HomeMy WebLinkAbout03-3207WASHINGTON MUTUAL BANK, FA 1N THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
MICHELLE LOCKHART ACTION OF MORTGAGE FORECLOSURE
Defendant
02-
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action
within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if 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
claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. S1 DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSAR10 QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION, ES POSSIBLE QUE USTED PUEDA PERDER D1NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA
DE ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
WASHINGTON MUTUAL BANK, FA,
Plaintiff
VS.
MICHELLE LOCKHART,
Defendant
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.C. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorney I.D.# 15700
Attorney for Plaintiff
WASHINGTON MUTUAL BANK, FA,
Plaintiff
VS.
MICHELLE LOCKHART,
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW c~,..~ ~ ~ ~2, o7
: ACTION OF MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, WASHINGTON MUTUAL BANK, FA, is a Corporation, with an address of P.O. BOX 1169,
DEPT. 2665 MILWAUKEE, WISCONSIN 53201.
2. Defendant, MICHELLE LOCKHART, is an adult individual, whose last known address is 523
WARREN AVENUE, NEW CUMBERLAND, PENNSYLVANIA 17070.
On or about, February 28, 2002, the said Defendant, executed and delivered a Mortgage Note in the sum
of $108,050.00 payable to THE WASHINGTON SAV1NGS BANK, FSB, which Note is attached
hereto and marked Exhibit "A".
Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment of the same, Defendant, made, executed, and delivered to original Mortgagee, a certain
real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1750, Page 3510 conveying to original Mortgagee the subject
premises. The Mortgage was subsequently assigned to WASHINGTON MUTUAL BANK, FA and
recorded in the aforesaid County in Mortgage Book 686, Page 1173. The Said Mortgage and
Assignment are incorporated herein by reference.
5. The land subject to the Mortgage is: 523 WARREN AVENUE, NEW CUMBERLAND,
PENNSYLVANIA 17070 and is more particularly described in Exhibit "B" attached hereto.
6. The said Defendant is the real owner of the property'.
The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on March
01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $20.52 per day
From 02/01/2003 To 08/01/2003
( based on contract rate of 7.000%)
Accumulated Late Charges
Late Charges $28.75
From 03/01/2003 to 08/01/2003
Escrow Balance
Attorney's Fee at 5% of Principal Balance
TOTAL
$107,046.83
$4,350.23
$28.75
$201.25
$778.22
$5,352.34
$117,757.62
**Together with interest at the per diem rate noted above after August 01, 2003 and other charges and
costs to date of Sheriff's Sale.
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at SheriWs Sale. If the
Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any jurisdiction.
9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of
1974 is not required in that the original principal balance exceeds $50,000.00.
10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any
way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended.
11. The within Mortgage is insured by the Federal Housing Administration under Tire II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, Plaimiff demands judgmem in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 7.000% ($20.52 per diem), together with other charges and
costs including escrow advances incidental thereto to the dat~ of Sheriff's Sale and for foreclosure and sale of
the property within described. .,~//
PURCEgc~E, KRl~ & HALLER
Leon P. Haller, Esquire
Attorney for Plaintiff
I.D. # 15700
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
Wmf27xnc 1744x2796x2 tiff) [14]
Multisute
NOTE
lllitlllllll
1.
-Bo~ower- mens each pemoe sisnina s~ the n~d of this Note, and the peuon's mccmsors and usiSm.
