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HomeMy WebLinkAbout04-0387 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FORPLAINTWF WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 04 -3P7 e.;u~L '--r~ v. CUMBERLAND COUNTY SEAN G. HARPOLD 824 HILLSIDE DRIVE CAMP HILL, PA 17011 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. W YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. W YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 86093 File #: 86093 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL EST ATE. 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known addressees) of the Defendant(s) are: SEAN G. HARPOLD 824 HILLSIDE DRNE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 0411 8/200 [ mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CHARTER ONE MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1695, Page 803. By Assignment of Mortgage recorded 4/29/02 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 686, Page 4064. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 86093 , 6. The following amounts are due on the mortgage: Principal Balance Interest 07/0112003 through 01/29/2004 (Per Diem $19.53) Attorney's Fees Cumulative Late Charges 04/18/2001 to 01129/2004 Cost of Suit and Title Search Subtotal $106,110.22 4,159.89 850.00 191.11 $ 750.00 $ 112,061.22 Escrow Credit Deficit Subtotal 0.00 506.63 $ 506.63 TOTAL $ 112,567.85 7. 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. 8. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 112,567.85, together willi interest from 01/29/2004 at the rate of$19.53 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: FEDERMAN AND~. E. ~P /ZA - \ /s 'r~. al'a FRANK F DERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 86093 ALL 'rIUl.T CERTAIN ernet or parcel of land and premises, situate. lying an1 being in the llol:01.\9h of wo>:mleyo!)..,.-g in t~e County of Cumberland and commonwealth of Pennsylvania, more particularly described aa fOllo~a: 9EGINNING at a point on the western line of Hillside Drive, tWO hUndred nin~e(.two and eight one-hundredths (29~.D8) feet measured nor=hwardly along said line from the nor~hern line of Poplar ChAron Road; thcnce South fifty-three (53) dea~e~ thi~ty (3l1 minutes west, one hundred thirty (130) feec ~o a poinc i~ the Ca~~erD bound~ry line of Lot numbered Fifteen (~51 I thenee North thirty-six (3~) degrees thirty (3D) lII1nut.,s west, along tile "'aatern boundary line of Lot numbered Plfteen (1SI. eighty-two (82) feet to a point; thence Nor,b fifty-three (53) degreea thirty (30) minutes East, one hundred thirty (130) fee~ to a paine in the west.C&:n line I,f Hillside Drive; thence by t:he lal:.terf south thirty-six t36) degree" thirty (30) minuteD E~ot, eighey~two (82' ftlet to a point., t:he place of BEG:INNING. BIllING the Jlortbern dxty (~O) feet of LOt numbered Ten (101 and the southG= t~nty.tl#O (22) feet of Lot numbered Eleven (11) , on the plan of section ftB", Kivarview, said plan being recorded in the plan Book. lO, page 21. UNDER ,l\ND StnlJllCT, nevertheless, to Building and Use Restrictions as s~~ forth in instrument dated Septembar 4, ISS8, recO~~od in Misc. BOOk 136, p~ge 338 (erroneously Set fo>:tb as PIll;!e 388 1n prior record), which ...,..c hereby extended to cover such portions of the land herein described, ~ot o>:iginallY covered and eo utility easements in favor of Pellllaylvania power and Light Company an.! Bell Telephone C.)~ny ss ahown in inlll;ruments of prior >:eco;ro. BEXNG the s.une premises whieb F~Bncea s. Fogarty, II widow, by deed da~dd ~ 10, 19'6 and reoorded in the Office of tile Recorda:: of Deed" in and' fO%' CUmberland C01.Wty. PeIUUlylWlnin, in Deed !look 139, Page 227, granted and conveyed 1001:0 Daniel J. lIeat and oilUle C. Bast, hl.llll:l"nd and ",i.eel grBneu~B hereta-. BEING KNOWN AS: 824 HILLSIDE DRIVE. VERlFlCATI01\l Yolanda Williams hcreby statcs that shc is VICE PRESIDENT LOAN DOCUMENTATION of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mongage Foreclosure are true and correct to the best of her knowledge, information and belief The undersigned understands that this statement is made subject to the penalties of] 8 Pa. C S Sec. 4904 relating to unsworn falsification to authorities DATE Id(C~ Vicc Presidcnt Loan Documentation }j GJ ~ 0 ...., ,- c-" ft- ~ ~. ~~ (~ 0 0 p'--; ~..~. ~- ., '- =? ." ?- - fli ::1 -- CI'l ~'j w -q~ 't: W <::> ::rJ 0 G ....} PJ 0 (: ".. ::::! ~ ~ ~ ," ~ i:j:'8 -u '.,j --'" ~ 6"- ::- <2 ,;''"('J ::'2 orri -....} N p:: .::- :.;! ~ ::-.0 -< "'--(~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-00387 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HARPOLD SEAN G R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HARPOLD SEAN G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , HARPOLD SEAN G 824 HILLSIDE DRIVE CAMP HILL, PA 17011 824 HILLSIDE DRIVE CAMP HILL IS VACANT. DEFENDANT DOES NOT LIVE AT THAT ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 11.04 5.00 10,00 .00 44.04 /7 So a~~"'-:::/ ~~~/. -- R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/17/2004 Sworn and subscribed to before me this lYe!;:, day of ~ clM'( A.D. Sk... / u..