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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC MORTGAGE a division of PNC
BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
N0. ~b -~ ~~ S C jVi~
Plaintiff,
vs.
R. Jacob Johns
Defendants.
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT IN MORTGAGE FORECLOSURE
WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF
OR A DEFAULT 7UDGMENT MAY BE ENTERED AGAINST
YOU.
Attorney for Plaintiff
COMPLAINT IN MORTGAGE
FORECLOSURE
MORTGAGE FORECLOSURE
Filed on behalf of Plaintiff
Counsel of record for this party:
Louis P. Vitti, Esquire
PA I.D. #01072
Vitti and Vitti and Associates, P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
~ asa ~trg
~~'
Vitti and Vitti and Associates, P.C.
BY: Louis P. Vitti, Esquire
I.D. #01072
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725 Attorney for Plaintiff
PNC MORTGAGE, A DIVISION OF PNC BANK, IN THE COURT OF COMMON PLEAS OF
NATIONAL ASSOCIATION, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
vs. :CIVIL ACTION -LAW
R. Jacob Johns,
Defendant. ~ No.
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 THE
ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED
THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A
JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER
NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
i-800-990-9108
(717) 249-3166
COMPLAINT IN MORTGAGE FORECLOSURE
NOW, comes the Plaintiff by its attorneys, Vitti and Vitti and Associates, P.C. and
Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers
1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a national association having a principal place of business
located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is successor by merger
to National City Mortgage a division of National City Bank.
2. The Defendant(s) is/are individuals with a last known mailing address of 1083
Huron Drive, Harrisburg PA 17111. The property address is 1786 Weatherburn Drive, New
Cumberland PA 17070 and is the subject of this action.
3. On the 30th day of November, 2007, in consideration of a loan of One Hundred
Eighteen Thousand One Hundred Forty Six and 00/100 ($118,146.00) Dollars made by
National City Mortgage a division of National City Bank to Defendant, the said Defendant
executed and delivered to National City Mortgage a division of National City Bank a "Note"
secured by a Mortgage with the Defendant as mortgagor and National City Mortgage a
division of National City Bank, as mortgagee, which mortgage was recorded on the 4th day
of December, 2007, in the Office of the Recorder of Deeds of Cumberland County, at
Instrument No. 200745056. The said mortgage is incorporated herein by reference thereto
as though the same were set forth fully at length. The Plaintiff is the legal owner of the
mortgage and is seeking enforcement of the mortgage through foreclosure.
4. The premises secured by the mortgage are:
SEE EXHIBIT 'A "ATTACHED HERETO.
5. Said mortgage provides, inter alias
"that when as soon as the principal debt secured shall become due and payable,
or in case default shall be made in the payment of any installment of principal and
' interest, or any monthly payment, keeping and performance by the mortgagor of any of
the terms, conditions or covenants of the mortgage or note, it shall be lawful for
mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the
mortgage, of principal debt, interest and all other recoverable sums, together with
attorney's fees."
6. Since July 1, 2010, the mortgage has been in default by reason, inter alia, of
the failure of the mortgagor(s) to make payments provided for in the said mortgage
(including principal and interest) and, under the terms of the mortgage, the entire principal
sum is due and payable.
7. In accordance with the appropriate Pennsylvania Acts of Assembly and the
Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the
mortgagee's intention to foreclose. The appropriate time period has elapsed since the
Notice of Intention to Foreclose has been served upon the mortgagor(s).
8. The amount due on said mortgage is itemized on the attached schedule.
9. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases
from liability for the debt secured by the mortgage any mortgagor, personal representative,
heir or devisee of the mortgagor who is not a real owner of the property at the time of the
filing of this Complaint.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6),
Plaintiff demands judgment for the amount due of One Hundred Twenty Eight Thousand
Nine Hundred Seventy and 31/100 ($128,970.31) with interest and costs.
Respectfully submitted,
VITTI SOCIATES, P.C.
