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SHERIFF'S RETURN - NOT FOUND
` CASE NO: 1999-05472 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF AMERICA FSB
VS.
HUNT JEFFREY C 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: HUNT JEFFREY C
but was unable to locate Him in his bailiwick. He therefore returns
the REINSTATED COMPLAINT MORT/FORE
NOTICE
NOT FOUND as to the within named defendant
HUNT JEFFREY C
DEFT. NO LONGER RESIDES AT ADDRESS STATED
RETURN NO FOUND AS PER ATTORNEY 11/3/99.
Sheriff's Costs: So answers
ers:
Docketing 18.00 /
Affidavit 6.00
Surcharge 8.00 iJI; om in er
$3TZ0 11/031999 UG & HALLER
Sworn and subscribed to before me
this ee day of /?.,...1?•_
199_ A.D.
-`?(2.g'"
BANK OF AMERICA, FSB
Plaintiff
VS.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. Q9 - S.VrIA ?i r? ?er/Y1
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
-(? I'® &P 9, 19
N O T I C E
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 claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A 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 Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S 0
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SO 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 SO 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 DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
TRUE (,.npv )-r?neA REOOM
p? ,? ...; . ,to yet (mykw
Aisle
BANK OF AMERICA, FSB : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PEN14SYLVANIA
VS.
NO.
JEFFREY C. HUNT AND JUNE L.
HUNT CIVIL ACTION - LAW -
Defendants IN 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 within 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
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BANK OF AMERICA, FSB
Plaintiff
Vs.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, BANK OF AMERICA, FSB, is a Delaware
corporation, with an address of PO Box 26388, Richmond, Virginia,
23260-6388.
2. Defendant, JEFFREY C. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055. Defendant, JUNE L. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055.
3. On or about October 30, 1992, the said Defendants
executed and delivered a Mortgage Note in the sum of $82,039.00
payable to MARGARETTEN & COMPANY, INC., which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds office of the within County and
Commonwealth in Mortgage Book 1098, Page 641 conveying to
original Mortgagee the subject premises. The Mortgage was
subsequently assigned to BANK OF AMERICA, FSB and recorded in the
aforesaid County in Mortgage Book 502, Page 3 on August 15, 1995.
Said Mortgage and Assignment are incorporated herein by
reference.
• S. The land subject to the Mortgage is: 349 SPORTING HILL
ROAD, HAMPDEN, PENNSYLVANIA 17055 and is more particularly
described in Exhibit °B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on December 1,
1998 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 75,537.00
(b) Interest at $15.52 per day
from 11/1/98 to 10/1/99
(based on contract rate of 7.500%) 5,183.68
(c) Accumulated Late Charges 112.06
(d) Late charges at $28.85
per month for 11 months 317.35
(e) Escrow Deficit 225.56
(f) 5% Attorney's Commission 3,776.85
$ 85,152.50
*Together with interest at the per diem rate noted in (b) above
after October 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
z
r
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. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. Plaintiff has complied with the procedures required by
a
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
?t
' Assistance Payments Program) and Defendants have either failed to
meet the time limitations as set forth therein or have been
z, determined by the Housing Finance Agency not to qualify for
assistance.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.500k ($15.52 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL, KRUG HALLER
By - %??j
Leon P. Halle
Attorney for Plaintiff
Z.D. #15700
1719 N. Front Street
Harrisburg, Pa. 7.7102
(717) 234-4178
a6.I w:I.!
ADJUSTABLE RATE NOTE
17304145
349 SPORTING HILL RD. HAMPDEN, PA 17055
L PARTIES
'Borrower' name aa2 puss aping at the I= of thp Note, and the par m's anocaaora and sedgy,
otma
Margaretten 6 Company. Inc.,
corporation organized and existing under the laws of the State of
ad It, saomsaon and a nt2na.
New Jersey
L BORROWER'S PROM= TO PAY1 INTEREST
In resam fm a ism received from leader, Sommer promises to pay the principal mace of
DcnEi-g(Uhty- S T02, 039VDond, Thirty-
.Plwhtmu,totheno?oL lIead r. WmeowMboewtWmmpid
primJpal, Dom do due of disbursement of the loan proceds by Linder, at a run of
Six 6 One-Half
partner ( 5 1/2 %) per your. The interest race may change in cordsoro with Paragraph 5(0
of this Now
3. PROMISE TO PAY SECURED
Iwnoeees'e promise to Pay Is would by a monpye, dead of cwt or similar aeanity instrument died is dated the same
date u desNote ad called the'Seturity L2Am L' That Security Wtinmetpraena do Leader faamImes wbichmipht
re alt If Boren wr defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower dull male a pymad of principal sod intense to leader m the fwd day of acb moth beginning ea
D1??e due 1?, 2•'1°P Principal seal Waal mmaWnt mOu fire dry of November 2022 '
wag is called the maouity data.
(B) Place
Psymed"be taade at Ona Ronson Ro d, Ise7 1 New Jera 088 0
(C) Amount or u aW ol?ar Pima a Im`r my daq rtYv tftly codes to Resonant.
Initially, each moo WyEPaymetof principal and interim will be In the season of S 518.54
pThin iimwntN I1?6sred ofiw3easm . and 54 1,0
y payment"by the Security instrument don "be applied apriodpai,
Intere d ad other in= in do order described in the Security Inhuman. This amount may deep in second aoaa wish
Pwgnpb 3(B) of Win Nona
S. WERESf RATE AND MONTHLY PAYMENT CHANGES
(A) Clangs Data
The intact rate may chug ou Ibe first day of J near9 1yg` . and m that dry of sash memasdiag
year. 'Chap Dab' Imes ved date on whkL oe to?steu JAMS.
(B) The buie e
Beginning with do Bm Clap Dam, the InWest ram will be band m a Ions. "Sedate toms the wady swop
yield m United Stems Trans" Semritir xUvaad to a constant maturity of am year, a made available by do Faded
Reserve Board. 'Cnnml Enda' mess do aced racsal lndet figure available 30 dap before des Chop Dar. Hthe l dse
(a dafimd above) is on longer avilable, Leader will on, a a over Indos my iada pracdbed by do SsaMary (a ddind
in Paragraph 7(B)). Leader will give Borrower anion of Ilea now, Indent.
(C) Calculation of Intend Res Charges
Before ouch Chap Dean Lander wiU cd=lw a mew icterat ne by adding a margin of
Two
percentage points ( %) to We Correct te'dac and rounding the mom to the csrm osaeWhth of me
percentage point (0125%). Sub)ea a the idmlra stated io Paragraph 5(D) of this Note, this vended s mnt will beIhs raw
interest ran until the cost Chop Nits.
FHA MUL713TATS ARM NOTE
MAR-730 FA0t1Ora Iaf0
nu cr. xe.
441-4501712-704
October 30th, 1992
rwwwa
W
(D) Limits on Interval Bate Chs4' aterad lba no
i will last cab ab owill ver v be more d an flddecrew by mm ,hen con pamebp Pohl (1.0%) m my single Chmp Doe.
in paragraph 2 of Oda Nob, Procurator point, (5.0%) higher w inure then the Wild beet ram need
(E) Ca)eulaUou of paymart Chaw
informed If the Lena rata change m • mop Dam, Lander will calculate the amount of onoWly Palmer of Principe, and
mroughwhich would be aaneuuy to may do unpaid principal bebooe In NU at the wmnlty dam If the new inte ms rate
he owdmthe Yequel pymmte. In meting such calculation, Landerwin me the mpaidprmcipal balance which would
to Chanp Dab ifthen hod bee no default inpsymmat on the Nob, radwasol by mho mount ofany pnpymanb
Mbdpd. The result of Odr nlculadon will be the am= of the new monthly payment of principal and to tra4
(p) Notice or Clrarrgm
Lander will give notion b Bmrowm of any change in the intend rate end mouthly psymmt amount There nctim met
b
the e Sim at lean u days befen the new, ninthly payment amount Is duo, ad eon ad forth the time of the Dolm. (H
d Cand fathDe e, OW she old famed rate, (n) the new icemen rate, (v) the mw mmthtypaym ur smmmt, (vi) the Curmat
which published, (viQ the method of pl?+dat am champ in moaddy payment mom m,. and (viii) my
other ds land the doe it was
In
(G) Effective Dam of Change by law foe tiob to time.
A new, interest rate olculaud in amordsne with Penpapho S(C) ad S(D) of this Note win become eNxtive ou the
tamp Dam. Bonoev ahan mdm a paymmt in Ote mw thlyamormrbegbningouthe funPaymmr dam which ocuun
stIron 2S days after Lender hen given Burrower the notice of chmpm ngotrad by paragraph S(P) of this Note. Borrower
ahaB have co obilgation to m bsmmm in the mmWly payment amount calculated in ratimdaoo with Pungraph S(E)
of this Nob fm m due occumog Im than 25 days after Laude has iii the payment summer calculated in smordmre withPanpaph S(B) of this Nate decreased. required MUto Sil" M If timely e mootim
of the derneaae and Burrower cede any notably payment amoaob mfg g thbid Lender failed which should base
Mood in a timely notion. tlm Borrower bar the option to elates 0) dewed the e the retme pa py to mmt e amount m hould d ban hem
with interest thercoo at the Nee cab (a cab equal to to M° been sou of a encm payment,
Car) request Out m mceer heaven ram which should have b beeen amid iOpagot n), m
my payment, with inmost w therma al on demand Now rata be applied payment of • of principal. LeoderY
beobligaforetion
_ pay the demand foryietum is mde. r with know on demand is not uaigmble cute if this Nola is otherwise aasipd
6. BORROWER'S RIGHC 70 PREPAY
Borrower bar the right on Pay the dean evidenced by this Nom, in whole or in put, without ciurge or penalty, on "T
firm day of my mouth.