- f2 ~ II P. ----- Pr t onotary ,"h SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00387 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE TNC VS HARPOLD SEAN G R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HARPOLD SEAN G but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On March 17th, 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 25.50 .00 50.50 03/17/2004 FEDERMAN & PHELAN So . an~.~e...E J::~.s'. . .'. :..../..;,...------;:;;.7 ../;::P"~~' R. (Thomas JQ ine Sheriff of Cumberland County Sworn and subscribed to before me ... this /1- day o~ ,2.t.Jr.J1f A.D. q... '{,4 ~. (). ~ A.Jft1/' .. / Prothonotary ,T J In The Court of Common Pleas of Cumberland County, Pennsylvania Wells Fargo Home Mortgage Ine VS, Sean Harpold SERVE: same No. 04-387 civil Now, JanuarY 30, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~ y.;p;' r ';7~~~..~;;...I> , Sheriff of Curnberland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ @ffb:e of tlr~ ~4~riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17 I 0 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania WELLS FARGO HOME MORTGAGE INC vs County of Dauphin HARPOLD SEAN G Sheriff's Return No. 0437-T - -2004 OTHER COUNTY NO. 04-387 AND NOW:March 9, 2004 at 3: 37PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon HARPOLD SEAN G by personally handing to SEAN G HARPOLD 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at DAUPHIN DAUPHIN HBG, PA CO SHERIFF'S OFFICE ROOM 104 CO COURT HOUSE FRONT & MARKET ST 17102-0000 before me this 10TH day of MARCH, 2004 ~~~'\~~ ( PROTHONOTARY So Answers, Jf~ ::"~:~ 7;'Y' ::J Deputy ~ Sworn and subscribed to Sheriff's Costs: $25.50 PD 02/04/2004 RCPT NO 187676 KH FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., rd. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., rd. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (2 I 5) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INe. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND County SEAN G. HARPOLD No. 04-387 CIVILTERM Defendants PRAECIPE TO REINSTATE CIVIL ACTIONfMORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: March 29. 2004 Ijrh. Svc Dept. (') ~. -cl~h n'll>'.! ~t~;: ~~. ~(.::) ).;..~; ==3 ~ ..... <= = .=- :x - :::tl W o i'. "f1 " ~p ~~ :r:3J stq 01 --I .".. ::0 ~ -u :x ~ ..0 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00387 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HARPOLD SEAN G R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HARPOLD SEAN G but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On April )9th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County .00 .00 37.00 04/19/2004 FEDERMAN & PHELAN Sworn and subscribed to before me this :</.Ak day of ()~ ,)ovY A.D. (I 1"'- Q )Mj,. ~ AlA, N Prothonotary - @ffice of tIre ~lrc:riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17l 0 I ph: (71 7) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania WELLS FARGO HOME MORTGAGE INC vs County of Dauphin HARPOLD SEAN G Sheriff's Return No. 2859-T - -2004 OTHER COUNTY NO. 04-387 AND NOW:April 13, 2004 at 8:26AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon HARPOLD SEAN G by personally handing to SEAN G HARPOLD DEFT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at DAUPHIN CO SHERIFF'S OFFICE ROOM 104 DAUPHIN CO COURTHOUSE FRONT & MARKET STS HBG, PA 17101-0000 Sworn and subscribed to So Answers, C;R~ before me this 14TH day Of~RIL, 2004 Stif9 rl (\, . , ~)!' "1 f/ ,~1 f I' .t. ,1"1 .AI"I.... ') . - ~,. 'J ,......... , (. (,e'r,.{'l w..-U , Sheriff of Dauphin County, Pa. PROTHONOTARY By \) ( ~put Sheriff's Costs: $0.00 PD 00/00/0000 RCPT NO KH FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHlLADELPHlA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-387 CIVIL TERM SEAN G. HARPOLD Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against SEAN G. HARPOLD, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale oftlae mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/30/04 to 5/18/04 TOTAL $112,567,85 $2,148.30 $114,716.15 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~)uiu~J FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: rn."'f. ~O ~OO'l e~;,)K.. ci<~ I PROPROTHY ~ ~ FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71 ';) ';/i1-7000 WELLS FARGO HOME MORTGAGE, INC. Plaintiff FILE COpy ATTORNEY FORPLAINTWF : COURT OF COMMON PLEAS : CIVIL DMSION Vs. : CUMBERLAND COUNTY SEAN G. HARPOLD Defendants : NO. 04-387 CIVIL TERM TO: SEAN G. HARPOLD 824 IDLLSIDE DRIVE CAMPIDLL,PA 17011 DATE OF NOTICE: MAY 4, 2004 TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. TIllS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.W YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITIl THE COURT YOUR DEFENSES OR OBJECTIONS TO TIlE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~rlMrlu~ FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71 'i) 'i61-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INe. Plaintiff : COURT OF COMMON PLEAS : CML DIVISION Vs. : CUMBERLAND COUNTY SEAN G. HARPOLD Defendants : NO. 04-387 CML TERM TO: SEAN G. HARPOLD 255 CUMBERLAND STREET HARRISBURG, PA 17102 DATE OF NOTICE: M A V 4. 