn Jh !'U N I O . .o?lf Jy 1101 1" G 3 /? C '? [K CPlyhtwc c/ C3C ::. .' o . ub., . c7 (1LUL!:! .. : r3 Stare. z,F.e 13 M l il ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the crd to yoU. ¦ Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: , ?C) l.. t)Wlto'?utvl[? 1o le?cao? d?c>/ C , /79 /7013 A. Received by (Please Prnt Clearly) C. Signature X /J _ LYI D D ? Agent ??rYI v ti i ? Addre D. Is delivery address diff"t front am 17 ? Yes If YES, enter delivery address below: ? No 3. Service Type R-Certified Mail ? Express Mall ? Registered [Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes EXHIBIT " U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: East Pennsboro Township 98 South Enola Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 5, 2001 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, vs. BARBARA A. STUCKEY rt/ic/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLYILDP Dated: r Scott eDiettenek E PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 !'1 te5a1 ceaa_Spc!on ,? ?.LL :HC SE TWG eeee ain FCec of or paccels of land situated in :he Township 0: Las: Pennsborc, cacnty of Cur.:erland and State of Pe.^.nsylvan!a, =re Particularly bounded and dci=ilaed as fc'2ows, cc w' CC; Lc: rG. 2 Parcel #09-16-1050-055, BSING the wester-. half :f Lac No. 5 in the P' am rt lots laid cut by Francis H. SPenglar, sa!d plan being recorded in the Gf!i:e to: Be=c Ing C! Deeds in and for cumberland cauaty, Pen nsylvania, in Flan Book 2, Pa;e 2, BEGINNING It a point :n tht SCuthe=t side of Tyne Street !n the line running th=usn the center of the partition wall of the double frame dwelling hcae e:ecced an lot No. 51, e:¢endl.ng along Pyne 5t:eet in a westerly di rt=i-n 20 fen: acre or less; theme in a Southerly- direction 125 !__. Ca a 1- foot alit'; thence along said alley in at easterly direction 20 fee:, core or 1.253, to a point !n the runninc throe?h the center thenck !n a Ncrtheriy d!rea_ton are c? the fix _u:.?tng :h:;ugh the an Let Na. 51; ten-er cl the Part!einn wall of tie a!c remenCicr.ed dwelling house, 'IS tint c the Place of Be?ir non g. F.dvIvG :herein erected cha Western half o a 2 / ab a frame due'lins house %now. as Nc. 2 East Pine 5treet la'_so MLncm as 0•i• .- 5tae2c', South E Penrsylvan_,a, and also a cement block eara_e. Lc: NO. 2 Parcel #09-16-1050-054 3BGI1n7TNG at a Point on the Southeaster-. ii..^.e of East Pdne (sometimes s^yel'_ed P,,--el S C_eC C, said pct-._ neirg 2i feet in z Ne::::essteriy d__x_:on from the cec_e_ 1:.^.e of an alley; tierce along the Sou t e:stncn lire CO Ptre Street, North 45 degxes 30 _ minutes East 20 ?__ :o a point; theme a3zrg Premises known as Nc. 2 ctn- Street, Scu Ch 40 dec=rees 70 minutes Las: 125 :net to a punt en the N:rtbwesce:n lint at a 1- Chance a_tn? said alley South 45 decrees St mantes W23C 27 tit Cc a fees wide e11.ey: point; thence thral•_ the c_r_er a_ a Pa_-1_San wall sn.a_3t_L3 the e.T.a es 1 and 4 Pine 5tre et, NC= 'n 40 degre of 3G m__Q.ss Aas_ ._._ t; 2 Point, `.a place of B'oGll'TNING. 4vIVG thereon erec_ed a two and cr,e-hha._ store Erase dwea ing known as Na. 4 Pine Street. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa R C P 3129Ib1 TO: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 5, 2001 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of. Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on ajudgment in the action of EASTERN SAVINGS BANK, FSB, Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMIT9, DURKIN & CONNELLY ULI P . Dated: gy; r ? Scott A. Diettrerick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I`) Legal Cescripti:n •1 ALL TRCSS TWO cereaa Pieces Me marce_s o! land si Crated !: the :cwnship :! East Penns. County c! Com;:e:lard and State c! PennsylVAh;a, care Pa:"Itulacly banded and des cr'_red as IzIlows, to W.:; LCT 110, l Parcel #09-16-1050-055. SS2NG he western ial! c! Lot No. 21 in :he P:an :! lots laid cut by Prarria N. Spanglar, said plan being recorded in a-- Of'___e !cc Sec_.d_eg a! let's dr. and !. Cuelberland :aunty, P_nasyl'rania, dr. Plan Sock 2. Pnee 2. 