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Home My WebLink About01-6127WASHINGTON MUTUAL HOME LOANS, INC. sUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. LINDA HERSHEY AND BRIAN W. HERSHEY A.K.A. BRIAN HERSHEY Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIlE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action ~it~in~ twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and ~ilir6g~m writing with the court your defenses or objections to the claims set forth against you. You are warned that ffyou fail to do so ~ ~ase may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights imp6rtant 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· i ~ ,~' CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJ'AS 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 SU ABOGADO, .~.~..~,~STRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION LAS QUEJAS EN ESTA DEMANDA ~':I])!~~ RE ' CUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU ~.~ ~d~CA ~JUI~ USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA ~CISION, ES POSSIBLE QUE USTED PUEDA PEP, DER D/NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. . '. :', LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. ~ '~-·! SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS) (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. LINDA HERSHEY AND BRIAN W. HERSHEY A.K.A. BRIAN HERSHEY Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attomey 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. Plaintiffis 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 assurne that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiffand mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. LINDA HERSHEY AND BRIAN W HERSHEY A K A. BRIAN HERSHEY Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffis WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY W ,~; MERGER TO FLEET MORTGAGE CORP., a corporation whose address is P.O. BOX 1169, DEPT. 1. i ,-2665, MILWAUKEE, WISCONSIN53201. 2. Defendant, LIN-DA HERSHEY, is an adult individual whose last known address is 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. Defendant, BRIAN W. HERSHEY A.K.A. BRIAN ; h~i HERSHEY, is an adult individual whose last known address is 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. On or about, April 03, 1998, the said Defendants executed and delivered a Mortgage Note in the sum of $90,800.00 payable to GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P., which Note is attached hereto and marked Exhibit "A". Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, 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 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FLEET MORTGAGE CORP. and was recorded in the aforesaid County in Book 175, Page 42. Washington Mutual Home Loans, Inc. is Successor in Interest by Merger to Fleet Mortgage Corp. Said Mortgage and Assigmnents are incorporated herein. 5. The land subject to the Mortgage is: 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. : The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on March 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $88,338.70 Interest at $18.15 per day From 02/01/2001 To 11/01/2001 ( based on contract rate of 7.5000%) $5,517.60 Accumulated Late Charges $0.00 Late Charges $33.53 From 03/01/2001 to 11/01/2001 $268.24 Escrow Deficit $1,311.16 Attorney's Fee at 5% of Principal Balance TOTAL $4,416.94 $99,852.64 **Together with interest at the per diem rate noted above after November 01, 2001 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclosure 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. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM,, for the aforementioned total amount due together with interest at the rate of 7.5000% ($18.15 per diem), together with other charges and Costs including escrow advances incidental thereto t~e date of Sheriff's Sale and for foreclosure and sale of the property within described.~ ,~& ~CE~LL__ //~ By: PU & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Fmc545~8 (1696x2200x2 tiff) [8] 'lid~ltistate ORIGINAL- AlqtXL 03, :1.998 53 CARLA. 