(U.S. 5 108,o50.o~ ) plusintes~st, totheorde~ of L,m:Io-. lnte~P, willbe charsed ~m tmp~Cll~incipal, fl'om
s&'ne dine ss this Nol=e and called the 'S~ hlSt~tmsq- · The Secuflty lnstf"dment Im~cts the L(nM~ from Io~cs
(A) Time
Bomm~ shah make a paymcm of pl~ncipal and imnut lo l--=nd~ m~ the firm day of esch momh beginning ~
(~ Amount
be pail of a lm~r monthly psymem mqkired by the Security 1~, that shall be sl~lied to p~, ~ ~
(I)) Alloele to this Note for Payment A4Jmtmems
pa~ of Offs Note. ICheck q~41~bte box]
B G~''d ~ MI~ ~ l~']
Gmwi~ .~luhy
6. BO~,ROV~'S FAILURE TO pay
If Le~'r has r~ r~'ived ~e full mo~y paym~ r~]ircd by ~ ~y ]~m~m, ss descrlbM iu p~ra~
4(C) of this Note by thc e~ of ~l£t~ ~'~i~.fqm ~ after the payr~nl is dl~, 4c~ may
mgui?~ms of the Seer~ts~ in Ihe ctqe of paymem defaulU, ~qnlre immedia~ imymf~ in full ~ ~ ~ ~
/~.~)
Wmf27xnc (1744x2795x2 tiff) [15]
Wmf27xnc (1712x2208x2 tiff) [10]
ALL ~a~ tract or parcel.of land end 'pre~Ises, situate,
~he Borough of Le~oyne. zn the County 0£ Cumberland and
Pennsylvania, =ore pnr=icnlarll .deScribed as.iollm~a;
Co~n~ealth
of
B~INNIN~ ac m point on the southvesc line ei Warren Strea~, ~aid point being
one hundred'fourteen aa4 eight-tenths (!14.8) ~eet ,~rCh~esc of the
intersecclon o~ the southwest line of ~arren 5:ce~t and the northwest linm
Ol Clark 5kreet; said point being also on the di?idtn8 line between ~oka
377 and 378 on the herslna~ter mentioned Plan of Lots; thence alonB said
ii.i/ins line. South. 60 degree~ ~e~, on~ hundred ~enC~i~e (1~) geeb
': to a point on the dlv/d~ l~ne bekve~ ~cs 375 and 378 on ~id PZan~ bbe~e .
along ~8id di~ldtn~ line North 30 gegrees VesC, ~ifCI~ne and ii~ty hun~r~ .
~- s~d. plan; ~ence aloni ~il divigfll lin~, ~or~ 60 degrees ~s~ On. hundr~ '
· ~: twenCy~ive (125) feet to a polnC.~ the ~uChvest line of garr~.Sc~et;
" thence along the sou~c line of ~en S~eeC, Soe~ 30 de~a-~st,
. ~ty~ne and fifcy.hundred~ (~l,~) feec Ca a point, ~m place uf
'IIAYI~; thereon erected a one and one-hml~ story frame dvelZing known as No.
523 Warren Street, l~_~oyne, Pennsylvania. g. '
I Certify this to be recorded
In Cumbdrland County PA
COMPANY NAME: ~ ~ m'~, m
VERIFICATION
I verify that the statemems made in the foregoing Complaint are true
and correct.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to
authorities.
Dated a.~ 7, ~003
By
Title Dean LaRocha Att. Asst. Secretary
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03207 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CI/MBERLAND
WASHINGTON MUTUAL BANK FA
VS
LOCKHART MICHELLE
KENNETH GOSSERT ,
Cumberland County,Pennsylvania,
says, the within COMPLAINT - MORT FORE
LOCKHART MICHELLE
DEFENDANT , at 1620:00 HOURS,
at 523 WARREN AVENUE
LEMOYNE, PA 17043
MICHELLE LOCKHART
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to
was served upon
on the 8th day of July
by handing to
law,
the
, 2003
- MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.73
Affidavit .00
Surcharge 10.00
.00
39.73
Sworn and Subscribed to before
me this /~ ~ day of
A.D.
P~o~ honot ary
So Answers:
R. Thomas Kline
07/09/2003
PURCELL KRUG HALLER
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03221 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COYNE KATHRYN ~LNlqE
VS
HERNANDEZ CARLOS RAMIREZ
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
HERNANDEZ CARLOS RAMIREZ
DEFENDANT , at 2118:00 HOURS,
at CUMBERLAND COUNTY PRISON
CARLISLE, PA 17013
CARLOS R HERNANDEZ
was served upon
on the 8th day of July
1101 CLAREMONT RO~LD
by handing to
the
, 2003
a true and attested copy of PROTECTION FROM ABUSE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this I~ day of
~o~33 A.D.
~ ~othonot ary ' ~'
So Answers:
R. Thomas Kline
00/00/0000
LS
WASHINGTON MUTUAL BA2NK, FA
PLAINTIFF
VS,
MICHELLE LOCKHART,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
P R A E C I P E
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT "in rem" in favor of the Plaintiff and
against Defendants MICHELLE LOCKHART for failure to plead to the
above action within twenty (20) days from date of service of the
Complaint, and ~ssess Plaintiff's damages as follows:
Unpaid principal balance
Interest
(Per diem of $20.52
from 2/1/03 to 8/1/03)
Accumulated late charges
Late charges
($28.75 per month to 8/03)
Escrow Deficit
5% Attorney's Commission
$107,046.83
$ 4,350.23
$ 28.75
$ 201.25
$ 778.22
$ 5,352.34
TOTAL
$117,757.62'*
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and ether
charges and costs to the date ef Sheriff's Sale.