BY:
Lo P. Vitti, Esquire
Attorney for Plaintiff
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance
Interest @ 6.0000%
(Plus $18.7971
Late charges through
0 months @
Accumulated bef
(Plus $36.17
from 06/01/10 through 12/31/2010
per day after 12/31/2010 }
12/6/2010
36.17
orehand
on the 17th day of each month after 12/6/2010
Attorney's fee
Escrow deficit
(This figure includes projected additional charges that may be incurred by the
Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the
sheriffs sale)
BALANCE DUE
114,349.20
4,003.79
144.68
5,717.46
4,755.18
128,970.31
EXHIBIT ~~A"
LEGAL DESCRIPTION
Legal Description
ALL THAT CERTAIN lot or parcel of land situate in Lower Allen 'Township, Cumtxrland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point, said point being the following eight eaurses and distances from Ptrimeter
Coordinate 3 as shown on the As-Built Plan. referenced herein: 1) by a carve to the right having a radius
of two hundred fifty-six and forty-eight hundredths {256.48} feet, an arc distance of two hundred seventy-
seven andthirty-one hundredths (277.31) feet to a point at the intersection of Capitol View Drive and the
centerline of Weatherburn Drive; 2) along the centerline of Weatherburn Drive aforementioned, South
eighty-eight (88} degrees thirty-eight (38) minutes forty-five (4S) seconds East, a distance of one hundred
eighteen (118) feet to a poirrt; 3) Nosdi thirty-two (32} degrees fitly-six (S6) minutes eighteen (1$)
seconds East, a distance of seventy-eight and fifty-five hundredths (78.55) fcck; 4) North fifty-seven {S7)
degrees three {03) minutes forty-two (42) seconds West, a distance of fifty {50) feet to a point at the
corner of Lot No. 72 (Building "O"} 5) North thirty-two (32) degrees fifty-six (5ti} minutes eighteen {l8)
seconds East, a distance of forty-eight {48) feet; 6) North fifty-seven {57} degrees three {03) minutes
forty-twa (42) seconds West, a distance of two {02) feet; 7) North thirty-two (32) degrees fifty-six. (Sri)
minutes eightcerr (18}seconds East, adistance afsixty-six (66) fact; 8} Nonh fifty-seven (57) degrees
three (03) nvnutes forty-two (42) seconds West, a distance of four {t~ui) feet to a point on the dividing line
between Lot No, 67 and Lot No. 68, said point being the point and platx of BEGINNING; thence along
the said dividing line and passing through the centerline of a party wall dividing units b7 and 68, North
fifty-seven (57) degrees three (03) mhrutes forty-two {42) seconds West, adistance of thirty-two (32} feet
to a point; thence North thirty-two (32) degrees fifty-six (S6} minutes eighteen (18) seconds East, a
distance of five (OS) feet to a point; thence South fifty-seven. (S7) degrees three (03}minutes fatty-two
(42) seconds East, a distance of eight {08) feet to a point; thence North thirty-two (32) degrees f ifry-six
(Sb) minutes eighteen {18) seconds East, a distance of twenty-one (21) feet to a point; thence South. fifty-
seven (57) degrees three (03) minutes forty two {d2) seconds East, a distance of twenty-four (24) feet to a
point; thence South thirty-two (32) degrees fifty-six {56) minutes eighteen (18) seconds'West, a distance
of twenty-six (26} feet to the point and place of F3EGtNNfi1G.
BEING Lot No. 67 as shown en Amended Final Plan of Hunter's Ridge, recorded in Plan Book 58, Page
62, and as more particularly described on As-Built Plan of Station 1, Hunter's Ridge, dated November 7,
19$9, and recorded in Plan Book 54, Page 83.
TUGETNER with the right to use any Limited Common Area appurtenant to the lot being conveyed
herein pursuant t+u the Declaration, the Amended Final Plan far Floater's Ridge, the As-Built Plan
referenced herein, and the Declaration os Assignment of Limited Gammon Area for Hunters Ridge,
dated May 10, 1990, and recorded. in Miscellaneous Book 380, Page 519.
UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of
way of record or visible upon inspection ofprrmises.
BEING THE SAl14E premises which Jason M, Kanovich, a single man, by his deed dated the 29°i day of
November, 200'7 and to be recorded simultaneously herewith, granted and conveyed unto R. Jacob johns,
a single man, MORTGAGOR herein.