172§7 FHA-O- 643870 1. PAMflA,~ "B~ mcans cmch person '_.J~h,~ al: ~ ~ of th~s Note, and thc perscm's successors and assi~n~ *Lendcr" means GA~d'&Y ~iDX~ DXVE~XI,~u ~ORTGA~K 8~.V]'CES, L.P. BORROWER,S PROMISE TO PAY; INTEREST hi. rctum for a loan recelv~l from I~ndcx, Borrower promlscs to pay thc prlnclpal sum of Ktshc Hu~dx'ed and no/100 I~f.n~cy ~housa~d Do]]aFS (LT.S. $ 90,800.00 ), plus ;.~',r~, tO tl~ or4er ~ Lcnd~. T~c~st will bc charged on unpaid p~nclpal, fromthedat=ofdlsburs~mantc~thcloanproceedsbyLcnder, at the rate ot' Seven aud One Hal. f percent( 7.500 %) pcr y~ar unti! the full amount c~ principal has been paid. 3. PROMISK TO PAY SECUBI~ Borrow~s prom~¢to pay h securr~lby a mortgag~ dr~dof trust o~ s/milar securRy b~m~me~that~s d~tcdth~ sam=dst= as d~ Note and cafled th~ ~ccu~ Imtnnnent." The Security lnstmmentprotects the Lender from lmscs wl~ch might result if Borrower defaults under this No~. MANNER OF PAYM~AqT (A) Bmr)wet ,,1,.~ ~ a ~t ~ ~ ~d ~ to ~ ~ ~ ~ ~y ~ ~ m~ ~--;-~ on ~u~ X998 , .~p~;n~t~=in;ng~y~ ~Y 2028 ,~ ~ ~~ ~ed ~"~P~.' ' Pa~t~l!~ma~ ~e ~os~ Ft~s~ Ave~, 2nd F~E C~8hohochu, Pa. by ~ to B~. ~ ~ s~ ph~ ~ ~ may ~te h ~ (C) ~o~t ~m~;h~pa~t~nd~ ~ h ~o~to~U.S. S 634.89 ,~o~ ~ Nom. [C~ app~b~ b~] Fmc54548 (1696x2200x2 tiff) [9] 6. BORROWER'S FAILUBE TO PAY .. ~C) ~ ~ N~ ~ ~ ~d~ P~h by ~d~ ~ ~~t~ ~ ~my ~a la~ of F~ - ~ '~~tm ~ ~ ~ ~ .... ~ ac~cd ~sL ~er my ~ n~ to - P ~a~t. ~ m~ ~~lnfi~ ~ ~ ~ ~ ~ ~ ~t ~ ~y ~uent ~ ~ the ~e of ~ ~ ~ No~ d~ ~ ~ ~~ ............ . ~N~ ~ ~ ~ ~Ho~a.. ~d tv~ ........ If ~h~ ~~~ ...... - . . ~ m ~~ ~may teq~e~to pay ~ ~d ~ m~ r~ ~ 7. W~ B~ ~ ~ ~ ~n ~ 8. G~G OF N~ by ~ it or ~ m~: it ~ ~ ~ 9. OBMGA~O~ OF ~ ~ ~ more ~ o~ ~ ~ N~ ~ Not~ ~ ~to ~ m~t~ · Note ~t ~ ~ ~ ~ a~ ~ ~ t~. ~y ~ ~ ~i~ ~ Nme m~ ~ ~d to ~of~e mo~m~~N~ ~_ ~BY S~GNINGBELOW, Borm~sm'accepts and agree~ to tho terms (se-,') Pay to the order of (Sea) _, -~'~,= V,"~.~ot Racoarse (Seal) (Se~) Fleet Mortgage Corp. P~m PATEL Document Execu~ng Officer IOOlR~.Frm Fmc5454,8 (1696x2200x2 tiff) [10] G-643870 NOTE ALLONGE Nlonge to bhat certain Note Dined: In the amount off. Re: Address Commim~ent Number:. $ '90,800.00 53 CAB. LA. D~.ZVE SIIlP~'E~SBU~.G, PA 17257 GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, LP. without recourse pay to the order of FLEET N%ORTGP, G1:- BY ITS GENERAL PARTNER: GATEINAY FUNDING, INC. / r AU.ONG.Frm Fmc545~8 (1696x2200x2 tiff) [7] NOTE NOTE Fmc54548 (1696x2200x2 tiff) [5] COIVIlVIONWEALTH OF COUNTY OF FMO Lo~ No · Pennsylvania Cumberland 58236727 F_,ffe~tiv¢ Date: Borrower(s): Proper~ Address: COMPLIANCE AGRRRM~NT October 2, 2000 Briau W. Hershey Linch Hershey .53 Cmfla Drive Shippcrmburg, pA 17257 Tho undersigned Bo]Tower(s), in considerafio~ ofth~ Subord~at~ Not~ ~d Su~a~ M~gage or ~ of ~t o~ed by F~ M~e Co~, ~ ~s~ ~ ~ C'~d~') ~ ~e ~o~t of ~,01~, ~ ~ ~ m~g ~e ~t 1~ ~ by a ~ of~e ~ Ap~l 3, 1998 a~ to ~ly ~p~a~ wi~ ~y ~ ~u~ ~ ~ ~, or i~ ~ m ~ ~cnl e~ in ~e ~mJ~o~ No~ ~d Sub~ M~ ~ ~ ofT~ ~abli~ ~ m ~1~ c~, ~ ~ obtain i~ for ~y ~v~ ~ ~m~n, ~c~ bm not ~ ~, ~o F~ N~ M~ ~iaHon, &e Oov~t N~on~ M~ago ~ ~e F~ Home ~ M~e ~o~o% &o ~mt of Hous~g ~d U~ Devel~ ~ ~t of Ve~s A~, ~ ~y m~ bond~g ~oHW, ~ ens~ m~biliw of ~e ~is~ N~ ~d ~a~ M~o ~ De~ of~. ~ ~m ~y ~clude, ~t ~ not limited ~, all ~g~, co~ ~ion or m~H~ of ~y d~mt ~ht~ ~ such 1~, ~ may ~ ~u~ ~e ~d~ ~l ~ply w{~ aH ~u~ wi~ ~ (30) ~ ~m &e ~te ~ ~ m~e by Lm~ or i~ ag~L If B°~s) ~s m me~ i~ obli~Ho~, ~w~s) ~l~ge {iabHi~ for all cos~ ~clud~g, but not limit~ ~, ~ ~, ~ fe~ co~ cos~ ~d m~ ~ms~ ~d by L~d~ m ~fo~e im righm ~ &e P~ No~ ~d S~or~ Mo~e ~ ~ of Tm~ CON~dONWEALTH OF Pennsylvania) ) COUNTY OF ~ ) ~ ~,,~,J,~, · ey;Bon'owerf in tho ymr 2000, bofom me, tho undersigned, I~r~onally ap!~ed ..... ~(~,,~di~s) ~ ~s) i~ (~) ~lb~ ~ me wim[n ~t ~d ~ ~8~ to me mat ~ / she / th .,, · ~¥ , · · . . . ~ u~s.. __ -.