2/1/14 THIS FIRM IS A DEBT COLLECfOR ATTEMPTING TO COLLECf A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECf THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECf A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 OBJECfIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~l.p..1l..I'N..fiJJL FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff @ffice of t1rP~1rpriff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin COWlty Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (71 7) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania WELLS FARGO HOME MORTGAGE INC vs County of Dauphin HARPOLD SEAN G Sheriff's Return No. 2859-T - -2004 OTHER COUNTY NO. 04-387 AND NOW:April 13, 2004 at 8:26AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon HARPOLD SEAN G by personally handing to SEAN G HARPOLD DEFT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at DAUPHIN DAUPHIN HBG, PA CO SHERIFF'S OFFICE CO COURTHOUSE FRONT 17101-0000 ROOM 104 & MARKET STS /1.,. ii > ~_t_"""'A ':, ~" JlJ~(..V>t(?,/]t)' : t""./i;:J ,/"\ \-!"p"'~". Oftdl>,RIL, 2004 f I I' L/..,' -\ '-1'~ . t: t1,1:~ " 1~\t ,:"'- ... ( .' (<,~,;t.~,.::V;;""L.../ So Answers, JR~ Sworn and subscribed to before me this 14TH day Sheriff of Dauphin County, Pa. PROTHONOTARY By \ )~~ ,/..; Deput ( Sheriff's Costs: $0.00 PD 00/00/0000 RCPT NO KH t~\~ _ C> .Q- --- w D I" ~ "'l ~ ~ Q ~ _ --0 j;)> 1::J G -----z-:t::. :', ~-') ~::) C) ~~ ." --1 ~'r .' ;'-.) :-~' 23 c:: ' c;) CJ , . , 1'......1 (}', <" FEDE~ANandPHELAN,LLP By: FRANKFEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DMSION v. NO. 04-387 CML TERM SEAN G. HARPOLD Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant SEAN G. HARPOLD is over 18 years of age and resides at, 824 HILLSIDE DRIVE, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~r(, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c: -,;-, ---I ;,1 ',) Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center MAY -18-2004 10:46:21 _ Military Status Report . Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 <Last Name Pirst Middle Begin Date I Active Duty Status I Service/Agency HARPOLD Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status ofthe Defendant(s), per the Information provided, as to all branches of the Military. ~( Kenneth C. Schetlen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization ofthe Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to~cra.helpdesk@osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https:/ /www.dmdc.osd.mil/udpdri/owalsscra.prc _Select 5/18/2004 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION SEAN G. HARPOLD NO. 04-387 CIVIL TERM Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ fL FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~., '. -,' '.-) ~n '---' I') 0_ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO HOME MORTGAGE, INC. Plaintiff, v. No. 04-387 CIVIL TERM SEAN G. HARPOLD Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $114,716.15 Interest from 5/19/04 to SEPTEMBER 8, 2004 (per diem -$18.86) $2,131.18 and Costs TOTAL $116,847.33 ~ R,-.. ~cl.iJ\J"Y"t.lLN.. , FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. '..0 ("'oj ,--, ,-, ~ (::) (>J ~:: ,_. Lt_ c::, o c;-, ,-, r...:S u z O~ z 0 "'> .... .... ~'"" r.J Eo< i. r-l;.. '" ~ '""", ~ U ~z ~'E' Zz '" ~ ~~ Or-l !:r1 '"" r-l = 0 '" I:: ~~ r.. 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(Y) -.J 't ~ ~ '-> (:::t ()J AL.L THAT CERTAIN Iract or parcel of l$lId and premises, situale, Iyin! and beiDJ in tho Borough of Wormley,burg in tho CoWley of Cumberland and Commonweallb of Pennsylvunia. lOOre particularly described lIS follow,: BEGINNING at a IlOint un the W."lerD line of Hillside Drive, two hundred nincIy-two al1d elgbl 0(1(- hundredths (292,08) feci measured Northwardly along said line from ~ NOI'tIIem line (If Poplar CllUrch Road; thellce Soutb f.f1y-three (53) degrees thirly (30) minutCll WOSt, OIle hundred thirty (130) feet ((I a pOint In the Eastern boundary line of Lot Numbr:red p\l\een (15); thence North tbiny-llix (3(.) degrees thirty (301 minutes We!:!, alllDg tbe Eastern boundary line Of Lot Numbered Fifteen (15), eigllty-tWO (82) feel. ro a point; thtnce NOM fifly-th,ee (53) degrees thirty (30) minutell E.a$t, oDe hundred Ibirty (130) feet to a poim in the Weslel1lline of Hillsid. Drive; thtnce hy tbt latter, Sonlll thirty-six (3(i) degrees U1irty (3Q) minutes &st, eighty-two (82) feet ((I a poi1\t, \be plllCe of ~ing, TI1'LE TO SAID PREMISES (S VESTIID IN Sean <.t Harp<Jld, Single Person by Dee<J from Daniel], Iklit IlIId Diane C, Ilesr, Hi. Wife dated 1115fL999 and recordtd 1/27/1999 in R.t.:ord Book 204 Page 636, Tax Parcel #47..18-1302-153 WRIT OF EXECUTION and/or ATT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-387 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To ,atisfy tho debt, interest and