33GI$42NG at a point w :hs Scu:he:a side c! Pyae Street in C12 line rJnning thccuch the center of tie partitdon wall c! the double frame dwelling hcese ere.ced an lac No. 51, utending alpcg Pyne Street in a Nescer_y directaca 20 feet acre or less; thence in a Southerly ddret:i:r. 123 !c- cc a i5 !Sot alley; thence along said alley in an eaa ter l_/ dal c_inn 37 mare Cz 'less, to a pa ir.t _n the :unndng throuch the c_..__• on Lot No. 51; thc-A in •a em r_.e_17 eare_:ion a'r_n5 .e li•ne rnn_ _ nra- - t- eentet c4 the pa: ci:ie. wall of t%e ale:eme...__red dv_lL ng hause, 'S •fee_ to the Plats of M.AvING thereon e_____d cha 'de9.__? half of a 2 1/2 a_cry dcubl_ __art dwelling house 3:n:wn as No. 3 Saat Fine S:reef (2150 ?^c as Pyhe n_r_et), _CU:h Sncla, ' penr.571vati2, and also a esnent Meek garze . LOT NO. 2 Parcel #09-16-1050-054 33GIIQI:NG a poi..^.t e., • aou.reas_erc lint c! S'zs: ?;,..e Iseoe_.mes spelled ?yea) s: , said point be-nC 27 fee: in a NzrtSeas:erly d 1]n frOT It C_n _ 1'_qe of an 2l ?11 chance alnnc the Southeasc__- 1_.^.e .! :_..e S_____• NCr:h 45 de?zees It _l_• __ee. r..inures Ease 17 !a-- to a pock e; to care along premises ??cwn as Na. e Pere Street, South 40 decrees 30 sirs tcs 59s: 125 fes_ cc a pc_nt on one Nc:thwes:ern Sinc of •a lest wide Rile,(; -burs along said alley acut:: 45 degrees 30 r.._nu_tsWoo: 2: !let _0 a paint; thence through cue cents. c_ a par._:acn wall sar a.-s:u.g the e _ _:_,s es 7 and 4 Site State, North 40 des. _a 30 -____e3 'w___ _____ to a meant, the Place _ S'c=rMIG. :SAVING thceon erected a :•:a and ene.hal_! at:.-I !rant dwelling h.. own 13 No. 4 Pine Street. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.RC P 3129(b) TO: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on December 5, 2001 at 10:00 a.m., the following described real estate which Barbara A. Stuckey n/Wa Barbara A. Sheaffer and Bryan J. Sheaffer, are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: Nos. 3 and 4 E. Pine Street Enola, Pennsylvania 17025 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of EASTERN SAVINGS BANK, FSB, Plaintitl; Vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendant(s). at EX. NO. 99-3582 Civil in the amount of $91,572.78, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above save date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, DURKIN & CONNELLY LLP Dated: Q ?? 01 Scott A. DiettericKIE PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 • 1 '• • 1i 1 • ALL :HOSE TWO Cerra it Prects or Parcels of land si Gaited in the 7cwnship of East Permbore, County of Cum=errand and State .f Pennsylvania, core particula=ly bounded and dese'bed as fallows, to wic: Lc: NO. L Parcel #09-16-1050-055, EE:NG he western half of Lot Nc. 51 in the Plan ca_ lots laid cut by P:anci9 4. span,,&, said plan being recorded in the office far Rotor iing of Deeds in and Ic= Cumberland COUn Y, 2en3syl•:ani a, in Pia" Sack 2, Pace 2, SEGINNING at a point on the Scutheta side of Pyle Streec in the :t a =-.ring thzcueh the eence= of the partition wall of the double frame dws'_linc F.c-se erected on toe No. 51, a::tending clang pyne street i" a Weals.`/ direction 20 Leer more or less; thence in a Southerly d'_recticn its fett to a 15 foot alley; thence alcr,5 said alley 13 an easrerly d_. _c tor. 20 f_•__, acre c less, to a point in the --.ruing thrcuch the center on Let No.• _1; thenct ir.a Hc__he_ly d__c__: n tic "c ;hol line :annine tnrr.;h the cancer of a pa.tiafon wall of the atrrcmcnticned dwelling hc'.se, __c fee- to the Place of k7.VING chereom erected the Waste=r, half of a 2 112 stt-y drtble Lame dwelling house Y.nown as No.. 1 Eac: Pine Street false ?-cwc as Pyne Straecl, South Erc:a, Penasylvaia, and also a eenent blcek gz:age. LOT NO. 2 Parcel #09-16-1050-054 BzC;rN ;G at a point on the Sea:heal x=- line of East Fine (acme_ames spelled p}-eI street, said point bttac 27 fact in a Ncrtheaste=iy dc^ r__cn from the center line of an alley; t once along t.