- ~..._.. %~J~ ~ ~ I .. ',: . .... J ~CO~ ~ ~ ~: ~1~ ~, ~e ~~ Cou~el~ ~10 Eu~ Dfiv~ Legal Description \ \ VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts comained in the foregoing COMPLAINT for the Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: October 23, 2001 Leon P. Haller, Esquire SHERIFF'S RETURN CASE NO: 2001-06127 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS HERSHEY LINDA ET AL - REGULAR DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to taw, says, the within COMPLAINT - MORT FORE was served upon HERSHEY LINDA the DEFENDANT , at 1842:00 HOURS, on the 1st day of November , 2001 at 53 CARLA DRIVE SHIPPENSBURG, PA 17257 LINDA HERSHEY a true and attested copy of COMPLAINT - by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.35 Affidavit .00 Surcharge 10.00 .00 40.35 Sworn and Subscribed to before me this ~ day of ~ ~o~ A.D. ~r6thonoth~-~- So Answers: R. Thomas Kline 11/02/200 PURCELL KRUG & HALLER Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-06127 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS HERSHEY LINDA ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon HERSHEY BRIAN W the law, DEFENDANT , at 1842:00 HOURS, on the 1st day of November , 2001 at 53 CARLA DRIVE SHIPPENSBURG, PA 17257 LINDA HERSHEY, WIFE a true and attested copy of by handing to COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ ~ day of A.D. P~o~honota'r'y- ' So Answers: R. Thomas Kline 11/02/2001 PURCELL KRUG & HALLER By: Deputy Sheriff WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001 6127 : : IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $18.15 from 2/1/01 to 11/1/01) Late charges ($33.53 per month to 11/01) Escrow Deficit 5% Attorney's Commission TOTAL $88,338.70 $ 5,517.60 $ 268.24 $ 1,311.i6 $ 4,416.94 $99,852.64** ** 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, ~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\M KFADOCS\CU M B ERLA\H ERS h EY,P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 6127 WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $ 99,852.64 ~ Interest at $18.15 per diem to sale date $ 7,242.48 Late charges at $33.53 per month to sale date $ 201.18 Escrow Deficit $ 2,000.00 TOTAL $109,296.30' *SALE DATE: WEDS.,JUNE 5, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: March 12, 2002 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 53 CARLA DRIVE, SHIPPENSBURG, PA 17257. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:\MKF'tDOCS\CU M B ERLA\H ERSH EY.W ALL that certain lot of land situate in the Township of Southampton, County of Cumberland and the Commonwealth of Pennsylvanla, being Lot No. 29 in Section 3 in the development known as South Mountain Estates, said plan recorded in Plan Book 22, at page 25, bounded and described as follows: BEGINNING at a point in the Western edge of Carla Drive at comer of Lot No. 28 in said Development; thence by the ~Vestem edge of Carla Drive, South m"~eteen (19) degrees twenty-eight (28) minUtes thirty (30) seconds East, one hundred twenty (120) feet to a comer of Lot No. 30 in said Development; thence by Lot No. 30, South seventy (70) degrees thirty-one (31) minutes thirty (30) seconds West, one hundred fifty (150) feet to a point at other lands now or formerly of Joseph B. Hazzard, et ux; thence now or formerly of Joseph B. Ha~'ard, et ux, North nineteen (19) degrees twenty-eight (28) minutes thirty (30) seconds West, one hundred twenty (! 20) feet to a point at corner of Lot No. 28; thence by Lot No. 28, North seventy (70) degrees thirty-one (31) minutes thirty (30) seconds East, one hundred fifty (150) feet to a point in the Western edge of Carla Drive, the place~of beginning. CONTAINING 18,000 square feet, per survey ofJ. H. Rife, R.S. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. BEING THE SAME PREMISES WHICH Monarch Investments by corrective deed dated 4/3/98 and recorded in Deed Book 175 Page 42 granted and conveyed unto Brian W. Hershey and Linda Hershey. TO BE SOLD AS THE PROPERTY OF LIN-DA HERSHEY ~ BRIAN W. HERSHEY A/K/A BRIAN HERSHEY ON JUDGMENT NO. 2001 6127. PARCEL: 39-36-2436-019 WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LIN~A HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW ~ : : NO. 2001 6127 : : IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that'- on ~d~/3, ~2~ the following judgment has been entered against you in the above- captioned matter: $99,852.64 and for the sale and foreclosure of your property located at: 53 Carla Drive, Shippensburg, PA 17257 Dated: Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 - PROTHONOTKRY ~ £ I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Brian W. Hershey a/k/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 K:\MK F\DOCS\C UMB ERLA\HERSHEY,N WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6127 