MA MMTWAfE ARM NOTE
MA147343 PAGE 2 OY3 (9ral)
Ox
7. BORROWER'S FAILURE TO PAY
(A) Late Chap fa Overdue Payments
If Leader has ant received the full enothlypayment required by the Security foWOmmt, u decdbd In P&MI 4(L)
of this Note, by the and of fifiam calm is drys filer the payment Is due, {order my colleen a hear Chute In the amermt
of Four percent ( 4 B) of the overdo ammnt of each pqm
(B) III
If Bortauer defiufts by fellioS o pay in full soy mmtidy payment, then f.mder my, map a Iloilted by re` hshow
of the Bammry in the ase of payment defaalte, requirs immediate payment in kU of the pdndpsl bdmm
and All accrued inMMBL I my chocm not to eaucim ibis option without wdviep its does in the?m
of eda
Nbsequmt dalWIL This NOW door net mthdm mminWm when ant Permitted by HUD regulations. As Used in this
Now, 'Smratsry' mace the Secretary of Hearing ad Urban Development or his a her dedra s.
(C) Payment of CCs and Exporter
If Leader her mgWred Immediate payment in full, n described shove. Lender my regalra Barownt to pay costs ad
enpen including reasonable and customary ammy's fsm for =forcing this Note. Such face and coast shill btu instead
from the date of dieWmmmt at the sams rate m the principal of this Note.
S. WAIVERS
Borrower ad my other peron who ism obligation under this Note waive the rights of pra===t and ontics of
dishonor. 'Pma brawl =cep the right to require Lmdr to dwmd payment or moo=s due. 'Notion of dishoa'
mace-- the right to require Leader to give mtise to other Anon that amounts due have not bem pdd.
0. GIVING OF NOTICES
Unless applicable law requires a different m I my when that oast be glum to Borrower order this Note will be
given by delivering it or by milling it by find than mail to Borrower at the poppy address above a at a different ddres,
if Borrower has Sim Lander a notice of BarrnwerY different Whom.
Any notim that moat be Sian to fader under this Note will be Sim by fuel rims mail to Iadu "the ddsu scud
in paragraph 4(B) or d a different addrm if Basoeer it Sim a Maw of that diffma ad&=.
10. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If mom than ow Peron elga this Note, euh Person Is fully aW Penomlly obligated to Isep all of the promises made
in this Non, including the promLso an pay the full amount owed. Any Peron who is a gossamer, many or rodosm of 60
Nola is 0110 obligated n do those III Any Parent who takes over these obliptima, including the obiiptims of ¦
parmror, minty a indorser of this Non, is also ollfgded to keep all of the promises made in this Nun. Lendermav
enfam is rights Under Wb Note agdod each pe. lndlWduanyormgdntdlsip odcekipew. Any-per sigdng
this Non my be required to pay all of the amermts owl under "Note.
BY SIGNING BELOW, borrower accepts and agrees to the term and envmmts contained in this Nam.
WITNESS /d 3?ed
C NUNT
t e? --------- 9JU ILL46911a
MW RECOURSE PAY TO THE OOM
BANK OF AMERICA, FSB
MAR R„ 'eco PAD NC.
BY: I
TTTLE Stf112MLSafdaneAWtSecretary
pAy WnNOUT RECOURSETUTHE ORDER OF
NK OF AMERICA, FRB
MA MULTITME ARM NOR
MALI PACE 3 Mg ant)
EXHIBIT A
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, southwardly, 60 feet to a point at-'the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAVING THEREON ERECTED a dwelling house.
BEING THE SAME PREMISES which Walter F. Zielonis and Margar-
et Zielonis, also known as Margaret R. Zielonis, his wife, by
their Deed dated 00-06F93 U, 1992, and recorded immediately prior
hereto in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, granted and conveyed unto Jeffrey
C. Hunt and June L. Hunt, husband and wife, Mortgagors herein.
i06kjo98 PACE 645
„ n
?/?(?
C08PARY MM: BANK OF AMERICA, FSB
I verify that the statements made in the foregoing Complaint
are true and correct.
I understand that false statements herein are made subject
to the penalties of 18 Fa. C.S. Section 4904 relating to uneaorn
falsification to authorities.
Dated: PL= 31, 1999
ay vonvonne a ea erger
Aaei
Title stant Vice President
OFFIarnF ^Ilr!!IFF
CUP t
OCT ZS 48 PM '99 L?R
f E It ; i •;; ;" L Y:;ri 1;1
BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
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 JEFFREY C. HUNT AND JUNE L. HUNT 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 $75,537.00
Interest $ 5,183.68
(Per diem of $15.52
from 11/1/98 to 10/1/99)
Accumulated late charges $ 112.06
Late charges $ 317.35
($28.85 per month to 10/99)
Escrow Deficit $ 225.56
5% Attorney's Commission $ 3,776.85
TOTAL $85,152.50**
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and other
charges and costs to the date of Sheriff's Sale.
PURCELL, KRUG & HAL
i
By -
Leon P. Haller PA I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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BANK OF AMERICA, FSB,
PLAINTIFF
vs.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R C P 237.1
I hereby certify that on FEBRUARY 16, 2000 I served the Ten
Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
By
Leon P. Haller A I.D. #15700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
BANK OF AMERICA, FSB : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 1999-05472
JEFFREY C. HUNT AND JUNE L.
HUNT : CIVIL ACTION - LAW
Defendants : IN MORTGAGE FORECLOSURE
DATE OF THIS NOTICE: February 16, 2000
TO: JEFFREY C. HUNT
211 ASHFORD PLACE
POINCIANA, FL 34758
JUNE L. HUNT
506 EAST ELMWOOD AVENUE
MECHANICSBURG, PA 17055
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM 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:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
PURCELL, KRUG & HAL
CC: James M. Bach, Esq.
352 South Sporting Hill Rd.
Mechanicsburg, PA 17055
By
Leon P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
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' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption: ( ) Confessed Judgment
BANK OF AMERICA, FSB, ( XX) Other IN MORTGAGE FORECLOSURE
PLAINTIFF
File No. 1999 - 5472
vs. Amount Due S 85,152.50
JEFFREY C. HUNT AND to $15.52, $ 3,848.96
JUNE L. HUNT, ?% /17 1
DEFENDANTS Late chargea$28.85 $ 201.95
F&scrcw Deficit $. 2,000.00
osts
TO THE PROTHONOTARY OF THE SAID COURT: Total $ 91 203.41
Pius costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cuurberland County,
for debt, interest and costs, upon the following described property of the defendant(s)
Real estate: 349 Sporting Hill Road, Mechanicsburg, PA 17055
IN MORTGAGE FORECICSURE
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND 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)
REAL ESTATE: 349 Sporting Hill Road, Mechanicsburg, PA 17055
REAL OWNER: Jeffrey C. Hunt and JNne L. Hunt
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)
defendant(s) described in the attached exhibit.
MAR G 6 M
Date Signature:
as a lis pendens against real estate
Print Name: Leon P. Haller, Esquire
Purcell, Krug & Haller
Address: t ?i 9 °rcmt Street
Harrisburg, PA 17102
Attorney for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ID No.. #15700
(over)
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (Pa R.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, southwardly, 60 feet to a point at the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAVING ERECTED THEREON a dwelling known as 349 Sporting Hill Road,
Mechanicsburg, PA.
BEING THE SAME PREMISES WHICH Jeffrey C. Hunt and June L. Hunt by
deed dated January 11, 1999 and recorded January 25, 1999 in
Cumberland County Deed Book 193 Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO BE SOLD AS THE PROPERTY OF JEFFREY C. HUNT ON JUDGMENT
NO. 1999 05472.
TAX I.D. 10-22-0525-060
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BANK OF AMERICA, FSB, . IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
JEFFREY C. HUNT AND NO. 1999 CIVIL 5472
JUNE L. HUNT,
DEFENDANTS 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 349 SPORTING HILL ROAD, MECHANICSBURG, PA
17055:
1. Name and address of the Owner(s) or Reputed Owner(s) :
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
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):
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
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:
UNKNOWN
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
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Bach, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
(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 relatin o unsworn
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 3, 2000
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BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
held: the Sheriff's Sale of Real Property (real estate) will be
DATE: WEDNESDAY, JUNE 7, 2000
TIME: J0:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
349 SPORTING HILL ROAD
HAMPDEN TOWNSHIP - MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 1999 05472
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
JEFFREY C. HUNT AND JUNE L. HUNT
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` be filed by the
Sheriff of thts County thirty (30) da-:s after the sale and
distribution of the proceeds of sale 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 Dis_r_buticn may be obtained
from the Sheriff of the Court of Common Plea= 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 -,.r 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 17,013
717-243-94 00
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 ir. 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 th-- Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Ccurt.