Leon P. Hailer PA I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
K:iMKF/DOCS/QUM BE RLA/LOCK P
WASHINGTON MUTUAL BANK, FA
PLAINTIFF
VS.
MICHELLE LOCKHART,
DEFENDANT :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on August 13, 2003 I served the Ten Day
Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
P. Hailer P~ I.D.
Attorney for Plaintiff
Purcell, Krug & Hailer
1719 North Front St.
Harrisburg, PA 17102
#15700
WASHINGTON MUTUAL BANK, FA,
Plaintiff
VS.
MICHELLE LOCKHART
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 03-3207 CIVIL TERM
CIVIL ACTION LAW
IN MORTGAGE FORECLOSURE
DATE OF THIS NOTICE:
AUGUST 13, 2003
TO:
MICHELLE LOCKHART
523 WARREN STREET
I~{OYNE, PA 17043
Tills LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR TItlg PURPOSE OF COLLECTING TItE DEBT.
IMPORTANT NOTICE
YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE 1N 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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
PURCELL, KRUG~
~E , A~~Plaintiff
I.D. # 15700
1719 N. Front St., Harrisburg, PA 17102
(717) 234-4178
WASHINGTON MUTUAL BANK, FA
PLAINTIFF
VS.
MICHELLE LOCKHART,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
NOTICE OF ENTRY OF JUDGMENT
TO THE ABOVE-NAMED DEFENDANTS:
You are hereby notified that
following judgment has been entered
captioned matter:
'~.~ /~ ~/~J ~ the
a°~ainst /yOu in the above-
$117,757.62 and for the sale and foreclosure of your property
located at: 523 WARREN STREET, LEMOYNE, PA L17043
Dated:
Attorney for Plaintiff:
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234-4178
PROTHONOTARU )~
I hereby certify that the following person(s)
addresses are the proper individuals to
pursuant to PA R.C.P. No. 236:
and their respective
receive this Notice
Michelle Lockhart
523 Warren Street
Lemoyne, PA 17043
WASHINGTON MUTUAL BANK, FA
PLAINTIFF
VS.
MICHELLE LOCKHART,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
P RA m- C I P E
TO THE PROTHONOTARY OF TH~ WITHIN COUNTY:
Please enter JUDGMENT "in rem" in favor of the Plaintiff and
against Defendants MIC~ELLE LO~T for failure to plead to the
above action within twenty (20) days from date of service of the
Complaint, and assess Plaintiff's damages as follows:
Unpaid principal balance
Interest
tPer diem of $20.52
from 2/1/03 to 8/1/03)
Accumulated late charges
Late charges
($28.75 per month to 8/03)
Escrow Deficit
5% Attorney's Commission
$107,046.83
$ 4,350.23
$ 28.75
$ 201.25
$ 778.22
$ 5,352.34
TOTAL
$117,757.62'*
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and other
charges and costs to the date of Sheriff's Sale.
Leon P. Haller PA I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
WASHINGTON MUTUAL BANK, PA
PLAINTIFF
VS.
MICHELLE LOCKHAF[T,
DEFEND/~kNT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said
Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly
sworn according to law deposes and states that the Defendant(s)
above named are not in the Military or Naval Service nor are they
engaged in any way which would bring them within the Soldiers and
Sailors Relief Act of 1940, as amended.
Sworn to and sub$.cribed :
before ~e this 6/ day :
of ~'"~'~20 0_%
NOTARIAL SEAL
MARYLAND K, FERRET~, Nota~ Public
Lower Paxton Twp,, Dauphin County
My Commission Expires Aug. 8, 2006
LEON P. HALLER, ESQUIRE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO. 2003 3207
WASHINGTON MUTUAL ]BANK,
PLAINTIFF
VS.
HICHELLE LOCKMART,
DEFENDANT(S)
FA
TOTAL AMOUNT
OF JUDGMENT $117,757.62/
Interest at $20.52 per diem
to sale date $ 2,667.60
Late charges at $28.75 per month
to sale date $ 115.00
Escrow Deficit $ 2,000.00
TOTAL $122,540.22'
*SALE DATE: WEDS.,DEC. 10, 2003
(PROTHONOTARY'S USE)
Plaintiff
Attorney
Sheriff
This Writ
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue Writ of Execution in the above captioned case.