VERIFICATION
AND NOW Louis P. Vitti verifies that the statements made in this Complaint are
true and correct to the best of his knowledge, information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the
pleading is submitted by counsel having sufficient knowledge, information and belief based
upon the information provided him by the Plaintiff.
L . Vitti
Dated: December 6, 2010
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?r r??d
4v??"tr 4[till
F,C
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,U
P 11j, S y 0. !`
PNC Mortgage
vs.
R. Jacob Johns
Case Number
2010-7715
SHERIFF'S RETURN OF SERVICE
12/16/2010
12/22/2010
12/28/2010
Ronny R. Anderson, Sheriff who being duly sworn according to law states that he rr
and inquiry for the within named defendant, to wit: R. Jacob Johns, but was unable
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to se
Complaint In Mortgage Foreclosure according to law.
06:53 PM - Dauphin County Return: And now December 22, 2010 at 1853 hours I,
of Dauphin County, Pennsylvania, do herby certify and return that I served a true cc
Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: R. JC
known unto himself personally, at 1083 Huron Drive, Apartment D, Harrisburg, Pen
contents and at the same time handing to him personally the said true and correct c
Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he
and inquiry for the within named defendant to wit: R. Jacob Johns, but was unable
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as no
defendant R. Jacob Johns. Request for service at 1786 Weatherburn Drive, New C
Pennsylvania 17070 is vacant. The New Cumberland Postmaster has confirmed, F
moved and left no forwarding address.
SHERIFF COST: $57.30
December 28, 2010
SO ANSWERS,
a a diligent search
locate him in his
s the within
ack Lotwick, Sheriff
y of the within ?
:ob Johns by making
Sylvania 17111 its
lpv of the same.
nade a diligent search
o locate him in his
found as to the
.imberland,
. Jacob Johns has
R ANDI?RSON, SHERIFF
(,0lin?yj1j1te ^2I`f. inc,
(ptijo- of t4 c*hcrf ff
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889'
Jack Lotwick
Sheriff
PNC MORTGA IE
Commonwealth of Pennsylvania BANK NATION L
County of Dauphin R. JACOB JOHNS
Sheriff s Return
No. 2010-T-3721
OTHER COUNTY NO. 107715
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
A DIVISION OF PNC
ASSOCIATION
VS
And now: DECEMBER 22, 2010 at 6:53:00 PM served the within COM LAINT IN MORTGAGE
FORECLOSURE upon R. JACOB JOHNS by personally handing to R. JACOB JOHNS 1 true
attested copy of the original COMPLAINT IN MORTGAGE FORECLOS RE and making known to
him/her the contents thereof at 1083 HURON DRIVE APT D HARRISBURG PA 17111
DEFT
Sworn and subscribed to
before me this 23RD day of December, 2010
0-?00*2
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
M Commission Expires August 17, 2014
So Answers,
Sheriff chi
Deputy Sheriff
Deputy: W CO
Sheriff s Costs:
a
FILED-OFFICE
OF THE PROTHIO O T' qr "
2011 FEB -2 PH 12: 00
CUMBERLAND COUWA NT";'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC MORTGAGE, A DIVISION OF PNC CIVIL DIVISION
BANK, NATIONAL ASSOCIATION,
NO. 10-7715 Civil
PRAECIPE FOR DEFAULT
Plaintiff, JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON-
MILITARS' SERVICE
vs.
R. JACOB JOHNS,
Defendants.
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vit:ti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
l?l??r? yrizc???
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL:,
ASSOCIATION,
Plaintiff,
vs
R. JACOB JOHNS,
Defendant.
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
NO: 10-7715 Civil
Enter judgment in Default of an Answer in the amount of $129,477.83, in favor of
the PNC MORTGAGE, et al, Plaintiff in the above-captioned action, against the Defendants, R.
Jacob Johns and assess Plaintiffs damages as follows and/or as calculated in the Complaint:
Unpaid Principal Balance $114,349.20
Interest from 06/01/10-01/27/11 4,511.31
(Plus $21.2840 per day after 01/27/11)
Late charges (Plus $36.17 per
month from 12/06/10-06/01/11 $217.02) 144.68
Attorney's fee 5,717.46
Escrow Deficit 4,755.18
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
Total Amount Due $129.477.83
The real estate, which is the subject matter of the Complaint, is situate in Lower Allen
Twp, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 1786 Weatherburn Drive, New
Cumberland, PA 17070. Parcel No. 13-25-0068-237.
uis P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION, :
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS, :
Defendant.