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
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LEGAL OESCRI?T:ONT
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a pcint at the Easterly side of Sporting Hill
Road, which point is 575 fee= southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
:fps. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing lire, southwardly, 60 feet to a point at the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 113.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
cu:vcng to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEINC Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42,
HAL'=NG ERECTED THEREON a dwelling known as 349 Sporting Hill Road,
Mec?anicsburg,
BEING THE SAME PREMISES WHICH Jeffrey C. Hunt and June L. Hunt by
deed dated January 11, 1999 and recorded January 25, 1999 in
Cumberland County Deed Book 193 Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO 3E SOLD AS THE PROPERTY OF JEFFREY C. HUNT ON JUDGMENT
NO. 1999 05472.
TAX I.D. 10-22-0525-060
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BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
RELIEF FROM STAY
UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
JEFFREY C. HUNT
BANKRUPTCY NO. 1-99-00864
Debtor
CW*TER..7
BANK OF AMERICA, FSB
•F.:.:.
Movant J Ral -Mi.
VS.
JEFFREY C. HUNT and
MARKIAN R. SLOBODIAN, Trustee ?-
Respondents yc:urt
r
DEFAULT ORDER ON MOTION FOR RELIEF FROM STAY
This -A day of 1999, upon default,
no response or objection to the Motion having been timely filed by an
interested party, it is
ORDERED that the above captioned Motion is granted insofar as it
requests relief from the automatic stay imposed by 11 U.S.C. 5362.
BY THE COURT:
Robert J. Woodside
United States Bankruptcy Judge
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BANK OF AMERICA, FSB
Plaintiff
VS.
JEFFREY C. HUNT AND JUNE L.
HUNT
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99-5472 CIVIL TERM
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
#tRisocipy
COURT OF COMMON PLEAS OF CUMBERLAND COLE R 7 JE j)
r JUDICIAL DISTRICT ??
COMMONWEALTH OF PENNSYLVANIA AAA
AFFIDAVIT OF SERVICE OF PROCESS
BANK OF AMERICA, FSB NO.
Pwrdff
CIVIL ACTION - LAW
versus IN MORTGAGE FORECLOSURE
JEFFREY C. HUNT AND JUNE L. HUNT
Defendmt
Know all persons by these presents that I, A616 _ y M - C it /hP , was assigned to duly
execute this service upon the following defendant: JEFFREY C. HUNT at 211 ASHFORD PLACE
POINCIANA. FL 34756. I hereby depose and say:
1) That I am of the necessary age and sound mind to execute said service.
2) That I am not a party to the action or have any interest in it. -
3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private
investigator.
I hereby certify that on 1 1- Z9 - 4 4 at approximately 1945 Oa.m. m. a true and coragct
copy of the COMPLAINT IN MORTGAGE FORECLOSURE were served on the above-named
party or witness In the following manner.
X I personally delivered them into the hands of the person to be served.
? By leaving a copy at his/her usual place of abode with whose.
relationship to the defendant is and who Is of suitable age and discretion
and also residing therein.
? By leaving a copy with the manager/clerk of place of lodging in
which defendant resides.
? By leaving a copy with the agent in charge of defendant's office or
usual place of business, Job title or position of agent is
? Auer due and diligent efforts, described below, I was unable to serve the process
nWHOlon of Raelple t:
Sex: _ ,_ Race: C -e u . Approximate Height JTjJ n ppmmiete weight M Approximate Ago: _Lt
FURTHER AFFIDAVIT SAYTH NOT.
Subscribed ands 9m to before me this
g re of Pro se erver day of AVY A , 1999.
Notary Public
IDA L. WATFOAD
MY t:OaMaegNI ce641M
E,XPgEB: hey 11, 2001
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BANK OF AMERICA, FSB
Plaintiff
Vs.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
THIS LAW FIRM IS A DEBT
TO COLLECT A DEBT OWED
OBTAINED FROM YOU WILL
COLLECTING THE DEBT.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. q 9 . Sv ?,z ?ti :l TG,--
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COLLECTOR AND WE ARE ATTEMPTING
TO OUR CLIENT. ANY INFORMATION
BE USED FOR THE PURPOSE OF
N O T I C E
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 claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A 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 Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S O
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA CENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU 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 DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLF.VE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
BANK OF AMERICA, FSB : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO.
JEFFREY C. HUNT AND JUNE L.
HUNT CIVIL ACTION - LAW -
Defendants IN 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 within 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
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BANK OF AMERICA, FSB
Plaintiff
VS.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.5Y7.2 7t,
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, BANK OF AMERICA, FSB, is a Delaware
corporation, with an address of PO Box 26388, Richmond, Virginia,
23260-6388.
2. Defendant, JEFFREY C. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055. Defendant, JUNE L. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055.
3. On or about October 30, 1992, the said Defendants
executed and delivered a Mortgage Note in the sum of $82,039.00
payable to MARGARETTEN & COMPANY, INC., which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds office of the within County and
Commonwealth in Mortgage Book 1098, Page 641 conveying to
original Mortgagee the subject premises. The Mortgage was
subsequently assigned to BANK OF AMERICA, FSB and recorded in the
aforesaid County in Mortgage Book 502, Page 3 on August 15, 1995.
Said Mortgage and Assignment are incorporated herein by
reference.
5. The land subject to the Mortgage is: 349 SPORTING HILL
ROAD, HAMPDEN, PENNSYLVANIA 17055 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on December I,,
1998 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 75,537.00
(b) Interest at $15.52 per day
from 11/1/98 to 1011199
(based on contract rate of 7.500%) 5,183.68
(c) Accumulated Late Charges 112.06
(d) Late charges at $28.85
per month for 11 months 317.35
(e) Escrow Deficit 225.56
(f) 5% Attorney's Commission 3,776.85
$ 85,152.50
*Together with interest at the per diem rate noted in (b) above
after October 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No 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. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, so
amended.
11. Plaintiff has complied with the procedures required by
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and Defendants have either failed to
meet the time limitations as set forth therein or have been
determined by the Housing Finance Agency not to qualify for
assistance.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.500% ($15.52 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL, KRUG l HALLER
By
Leon P. Halle
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
17304145
ADNSTABLE RATE NOTE
PRA C. Na.
441-4
October 30th, 1992
349 SPORTING HILL RD, HAMPDEN, PA 17055
1. PARTIES
.Bm mover' "' each Pawn sping At the it= of this NOW and the parson's Nannesnra and NwVu. 'Ienda'
Margaratten b Company, Inc.,
corporation organized and existing under the laws of the State of New Jars
and its successors and assps. ey
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a low received from Lender, Borrower Freedom to pay the principal anm of
Eighty- Two Thousand, Thirty- Nina and 00 100
Dollars (U.S. S 82,039.00 ), Plus burned, to the order oKander. Interact will be charged an unpaid
PrindPRI, from the dote of disbursement of the tom proceeds by Isuder, at • rate of
Six 6 One-Half
t0lNote.6 1/2 R) Pa ymr. The interest two may deals in wmntmce with Paragraph 5(C)
oPa c
this
3. PROMISE TO PAY SECURED
Horrawr's promise m pay is secured by a mortgage, deed of trod or similar security mstrumont that is dated the ume
date u this Notead called the'Setudty Instrument. ' That Security Instrumentpmtwta the Lander from lomuwhich might
result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Bonowar shail Duke ¦ payment of Principal and interM to I.anda an the firstday of each month beginning an t
December 1st, 1992• Any Principal and intend remaining an the fird day of
will be due an that date, which is Called the maturity dn. November 2022
'
(B) Plano
PayeautdWlhemudeet One Ronson Ro d, Is• i Newdmgnar u! Jer •y OS890
or at weh ot?er Flsee u may wnbeg oy nation to Borrower.
(C) Amami
Initially, each monthly payment of principal and interest will be in the Amami of $ Five Hu aired JI% teen and 54/10 518.54
This emamt w II 6e pan o u uryu mouthly psyment niqui by the Security Instrument that" be applied to principal,
interest and other items in the order dumbed in the Security Imemmunt. This Amount may change in umrdmon with
Paragraph 5(13) of this Nota
S. INTEREST RATE AND MONTHLY PAYMENT CHANCES
(A) Change Data
ran interest rate may chap an the fad day of J nua r 1 . and an that day of each succeeding
year. 'Change Date' means each date on which the m&nu2.rend c0h p.
(B) The Inds
Beginning with the firer Charge Data. the intend rate will be bead an an lams. 'Index' mums the weddy average
yield an United Stage Trewry Securities adjusted to a coastal maturity of we year, u made available by the Federal
Reserve Board. 'Curmat Indn' mans tba moo racmt Index figum available 30 days befom Mn Charge Due. If the idea
(u defend above) is an longer milable, Lender will stun u a new Index my idmt pmo nyd by the Secretary (u defined
in Paragraph 7(B)). I.a will give Borrower notion of the new Index.
(C) Calculation of Intend Rae Changes
Before each Change Daft, Lender will calculate a new intamt rate by adding a magic of
Two
petcmta fe Points ( 2 in the Curtest led= and rounding the sum to the mums: ow-eighth of am
percentage point (0.175;6). Subject to the limits staid in Paragraph 5(D) of this Note, this rounded Amami will be the now
interest ran until the nut Chap Dlte.