cost, due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From SEAN G. HARPOLD (I) You are dirocted to levy upon the property of the defendant (sland to ,ell SEE LEGAL DESCRIPTION (2) You are also directod to attach the proporty of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garni,hoe(s) that: (a) an attachment 00, been issued: (b) the gamishee(s) i, enjoined from paying any dobt to or for the account of the defendant (,) and from delivering any property of the defendant (,) or otherwise dispo,ing thereof: (3) Ifproperty of the dofondant(s) not levied upon an ,ubject to attachment i, found in the possession of anyono other than a named garnishee, you aro directed to notify himlher that he/she has boen added as a garnishee and i, onjoined a, above stated. Amount Due $114,716.15 L.L. $.50 Interest FROM 5/19/04 TO 9/8/04 (PER DIEM - $18.86) - $2,131.18 AND COSTS Atty', Cornrn % Due Prothy $1.00 Atty Paid $213.54 Other Co,t, Plaintiff Paid Date: MAY 20,2004 (Soal) CURTIS R. LONG Prothono~ ~A/Jlh.. ~ .?f~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 WELLS FARGO HOME MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS SEAN G. HARPOLD CIVIL DIVISION Defendant(s). NO. 04-387 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) WELLS FARGO HOME MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 824 HILLSIDE DRIVE, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) SEAN G. HARPOLD 824 HILLSIDE DRIVE CAMP HILL, P A 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4, Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GMAC MORTGAGE CORPORATION D/B/A DlTECH.COM 3200 PARK CENTER DRIVE, SUITE 150 COSTA MESA, CA 92626 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7, Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 824 HILLSIDE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties ofl8 Pa, C,S, Sec, 4904 relating to unsworn falsification to authorities, Mav 18.2004 DATE _~Ostk &()~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 1"'.,.' c:.:.. C) "::q .--1 i'j f'.) <.;c' C) r " ..-., r-,,) {) , WELLS FARGO HOME MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 04-387 CIVIL TERM SEAN G. HARPOLD Defendant(s). May 18,2004 TO: SEAN G. HARPOLD 824 HILLSIDE DRIVE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 824 HILLSIDE DRIVE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8. 2004 at 10:00 a,m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of$114.716.15 obtained by WELLS FARGO HOME MORTGAGE. INC. (the mortgagee) against you, In the event the sale is continued, an announcement will be made at said sale in compliance with Pa,R,C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling (215) 563-7000, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, Yon have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house, A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within 30 days of the sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 AL.L THAT C1lltTA1N trlll:t or pan:el Qf land and premi.es, Sil\lale. lyill3 and bei.llJ in tho Borough of Wormleysburg in tho CoUllty of Cumberland and Comlllonwealth of rennsylvaui8, lIlO<<l particularly described as follows: BEGtNNING at a point OOlite Wester1l11ne of Hillside Drive, two hundred ninety-two and eighl one- hUlldrO.llbs (292,(}8) feci measured Nonhwardly along said line from tile: Northern line of Poplar Clrul'Ch Rood; lheuee Soutb fifty-three (53) degrees thirty (30) minUICll West. one hundred thirty (130) f.~ to a point in tho E:al;tern boundary line of Lot Numbered foil\een (15); thence North thirty-six (36) degrees thiny (30) minults WC1rt. aJoog tile Eastern boundary Ii"" of Lot Numbered Fifteen (15). eighty-tWO (82) feCllo a point; thtnce North fifly-lbrec: (53) degrees thirty (30) rninutes Ea.<I, ODe hundred Winy (130) feci 10 a point In the Western lillC of HilIsid. Drive; thence by the taller, Soo\tllhlny-si~ (36) degrees thirty (30) minutes East, eighty-two (82) feet to a point. /be pllice cf beginning. TlTLE TO SAID PKEMlSES IS VESTFO IN Sean (I. Harp<lld. Single Person by Deed from DanIel J, lleM and Diane C, IksI, His Wife dated 7/15/1999 and recorded 7/2711999 in Rt:COrd Book 204 Page 636, Tax ~l #47-18-1302-153 l""-,") ;~-_i; ...~) --4--- -11 ;:.-j 1;1 ".) C,) i',,) Li\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO HOME MORTGAGE, INC, ) CNIL ACTION ) vs. SEAN G, HARPOLD ) CNIL DNISION ) NO, 04-387 CNIL TERM AFFIDAVIT OF SERVICE PURSUANT 110 RULE 3129 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for ~~LLS FARGO HOME MORTGAGE. INC. hereby verify that on MAY 24. 2004 true and correct copies ofthe Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: August 13.2004 ~-t~ F NK FEDERMAN, ESQUIRE Attorney for Plaintiff ~: i\'~\<,'" ." :<<<-" ...", .:"~-~ m", H ';l " e~ ~ 1 o ~ 1:' ~ :,. 3. ~ (;g~g.g-~ ~~a~~ ~ii6' 5l8- f:@ ~~~~E- ~ 8.~. a C". iii VJ 3 ..... g g. ~e~s,~ - -....,,::1 ....., Q"~.8 0 ~ H8h 0:;'-<:,& g.~ a."o.... a",e O~gn[. e =0 <.'> Po. s,~~g g ... ~ g ~&~~~ ~8gJ5f ~i a-::T. .... ~ tI1 ('> " 3<; ~ 1l!lm~ li . '" 5" [~~~ il" ~g. :::.:~. go 0 ~~~O[ o. " ~.~ -~. g.n@n .gg8[ g.