`. iauthe:sce_ n_ a of Pine Street, Nc.:h 45 re?s :0 minutes East 20 fec _e a pint; thence along premises known as No. 5 P_nc e_re_c, South 40 decrees 30 minutes East 125 c__: _c a pcinc e. the Ncrthwes:em line of a 15 _•t wide alley; hecae along said zlle/ G=urh 45 degrees 1, m'_nutes Was: 20 feet to a t f• poi=, e; Che"oe rhmcgh the center of a oarti cr en all sepal 3tina the _ pr_m49e9 7 and 4 PSSe Street, North 47 dal;=122 30 min'ates West 125 f___ cc a point, th_ place of BEGINNING. SAVING tne_t=r a=acted a t•.t and one-half a=cry frame d.•e13Lng known as No. ; Pine Street, r L L r '.. Alb. fee halo In ftJpa Tor motor postaB6 and pa.t,me(k-'Ingube of •'?e;fMOIR ?foff(`Urronl PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: .I/.T . ., • 1 l One Piece of ardinary moil addressed m: O 4A, . CU. -w CPS;„ cif c aL" Ul^e C L,-r eu-I, e 4 ? ,,4- 7o r r b rorm eel /, Mar. 1989 o„_,LG U.S. POSTAL SERVICE _ CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: I One Pieta al ordinary T.J addressed to: =?A,y ?e?Lxs Jz,w ???5 ?)?.IIG Ur ra rorm 3e n, Mar. 1989 w Orl(? U. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Roceivan Fom. ` - , r OOnee piece of oIdInagry mml addresaed 1. It I Allix lee hors in 5lempa .:or Melerlpostege and yyjo•••a?'ytt1;merk,kngy ra of master ?'tUJlent w _ STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND SS. Robert P 2legler I, -------- - - ------- ----------------°- Recorder of Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ---------------- Sweet Air Investment Inc ' -- stn ------------- ---------- is the grantee the same having been sold to said grantee on the _______ ------------------- day of -- O1- - -- - Dec 01 A. D.,. _____, under and by virtue of a writ________ Execution 6th - -------------------------------- issued on the -------------- ---- Sept 01 day of -------------------------- A. D., ----- , out of the Court of Comman Pleas of said County as of civil ----------------- ---------------°----- Term,: 1999 Number 3582_ Eastern Savings Bank FSB ......... atthesuit of_____________ ------------------------ ------------ Barbara A Stuckey nka Barbara A Sheaffer & Bryan J ------------ against---------- 249 ----- 3381 ------------------------------- as duly recorded in Sheriff's Deed Book No-------------- Page ------------- IN TESTIMONY WHEREOF, I have hereunto set any hand and seal of said office this _ - ___ day of-----°l9acFl----------- A.D., ?°-1- -- Recorder of -;Is Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2002 Eastern Savings Bank, FSB In The Court of Common Pleas of VS Cumberland County, Pennsylvania Barbara A. Stuckey n/k/a Writ No. 1999-3582 Civil Term Barbara A. Sheaffer and Bryan J. Sheaffer Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 21, 2001 at 8:38 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Barbara Sheaffer, by making known unto Barbara Sheaffer personally at 4 East Pine Street, Enola, Pennsylvania, its contents and at the same time handing to her personally the said true attested copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 14, 2001 at 9:50 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Bryan J. Sheaffer, by making known unto Bryan Sheaffer personally at The Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 6:05 o'clock P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaffer, located at 3 & 4 East Pine Street, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Barbara A. Stuckey n/k/a Barbara A. Sheaffer by regular mail to her last known address of 4 East Pine Street, Enola, PA 17025. This letter was mailed under the date of October 2, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly swom according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Bryan J. Sheaffer by regular mail to his last known address of The Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013. This letter was mailed under the date of October 2, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Scott Dietterick for Sweet Air Investment, Inc. It being the highest bid and best price received for the same, Sweet Air Investment, Inc. of 11350 McCormick Road, Suite 200, Hunt Valley, MD 21031, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $990.11, it being costs. Sheriff's Costs: Docketing $30.00 Posting Handbills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 22.75 Certified Mail 1.41 Levy 30.00 Surcharge 40.00 Postpone Sale Law Journal 395.60 Patriot News 272.28 Share of Bills 25.66 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 Poundage 19.41 $ 990.11 Sworn and subscribed to before me This day of ,Ca,..,. 