Erh/b r
FKA MULTISTATE ARM NOTE f? ,
MA1413m PAGE IOF3 0191) w,R.??„7
P Units on Interest Rate Chary" .
The interest ado will aver I=- or dearnu by non tbu as pre 'UP Point (1.011) a sty lolls Chop Date.
The interest rate will sever be mm Ihas five pa
in Pantnph 2 of this Note. aotop Points (1.0%) WOW Of lower Wu the Initial intreal
a me sated
(E) CdtWatlon of Payma t Chary,
If the I., raw chant" an a Chap Dale, Lander will alulaa dal anamna of motdhly pymat of prhwpl std
interest which would be exaay to rally the apald prledpal lawn, in lull at do n nAry dale a the new Wines w
brit
owed an h su6 totiallyqul pymats. to nuldn/ vA abule0a, leads WII ua 0a WPW plalpl bdua which woWd
Chun Due If than bad but an default In psymrnt an the Note, reduced by do asnat of my Pmpymau
to
Pflocipal.
o mulryu this alulWm will be der amount of the stew mootbly pymat of Pdodpd ad Interest.
(F) Notl
ce or am
I andu will tin Doti" to Borrower of ay duap Is du lethal nle ad monhly payment emmm. The and" soul
be Jim at lead 21 days before The saw onaddy raymnl amanl Is M. and mats on forth (I) the dab of the ado" M
Ile Chap Date, (III) the old wleral nor, (Iv) ON new, tearest rate, (v) the raw malhly Psym of amoum, (W) We Comm
Indu ad the date It was published, (vil) the medical of alonlatwt the chop to mosWy paymat amount, and (vfti) my
other information which may be requlnd by law from Ilene to fife.
(G) Plfactlve Dale of Cheryl
A new, intern ale alulated u aaordaoce with Parynpbs /(C) ad 1(D) of this Note will baoome affective an the
Coup Dm. Borrower ahml subs s phenol is Ih ate euWly auane blladat an the fine pya at des which ocean
a last 25 days after Leader bu diva Borrower IM Moth of Jaya "In! by Pares"h 1(L) of Ibh Note. Borrower
of IWb Neste for apda to pay my immas In 04 conoWy pysfn ataal aloulud in aaadasa with Psnynph 1(L)
Y paynfe dale ocounlnt laws dare 21 days after Leader br Ilea do raquired action. If the monthly
paym at an runt allulatd in accordance with PuMnph 1(B) of Wla Now duraued, ben Lander filled to tie doodywta
of the decraaa and Borrower mada my madbly peye al usmis aadwt tin payment Sams t which should have bas
stated in a dandy msla, than Bonowvr W der option to altbor (1) dandy dal anus to Borrower of my seams paym m,
w
ith inlerut theme at the Note raw (a isle equal to the letered me wbleh obould haw ben stated in a tinaly coda), or
III)
obeli sq oio t rarest my small with Interval Uwe" a We Note rate, he swirl u pymnt of principal. Lenders
Y uaas psynunl with InterM as defied Is rest saaltable even If this NW Is othmm" swiped
before the demand for mmm Is mdse.
G' BORROWER'S RIGHT TO PUPAY
Borrower hu Won d1W to Pay der debt aidemad by Ibis Nme, in whole or to pre, vAth at cl arp or Penalty, an tq
fins dry of ay mnIb.
aeon MULTIPfAT[ ABM NOT[
MU-7143 PAOL1 O?e 01911
nx
7. BORROWER'S FAILURE TO PAY
(A) Late Charge for Orerd ere Paymets
If yonder has not received the full monthly Payment rtquhod by ON Security homm eat, a drMbed in Paragraph HC)
of this Now, by the and of fift m calendar dap after the payment is due, Lender my culled a late ehur in the amoant
of Four Pemmt ( d R) of the overdue amamt of each paymmL
(B) Default
If Bona ver defaults by falling to pay in full my mouhly payment, then lender my, except as limited by regntations
of the Secretary in the eras of payment defaults, require immediab Payment in full of the principal bahum remakins dm
and Ali accrued interest. Leader may choose not to mucis this option without waiving its rights in the event of my
subsequent default. This Nom doa am authorise swelalation when out Permitted by HUD roplatians. As used in this
Note, 'Sacmury memo the Secretary of Housing and Urban Development or his or her desigoa.
(C) Payment of Colts and Expmw
If Lender has required immediate payment in full, a described above. Lender my require Bononer to pay eons and
expense including reasonable and customary attorney's fees for ealiming this Nom. Such fns and aura shall bee Internet
from the dam of disbursement a the ante ram as the principal of this None.
8. WAIVERS
Borrower and my other person who has obliptiom under this Now waive the rights of presentment and cline of
dishonor. 'Presentment' meant the right to require Leader to demd Payment of amounts dw. 'Notion of dishonor'
mss the right to squire Lander to give notice to other persons that amamts des have not been paid.
9. GIVING OF NOTICES
Unless applicable law mpdm a different method, my notice that must be Sim to Bosoem urine this Nom win be
given by delivering it or by mailing it by find clan mail to Bommror at the property addmm above or at a diffgmt address
if Bomwu has given Lander a notice of Borrower's different address.
Any nodw that most be given to Loader under this Nino will be givm by first class mail told at the address rated
in paragraph e(B) or 9 a different ddrta if Borrower is given a notice of that different ddrm.
10. OBLIGATIONS OF PERSONS UNDER TIES NOTE
If mre than me person sips this Nate. each person is fully and pe soslly obligated to Imep all of the premiss made
in this Nom, including the promise to pay the toll amount owed. Any person who is a pasnmr, surety a mdoner of this
Nom is also obligated to do them things. Any peso who treks over them obilgdos, including the obligations of s
guummr, surety or mdoar of this Now, is also obligated to keep all of the promises made in this Now. Lender
eafom its rights under this Note against each person idividaallyoragaimt all signatories together. An 7j
this Nos mbe yonefKf°0dsigma
y required to pay all of the amomts owed under this Nom.
BY SIGNING BELOW, borrower accepts and agras to the term end covenants cumisd in this New
WITNESS
? ? ?d 9c 4a
4JU ---- - ? ------ L ?NT
OWff 1 11T RECOlAiBE PAY TO THE OR"
0 F BANK OF AMERICA, FSB
MAR R 0-f 00 PAD NC.
BY; 'n
LE Susan E.Cardone Ass" Secrotary
PAY WITHOUT RECOURSE TO THE ORDER OF
NK OF AMERICA, FSB
IBA MN.TWATE ARM NM
MAx•7103 PAGES GPS (5191)
EWIIBIT A
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, southwardly, 60 feet to a point at-'the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly Bide of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAVING THEREON ERECTED a dwelling house.
BEING THE SAME PREMISES which Walter F. Zielonis and Margar-
et Zielonis, also known as Margaret R. Zielonis, his wife, by
their Deed dated OC%06FR 9(,, 1992, and recorded immediately prior
hereto in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, granted and conveyed unto Jeffrey
C. Hunt and June L. Hunt, husband and wife, Mortgagors herein.
j6&1098 PACE (345
XI ilL ! 1J
COMPANY NAMB: BAMK OF AMERICA, FSB
T verify that the statements made in the foregoing complaint
are true and correct.
I aaderstaud that false statements herein are mach subject
to the penalties of 18 Pa. c.s. section 4904 relating to uneworn
falsification to authorities.
Dated: MJUZT 31, N99
Hy vonne a ss erger
Title sistant Vice President
C!- !t•J
Vr
r.
z
r
r
?o
? U
r
e.u wun eoaoiu•n.au......ur
axmroi mavere Jron ranarn•
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-05472 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF AMERICA FSB
VS.
HUNT JEFFREY C 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: HUNT JEFFREY C
but was unable to locate Him in his bailiwick. He therefore returns
the COMPLAINT - MORT FORE
NOT FOUND , as to the within named defendant
HUNT JEFFREY C
DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT
NO FORWARDING, BELEIVED TO BE LIVING IN FLORIDA
Sheriff's Costs: So answer; s?
Docketing 6.00
Service 8.06
Not Found Return 5.00
Surcharge 8.00 omas ine, eri
$?S PU CE7 149KRUG & HALLER
Sworn and subscribed o before me
this t day of
19- A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05472 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF AMERICA FSB
VS.
HUNT JEFFREY C ET AL
CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon HUNT JUNE L the
defendant, at 19:40 HOURS, on the 16th day of September
1999 at 506 E ELMWOOD AVE
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to JUNE HUNT
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 6.30
Affidavit .00
Surcharge 8.00 ma ine, ri f--
$ 32. J U0917 1 9 & HALLER -
09 17//1999 _
by ?-- `
epu y
Sworn and subscribed to before me
this /7t day of
19 ?,g A.D.
--I t°y "
BANK OF AMERICA, FSB
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
THIS LAW FIRM IS A DEBT
TO COLLECT A DEBT OWED
OBTAINED FROM YOU WILL
COLLECTING THE DEBT.