~~ if g"O l'; :::: =~ g.~ I;;"'=:r ~ :: il ~ o ~. . ~ ~ g r r.n ;:! ~ ~ a "..3 tl a~5' g t;;" ~ 8- ~~g~ R"1li oQ ;:: ~ 8." ~~'g~ ~1li'i1f o g 0' ~ "'.... "'.., -.0 g g " z '-0 t;;" 9 ~~ ~. ",' ~ g, ~ . ;:. ~ "'.., ~E :;:-z ~~ "', ~ 0 -~ o~ ~a ~ '" :;;: ~ w ~ N '" ~ p g o 5 o>~ r-< ..., Q. 8 s. [JJQ. ~ .. ... .. w N '" = .. ~ '" ... Q.l:l " '" ~ \0 00 ~ Q. 0 )> 3: n co Z l: 3 0' co ., () is z e"2i~0 ;;:J . ffi~ ~ fl $"-.J"t:lt'd ~ ~ g, ~~g~ ,. ?() ~ ~ ~ ~ e:..,.,o~ \:6 ~ ~ "'. '" \0::<> 0 ~ .' ~i~~ N...., R ~ ~ Rio ~ - a "'> ~ ~ r ~8..CI:l"'t1 0 ::l >> O'<g.::r: il. t!1 ~ ~ .. t~~f!1 ~ ~ OOl:<:Ti;; 00 ." ~ ~ ~(f~~ N t!1 ... Z " C/:!' ~ ~ ~ i ,. ~ 8. .tt-. ~ ~.. D-. t""-l ;$ ~ ... 0'" r-< . ...., s . '-<C/:!O> - ~ ~ . " ...., _. t!1 ~ ... " 1:1 1:1 .. - tD ~ .gi5 ;;; 1:1 !l 0 1:1 ~ () ~ ~ ~ ~ n ~ --< ~ q ~ w 0 ~ w ~ 'TO N 0 ~ 0 ~ :iJ ~ " 0 ~ ~ ~ - g ." ~ ~ 0 tXl '" 0 ...., ~ :>< ~ N !?) .'" ,"'" '" ~ ~ ~ ~ - t!1 '" ~ ~ ~ '" 0 () ~ 0 .0 ::; '" ~ ~ ;2 ~ w " 0 '" ~""TES~ '" i " ~f(~\ II .~ - '0 '~"""J~ 02,< ~~~_"" 00.. $ "<, ,n"J 01 414/(10 OOd 1, A "<00 OPf? 14y" Oli.1,ztp .::.':; 'Of") ~ cOD _" "Iq 'E: i9103 . ;;; C) .;.:;? -n 0;- ,~ '(:::. l:n Cf' (~) r,' r<; " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: D~-3't7 I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby ce ify that the Sheriffs Deed in which Deborah Krekstein is the grantee the same having been sold to sa grantee on the 8th day of September A.D., 2004, under and by virtue of a writ Execution issued on th 20th day ofMav, A,D" 2004, out ofthe Court of Common Pleas of said County as of Civil Term, 200 Number 387, at the suit of Wells Fargo Hm Mtg Inc against Sean G Harpold is duly recorded in Sheri s Deed Book No, 266, Page 4546 IN TESTIMONY WHEREOF, I have hereunto s t my hand lit and seal of said office this ~ day o~ ,D, 20~, '. Wells Fargo Home Mortgage, Inc. VS Sean G. Harpold In The Court of Common Pleas of Cwnberland County, Pennsylvania Writ No. 2004-387 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that e made a diligenl search and inquiry for the within named defendant, to wit: Sean G. Harpold, but was unable to locate him in his bailiwick. The residence at 824 Hillside Drive, Camp Hill, PA 17011 is vacant. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law, DAUPHIN COUNTY RETURN: And Now: July 2, 2004 at 7:52 o'clock A. " served the within Real Estate Writ, Notice and Description upon Sean G, Harpold by personally handing to defendant one lrue attested copy of the original Real Estate Wri Notice and Description and making known to him the contenls thereof at Dauphin County Sheriffs Office, Harrisburg, PA 17108. So Answers: J.R. Lotwick, Sheriffo Dauphin County, Pennsylvania. Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that n July 13, 2004 at 3:32 o'clock P.M., he posted a true copy of the within Real Estate Wr t, Notice, Poster and Description, in the above entitled action, upon the property of Sean G. Harpold located 824 Hillside Drive, Camp Hill, Pennsylvania, according to law. R, Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within name defendant, to wit: Sean G. Harpold, by regular mail to his last known address of255 Cumberland Street, Harrisburg, P A 171 02. This letter was mailed under the date of J y 13,2004 and neverreturned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 8, 2004 at 10:00 o'clock A,M. He sold the same r the sum of$102,000.00 to Attorney Gary Lysaght. It being the highest bid and best p ce received for the same, Attorney Gary Lysaght of 1350 Fishing Creek Road, Harrisbur PA 17112, being the buyer in this execution, paid to SheriffR, Thomas Kline the sum of $106,853.60. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed $30.00 2040,00 15,00 15.00 30.00 Auctioneer Law Library Prothonotary Mileage Out of County Dauphin County Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 10.00 .50 1.00 11.10 9.00 26.25 15.00 20.00 232.85 242.14 30.49 25.00 39.50 $ 2792.83 Sworn and subscribed to before me This Sul daY,of(~ 2004;' A.D.:Wr6' () 'n1,j1P-,<.-' Aflti1 r thonotary ~~~~#~ R. Thomas Kline, Sheriff BY~l,.!.J"..~ Real ~Deputy ~ ,tP 30' v \.~ )3 Ck... <; 7 12"", i n'l? . SCHEDULE OF DISTRIBUTION SALE NO. 39 Date Filed: October 08, 2004 Writ No. 2004-387 Civil Term Wells Fargo Home Mortgage, Inc. VS Sean G. Harpold 824 Hillside Drive Camp Hill, P A 17011 Sale Date: Buyer: Bid Price: September 08, 2004 Attorney Gary Lysaght $102,000.00 Real Debt: Interest: Attorney Costs: $114,716.15 2,131.18 213,54 Total: $117,060.87 DISTRIBUTION: Receipts: Cash on account (06/10/04): Cash on account (09/08/04): Cash on account (09/22/04): Total Receipts: $ 1,500.00 100,000.00 6,853.60 $108,353.60 Disbursements: Sheriffs Costs Legal Search State Transfer Tax Local Transfer Tax Borough ofWormleysburg Attomey Frank Federman Wells Fargo Home Mortgage, Inc, $ 2,792.83 200,00 1,306.80 1,306.80 481.60 1,500.00 100,765.57 Total Disbursements: ($108,353.60) Balance for distribution: 0.00 So Answers: c~~~ R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTOR EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 39 Held Wednesday, September 8, 2004 Date: September 8, 2004 TAXES: Receipts for all taxes for the years 2001 to 2003 inclusive, Taxes for the CUffe year 2004. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or se Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims, MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below, JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2004, and recorded , 2004, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Daniel J, Best and Diane C. Best by dee daled July 15, 1999 and recorded July 27, 1999 in the Office of the Recorder of Deeds in nd for Cumberland County, at Carlisle Pennsylvania, in Deed Book 204, Page 636, grant d and conveyed to Sean G. Harpold, single person.. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should b established to the satisfaction of the closing attorney acting for this Company. 2, Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage i area and encroachments which an accurate and complete survey would disclose, 4, Payment of State and local Real Estate Transfer Taxes, if required, 5, Public and private rights in the roadbed of Hillside Drive. 6, Building conditions, easements, and setbacks as shown on or set forth on the Plan of Riverview recorded in Plan Book 10, Page 21. 7. Building and use restrictions for Riverview recorded September 4, 1958 in Miscellaneous Record Book 136, Page 338, 8. Mortgage in the amount of $108,850.00 given by Sean G. Harpold to Charter On Mortgage Corporation dated April 18, 2001 and recorded April 26, 2001 in Mort age Book 1695, page 803, Said mortgage was assigned to Wells Fargo Home Mortg ge, Inc. by instrument recorded April 26, 2001 in Miscellaneous Record Book 686, ge 4064. Complaint in mortgage foreclosure filed by Wells Fargo Home Mortgage, Inc, a Plaintiff, against Sean G, Harpold as Defendant, on January 30, 2004 in the Offi e of the Prothonotary of Cumberland County to File No, 2004-387. Judgment in the amount of $114,716,15 entered May 20, 2004. 9. Mortgage in the amount of $36,000,00 given by Sean G. Harpold to GMAC Mo gage Corporation dated August 10, 2000 and recorded August 31, 2000 in Mortgage ook 1636, page 531. Said mortgage was subordinated to the lien of mortgage record din Mortgage Book 1695, Page 803, by subordination agreement recorded April 26, 001 in Miscellaneous Record Book 673, Page 91. 10, Rights granted to Pennsylvania Power & Light Company by instrument recorde June 10,1959 in Miscellaneous Record Book 144, Page 213. 11. Rights granted to Bell Telephone Company of Pennsylvania by instrument reco ded January 28,1960 in Miscellaneous Record Book 147, Page 319. 12, Under and subject to the reservation for ingress, egress and regress retained by eed dated February 24, 1959 and recorded February 27, 1959 in Deed Book "Y," V lume 18, Page 283. 13. Rights granted to Bell Telephone Company of Pennsylvania by instrument rec ded November 3,1958 in Miscellaneous Record Book 140, Page 189. 14, Rights granted to Pennsylvania Power & Light Company by instrument record d February 24,1959 in Miscellaneous Record Book 140, Page 496, 15, Building conditions, easements and setbacks as shown on or set forth with the Ian of Riverview Section "B" recorded in Plan Book 10, Page 7, 16, Satisfactory evidence to be produced that proper notice was given to the holde of all liens and encumbrances intended to be divested by subject Sheriff Sale. 17. Satisfactory evidence to be produced that the advertisement of the property was sufficient despile the lack of reference to any improvements on the subject premis s, 18, Real estate taxes accruing on and after January 1, 2005 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been mad to determine support arrearages regarding House Bill 1412, Act 58 of 1997, no has any search been made for environmental liens in Federal District Court. ~JAJ'~, Robert G, Frey, Agent . Note: Thi, Title Report ,hall not be valid or bi d1ng until countersigned by an authorized signatory. \ REAL ESTATE SALE NO. 39 Writ No. 2004-387 Civil Wells Fargo Home Mortgage. Inc. vs. Sean G. Harpold Atty.: Frank Federman ALL TIlAT CERTAIN tract or par- cel of land and premises, situate. Iytng and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly de~ scribed as follows: BEGINNING at a point on the Western line of Hillside Drive. two hundred rUnety~two and eight one~ hundredths (292.08) feet measured Northwardly along said line from the Northern line of Poplar Church Road: thonce South flfty-three (53) degrees thirty [30) minutes West. one hundred thirty U30} feet to a point in the Eastern boundary line of Lot Numbered Fifteen (15); thence North thirty-six (361 degrees thirty (301 minutes West. along the East- ern boundary line of Lot Numbered Fifteen [15). eighty-two (82) feet to a point; thence North fifty-three [531 degrees thirty (30} minutes East. one hundred thirty (30) feet to a point in the Western line of Hillside Dlive: thence by the latter. South thirty-six (361 degrees thirty (30) minutes East, eighty-two (821 feet