2001, A.D. Q. 7h. . ?y r thonotary S R. Thomas er Kline, Sheriff BY L / /?U (LLB S WUA Real Estate Deputy 3'? .Uti 1vo ut-3:0 3Q U2"119 9sl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, Plaintiff, CIVIL DIVISION NO.: 99-3582 Civil vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J.SHEAFFER, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 Eastern Savings Bank, FSB, Plaintiff in the above action, sets forth as of the date the Praecipe for the Reissued Writ of Execution was filed the following information concerning the real property located Nos. 3 and 4 E. Pine Street, Enola, Cumberland County, Pennsylvania 17025: 1. Name and Address of Owner(s) or Reputed Owner(s): BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: BARBARA A. STUCKEY n/k/a 4 East Pine Street BARBARA A. SHEAFFER Enola, PA 17025 BRYAN J. SHEAFFER c/o Cumberland County Prison 1101 Clarmont Rd. Carlisle, PA 17013 3. Name and Address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: EASTERN SAVINGS BANK, FSB Plaintiff EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola, PA 17025 4. Name and Address of the last record holder of every mortgage of record: EASTERN SAVINGS BANK, FSB Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: NONE 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 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. §4904 relating to unworn falsification to authorities. JAMES, SMIT U & CONNELLY LLP DATED: ? 30 BY: Scot A rick, squire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, VS. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Barbara A. Stuckey a/k/a Barbara A. Sheaffer 4 East Pine Street Enola, PA 17025 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717)240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, [DgRKIN & CONNELLY LLP DATED: 0 -30 n? BY: Scott A. biet'terick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE a !'1 Leg a` Oeacription ,? ALL THOSS TWO certain pieces or psr_ela o- laid situated in the Township of East Pennsboro, County of CuribGrland Lad State of Pennsylvaa!a, mere particularly hounded and described as fcllows, to wi e: LCT NO. 1 Parcel #09-16-1050-055, 952NG the western half of Lot No. 51 t.. the Plar ct to ez ia!d cut by Farris H. Spanglac, Said Plan being recorded in the Office for Recording of Heeds in Sad for Cumberland CorntY, panrsYlvania, in Plan Book 2, Page 2. BEGINNING at a point on the Southern side of Pyre Street in the line running through the center of the partition wall cf the double frame dwe'l'ling house erected on lot No. 51, extending along pyre Street in a flies erly direction 20 t et more or less; thence in a Southerly direction 125 f__- _ to a 15 !not alley; thence along said alley in. an. gas direction 20 feet, morecr less, to a point !n the rurctag thrcuch the center Lot_y _,.. 'later-_ on t,. .. Line runrg on Let No. 5'.; t.w_ne! in a Ncrehe__r acne in enrcugh the center of the partition, wall. cf the afcriimentioned dwelling house, 125 f___ to the Place o! 3:ginmiag. HAV:NG tharecn annelid the Western, half of a 2 1i2 story double !rams dwelling house l:acwn as No. 3 Saat Pine Streit (also Y^c•_m as Pyne Street), South enola, Pennsylvania, and also a cement block gatace. LOT NO. 2 parcel #09-16-1050-054 EEG-IMING at a print on the Southeastern line of East Pine (sometimes spelled Pane; Serest, said p__rt .,•_•.g a' _t in a NerCteascerly direction f_-em the center lire of Pine Street, NCreh 49 degrees 30 an alley; thence along the Sout:.saitern 'line of minutes East 27 feet no a point; then= along preinis05 ?