NO.99 .5 Y71 ez?y
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COLLECTOR AND WE ARE ATTEMPTING
TO OUR CLIENT. ANY INFORMATION
BE USED FOR THE PURPOSE OF
N O T I C E
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 claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A 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 Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S O
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, O SO ABOGADO, REGISTRE CON LA COUTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDF. A ESTA DEMANDA, BE 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. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013 TRUE COPY FROM RECORD
717-243-9400 in Testimony whereof, I here unto set my hand
and the seal of said Cou at Carlisle, Pa.
s_.&_day 9q9
<'7/ arothonota? ryA-
BANK OF AMERICA, FSB
Plaintiff
V8.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW -
: IN 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 within 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
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
BANK OF AMERICA, FSB
Plaintiff
VS.
JEFFREY C. HUNT AND JUNE L
HUNT
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- .S-4 7.Z aa 7-,e,-
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, BANK OF AMERICA, FSB, is a Delaware
corporation, with an address of PO Box 26388, Richmond, Virginia,
23260-6388.
2. Defendant, JEFFREY C. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055. Defendant, JUNE L. HUNT, is an adult individual whose
last known address is 126 HILL LANE, MECHANICSBURG, PENNSYLVANIA
17055.
3. On or about October 30, 1992, the said Defendants
executed and delivered a Mortgage Note in the sum of $82,039.00
payable to MARGARETTEN & COMPANY, INC., which Note is attached
hereto and marked Exhibit "A°.
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1098, Page 641 conveying to
original Mortgagee the subject premises. The Mortgage was
subsequently assigned to BANK OF AMERICA, FSB and recorded in the
aforesaid County in Mortgage Book 502, Page 3 on August 15, 1995.
Said Mortgage and Assignment are incorporated herein by
reference.
S. The land subject to the Mortgage is: 349 SPORTING HILL
ROAD, HAMPDEN, PENNSYLVANIA 17055 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on December 1,
1998 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 75,537.00
(b) Interest at $15.52 per day
from 11/1/98 to 10/1/99
(based on contract rate of 7.500%) 5,183.68
(c) Accumulated Late Charges 112.06
(d) Late charges at $28.85
per month for 11 months 317.35
(e) Escrow Deficit 225.56
(f) 5% Attorney's Commission 3,776.85
$ 85,152.50
*Together with interest at the per diem rate noted in (b) above
after October 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No 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. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. Plaintiff has complied with the procedures required by
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and Defendants have either failed to
meet the time limitations as set forth therein or have been
determined by the Housing Finance Agency not to qualify for
assistance.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.500 ($15.52 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL, KRUG HALLER
By
Leon P. Halle
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
17304145
f?HIC 1 f::°,!
ADJUSTABLE RATE NOTE
r tNA c,e No.
441-450
October 30th, 1992
ne.essa?
349 SPORTING HILL RD, HAMPDEN, pp 17065
1. PARTIES
'Bmrowwr° owsos each Pardo signing at the tlma of this Now, aed the per'm's so meoo ad udgea. 'L wa.
mew
Margaretten @ Company, Inc.,
corporation organized and existing under the laws of the State of New Jars'
and its successor, and andgm.
2. BORROWER'S PROMISE TO PAY; DnZRESI'
In raturn for • lean modved fors Lester, Borrower promises to pay the principal amen of
Eighty- Two Thousand, Thirty- Nine and 00 100
DoNra (U.S. S 82.03 9 . 00 ), plus interest, to the order of Isodar. Intend will be dwryed on apsW
principal, from the date of dhbmwmmt of the lea proceeds by Leader, at a ate of
Six A One-Half
Percent( 6 1/2 16) per year. The intend rue may ehattge In somrdam with Paragraph S(C)
of this Now.
3. PROMISE TO PAY SECURED
borrower's promise to pay is second by • modgage, dad of had or similar severity Insinuated that h dated the ems
date as Oda Nom and called the'Sesuity msrfummt.' That Security mmwmeatprctecm the lender Oorslaee, which might
=Wt if Borrower da(sulw node this NOW
4. MANNER OF PAYbtENT a
(A) Time
Borrower shall maim a payment of principal and income to Issde as the fire dry of each month beginniq on S
December lat. 1992• Any principal and intoned mooloing on the fiat day of November 2022 '
will be der on flat due, which is rolled the maturity data.
(B) Pins
Payment shag be made at One Ronson Ro d, Ise111 Now Jer a 068:aO
or at such =9 plan as [ea?Er may dmgoa? r?wnmglry notice to Borrower.
(C) Amami
I01619y, aseh monthly payment of Principal and intend will be in the amo®t of S 518.54
This Five N dyad Ffi7ryer Moon and 64 1.0 thi moment be pan o a w m y Payment r?gwred M' the S.Wty lw soca t dat ebaB bo oppild m pdmipai,
intend and other items in the odes described in the Security Ioaummt. 7hm ancestor may chugs in amordsom with
Paragraph S(B) of this Notes
S. RCIERM RATE AND MUMMY PAYhffNI CHANCES
(A) Change Date
The interest rate my change co the rust day of J nun r 1 . and an Oat day of each amending
year. 'Chop Dam' roams each time co which them r.? mu?dRe?mga
(B) The Inder
Beginning with the Rau Chugs Dale, The intend ate will be hued no a leas:. 'Iodea' come the curtly average ij
yield on United Stamm Treasury Secmitie Amo d to • constant maturity of ors year, as made milable by the Federal
Reamn Beef& *Cm mm Inds' -a Me most amt Index firm asdlabte 30 days befog do mange Data If the Index -`
(as defined shwa) Is nc longer "We. Leader will ma a a new Ida my Was Pmes? by gas Sea" (a dsBead
in Paragraph 7(B)). lade' will gin Borrower actin of the near lodea.
(C) Camuiatic n of kdered Ram Change
Before each msg. Data, Leader will aleumm a mw interest ere by adding a margin of
PercT wo points (y %) to the Cmr mt Inch and rme deg the am to the notated oadghth of ors .
persmmge point (0.125%). Subject to the limits dated in Pangeph S(D) of this Note, this receded amoat will be do am
interest rare until the ant merge Dire.
(? t ; ,
1 XI11b
FHA MULTISTATE ARM NOR 7 8 f? }
MAR•7303 PACE I Of 3 LUM) `a.'ra•^
(D) Limits on Intvvet Rats Change
Ibe Intent nu wIB nova Immerse or decraan by more than aim pacmmi a pniml (I.o%) on any Ingle (lump Doe,
Tho interest rats will never be more than five percentage points (5.0R) higher or lower than the initial intent rate stand
In Paragraph 2 of the Note.
(E) Calculation of Payment Cbusgs
If the lotemt nn cbanta on a Champ Den, Lender will calculate the smmmt of monthly payment or principal and
intent which would be necessary to ropy the unpaid principal balance in Nil at the maturity data at the new intent rate
through substantially equal pymenm. In malting such calculation, LanderwM me the unpaid principal balance which would
be owed on the Chop Deft if tbere hod been no default in payment on the Note, mkwW by the denied of my prepayments
to principal. The result of this calculation will be the ammmt of the Sew monthly payment of principal and interest.
Rrl Notice of Changes
Lender will give notice to Borrower of any longs In the intent roe and moodily payment auccitat. The nodes mid
be Sim at law 25 days before the mw monthly payment ammmt is don, ad mop IN forth (I) the clan of the notice, Qu
do mange Dan, (Iii) the old internal ram, (v) the new intent rate, (v) the mw monthly payment amount, (vo the Current
Inden and the dam it was published, (vif) the method of calculating the change in mmthly payment amount, and (Viii) my
other information which may be required by law ham time to time.
(G) E fedive Dam of Chance
A new interact rate Woolard! in accordance with Pangnphs SIC) and S(D) of this Note will become effective on the
Clamp Dam. Bon shaumdoapayntentinthemw ddyammmtbejionegmlbafirapaymmtdamwhichocaurs
at teat 25 days agar Landau has given Borrower the notion or chmgn required by Paragraph S(1) of this Note. Borrower
"have no obligation to pay my ednaa in the monthly payment smonnt calculated in aoondanee with paragraph S(B)
of this Note for my payment doe occurring less than 25 days ally Imder ha given the required nods. If the m dilly
payment amount alculatd in soc rdsom with Panpaph S(E) of this Note demand, but Leader failed to give timely codes
of the decree and Bonwve male my monthly payment dentures wading the payment amount which should have been
sated in a thusly notice, thin Borrower has the option to either (I) demand the tenon to Borrewn clay enan payment,
with intend thereon at the Nine ram (a nee equal to the interest ram which should have been peed In a timely notice), or
(to request that any maw payment, with intent thereon at the None nn, be applied as payment of principal. Lander's
obligation to =turn my excess psynmt with intoned m demand is to anigmhie even if this Nom Is otherwise aaipd
before the demand for =main is me&
6. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the dobt evidenced by the Note. in whole or in prat, without dharge a penalty, on thP
fop day of my month.
SEA muLTWATE ARM NOTI
MAR.AOy PAGES Or 3 Olin)
?"
7. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
I tender has not received the full monthly payment mgWmd by the Semriry Lub m t, u deerdbd In Paragraph A(Q
or this Nate, by the and of ROseo alendar drys aller the payment Is due, fender may collect a late d wp in, the amwmt
or Four Percent ( A Ise) of the overdue moment of each payment.