to a point, the place of beg.iru1ing. TITLE TO SAiD PREMISES IS VESTED IN Sean G. Harpold, Single Person by Deed from Daniel J. Best and Diane C. Best, His Wife dated 7/15/1999 and recorded 7/27/ 1999 in Record Book 204 Page 636. Tax Parcel #47-18-1302-153. , , WELLS FARGO HOME MORTGAGE, INC. . CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEA SEAN G. HARPOLD CIVIL DIVISION Defendant(s). NO. 04-387 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO HOME MORTGAGE. INC., Plaintiffin the above action, by its atto ey, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution as filed the following information concerning the real property located at 824 HILLSIDE DRIVE AMP HILL PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot b reasonably ascertained, please indicate) SEAN G. HARPOLD 824 HILLSIDE DRIVE CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in thejudgmenl: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property 10 be sold: Name Last Known Address (if address cann t be reasonably ascertained, please indical ) None ~, , 4, Name and address oflast recorded holder of every mortgage ofrecord: Name Last Known Address (if address cannot e reasonably ascertained, please indicate) GMAC MORTGAGE CORPORATION D/B/A DlTECH.COM 3200 PARK CENTER DRIVE, SUIT 150 COSTA MESA, CA 92626 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot e reasonably ascertained, please indicale) None 6, Name and address of every other person who has any record interest in the property an whose inlerest may be affected by the sale, Name Last Known Address (if address cannol e reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has y interest in the property which may be affected by the sale: Name Last Known Address (if address cannot e reasonably ascertained, please indicate) TenanUOccupant 824 HILLSIDE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify Ihat the slatements made in this affidavit are true and correcl to the best of y personal knowledge or information and belief. I understand that false statements herein are made s bject to the penalties ofl8 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 18, 2004 DATE - ~ o.(d~.. ~ doM"LD ~ FRANKFEDERMAN,ESQUffiE Attorney for Plaintiff . WELLS FARGO HOME MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 04-387 CIVIL TERM SEAN G. HARPOLD Defendant(s), May 18, 2004 TO: SEAN G. HARPOLD 824 HILLSIDE DRIVE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFO ATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCH RGE IN BANKRUPTCY AND THiS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONS RUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY' Your house (real estate) al. 824 HILLSIDE DRIVE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8, 2004 at 10:00 a.m, in Ihe Cumberland C unty Courthouse, South Hanover Slreet, Carlisle, PA 17013, to enforce the court judgment of$ 14716.15 obtained by WELLS FARGO HOME MORTGAGE, INC. (the mortgagee) against you In the evenl the sale is continued, an announcement will be made at said sale in compliance with Pa.R, .P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, 1 te charges, costs and reasonable altomey's fees due, To find out how much you must p y, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court 10 stri judgment, ifthe judgment was improperly entered, You may also ask the postpone the sale for good cause. e or open the urt to 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, The sooner you contact one, the ore chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OT ER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If Ihe Sheriff's Sale is not stopped, your property will be sold to Ihe highesl bid er. You may find out the price bid by calling (215) 563-7000. 2. You may be able 10 pelition the Court to set aside the sale if the bid price was ossly inadequale compared 10 the value of your property, 3. The sale will go through only if the buyer pays the Sherifflhe full amount due n the sale, To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid 10 the Sheriff, you will remain Ih owner of the property as if the sale never happened. 5, You have the righl to remain in the property until the full amount due is paid t the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal procee ings to evict you. 6, You may be entilled to a share of the money which was paid for your house, schedule of distribution of Ihe money bid for your house will be filed by Ihe Sheriff within 30 days 0 the sale. This schedule will state who will be receiving that money, The money will be paid out in acc rdance with Ihis schedule unless exceptions (reasons why the proposed distribution is wrong) are file with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home b ck, if you acl immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OF CE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lraot or parce.! of laud and premises, SilUale, lying ana being illlhc Bor ugh of Wormleysburg illlh. CoUllty of Cumberland and COltUIIonwealth of pcnnsylvlIuill, IIIQre partie arly described as follows: BEGINNING al a point OIllhe Western line of Hilt'lide Drive, two hur.dred nlnety.lwo and eighl Ont- hundredths (292.08) reer m"".ured Northwardly along s.aid line from lbe Norr.bern line of Poplar .' ur<:h Road; lhence South fifty-three (53) degrees lI1irty (3()j minUlCS WtSI, one buodred thirty (130) f et 10 a point in th. Ea.