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $18.15 from 2/1/01 to 11/1/01) Late charges ($33.53 per month to 11/01) Escrow Deficit 5% Attorney's Commission TOT/fL $88,338.70 $ 5,517.60 $ 268.24 $ 1,311.16 $ 4,416.94 $99,852.64** ** Together with additional interesE 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~~~-~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\HI=RS HEY.P WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001 6127 : : IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVIC~ PURSUANT TO PA. R.C.P. 237.] I hereby certify that on DECEMBER 11, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug &Haller 1719 North Front St. Harrisburg, PA 17102 WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. LINDA HERSHEY AND BRIAN W. HERSHEY A.K.A. BRIAN HERSHEY Defendants : NO. 01-6127 .' : : : CIVIL ACTION LAW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : IN MORTGAGE FORECLOSURE : : DATE OF THIS NOTICE: December 11, 2001 LINDA HERSHEY 53 CARLA DRIVE SHIPPENSBURG, PA 17257 BRIAN W. HERSHEY A/K/A BRIAN HERSHEY 53 CARLA DRIVE SHIPPENSBURG, PA 17257 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 TIlE 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 HEARTNG 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCE~/./ff.,H~A~.~L ER By. ~ L/ ~----~ LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 WASHINGTON MUTUAL HOME LOANS : INC., SUCCESSOR IN INTEREST BY : MERGER TO FLEET MORTGAGE CORP., : PLAINTIFF : VS. : LINDA HERSHEY AND BRIAN W. : HERSHEY A/K/A BRIAN HERSHEY, : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6127 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUA/~T 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 53 CARLA DRIVE, SHIPPENSBURG, PA 17257: 1. Name and address of the Owner(s) or Reputed Owner(s): Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Brian W. Hershey a/k/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every jud~L,ent 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 39209 West Six Mile Road Livonia, MI 48152 Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: UNE_NOWN 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 Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) t verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2002 WASHINGTON MUTUAL HOME LOANS : INC., SUCCESSOR IN INTEREST BY : MERGER TO FLEET MORTGAGE CORP., : PLAINTIFF : VS. : LINDA HERSHEY AND BRIAN W. : HERSHEY A/K/A BRIAN HERSHEY, : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6127 IN MORTGAGE FORECLOSURE NOTICE OF SW~RIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 5, 2002 TIME: LOCATION: 10:00 O'clock A.M. 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: 53 CARLA DRIVE SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: 2001 6127 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact,' be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE F~?.n, 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 s o the w~thln-~~ -ther prOp~ .... n plea ~ ~rice or ~__r_~F, S DEED IS - -~ o~ Com~,~ ._~uate ~-- ~ S~m~ . sues or Cou~u ~roSSlY i~ED BEFOKm ~.E . ~e~al is ~ to the petit~u~ -~ ~on or pe%~_ ~aragraphS .... The petl~ ~or before . ' in ~ ~ the ' or o~ r enta°n~d - ~n pleas o~ _ the c~ed~t = order o ser~tation to ~"~. 'on. ate must be p~e~=? : ~ the petat~ . ~sired, sugh~Division, .o~ attacneu ~ ~ .... date ~s ,u~ice - CaV~i ~e ~etitxon ~eci~ic ret~)Z~%strator s ~tation o~ ~ II a ~ ~ Court Au~"-~fore a the wit~ln ~" ~ hereto · to the court, A copy o~ the writ o~ Execution is attached puRCELL, ~UG & Attorneys for plainti~ ~7~9 North Front Street PA ~7~02 Harrisburg' 234-4~78 (717) ALL that ccrtai~t lot of land situate in thc Township of Southampton, County of Cumberland and thc Conm~onwcalth of Pennsylvania, being Lot No. 29 in Section 3 in thc development known as South Mountain Estates, said plan recorded in Plan Book 22, at page 25, bounded and described as follows: point in thc Western edge of Carla Drive at corner of Lot BEGINNING at a No. 28 in said Development; thence by thc Western edge of Carla Drive, South rfi'r{eteen (19) degrees twenty-eight (28) minutes thirty (30) seconds East, one hundred twenty (120) feet to a corner of Lot No. 30 in said Development; thence by seventy (70) degrees thirty-one (31) minutes thirty (30) seconds Lot No. 30, South to a point at other lands now or formerly of Joseph West, one hundred fifty (150) feet B, Hazzard, et ux; thence now or formerly of Joseph B. HaT~,ard, et ux, North nineteen (19) degrees twenty-eight (25) minutes thirty (30) seconds West, one hundred twenty (120) feet to a point at corner of Lot No. 28; thence by Lot'No. 28, North seventy (70) degrees thirty-one (31) minutes thirty (30) seconds East, OPe ' hundred fifty (I 50) feet to a point in the Western edge of Carla Drive, the place of beginning. CONTAINING 18,000 square feet, per survey of J. H. Rife, R.S. H3IVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 53 CAR!M~ DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. BEING THE SAME pREMISES WHICH Monarch investments by corrective deed dated 4/3/98 and recorded in Deed Book 175 Page 42 granted and conveyed unto Brian W. Hershey and Linda Hershey- HERSHEY TO BE SOLD AS THE PROPERTY OF LINDA HERSHEY AND BRIAN W. A/K/A BRIAN HERSHEY ON JUDGMENT NO. 2001 6127. PARCEL: 39-36-2436-019 WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001 6127 : : IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have, deposited in the U.S. Mails at Harrisburg, Pennsylvania on ~/~/A~ , a true and correct copy of the Notice of Sale of Re~Yl 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. Service addresses are as follows: Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Brian W. Hershey a/k/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 Green Tree Consumer Discount Company 39209 West Six Mile Road Livonia, MI 48152 Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 Domestic Relations Office Cun~berland County Courthouse Hanover & High Streets Carlisle, PA 17013 By. 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 .IR. BRIAN .I. TYLER JILL M. WINEKA NOTICE TO: Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Brian W. Hershey a/k/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 Green Tree Consumer Discount C~mpany 39209 West Six Mile Road Livonia, MI 48152 Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 (717) 533-3836 JOSEPH NISSLEY (1910-1982) 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 against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, ~. being notified of said Sheriff's Sale. By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS : INC., SUCCESSOR IN INTEREST BY : MERGER TO FLEET MORTGAGE CORP., : PLAINTIFF : VS. : LINDA HERSHEY AND BRIAN W. : HERSHEY A/K/A BRIAN HERSHEY, : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 6127 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 5, 2002 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: 53 CARLA DRIVE SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: 2001 6127 THE NA~E(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact,- be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGmeNT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL that certain lot of land situate in the Township of Southampton, County of Cmnberland and the Conunonwcalth of Pennsylvania, being Lot No. 29 in Section 3 in the development known as South Mountain Estates, said plan recorded in Plan Book 22, at page 25, bounded and described as follows: BEGINNING at a point in the Western edge of Carla Drive at comer of Lot No. 28 in said Development; thence by the Western edge of Carla Drive, South nineteen (19) degrees twenty-eight (28) minutes thirty (30) seconds East, one hundred twenty (120) feet to a comer of Lot No. 30 in said Development; thence by Lot No. 30, South seventy (70) degrees thirty-one (31) minutes thirty (30) seconds West, one hundred tlf~y (I 50) feet to a point at other lands now or formerly of Joseph B. Hazzard, et ux; thence now or formerly of Joseph B. Hazzard, et ux, North nineteen (19) degrees twenty-eight (28) minutes thirty (30) seconds West, one huudred twenty (120) feet to a point at comer of Lot No. 28; thence by Lot No. 28, North seventy (70) degrees thirty-one (31) minutes thirty (30) seconds East, one hundred fifty (150) feet to a point in the Western edge of Carla Drive, the place of beginning. CONTAINING 18,000 square fect, per survey ofJ. H. Rife, R.S. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. BEING THE SAME PREMISES WHICH Monarch Investments by corrective deed dated 4/3/98 and recorded in Deed Book 175 Page 42 granted and conveyed unto Brian W. Hershey and Linda Hershey. TO BE SOLD AS THE PROPERTY OF LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY ON JUDGMENT NO. 2001 6127. PARCEL: 39-36-2436-019 Re: Washington Mutual vs. Hershey Cumberland Sale 6/5/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Foz~ 3877) Received from: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Brian W. Hershey a/k/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In cnmpliance with Postal Service Foim 3877) Received from: Purcell, Krug &Haller Postage: North Front Street 1719 Harrisburg, PA 17102 /~~ One piece of ordinary mail addressed Green Tree Consumer Discount Company 39209 West Six Mile Road ~~-~=~ ....... ~:-:~ U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comDliance with Postal Service FO~L~ 3877) Received from: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Postmark: WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Plaintiff vs. LINDA HERSHEY and BRIAN W. HERSHEY a/k/a BRIAN HERSHEY Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6127 CIVIL TERM IN MORTGAGE FORECLOSURE WAIVER OF NOTICE I, Leon P. Haller, Attorney for Washington Mutual Home Loans, Inc. Successor in Interest by Merger to Fleet Mortgage Corp. holding Subordinate Mortgage in the amount of $5,104.28 dated October 2, 2000 and recorded November 17, 2000, in Mortgage Book 1652, Page 855, having received Notice of Sheriff's Sale scheduled for June 5, 2002, hereby waives notice of said Sale as required under Section 3129.2 of the Pennsylvania Rules of civil Procedure. ~ ....... Dated: ~,,, ,, [[u~[t[,,,[, [,[nl[ t It4~ [[[lUt t[[l~ll[[ [~l{l[l[[{[l[[[~ II Illflll}{ll]llll~[ [[11 t[llS [[[[[{[ {Il IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Washington Mutual Home Loans successor in interest by merger to Fleet Mortgage Civil Division VS, : No. 2001-6127 Brian Hershey and : Linda Hershey SUGGESTION OF BANKRUPTCY To: Prothonotary Please note upon the record that Brian Hershey and Linda Hershey, the defendants in the above-captioned action, filed a Voluntary Petition in Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on May 30, 2002, at 11:14 o'clock A.M., which petition was docketed to 1-02-02953. PURSUANT TO THE PROVISIONS OF 11 U.S.C. §362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT(S). CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, attorney for the above captioned defendant(s) in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or attorney's of record as follows: Washington Mutual Home Loans Successor in interest by merger to Fleet Mortgage Corp. Po 6ox i,~,55'"/ Date: June 5, 2002 Purcell ~& Hailer Attm Esquire 767 Path Valley Road P.O. Box 51 Spring Run, PA 17262-0051 [717] 349-7657 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: J I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Washington Mutual Home Loans Inc sbm Fllet Mtg Corp is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 13th day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 6127, at the suit of Washington Mutual Home Loans Inc sbm Flleet Mtg Corp against Linda Hershey & Brian w aka Brian is duly recorded in Sheriff's Deed Book No. 254, Page 387. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /~ --~ day of ~- , A.D. 2002 ,Recorder of Deeds Washington Mutual Home Loans, Inc., Successor in interest by merger to Fleet Mortgage Corp. VS Linda Hershey and Brian W. Hershey A/k/a Brian Hershey In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6127 Civil Term David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2002 at 3:52 o'clock pm, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Linda Hershey, by making known unto Linda Hershey personally, at 53 Carla Drive, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2002 at 3:52 o'clock pm, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Brian W. Hershey a/k/a Brian Hershey, by making known unto Brian Hershey personally, at 53 Carla Drive, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 5, 2002 at 4:35 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Linda Hershey and Brian W. Hershey a/k/a Brian Hershey located at 53 Carla Drive, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Linda Hershey, by regular mail to her last known address of 53 Carla Drive, Shippensburg, PA 17257. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff's Office. 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: Brian W. Hershey a/k/a Brian Hershey, by regular mail to his last known address of 53 Carla Drive, Shippensburg, PA 17257. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Leon P. Haller for Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. It being the highest bid and best price received for the same, Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. of P.O. Box 1169, Dept. 2665, Milwaukee, Wisconsin 53201, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $923.17, it being costs. Sheriffs Costs: Docketing $ 30.00 Poundage 18.10 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 23.46 Certified Mail 1.81 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 363.05 Patriot News 270.55 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 29.50 $ 923.17 paid by attorney 10/11/02 Sworn and subscribed to before me This /7 ~o~ day of G[~d,_,_~ 2002, A.D.~ 'Prothonotary . t.~ R. Thomas Kline, Sheriff Real Estate~Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-6127 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLANTIFF(S) From LINDA HERSHEY AND BRIAN W. HERSHEY A/FdA BRIAN HERSHEY (I) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION OF PROPERTY (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 garmshee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If pr°perty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount DueS99,852.64 L.L.$.50 Interest AT $18.15 PER DIEM TO SALE DATE $7,242.48 Atty's Comm % Due Prothy $1.00 Atty Paid $128.35 Other Costs LATE CHARGES AT $33.53 PER MONTH TO SALE DATE $201.18 ESCROW DEFICIT $2,000.00 Plaintiff Paid Date: MARCH 13, 2002 REQUESTING PARTY: Name LEON P. HALLER, ESQ. Address: 1719 N. FRONT ST. HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 CURTIS R. LONG Prothonotary, Civil Division By: Real Estate Sale On March 14, 2002 the sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA known and numbered as 53 Carla Drive, Shippensburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2002 By: Real Estate Deputy WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001 6127 : : 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 th~ daze the praecipe for the writ of execution was filed, the following information concerning the real property located at 53 CARLA DRIVE, SHIPPENSBURG, PA 17257: 1. Name and address of the Owner(s) or Reputed Owner(s): Linda Hershey 53 Carla Drive Shippensburg, PA 17257 Brian W. Hershey a/K/a Brian Hershey 53 Carla Drive Shippensburg, PA 17257 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Green Tree Consumer Discount 39209 West Six Mile Road Livonia, MI 48152 Company Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record llen on the property: U19F~NOW'N 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 Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements.made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Beon P. Haller PA r.D. #1S700 Purcell, Krug &Haller 17:1.~ North ~ront Street Harr±sburg, Pg. 17102 (717) 23~-~178 DATE: March 12, 2002 WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND C.OUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001 6127 : : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: TIME: LOCATION: WEDNESDAY, JUNE 5, 2002 10:00 O'clock A.M. 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: 53 CARLA DRIVE SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA sold THE JUDGMENT under or pursuant to which your property is being is docketed in the within Commonwealth and County to: 2001 6127 THE NAME(S) OF THE OW'N-ER(S) OR REPUTED ONNERS of this property is: LIN-DA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact,~ be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL that certain lot of land situate in the Township of Southampton, County of Cumberland and the Commonweallh of Pennsylvania, being Lot No. 29 in Section 3 in the development known as South Mountain Estates, said plan recorded in Plan Book 22, at page 25, bounded and described as follows: BEGINNING at