Date: SeptemiDer 9, 2003
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Leon ~er -
PA I.D. #15700
WRIT OF EXECUTION - MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA :
SS
COUNTY OF CUMBERLAND :
TO THE SHERIFF OF CUMBERLAND COUNTY:
Te satisfy Lhe judgment, interest and costs in the above
captiened case, yen are directed to levy upon and sell the property
described in the a%tached description known as 523 WARREN STREET,
LEMOYNE, PA 17043.
Date:
PROTHONOTARY/CLERK
CIVIL DIVISION
BY
DEPUTY
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Leraoyne in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on the Southwest line of Fr'arren Street, said point being one hundred
fourteen and eight-tenths (l l 4.8) feet Northwest of the intersection of the Southwest line of
Warren Street and the Northwest line of Clark ~reet; said paint being also or~ the dividing line
between Lot Nos. 377 and 378 on the hereinafter menttoned Plan of Lots; thence along said
dividing line, South 60 degrees West, one hundred twenty-five (125) feet to a point on the
dividing line between Lot Nos. 375 and 378 on said Plan; thenc~ along said dividing line North
30 degrees West, fifty-one and fifty hundredths (51.50) feet to a point on the dividing line
between Lot Nos. 378 and 379 on said plan; thence along said dividing line, North 60 degrees
East one hundred twenty-five (125) feet to a point on the Southwest line of Warren ~treet; thence
along the Southwest line of Y/arren Street, South 30 degrees East, fifty-one and fifly hundredths
(51.50)feet to a point, the Place of BEGINNING.
I-IH VING THEREON ERECTED a one and one-half stor~ frame dwelling known and numbered
as 523 Warren Street, Lemoyne, Pennsylvania 17043.
BEING Lot No. 378 on the Plan for Re-Subdivision of Lower Walton Tract as recorded in
Cumberland County Plan Book 3, Page 55.
surveyed by D. P. Raffensperger.4ssooiates, Engineers & Surveyors, Camp Hill,
Pennsylvanic~ by a survey dated.dugast 20, 1980, being Survey NO. 349-90.
ASSESSMENT #12-22-0820-053
BEING THE SAME PREMISES WHICH Norman C. Walker and Julie B. Walker
by deed dated 2/28/02 and recorded in Deed Book 250 Page 2899
granted and conveyed unto Michelle Lockhart.
TO BE SOLD AS THE PROPERTY OF MICHELLE LOCKHART ON CUMBERLAND
COUNTY JUDGMENT NO. 2003 3207.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 03~3207 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA Plaintiff (s)
From MICltELLE LOCKItART, 523 WARREN ST., LEMOYNE PA 17043.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 523 WARREN ST., LEMOYNE PA 17043 (SEE LEGAL
DESCRIPTION).
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
AmountDue $117,757.62 L.L. $.50
Interest TO 12/10/03 ~ $20.52 per deim = $2,667.60
Atty's Corem %
Atty Paid /$180.85
Plaintiff Paid $121.73
Date: SEPTEMBER 10,2003
(SeaD
REQUESTING PARTY:
Name LEON P. HALLER, ESQ.
Address: 1719 N FRONT ST
HARRISBURG PA 17102
Attorney for: PLAINTIFF
Telephone: (717) 234-4178
Supreme Court ID No. 15700
Due Prothy 1.00
Other CostsESCROW DEFICIT -- '1o9,, oO O.
LATE CHARGES $28.75/month ~- $115.00
CURTIS R. LONG
Proth~i~tary
WASHINGTON MUTUAL BANK, PA : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
:
VS. : CIVIL ACTION - LAW
MICHELLE LOCKHART, : NO. 2003 3207
DEFENDANT : IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug &Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 523 WARREN STREET, LEMOYNE, PA 17043:
1. Name and address of the Owner(s) or Reputed Owner(s) :
Michelle Lockhart
523 Warren Street
Lemoyne, PA 17043
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above: SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW):
5. Name and address of every other person who has any record
lien on the property: UNKNOWN
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale: Ui~KNO~R~
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:
TENANTS IF ANY ...
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of 18 PA C.S. Section 4904 relating to unsworn
falsification to authorities.