~crn boundary lint Of Lot N\lII1bcred Fifleen (15): thence NOrth thirty-six (36) ees thirty (30) minutes West, along the Eastern boundary line of Lot Numbered Flfwen (15), eight -two (82) feet to a point; thtnce North flfly-thrte (53) degrees thirty (30) minutes East, one bundred irty (13-0) feel to a point in !he Western line of HlIl.id. Drive: thence by tbe latter, Sotlch thiny-si (36) degtees tbir!)' (30) minUles East, eighty-two (82) feet to a point. Ihe place of begillning, TITLE TO SAm PREMISES IS VESTED IN Sean (l. I{;upold, Single Person by Deed fro Daniel J. Be.r and Diane C. Dest, His Wife dated 7/1511999 and recorded 7/27f1999 in R ' Book 204 Page 636. Tax I'arcel #47- J 8.1302-153 WRIT OF E~CUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA}. COUNTY OF CUMBERLAND) NO 04-387 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and co,ts due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (,) From SEAN G. HARPOLD (I) You are directed to levy upon the property of the defendanl (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S} a, follows: and to notify the garnisheo(s) that: (a) an attachment has been issued; (b) the garnishee(s) i, enjoined fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defend nt (s) or otherwi,e disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are dirocted to notify him/her that he/she has been added as a ganlishee and is enjoined as above stated. Amount Due $114,716.15 L.L. $,50 Interest FROM 5119/04 TO 9/8/04 (PER DIEM - $18,86) -- $2,131.18 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $213.54 Plaintiff Paid Date: MAY 20, 2004 Other Costs CURTIS R. LONG (Seal) By: Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Addre..: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 < " Real Estate Sale #39 On June lO, 2004 the sherifflevied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA Known and numbered as 824 Hillside Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June lO, 2004 i~(' ,If By:'< ~ Real Estat Deputy VI" ,;, -, < "I' '.' 'ld f\! 'f .' \ ; /. '~1 (if "~ .:J ~lQ. IU EE Z '{)Z I.UU ^R.j~l\' , . ,i~{) "J.H\J'3\"; "L J':; j:lk,dJ) ", @~ ~@~ REAL ESTATE SALE No. 39 Writ No. 2004-387 . Civil Term Welle Fargo Home Mortgaga, Inc. Vs . . SeanG. Harpold' Atty: Frank Federman .DESCRIPTION ALL THAT CERtAIN tract or parcel of land aIld premiSes, situate, lying and being in the Borough of Wonnleysburg in the County of Cumb~rland and Com'monw~alth of p~lI1"Ylvania; Wore particularly described " fu~m: ' . llEGINNINq at a point on the Western line of Hillside Dri"", two hundred ninety-two and ~ight . ~ne'hundredths (292.08) feet m~a-sured Northwardly along said lin~ from the Northern r 18I'.Churcb Road;th~~eeSouth fifty- . .~.lj1iI'ty,~~\VIl!l..~ tb i. .'. ,.~l3lI)~ttolP9"!'inthe~ . !;......._,.,,1. ':.~l,.<<ti~lf~,J$5);":" r~.NorlI1dility.~(36)degleel.Il1il!~.~3Q) lDjn-uteS Wes~ lIlong the l!aaterIl boundary liIle of ~ Nuritlired Fifteen (15), ~ighty.two (82) teet to a point; thence North fifty-three (53) d~grees thirty (30) minutes Eas~ on~ bondmt thirty (\30) feet ~o a point in th~ We,tern line of Hillsid~ Driv~; th~nce by the lat-ter, South thirty-six (36) degrees thirty (30) minutes Eas~ .~ighty-two (82) feet to a point; l!1~ place of BEGINNING. TITLE TO SAID premises is v~sted in Sean G. Harpold, Single P~"on, by Deed from Daniel J. Best and Diane C. Bes~ Hi, Wife, dated 7/15/ 1999 and recoro~d 7127/1999 in Record Book 204 Pag~ 636. TAX PARCEL #47-18-1302-153. . REAL ESTATE SALE NO. 39 Wlit No, 2004-387 Civil Wells Fargo Home Mortgage, Inc, vs, Sean G, Harpold Atty.: Frank Federman ALL TIfAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- sclibed as follows: BEGINNING at a point on the Western line of Hillside Olive, two hundred ninety-two and eight one- hundredths (292,08) feet measured Northwardly along said line from the Northern line of Poplar Church Road: thence South fifty-three (53) degrees thirty (30) minutes West, one hundred thirty (130) feet to a point in the Eastern boundary line of Lot Numbered Fifteen (15): thence North thirty-six (36) degrees thirty (30) minutes West, along the East- ern boundary line of Lot Numbered Fifteen (151. eighty-two (82) feet to a point; thence North fifty-three (53) degrees thirty (30) minutes East, one hundred thirty (130) feet to a point in the Western line of Hillside Olive: thence by the latter, South thirty-six (36) degrees thirty (30) minutes East, eighty-two (82) feet . j, to a point. the place of beginnJng, TITLE TO SAID PREMISES IS VESTED IN Sean G. Harpold, Single Person by Deed from Daniel J. Best and Diane C. Best. His Wife dated 7/15/1999 and recorded 7/27/ 1999 in Record Book 204 Page 636, Tax Parcel #47-18-1302-153,