CERTIFICATION OF MAILIN
G
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the
Defendant(s), in the above-captioned case on January 14, 2011, giving ten (10) day notice that judgment
would be entered should no action be taken.
VITTI & VITTI & ASSOCIATES, P.C.
BY:
6 uis P. Vitti, re
Attorney for Plaintiff
SWORN to and subscribed
before me this 27th day
of January, 2011.
Notary Public; ?- =-?
NOTARIAL SEAL
SHERRY L HOUSE
Notary Public
[My TY OF PITTSBURGH, ALLEGHENY COUNT)
Commission Expires May 15, 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION
vs
R. JACOB JOHNS,
TO: R. Jacob Johns
1083 Huron Drive
Apt. D
Harrisburg, PA 17111
Plaintiff, : NO: 10-7715 Civil
Defendant.
EM PORTANT NOTICE
Date of Notice: January 14, 2011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR. OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
(717) 249-3166
VITTI,& VITTI & ASSOCIATES, PC
BY:
-,Louis P. Vitti, Esquire.-.
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 152.22
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN 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 COLLECT A DEBT, BUT ONLY ENFORCEMENT
OF A LIEN AGAINST PROPERTY.**
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that lie is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Service Members Civil Relief Act of 2004 and designated therein as military service,
and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act,
and that the averments herein set forth, insofar as they are within his knowledge, are correct, and
true; and insofar as they are based on information received from others, are true and correct as he
verily believes. In the alternative, should the defendant(s) be currently serving in the military the
Service Members Relief Act does not apply as the mortgage in question did not originate before the
period of the Service Members military service and is secured by a. mortgage pursuant to 50 U.S.C.
App §533 formerly cited as 50 U.S.C. App §532 (a)(1)(2).
This Affidavit is made under the provisions AS'ce Members Civil Re lief Act of 2004.
3
t1:i, Esquire
SWORN to and subscribed
before me this 27th day
of January, 2011.
otary Public NOTARIAL-SEAL
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expires May 15. 2011
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-7715 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK,
NATIONAL ASSOCIATION Plaintiff (s)
From R. JACOB JOHNS
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $129,477.83 L.L.$.50
Interest 01/28/11-06/01/11 $2,639.22
Atty's Comm % Due Prothy $2.00
Atty Paid $189.80 Other Costs
Plaintiff Paid
Date: 2/2!11
David D. Bue, Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: LOUIS P. VITTI, ESQUIRE
Address: VITTI & VITTI tASSOC., P.C.
215 FOURTH AVE.
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 01072
FILED-OFFICE
CiF THE PROTHONOTARY
2014 FEB -2 PM 12' 11j'3
CUMBERLAND COUNT`'
1'EFIRSyLVfA,111IN
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC MORTGAGE, A DIVISION OF PNC CIVIL DIVISION
BANK, NATIONAL ASSOCIATION,
NO. 10-7715 Civil
PRAECIPE FOR WRIT OF
Plaintiff, EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
vs.
Code MORTGAGE FORECLOSURE
R. JACOB JOHNS, Filed on behalf of
Plaintiff
Defendant. Counsel of record for this
party:
V1 Louis P. Vitti, Esquire
7 3C Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
# l?/. GU 215 Fourth Avenue
Pittsburgh, PA 15222
_ (412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION,
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS, ;
Defendant.
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above-captioned matter as follows:
Amount Due $129,477.83
Interest 01/28/11-06/01/11 2,639.22
Total 132.117.05
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
in:
Lower Allen Twp, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 1786 Weatherburn Drive, New
Cumberland, PA 17070. Parcel No. 13-25-0068-237.
AbuisP. ,squire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION,
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief,
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the
Defendants' last known address is 1083 Huron Drive, Apt. D, Harrisburg, PA 17111.
V
ouis P. Vitti, Esquire
SWORN TO and subscribed
before me this 27th day of
January, 2011.