a point in the Western. edg~0f Carla Drive at corner of Lot No. 28 in said Development; thence by the Western edge of Carla Drive, South nineteen (1,9) degrees twenty-eight (28) minutes thirty (30) seconds East, one hundred twenty (120) feet to a comer of Lot No. 30 in said Development; thence by Lot No. 30, South seventy (70) degrees thirty-one (31) minutes thirty (30) seconds West, one hundred fifty (150) feet to a point at other lands now or formerly of Joseph B. Hazzard, et ux; thence now or formerly of Joseph B. Hazzard, et ux, North nineteen (19) degrees twenty-eight (28) minutes thirty (30) seconds West, one hundred twenty (120) feet to a point at corner of Lot No. 28; thence by Lot No. 28, North seventy (70) degrees thirty-one (31) minutes thirty (30) seconds East, qne hundred fifty (150) feet to a point in the Western edge of Carla Drive, the place of beginning. CONTAINING 18,000 square feet, per snrvey ofJ. H. Rife, R.S. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 53 CARLA DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. BEING THE SANE PREMISES WHICH Monarch Investments by corrective deed dated 4/3/98 and recorded in Deed Book 175 Page 42 granted and conveyed unto Brian W. Hershey and Linda Hershey. TO BE SOLD AS THE PROPERTY OF LINDA HERSHEY AND BRIAN W. HERSHEY A/K/A BRIAN HERSHEY ON JUDGMENT NO. 2001 6127. PARCEL: 39-36-2436-019 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-Newe and The ~3~t~i~c~[~E~ 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 Mamh 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COPY ~ ~ ........ .................................................. ~worn [o an{3 suDscr~Deo Demre ma t~7th day o~ ~ A.D J Harnsou~, uauphin Coun~ I ' ~ . / ' - - J ayCommissi~E~iresJune6,2~2 .J NOTARY PUBLIC M~r, Penns~anla ~a~n of ~ta~Y commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 268.80 $ 1.75 $ 270.55 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The un a Patriot-New , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA · COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 26, MAY 3, 10, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 47 Writ No. 2001-6127 Civil Washington Mutual Home Loans, Inc., Successor in interest by merger to Fleet Mortgage Corp. ',rs. Linda Hershey and Brian W. Hershey, a/k/a Brian Hershey Atty.: Leon p. Hailer ALL that certain lot of land situ- ate in the Township of Southampton, County of Cumberland and the Corn monwealth of Pennsylvania, being Lot No. 29 in Section 3 In the devel- opment known as South Mountain Estates. said plan recorded in Plash Book 22, at page 25, bounded and described as follows: BEGINNING at a point in the Western edge of Carla Drive at cor- ner of Lot No. 28 in said Develop R ~/~ Editor ~genthal, SWORN TO AND SUBSCRIBED before me this 10 day of MAY, 2002_ i3Pian Hershey Atty.: Leon p. Hailer ALL that certai~ lot of land situ ate tn the Township of Southampton County °fCumberiand and the Com~ monwealth of Pennsylvania, being Lot No. 29 in Seetlon 3 in the devel opment Mmwn as South Mountain Estates, said plan recorded tn Plan Book 22, at page 25, bounded and described as follows: BEGINNING at a potnt in the Western edge of Carla Drive at car ncr of Lot No. 28 in said Develop merit; thence by the Western edge of Carla Drive, South nineteen degrees twenty-eight {28) minutes thirty {BO) seconds East, one hun- od[2tt~o~l~ (120)feet to a corn.. thence b2 ~0 In s~d Develol>me~'~- enty (70} de-r .... oouth sev- m' . s ecs thirt o~res thirty (BO) sec~ ~One (B 1) ~ mmdred fifty tl~,.~ ~ .,nus West, at other lan.~.'~ ~ au/ieet to a Oolnt OO eph B. for. erl'y y at Joseph 13. ~(~so, et ux, North ntneteen I ,twenty-eight (28) m/n -(9) de- r u~ Seconds W~ * Utes thLr- twenty (120) feet ~st, any hUndred ~er of Lot No 28 o. 28 No.~ ' , uience by Lot ~hlrty one {31) nlin~tYte (7~? degrees ~econds East ~._ ~s dllrty (30) (150) feet to a ' -~c ~lUndred f/ltv ~edge of Car a ~)O~]l~t In the Wester~ ueginnthg. CoN~V.e., the place of square feet --^ I'~IINING 18 l~.s. . ~r survey ofj. ~. ~;e.~ BEING THE S *u~. 17257. WHICH MOnarch/A~mE PREMISES corrective deed ~ .ri.Vestments by ~ granted and co ~ it'$ Page W. Hershey and .n,Vey. ed Unto Brian :.~ w. HERSHEy --~ ~u~D BRI /~ERSHEy ~.. ' &/K/A BRIA~J