(B) Default
If Borrower defaults by failing to pay in full any mostbty payment, then fendermay, exceptu Um(td 6y mgulatlm
of the Swmtary in the ass, of Payment defaults, require immdiw payment in full of the prindpal balms r maininS due
and all accrued interest. Lender may choose not to exercise Wes option without evolving Its rights In the event of any
subsequent default. This Nom does not embolism woolerWon when son permitted by HUD regulation. As and in Us
Note, 'Secre4ry' mean the Saddlery of Housing ad Urban Dwalopmel or his or bar dm*w
(C) Payment of Cats and Expetsa
If Leader has required immedlaut payment in full. as described above, Leader may require Bosmwar to pay cew ad
mpanw Including seseonable and o nnowry attorney's fees for enforcing this Note. Such few and cam shag bar inland
from the date of disbunement at the same rate a the principal of this Note.
S. WALYBR.S
Borruwar and any other parent who by obligations under this NCO waive the rights of Pronounced and malft of
diabenor. 'Presentment' mew the right to require Leader to demand payment of amounts due. 'Noti m of dishooW
coma the right to require Lender to give coda to other persons that amounts due ewe uses base paid.
9. GIVING OF NOTICES
Unless applicable law sequin a different metbd, any notice that rem be given to Ba mws under this Note will be
given by delivering it or by tailing it by first elm mail to Sonvwar at the Property ddmw above or at a different address
if Bonvant ban Sim Lander a notice of Borsaver s different addram.
Any notionthat must be given m Linder mda the Nw will be give by fun ciw mail m Lender a the ddrea wtd
in paagraph 4(B) or at a different address If Borrower is given ¦ notice of that different address.
10. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If one than one person sips this Note, ash Foam is fully and personally obligated to loop all of the prnotiaa made
in this Nob, including the promise to pay the full amount owed. Any persw who is a pioneer, musty or colander of
Note is aim obligated to do these things. Any person, wise Wn over these obligations, including the obligation of-4
summation, surety a admatr of this Note, is Rise obligated to Imep all of the promises male in, fats Note. Linder may
mfon its rights under WisNom sgaiast each paned iodividullya spun all signatories together. Anympa. signs
this Note may be required to pay all of the womme; owed udder this Note.
BY SIGNING BELOW, borrower weepts and arm to the farms and covenants c uummed In Us Nate.
WITNESS 3/e.
C ?HQUNT?
L uluil.
au __
A 10 329c? _
OF OIJT RECOURSE PAY TO THE OROER
BANK OF AMERICA, FSB
BY•? LE
ea R I?CO PeAssetSeRcrw
PAYwrrHOUr RECOURSE TO THE ORDER OF
-MK OF AMERICA. FSB
PM MULTISTATE ARM PM
MA1,7303 PAGE 3 My 0111)
EXHIBIT A
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Noe. 2 and 21, Block "B"; thence along the
last said dividing line, southwardly, 60 feet to a point at-'the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the lest said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAVING THEREON ERECTED a dwelling house.
BEING THE SAME PREMISES which Walter F. Zielonis and Margar-
et Zielonis, also known as Margaret R. Zielonis, his wife, by
their Deed dated Qj T06F Q, 1992, and recorded immediately prior
hereto in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, granted and conveyed unto Jeffrey
C. Hunt and June L. Hunt, husband and wife, Mortgagors herein.
BOOKIOA PACE 645
„I. ;a
C MP"y NMH$ BANK OF AMERICA, FSB
I verify that the statements made in the foregoing Complaint
are true and correct.
I understand that false statements herein are made subject
to the penalties of 1S Pa. COS, Section 4904 relating to unsworn
falsification to authorities.
Datedt A=31, 1999
By
vonne ?
knn4e
Title Sietant Vice President
w4 SH'?:t'?
kppt
?l
BANK OF AMERICA, FSB
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5472 CIVIL TERM
JEFFREY C. HUNT AND JUNE L.
HUNT : CIVIL ACTION - LAW
Defendants : IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the complaint on the above captioned matter.
DATE: October 18, 1999
PURCELL, KRUG & HALLER
BY
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102
Attorney for Plaintiff
Attorney ID# 15700
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BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
. IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that ve dego ited in the U.S. Mails at
Harrisburg, Pennsylvania I on , a true and correct
copy of the Notice of Sale o Real Estate pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders 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, which mailing receipts
are attached. Service addresses are as follows:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Bach, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
B
PURCELL, KRUG HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
JOHN W. PURCELL
HOWARD B. KRUG
LEON P. HALLER
JOHN W. PURCELL 1R.
BRIAN J. TYLER
JILL M. WINEKA
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 2344178
FORECLOSURE DEPT. FAX (717) 234-1206
(117) 5313838
NOTICE TO:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
First-plus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Each, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
JOSEPH NISSLEY (1910.1982)
ANTHONY DISANTO
OF COUNSEL
HERSHEY
1089 GOVERNOR ROAD
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 a st the said
real estate will be divested by the sale and that have an
opportunity to protect your interest, if any, n notified of
said Sheriff's Sale.
By:
Leon P. Hal er PA I.D.15700
Attorney for Plaintiff
HANK OF AMERICA, FSB,
PLAINTIFF
vs.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTP.TE
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, JUNE 7, 2000
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO HE 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:
349 SPORTING HILL ROAD
HAMPDEN TOWNSHIP - MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 1999 05472
is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
JEFFREY C. HUNT AND JUNE L. HUNT
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 mortgagee
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
7?r y:
J
e_r.
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, soulhwardly, 60 feet to a point at the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "B", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAVING ERECTED THEREON a dwelling known as 349 Sporting Hill Road,
Mechanicsburg, PA.
BEING THE SAME PREMISES WHICH Jeffrey C. Hunt and June L. Hunt by
deed dated January 11, 1999 and recorded January 25, 1999 in
Cumberland County Deed Book 193 Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO BE SOLD AS THE PROPERTY OF JEFFREY C. HUNT ON JUDGMENT
NO. 1999 05472.
TAX I.D. 10-22-0525-060
Z 355 083 139 a N-
US PodW aavlce
Receipt for Certified Mail
JEFFIEY C HUNT^ 1
211 POIN IANOA FL P34758
E?
Fee
fir,
5-
'04
?Z v95 295 499
U3 Postal Service
Receipt for Certified Mail
No Insurance Coverane Provided.
JUNE L HUNT
506 EAST ELMWOOD AVENUE
MECHANICSBURG PA 17055
S?
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Snedel Deli Fee
ResMded Delivery Fee
Realm Receipt Sro
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2 f
hom a Date o.ro oekvemd?emd
F PeOm
z ee°edA?ees - .SS
d er
Re: Bank of America v. Hunt
Cumberland County Sale 6/7/00
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Postage:
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
V ?1 .; ?/ y v
S
Postmark:
Postmark:
Postmark:
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
James M. Bach, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
Postage:
Postage:
Postmark:
Postmark:
Postmark:
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BANK OF AMERICA, FSB, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -- LAW
JEFFREY C. HUNT AND NO. 1999 CIVIL 5472
JUNE L. HUNT,
DEFENDANTS SUPPLEME--MORTGAGE FORECLOSURE
'IAL
RETURN OF SERVICE
I hereby certify that I have deposited in the U.S. Mails at
Harrisburg, Pennsylvania on ?5I?1I('0 a true and correct
copy of the Notice of Sale of Real Estate pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders of record by
regular first Blass 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, which mailing receipts
are attached. Service addresses are as follows:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Bach, Esquire
352 South Sporting Hill Roa
Mechanicsburg, PA 17055
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
JOHN W.PURCELL TELEPHONE(717)234-4176
HOWARD B. KRUG FORECLOSURE DEPT. FAX (717) 234-1206
LEON P. HALLER
JOHN W. PURCELL IR.
BRIAN J. TYLER
JILL M. WINEKA
(717)533.3a3S
NOTICE TO:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Each, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
JOSEPH NISSLEY 0910.1252)
ANTHONY DiSANTO
OF COUNSEL
HERSHEY
1099 GOVERNOR ROAD
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 a net the said
real estate will be divested by the sale and that have a
opportunity to protect your interest, if any, n not' ed
said Sheriff's Sale.
By:
Leon P. Hal er PA I. .15700
Attorney for Plaintiff
BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUNT AND
JUNE L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
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, JUNE 7, 2000
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
349 SPORTING HILL ROAD
HAMPDEN TOWNSHIP - MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
M. 1999 05472
is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
JEFFREY C. HUNT AND JUNE L. HUNT
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 mortgagee
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 maybe 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
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County of Cumberland, and State of Penn n nia, more particularly bounded and described as follows, to wit:
sylva-
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardly from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last slid dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, southwardly, 60 feet to a point at 'the
dividing line between Lots Nos. 1 and 2, Block "B thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a radius of 696.78 feet, northwardly,
the arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. "B", on Plan No.
Manor, which Plan is recorded in the Cumberland County Recorderoof
Deeds Office in Plan Book 6, Page 42.