· . . 700
Purcell, Krug &Haller '
1719 North Front Street.
Harrisburg, PA 17102
(717) 234-4178
DATE: September 9, 2003
WASHINGTON MUTUAL BANK, FA : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
:
VS. : CIVIL ACTION - LAW
MICHELLE LOCKHART, : NO. 2003 3207
DEFENDANT : IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
TIME:
LOCATION:
WEDNESDAY, DECEMBER 10, 2003
10:00 O'clock A.M.
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
523 WARREN STREET
LEMOYNE
CUMBERLi~N-D COUNTY
PENNSYLVANIA
THE JUDGMENT in the amount of $117,757.62 under or pursuant to
which your property is being sold is docketed in the within
Commonwealth and County to:
NO. 2003 3207
THE NAME{S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
MICHELLE LOCKHART
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
'717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL IH. AF C£1tTAIN tract or Parcel oflandandpremises, situate, lytng and betng in tbe
Borough of Lemoyae in the Cou~y of Cuml~rland and Commonwealth of Penneytvani~
more particularly described as follows:
BEGINNING at a point on tbe Southwest line of Warren Street, said point being one hundred
fourteen and eight-tenths (l l 4.8) feet Northwest of the intersection of the Southwest line of
~Farren Street and the Northwest line of Clark Street; said polnt Ming also o~ the dividing line
between Lot Nos. 377 and 378 on the hereinaJter mentioned Plan of Lots; thence along said
dividing line, South 60 degrees ~Vest, one humtred twenty-five (125) feet to a point on the
dividing line between Lot Nos. 375 and 378 on said Pla~' thence along said dividing line North
30 degrees Yfest, fifty-one and fifty hundredths (51.SO)feet to a point on the dividing line
between Lot Nos. 378 and 379 on sald plan; thence along satd dividing linc, North 60 degrees
East one hundred twenty-five (125) feet to a point on the Southwest line of NXarren Street; thence
along the Southwest line of IVarren Street, South 30 degrees East, fifly-onc and fifly hundredths
(51.50)feet to a point, the Place of BEGINNING.
HAVING THEREON ERECTED a one and one~half story frame dwelling known and numbered
a~ 523 ~Varren Street, Lernoyne, Pennsylvania.17043.
BEING Lot No. 378 on the Plan.for Re-Subdivision of Lower Y~alton Tract as recorded in
Cumberland County Plan Book $, Page 55.
surveyed by D. P. Raffensperger g~saciates, Engineers & Surveyors, Camp Hill,
Pennsylvanic~ by a survey dated,4ugust 20, 1980, being Survey NO. 349-90.
ASSESSMENT #12-22-0820-053
BEING THE SAME PREMISES WHICH Norman C. Walker and Julie B. Walker
by deed dated 2/28/02 and recorded in Deed Book 250 Page 2899
granted and conveyed unto Michelle Lockhart.
TO BE SOLD AS THE PROPERTY OF MICHELLE LOCFZqART ON CUMBERLAND
COUNTY JUDGMENT NO. 2003 3207.
WASHINGTON HUTUAL BANK, PA
PLAINTIFF
VS.
MICHELLE LOCKHART,
DEFENDANT :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I h~ye/de~sited in the U.S. Mails at
Harrisburg, Pennsylvania on/~--/J~9 , a true and correct
copy of the Notice of Sale of Real ~state pursuant to PA R.C.P.
3129.1 to the Defendants herein and all iienholders of record by
regular first class mail (Certificate of Mailing form in compliance
with U.S. Postal Form 3817 is attached hereto as evidence), and
also to the Defendants by Certified Mail. Service addresses are as
follows:
Michelle Lockhart
523 Warren Street
Lemoyne, PA 17043
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
PURCELL, KRU~/& HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
NOTICE TO:
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FORECLOSURE DEPT. FAX (717) 234-1206
(7~7) 533..3836
JOSEPH NISSLEY (1910-1982)
ANTHONY DiSANTO
OF COUNSEL
HERSHEy
1099 GOVERNOR ROAD
Michelle Lockhart
523 Warren Street
Lemoyne, PA 17043
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129 1 attached
hereto. ·
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common Pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said
real estate will be divested by the sale and that v
opportunity to ~rotect ,7o~ ~ ...... ,~ e an
said Sheriff's Sale -, D~5~g net~fled of
~Leon P. Ha~fer P~wZI.D.15700
Attorney fer Plaidtiff
WASHINGTON MUTUAL BANK, FA
PLAINTIFF
VS.