=,n as No. 5 Pine Street, Sough 4C degrees 30 minutes East R5 feet to a pcirt on the Ncr:hwestern. line of a is feet wide alley; _nence along said Alley South 49 degrees 30 minutes Nest 27 feet to a point; then_ct through the center of a partition wall stcaratrng the`p • __miSes 3 and 4 P!re St_eic, Soneh 47 degrees 30 minutes 'des- _<_ ____ -o a prim t, `he_ plane of SECM1114-NG. _a ?- _ HAVING ther:ar Bloc led a two a.._ Cr._-..a _f st- __ !tame c«" _.l`_i g known as Nn. 4 pine Street. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EASTERN SAVINGS BANK, FSB, CIVIL DIVISION Plaintiff, vs. BARBARA A. STUCKEY n/k/a BARBARA A. SHEAFFER and BRYAN J. SHEAFFER, Defendants. NO.: 99-3582 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Bryan J. Sheaffer C/o Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 5, 2001, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 4 E. Pine Street Enola, PA 17025 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 99-3582 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Barbara A. Stuckey a/k/a Barbara A. Sheaffer and Bryan J. Sheaffer 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 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, South Hanover Street, Carlisle, Pennsylvania 17013. 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. 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 Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrators Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, QURKIN & CONNELLY LLP DATED: 1.7 O) BY: Scott A. Di tterick, Es Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND PERSONAL SERVICE a `. -X; a Legal. DescriPticn, i ALL THOSE TWO c__.ain pieces o: ;,sees', of land situa:ld in the Townahi7 Of Eas: Pen.^.ahore, coun:Y of eum5er:and and Slats of Penns Vlvan:a, note Parei=.+iaaY 6ound!d and described as fcllcwa, to wit: LOT NG. 1 Parcel #09-16-1050-055 . EE/NG c:^•e western half of Lot No. 51 in. .Plan o'_ !cgs laid ouC by Fra reds H. Spangler, mid Pian Se_nc receded in '-n: Office for R!nrda 5 of Desds in and fc.- Cumhe:Land Coup:y, Pennsylvania, in Plan Book 7. Page 3 EEGINNTNG at a point or. the Southern side of Pyne S:reecin the lice canning th.-Duct. the cents.- 09 the partition wall of the dcuhle frame dwe'_1_r.5 house ersc:ed on lot No. 51, a tendin along Pyne Street in a Westerly icn 20 fee- more o: less; :hence in a Soucheay direction 125 feet ec a 15 foot alley; :hence along said alley is an ang through the renter easterly d_ ion 30 feet, more co less, to a Point In the a .. arts-ioir. in a Ncofnerly d:.eotics a _c?g the line r•_ar1tn7g 5f heet tougho the or. Lot No. 5i; center of the pa.-ti t wa__ of _::e a__reme _.c ed dwe___ng brass, Place of Seginting. HAV:NG :hereon erettad the Western half of a E 1i2 stt_y d_---e f=ame dwe':1ic5 house Sou:- s_nola, }::Awn 86 NO., J E1Et line Street (also Y'1C6: as P'-T._ $__--tl i PtnnsY'cania, and 1150 a talent blcck garage. LOT NO. 3 Parcel #09-16-1050-054 on the Southeastern line of East :Pine iscme:imes spelled Pyne) Bwlin:ENG ac a Poi. Streee, said point be-,n= 27 !e e: in a Ncrtheaster..y dz.eee.on from the center line of an ality; thence along the Sout eastern care of Pine Sorest, Ncr-n 49 decrees JD miantes East 30 f__ _o a pmot; rhea! along premnv-s hn=wn as No. a P'^a S__!e_, _1_r._ .. a _5 south 4: de g- see IO ".L --s sag: 175 fee-. to a 3'tl_ Cf, the :^.rtltwes e_.^. !e!C wide alley; aeaoe 1_cag said all ey ..o. ° d.e.-gas 30 m:rules West 30 feet cc a thence :hr=ugh the center of a na_ti--ne all separatan_ the - r. ses ] and 4 Point; .Es .__t to a Pc>n:, thc•place of Pine street, Nor:h 40 decree! 3C mttuses BEGINNZ27G. •. erected a two acd ^-• half strr•/ frame dwelling as No, 4 Pine St__et. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-3582 CIVIL 19 _ CIVIL ACTION • LAW TO THE SHERIFF OF _ CUMBERLAND -COUNTY: To satisfy the debt, interest and costs due Eastern Savings Bank, FSB from Barbara A. Stuckey n/k/a Barbara A. Sheaffer, 4 E. Pine St., EnnolalFF(S) PA 17025 and Bryan J. Sheaffer, c/o Cumberland co. prison, aremont Rd., Carlisle PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at 3 and 4 E. Pine St., Enola PA 17025. (See attached 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/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 thereof; (3) If propertyofthe defenclant(s) not levieduponan subject to attachment is found in the possessionof anyoneother than a named gamishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $91,572.78 L.L. Interest"/13/99 - 12/5/01 $20,728.64 Due Prothy $1.00 Atty's Comm % Other Costs Atty Paid $2,026.50 Plaintiff Paid Date: September 6, 2001 REQUESTING PARTY: Name Scott A. Dietterick, Esq. CURTIS R. LONG .. Pro onotary, Civil Division by Deputy Address: P 0 Box 650 Hershey PA 17033 Attorney for: Plaintiff Telephone: (717) 533-3280 Supreme Court ID No. 55650 REAL ESTATE SALE No. -2-1- I Sept. 12, 2001 tho rariflwiedupon the amndant,; IntiiT;51 In the r( :i `'V SIIUated in East Pennsboro Township JIRI1EIIanG? GOllnt'd, P' *n? Enola- 3n di t?sia +P'7?1 end by th,? r,F?, `)Rtb.-__Sep-t.._17- ?001 "I'.uWIO. da$: 1 " °O b--Pine St. !:ribed ON iAhlblt "A" 00,11 On ,;rporated her'Aln, iv C)6_d :4 SYku. Real Estate Deputy G-7' CM cu:m C=v OiDli 09 Al`. ...? THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 567, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) as 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 Ihit 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 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 exactly as printed and published in their regular dally and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 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 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 #22 9th 2001 A.D. Pod / Teny L. Russell, Notary HetdsWhq, DaupMn conJq! My Cgnm+ss" F-xpbm June 9, f ! O ARY PUBLIC Member, PenneyNenleAmobletictsof ftmission expires June 6, 2002 P CUMBERLAND COUNTY SHERIFFS OFFICE < CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 pbcr+ or petals of ate of Statement of Advertising Costs kd mil ING the To THE PATRIOT-NEWS CO., Dr. of Las For publishing the notice or publication attached n being hereto on the above stated dates $ 270.78 fah" Probating same Notary Feels) $ 1.50 loin, in 9 rY ( ) side of Total $ 272.28 Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general )e receipt of the aforesaid notice and publication costs and certifies that the same have bons. 123 fat to warm half of a 2 'g b" knmrn m o known W Pyne hania and ulw a Snal. I fed to a pomr, u No.SPm no Fast 125 feet lion of a 15W silty tooth 49 I p uto a point; nion will 1 4 Piet SUM!, eb 125 red to a By ........................................ t yl i4 M and orobalf 1o.4 Pim SML PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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 of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 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 matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL. ESTATE SALE NO. 22 Writ No. 1999-3582 Civil Eastern Savings Bank. FSB VS. Barbara A. Stuckey n/k/a Barbara A. Sheaffer and Bryan J. Sheaaer Ally.: Scott A. Dielterick Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro. County of Cumberland and Stale of Pennsylvania, more particularly bounded and described as follows. to wit; LOT NO. I Parcel #09-16-1050- 055. ? Rog r M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001_ N07AR!N_ SEPl " LO'S E Cali .'n Ecr, iiesr ! ::: d County My Corrmission Expires l Larch 5.2W5 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : . ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 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 matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. RFaL. ESTATE BALE No. 22 Writ No. 1999-3582 Civil Eastern Savings Bank. FSB Vs. Barbara A. Stuckey n/k/a Barbara A. SheaIIer and Bryan J. Sheaffer Atty.: Scott A. Dietterick Legal Description ALL THOSE TWO certain pieces or parcels of land situated in the Township of East Pennsboro. County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows. to wit: LOT NO. 1 Parcel #09-16-1050- 055. BEING the western half of Lot No. 51 in the Plan of lots laid out by Francis H. Spanglar, said plan be- ing recorded in the Office for Re- cording of Deeds in and for t. Cumberland County. Pennsylvania. in Plan Book 2. Page 2. BEGINNING at a point on the { Southern side of Pyne Street in the j line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feel more or less: thence in a Southerly direc- Uon 125 feet to a 15 foot alley: thence along said alley in an easterly dimc- Uon 20 feet, more or less. to a point to the running through the center on Lot No. 51: thence in a North. erly direction along the line running through the center of the partition wall of the aforementioned dwelling house, 125 feel to the Place of Be- ginning. HAVING thereon erected the Western half of a 2 1/2 story double frame dwelling house known as No. 3 East Pine Street (also known as pyre Street), South Enola. Pennsyl- vania, and also a cement block ga- Rog M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 LOIS E. SDi'fDZ ilo: r/ PUNIC caflis!o eo CuCI"w"i'• r.51 County f Colraniss!on E1:plles Klatch 5, 2005 i :. . slP ? .f 4 exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 2001 Afftant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication arc true. REAL ESTATE BALE NO. 22 Writ No. 1999-3582 Civil Rog r M. Morgenthal, Editor Eastern Savings Bank. FSB Vs. SWORN TO AND SUBSCRIBED before me this Barbara A. Stuckey n/k/a 26 day of _ OCTOBER. 2001 Barbara A. Sheaffer and Bryan J. Sheaffer I Atty.: Scott A. Dlelterick / Legal Description ALL THOSE TWO certain pieces ?` or parcels of land situated in the f:OTAR4Al' EAL Township of East Pennsboro. LOSS E. $*;yD'.' ?1 our/ Public County of Cumberland and State of Caals'0 Bra, C:u,??i;erarACounty Pennsylvania, more particularly my Connmission E)Oms March 5, 2M5 bounded and described as follows, to wit; LOT NO. 1 Parcel #09-16-1050- 055. BEING the western half of Lot No. 51 in the plan of lots laid out by Francis H. Spanglar. said plan be- ing recorded in the Office for Re- cording of Deeds in and for Cumberland County. Pennsylvania. in Plan Book 2, Page 2. BEGINNING at a point on the southern side of Pyne street in the line running through the center of the partition wall of the double frame dwelling house erected on lot No. 51, extending along Pyne Street in a Westerly direction 20 feet more I or less: thence in a southerly direc- tion 125 feet to a 15 foot alley: thence I along said alley in an easterly direc- uon 20 feet, more or less. to a point in the running through the center on Lot No. 51; thence in a North- erly direction along the line running through the center of the partition wall of the aforementioned dwelling '. house. 125 feet to the Place of Be- ginning. HAVING thereon erected the 1 Western half of a 2 1/2 story double frame dwelling house known as No. i 3 East Pine Street (also known as l- Pyne Street). South Enola, Pennsy vania, and also a cement block ga- i rage. LOT NO. 2 Parcel #09-16-1050- 054. BEGINNING at a point, on the Southeastern line of East Pine (sometimes spelled Pyne) Street. said point being 27 feet in a North- easterly direction from the center line of an alley; thence along the Southeastern line of Pine Street. North 49 degrees 30 minutes East 20 feet to a point; thence along premises known as No. 8 Pine Street, South 40 degrees 30 min- utes East 125 feet to a point on the Northwestern line of a 15 feet wide alley; thence along said alley South 49 degrees 30 minutes West 20 feet to a point; thence through the cen- ter of a partition wall separating the premises 3 and 4 Pine Street, North 40 degrees 30 minutes West 125 feet to a point, the place of BEGIN- NING. HAVING thereon erected a two and one-half story frame dwelling 1 known as No. 4 Pine Street. 7 f: ti