HAVING ERECTED THEREON a dwelling known as 349 Sporting Hill Road,
Mechanicsburg, PA,
BEING THE SAME PREMISES WHICH Jeffrey C. Hunt and June L. Hunt by
deed dated January 11, 1999 and recorded January 25, 1999 in
Cumberland County Deed Book 193 Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO BE SOLD AS THE PROPERTY OF JEFFREY C. HUNT ON JUDGMENT
NO. 1999 05472.
TAX I.D. 10-22-0525-060
k}k cbpv
COURT OF COMMON PLEAS OF CUMBERLAND COUNP( D
9TH JUDICIAL DISTRICT r
COMMONWEALTH OF PENNSYLVANIA
IWO
AFFIDAVIT OF SERVICE OF PROCESS
BANK OF AMERICA, FSB NO. 1999 CIVI .472_
Plaintiff •+!i
CIVIL ACTION - LAW
versus IN MORTGAGE FORECLOSURE
JEFFREY C. HUNT AND JUNE L. HUNT
Drrcndanl
Know all persons by these presents that I, Al., o 4.) t )V. Oa w 0 , was assigned to duly
execute this service upon the following defendant: JE FREY C. HUNT at
I hereby depose and say: 1&66 't'?ary a t.t o e S!,
vrrp el.
l) That I am of the necessary age and sound mind to execute said service.
2) That I am not a party to the action or have any interest in it.
3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private
investigator.
I hereby certify that on 7 -70 - 0 d at approximately 2m Ua.m. ?p.m. a true and correct
copy of the NOTICE OF SHERIFF'S SALE were served on the above-named party or witness in
the following manner:
id I personally delivered them into the hands of the person to be served.
? By leaving a copy at his/her usual place of abode with whose
relationship to the defendant is and who is of suitable age and discretion
and also residing therein.
? By leaving a copy with the manager/clerk of place of lodging in which
defendant resides.
? By leaving a copy with the agent in charge of defendant's office or
usual place of business. Job title or position of agent is
? After due and diligent efforts, described below, I was unable to serve the process
Description of Recipient:
Sex: I _ Race: 11 St ON , Approximate Height: 5_?) 14pproximale Weight: _L" Approximate Age:
FURTHER AFFIDAVIT SAYTH NOT.
S not re of Pro ss Server
Subscribed and swom to before me this
day of F+er, 31 r , 2000.
Notary Public
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US Postal8 rVicel
Receipt for Certified Mail
JEFFq,EY C HUNT
211 7,tSHFORD PLACE
POINCIANA FL 3475,;
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1-95 295 499
US Postal Service„
Receipt for Certified Mail
No Insurance Covcraoe Provided.
JUNE L HUNT
506 EAST ELMWOOD AVENUE
WCHANICSBURG PA 17055
J
L/ it
Spatial Delivery
Rtl6lc lad Del" Fee Fee
2 7 ' Resl aed DeNVery Fee
??6 DO p?r0 to 2 Return Receipt ShZ to
pw n bNypm, ,2 Wham d Date DeNveree 2
RDate e q Sr Atllhed
PoeupeIt Fbji ?
or S TOTAVpostepe 8 Feel, r
\G, ',, I:• € Raeamark or tale i ,t
Re: Bank of America v. Hunt
Cumberland County Sale 6/7/00
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Jeffrey C. Hunt
211 Ashford Place
Poinciana, FL 34758
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
Postmark:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF NAILING
11n compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Green Tree Consumer Discount Company Postmark:
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
7-
Postage:
Postage:
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
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
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
James M. Bach, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
Postage:
Postmark:
Postmark:
Postmark:
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND Ss'
Robert P Ziegler
I+-------------
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________
- -- Secretary of Housing & Urban Dev of Washington D C
---------------------------- ------------------------------------ is the grantee
the same having been sold to said grantee on the ---- 7th
--------------------------------------- day of
June
---------------------------------------- A. D., "2000--- under and by virtue of a writ -_____________
Execution
------------------------------------------------issued on the ___ 8th --------------
day of --KUCb ------------------ A. D., 18t20011., out of the Court of Comman Pleas of said County as of
__--____ Ciyil gg
----- - - -- - - ----- - - - -- - - - Term, 19-------
Number_5472-------- ,at the suit of___Bank of -AMerica--FSB
------------------------------------------------
----------------------------------- against Jeffrey C Hunt & June D
---------------------------------------------------- is
duly recorded in Sheriff's Deed Book No. 226- -- Page _ 874 ----__.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this _-_2----- day
of -A1- MY --------------- A. D.,#9_2_! !!Lo Deeds
Bank of America, FSB In the Court of Common Pleas of
-vs- Cumberland County, Pennsylvania
Jeffrey C. Hunt and June D. Hunt No. 1999-5472Civil
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, says on
March 31,2000 at 4:49 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon the property of Jeffrey Hunt and
June Hunt located at 349 Sporting Hill, Road, Mechanicsburg, Cumberland County,
Pennsylvania according to law.
Shawn Harrison Deputy Sheriff, who being duly swom according to law, says on
March 31, 2000 at 6:28 o'clock P.M. EST he served a true copy of Real Estate Writ
Notice Poster and Description in the above entitled action upon one of the withinnamed
defendants to wit: June Hunt, by making known unto June Hunt at 506 East Elmwood
Avenue, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same
time handing to her personally the said true and attested copies of the same.
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: June Hunt by first class mail to her last known address 506 East
Elmwood Avenue, Mechanicsburg, Pennsylvania. This letter was mailed under the date
of April 3, 2000 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he made
diligent search and inquiry for the within named defendant Jeffrey C. Hunt, but was
unable to locate him in his bailiwick. He therefore returned Real Estate Writ Notice
Poster and Description NOT FOUND as to defendant Jeffrey C. Hunt.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due
and legal notice had been given according to law, exposed the within described premises
at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania
on June 7, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00 to
Attorney Leon P. Haller for The Secretary Of Housing and Urban Development of
Washington D.C., his successors and /or assigns. It being the highest bid and best price
quoted for the same The Secretary Of Housing And Urban Development Of Washington
D.C., his successors and/or assigns of One Sentry Place 475 Sentry Parkway, Suite 5000,
Blue Bell, PA being the buyer in this execution paid to Sheriff R. Thomas Kline the sum
of $ 912.81 it being costs.
Sheriffs Costs
Docketing 30.00
Poundage 17.90
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 13.64
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
7.12
15.00
30.00
363.05
288.30
24.80
25.00
26.50
$ 912.81 Pd By Atty
6/22/00
Sworn and Subscribed To Before Me
This_ Day of
R. Thomas Kline, Sheriff
2000, A.D. `7ytp0,?, nG?y -
r "onotar By e
Real Estate Deputy
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a ,
COPY
BANK OF AMERICA, FSB, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
JEFFREY =. HUNT AND NO. 1999 CIJiIL 5472
JUNE L. HUNT,
DEFENDANTS 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 349 SPORTING HILL ROAD, MECHANICSBURG, PA
17055:
1. Name and address of the Owner(s) or Reputed Owner(s) :
Jeffrey C. Hurt
211 Ashford Place
Poinciana, FL 34758
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
June L. Hunt
506 East Elmwood Avenue
Mechanicsburg, PA 17055
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):
Green Tree Consumer Discount Company
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
Firstplus Financial, Inc.
1600 Viceroy Drive
Dallas, TX 75235
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
sa e: affected by the
UNKNOWN
7. Name and address of every other person of whom the
P1z-ntiff has knowledge who has any interest in the property which
mat.- be affected by the sale:
TENANTS IF ANY ...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
James M. Bach, Esquire
352 South Sporting Hill Road
Mechanicsburg, PA 17055
(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 relatin o unsworn`
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 3, 2000
OFFI;;F. Of .,.r f,.lr_u fF
Man 9 ? oa PI1 ' 00
BANK OF AMERICA, FSB,
PLAINTIFF
VS.
JEFFREY C. HUN= AND
J ?:E L. HUNT,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 CIVIL 5472
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
hel d: That the Sheriff's Sale of Real Propertv (real estate) will be
DATE: WEDNESDAY, JUNE 7, 2000
TIME: 10:00 O'clock A.M,
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
349 SPORTING HILL ROAD
HAMPDEN TOWNSHIP - MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 1999 05472
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
JEFFREY C. HUNT AND JUNE L. HUNT
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 mortgagee
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 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
PAY THE MAY CAUSE
JUDGMENT YOUR PROPERTY TO BE HELD TO
BE SOLD OR TAKEN TO
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 Commcn Pleas of the within County. :he 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) 2 34 -4178
1'' ,
I. A_ -ESCR:PT-Cy
ALL THAT CERTAIN piece or parcel of land situate in the
Township of Hampden, County o: Cumberland, and State of Pennsylva-
nia, more particularly bounded and described as follows, to wit:
BEGINNING at a point at the Easterly side of Sporting Hill
Road, which point is 575 feet southwardiy from the southeasterly
corner of the intersection of Sporting Hill Road and Del-Brook
Road and which point is also at the dividing line between Lots
Nos. 2 and 3, Block "B", on the hereinafter mentioned Plan of
Lots; thence along the last said dividing line, at right angles to
Sporting Hill Road, eastwardly, 120 feet to a point at the divid-
ing line between Lots Nos. 2 and 21, Block "B"; thence along the
last said dividing line, sou'thwardly, 60 feet to a point at the
dividing line between Lots Nos. 1 and 2, Block "B"; thence along
the last said dividing line, westwardly, 118.25 feet to a point at
the easterly side of Sporting Hill Road; and thence along the
easterly side of said Sporting Hill Road by the arc of a circle
curving to the right, having a. radius of 696.78 feet, northwardly,
t;.e arc distance of 49.40 feet to a point; and thence continuing
along the easterly side of said Sporting Hill Road, northwardly
10.63 feet to a point, the place of BEGINNING.