MICHELLE LOCKHART,
DEFENDANT
CIVIL ACTION - LAW
NO. 2003 3207
IN MORTGAGE FORECLOSURE
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
pURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
held:That the Sheriff's Sale of Real Property (real estate) will be
DATE: WEDNESDAY, DECEMBER 10, 2003
TIME:
10:00 O'clock A.M.
LOCATION:
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
523 WARREN STREET
LEMOYNE
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT in the amount of $117,757.62 under or pursuant to
which your property is being sold is docketed in the within
Commonwealth and County to:
NO. 2003 3207
is:
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
MICHELLE LOCKHART
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE 0~,'
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE WR?.~, TO BE SOLD OR TAKEN T~
PAY THE JUDGMENT~
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that. has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALI, TH~T CERTAIN tract or Parcel ofland andpremises, situate, lying and being in tbe
Borough of Lemoyne in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNEVG at a point on the Southwest line of Warren ~tr~et, said point being one hundred
fourteen and elght-tenthe (114.8) feet Northwest of the intersection of tbe Southwest line of
Warren Street and the Northwest line of Clark ~treet; said point being also o~ the dividing line
between Lot Nos. 377 and $78 on the hereinafter mentioned Plan of Lots; thence along said
dividing line, South 60 degrees West, one hundred twenty-j?ve (125} feet to a point on the
dividing line between Lot Nas. 375 and 378 on said Plan,. thence along sam dividing line North
30 degrees West, fifty-one and fifty hun~edths (51.50) feet to a point on the dividing line
between Lot Nos. 378 and $79 on said plan; thence along sam dividing line, North 60 degrees
East one hundred twenty-five (125)feet to a point on the Southwest line of Warren Street; thence
along the Souzhwest line of Warren $treet, South $0 degrees East, fifty-one and fifly Imndredtl~
(51.50) feet to a point, the Place of BEGINNING.
~ F~rG THEREON ERECTED a one and one-half story frame dwelling known and numbered
as 523 Warren Street, Lernoyne, Pennsylvania .17043.
BEING LOt No. 378 on the Plan for Re-Subdivision of Lower Walton Tract as recorded in
Cumberland County Plan Book 3, Page 55.
.4~ surveyed by D. P. Raffensperger ~ssociates, Engineers & Surveyors, Camp Hill,
Pennsylvani~ by a survey dated Aug~st 20, 1980, being Survey NO. 349-90.
ASSESSMENT #12-22-0820-053
BEING THE SAME PREMISES WHICH Norman C. Walker and Julie B. Walker
by deed dated 2/28/02 and recorded in Deed Book 250 Page 2899
granted and conveyed unto Michelle Lockhart.
TO BE SOLD AS THE PROPERTY OF MICHELLE LOCK/qART ON CUMBERLAND
COUNTY JUDGMENT NO. 2003 3207.
Re: WAMU v. Lockhart
Cumberland 12/10/03
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comDliance with Postal Service Form 3877)
Received from:
Purcell, Krug &Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Michelle Lockhart
523 Warren Street
Lemoyne, PA 17043
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug &Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
Postmark:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ~ SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Washington Mutual Bank FA is the grantee the same having been sold to
said grantee on the 10th day of Dec A.D., 2003, under and by virtue of a writ Execution issued on the
10th day of Sept, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003
Number 3207, at the suit of Washington Mutual Bank FA against Michelle Lockhart is duly recorded in
Sheriff's Deed Book No. 261, Page 2801.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this cP day of
~ ,A.D2004 ~
Washington Mutual Bank, FA
VS
Michelle Lockhart
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3207 Civil Term
Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states
that on September 22, 2003 at 4:31 o'clock PM, 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: Michelle Lockhart, by making known unto Michelle Lockhart,
personally, at 523 Warren Street, Lemoyne, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states
that on October 10, 2003 at 10:47 o'clock A.M., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Michelle Lockhart located at 523 Warren Street, Lemoyne, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Michelle Lockhart, by regular mail to her last known address of 523
Warren Street, Lemoyne, PA 17025. This letter was mailed under the date of October 8,
2003 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, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for
the sum of $1.00 to Attorney Leon P. Haller for Washington Mutual Bank, FA. It being
the highest bid and best price received for the same, Washington Mutual Bank, FA of
P.O. Box 1169, Dept. 2665, Milwaukee, WI 53201, being the buyers in this execution,
paid to SheriffR. Thomas Kline the sum of $876.82, it being costs.
Sheriffs Costs:
Docketing $30.00
Poundage 17.19
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 22.08
Levy 15.00
Surcharge 20.00
Law Journal 344.45
Patriot News 263.20
Share of Bills 28.90
Distribution of Proceeds 25.00
Sheriffs Deed 40.50
$ 877.82
Sworn and subscribed to before me
This /~ e day of
2004, A.D. ,
Pr6thonotary
So Answers:
R. Thomas Kline, Sheriff
Real Estate ~bputy
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ac~ No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 816 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mamh 4th,
1854, and September 18th, 1949, respectively, and all have been continuousJy published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/Metro editions which appeared on the 28th day(s) of October and the 4th and 11th
day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication 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 stockhoJders 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.
MyCommissionExpiresJune-6,20~ ~ '~N~TA~Y P{UB~L;~~'~-
Member, Pennsylvania AsSOda~on Of Notaries
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Total $ 263.20
Publisher's Receipt for Advertising Cost
:o., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
dge receipt of the aforesaid notice and publication costs and certifies that the same have
By .............................................................. , .....
~t~. Re-
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L. 1784
STATE OF PENNSYLVANIA :
_.
COUNTY OF CUMBERLAND :
SS.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly 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 17, 24, 31, 2003
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE ~ALE NO. 60
Writ No. 2003-3207 Civil
Washington Mutual Bank, FA
VS.
Michelle Lockhart
Arty,: Leon P. Hailer
ALL THAT CERTAIN tract or par-
cel of land and premises, situate, ly-
ing and being in the Borough of
Lemoyne in the County of Cumber
land and Commonwealth of Penn-
sylvania, more particularly described
as follows:
BEGINNING at a point on the
Southwest line of Warren Street,
said point being one hundred Ibur-
teen and eight tenths {114.81 feet
Northwest of the intersection of the
Southwest line of Warren Street and
the Northwest line of Clark Street:
said point being also on the divid-
ing line between Lot Nos. 377 and
378 on the hereinafter mentioned
Plan of Lots: thence along said di-
viding line, South 60 degrees West,
31 .day of OCTOBER, 2003
LOIS fi. SNYDER, Notay Public
Cadisle Boro, Cumberland County
My Commission Expires March $, 2005
teen and eight-tenths (114,8) feet
Northwest of the intersection of the
Southwest line of Warren Street and
the Northwest line of Clark Street;
said point being also on the divid-
Lr~g line between Lot Nos. 377 and
378 on the hereinafter mentioned
Plan of Lots: thence along said di-
,riding line. South 60 degrees West.
one hundred twenty-five (1251 feet
to a point on the dividing line be-
tween Lot Nos. 375 and 378 on said
Plan: thence along said dividing line,
North 30 degrees West. fifty-one
and fifty hundredths /51,501 feet to
a point on the dividing line between
Lot Nos. 378 and 379 on said plan.
thence along said dividing line.
North 60 degrees Bast one hundred
twenty-five (125) feet to a poil~t on
the Southwest line of Warren Street;
thence along the Southwest line of
Warren Street, South 30 degrees
East, tifty-one and fifty hundredths
(51.501 feet to a point, the Place of
BEGINNING.
HAVING THEREON ERECTED a
one and one-half stoW frame dwell-
ing known and numbered as 523
Warren Street, Lemoyne, Permsyl-
vania 17043.
BEING Lot No. 37'8 on the Plan
for P~:Subdiviaion of Lower Walton
Tract as recorded in Cumberland
County Plan Book 3. page 55.
AS surveyed by D. P. Raffens-
perger Associates, Engineers & Sur-
veyors, Camp Hill, Pennsylvania, by
a survey dated August 20. 1980.
being Survey NO. 349-90.
ASSESSMENT #12-22-0820-053.
BEING THE SAME PREMISES
WHICH Norman C. Walker and
dulie B. Walker by deed dated 2/
28/02 and recorded in Deed Book
250 Page 2899 grartted and con-
veyed unto Michelle Lock-hart.
TO BE SOLD AS THE PROP-
ERTY OF Mlchelle Lockhart on
Cumberland County Judgment No.
2003 3207.
l My Comm~on ~-~q3lre$ ~