BEING Lot No. 2, Block "a", on Plan No. 1 of Del-Brook
Manor, which Plan is recorded in the Cumberland County Recorder of
Deeds Office in Plan Book 6, Page 42.
HAV_NG ERECTED T.HEREON a dwelling known as 349 Sporting Hill Road,
Mechanicsburg, PA.
BEING THE SAME PREMISES WHICH Jeffrey C. Hunt and June L. Hunt by
deed dated January 11, 1999 and recorded January 25, 1999 in
Cumberland County Deed Book 193 Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO BE SOLD AS THE PROPERTY OF JEFFREY C. HUNT ON JUDGMENT
NO. 1999 05472.
TAX I.D. 10-22-0525-060
OfF1;:FOF'.- "W"'!FF
r,•;,.?,
NaR 09 r ? 000
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 99-5472 CIVIL 19-MW
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Bank of America FSB
PLAINTIFF(S)
from Jeffrey C. Hunt 211 Ashford Place, Poinciana. F1 34758
Junp L. Hunt, 506 err Flmwnnri A. ue„MeCh h 9 Pa 12055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to
Real Estate 349 Sporting Hill Road, Mechanicsburg, Pa. 17055
(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 enjoingd 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 def enclarit(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee, you aie difected to notify himlherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due S85. /1/4B5/2/.50 L. L. $ 0.50
Srterest 10/1/9936B?96 DueProlhy 1.00
Atty's
Ally Paid 163.56
Plaintiff Paid
Date: March 8, 2000
REQUESTING
PARTY1:?u
E.U
Name orne l Ha1yer,Hgsauire
Address: 1719 North Front Street
Harrisburg. Pa. 17102
Attorney for: Plaintiff
Telephone: (717) 234-4178
Supreme Court ID No. 15700
Other Costs
Late Charges $28.85 $201.95
Curtis R. Loner
Prothonotary, Civil Division
by: _ t -)' i , "
Deputy
REAL ESTATE SALE NV. )
un.,'Y"a"-k /y a"O the sheriff levied upon the defendants
Interest In the real property situated ins ?-?-
Cumberland County, Pa., known and numbered as:3lC?jjanZ,,,j4/'#P A%,4
and more fully described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
nate:. '- a...aiY. xw- '_ By:
.1
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d
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..L,lddO
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Commonwealth of Pennsylvania, County of Dauphin) as
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Assistant 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 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 aver 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 and Metro editions/Issues which appeared on the 2nd, gth and 16th day(s) of May
2000. 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 [?ayphin in Miscellaneous Book "M",
Volume 14, Page 317. / I , 1 _
PUBLICATION __________
-
- V_?tt /1 _ °Uvw
-----------------
COPY Sworn
to
and subscribed before m is nd day it 00 A.D.
S A L E Olio Note a- Seal
Terry L. Russell, Notary Pudc
L
Hardsburg
usupwn count
1 n....
_ __
I? ,
y
My commission Expires June 6.2097 N RY PUBLIC
mmission expires June 6, 2002
Ayr;l
4i0G r Member, Pennsylvania AUOaatbnd NOt nae
y
?a 'f
?
CUMBERLAND COUNTY SHERIFFS OFFICE
T CUMBERLAND COUNTY COURTHOUSE
? CARLISLE, PA. 17013
irr, a
Statement of Advertising Costs
r.'of To THE PATRIOT-NEWS CO., Dr.
and For publishing the notice or publication attached
dM,6slerl hereto on the above stated dates $ 286.80
r tit! Probating same Notary Fee(s) $ 1.50
rS Hill Total $ 288.30
5
2
,.sher's Receipt for Advertising Cost
her of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
receipt of the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
I mvramg tin, By ...................................................
a point at the
Hill Road; and
r side of said
art of a circle
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,
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 LUX No. 00
writ No. 1999-5472 Civil
Bank of America. FSB
Va.
Jeffrey C. Hunt and June L. Hunt
Atty.: Leon P. Haller
LEGAL DESCRIPI1ON
ALL THAT CERTAIN piece or par-
cel of land situate In the Township of
Hampden. County of Cumberland,
and State of Pennsylvania, more par-
ticularly hounded and described as
follows, to wit:
BEGINNING at a point at the
Easterly side of Sporting Hill Road,
which point is 575 feet southwardly
from the southeasterly comer of the
intersection of Sporting Hill Road
and Del-Brook Road and which point
is also at the dividing line between
Lots Nos. 2 and 3, Block "B", on the
hereinafter mentioned Plan of Lots;
thence along the last said dividing
line, at tight angles to Sporting Hill
Road, eastwardly, 120 feet to a point
at the dividing line between Lots Nos.
2 and 21, Block "B"; thence along the
last said dividing We, southwardly,
60 feet to a point at the dividing line
between Lots Nos. 1 and 2, Block -e-,
thence along the last said dlviding
line, westwardly. 118.25 feet to a point
at the easterly sldae of Sporting Hill
Road; and thence long the easterly
side of said Sporting Hill Road by the
arc of a circle curving to the naht.
Ro r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
12 day of MAY. 2000
LOTS E. SNYDER, Notary Public
Connie Dom, Cumb*rlond County, PA
My CommiWon Eapir" Momh 5,1001
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 followine dates.
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.
NNAL =TATS SALE N0. 5o
Writ No. 1999-5472 Civil
Bank of America. FSB
vs.
Jeffrey C. Hunt and June L. Hunt
Atty.: Leon P. Haller
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate In the Townstup Or'
Hampden, County of Cumberland,
and State of Pennsylvania, more par-
ticLdarly bounded and described as
follows, to wit.
BEGINNING at a point at the
Easterly side of Sporting HW Road
which point Is 575 feet southwardly
from the southeasterly comer of the
Intersection of Sporting Hill Road
and Del-Brook Road and which point
Is also at the dividing line between
Lots Nos. 2 and 3, Block •B', on the
hereinafter mentioned Plan of Lots:
thence along the last said dividing -
Ine, at right angles to Sporting Hill
Road, eastwardiy, 120 feet to a point
at the dividing line between Lots Nos.
2 and 21, Block 'B'- thence along the
last said
dividing line. southward) .
60 feet to a point at the dividing line
`. between Lots Nos. I and 2. Block `B':
thence along the last said dividing
11ne,westwardly, 118.25 feet toa point
at the easterly side of Sporting Hill
Road; and thence along the easterly
side of said Sporting Hal Road by the
arc of a circle curving to the right,
having a radius of 696.78 feet, north-
wardly, the arc distance of 49.40 feet
. ! to a point: and thence continuing
i along the easterly side of said Sport-
ing Hill Road, northwardly 10.63 feet
to a point, the place of BEGINNING.
BEING -? t
Plan No.Iof el-Brook Manor, which
Plan is recorded In the Cumberland
County Recorder of Deeds Office in
Plan Book 6, Page 42.
HAVING ERECTED THEREON a
-'' dwelling known as 349 Sporting Hill
Road, Mechanicsburg, PA.
BEING THE SAME PREMISES
WHICH Jeffrey C. Hunt and June L.
Hunt bydeed dated January 11. 1999
1 and recorded January 25, 1999 In
Cumberland County Deed Book 193
Page 129 granted and conveyed unto
Jeffrey C. Hunt.
TO BE SOLD AS THE PROPERTY
OF JEFFREY C. HUNT ON JUDG-
MENT NO, 1999 05472.
TAX LD. 10.22.0525.060.
Ro r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
12 day of MAY 2000
LOIS E. SNYDER, Notary Publk
GOrW4 Sam, Cumbnland County, PA
My Commiwon Eapfrn March 5, 2001
I ?
1 :?
?I
$ 1000.00 Advance Costs Paid 3/14/00 Real Estate No 50
Leon P. Haller
Assessed Valuation $ 7,800
Writ No. 1999-5472
Bank of America, FSB
-vs-
Jeffrey C. Hunt and June L. Hunt
349 Sporting Hill Road
Mechanicsburg, PA
Real Debt $ 85,152.50
Interest $ 15.52 10/1/99-6/7/00
' 3,848.96
Atty
s Fees
Atty's Writ Costs 163.56
Escrow 2,000.00
Late Charges 201.95
Sheriff s Costs
Docketing 30.00
Poundage 17.90
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 13.64
Certified Mail 7.12
Levy 15.00
Surcharge 30.00
Legal Search
Law Journal 363.05
Patriot News 288.30
Share of Bills 24.80
Distribution of Proceeds 25.00
Sheriff s Deed 26.50
TAXES
2000 County, Library & Township taxes 233.15
Sewer 364.10
Sewer Lien 266.30