J? 0 h h , , ZX
Notary Pub • c
RRY L HOUSE
FOFPITTSBURGH, TARIAL SEAL
tary Public
ALLEGHENY COUNn Expires May 15, 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
_ CIVIL DIVISION C !a
PRAECIPE FOR WRIT OF E,CECUTION c rm
aption :
PAI ???rX at -/Di v?S cn o-P PwC
9
V5.
1?. Jacoh -??hr?5,
( ) Confessed Judgment tv ?o
( ) Other _
File No.
1zIL=771,5
.-ze
C:)
='0
Amount Due tLdq S/'
Interest a?, (0 3 1. ??
At ty' s Cor m
Costs
TO THE PROTHONOTARY OF THE SAID COURT :
The undersigned hereby certifies that the below does not arise out of a retail
installaent sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate ori.ginal proceeding filed pursuant to Act 7 of 1966 as
imnded; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above rretter to the Sheriff of
CLaz
ounty, for debt/, interest and costs upon the following deseri property of the
defendant (s) /) /' "I ? r) o D -?Of 'el- ,, .,/ / "-) ,4 /&/6,'- , .., -
PRAECIPE FOR ATTAC IM T EXECUI ION
Issue writ of attachment to the Sheriff of County, for debt,
interest and costs, as above, directing attacl,.ment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee (s) .
(Indicate) Index this writ against the garnishee(s' as ais
real estate of the defendant(s) described in the attached t. i
/110
DATE: Signature-
.
Pint Name:
ndens against
/J*-
.a6dress: G?115 ?6
/'/
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION, :
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS,
Defendant.
LEGAL DESCRIPTION
ALL that certain lot or parcel of land situate in Lower Allen Township, Cumberland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point, said point being the following eight courses and distances from Perimeter
Coordinate 3 as shown on the As-Built Plan referenced herein: 1) by a curve to the right having a radius
of two hundred fifty-six and forty-eight hundredths (256.48) feet, an arc distance of two hundred seventy-
seven and thirty-one hundredths (277.31) feet to a point at the intersection of Capitol View Drive and the
centerline of Weatherbum Drive; 2) along the centerline of Weatherburn Drive aforementioned, South
eighty-eight (88) degrees thirty-eight (38) minutes forty-five (45) seconds East, a distance of one hundred
eighteen (118) feet to a point; 3) North thirty-two (32) degrees fifty-six (56) minutes eighteen (18) seconds
East, a distance of seventy-eight and fifty-five hundredths (78.55) feet; 4) North fifty-seven (57) degrees
three (03) minutes forty-two (42) seconds West, a distance of fifty (50) feet to a point at the corner of Lot
No. 72 (Building "O"); 5) North thirty-two (32) degrees fifty-six (56) minutes eighteen (18) seconds East,
a distance of forty-eight (48) feet; 6) North fifty-seven (57) degrees three (03) minutes forty-two seconds
West, a distance of two (02) feet; 7) North thirty-two (32) degrees fifty-six (56) minutes eighteen (18)
seconds East, a distance of sixty-six (66) feet; 8) North fifty-seven (57) degrees three (03) minutes forty-
two (42) seconds West, a distance of four (04) feet to a point on the dividing line between Lot No. 67 and
Lot No. 68, said point being the point and place of beginning; thence along the said dividing line and
passing through the centerline of a party wall dividing units 67 and 68, North fifty-seven (57) degrees
three (03) minutes forty-two (42) seconds West, a distance of thirty-two (32) feet to a point; thence North
thirty-two (32) degrees fifty-six (56) minutes eighteen (18) seconds East, a distance of five (05) feet to
a point; thence South fifty-seven (57) degrees three (03) minutes forty-two (42) seconds East, a distance
of eight (08) feet to a point; thence North thirty-two (32) degrees fifty-six (56) minutes eighteen (18)
seconds East, a distance of twenty-one (21) feet to a point; thence South fifty-seven (57) degrees three (03)
minutes forty-two (42) seconds East, a distance of twenty-four (24) feet to a point; thence south thirty-two
(32) degrees fifty-six (56) minutes eighteen (18) seconds West, a distance of twenty-six (26) feet to the
point and place of beginning.
BEING Lot No. 67 as shown on Amended Final Plan of Hunter's Ridge, recorded in Plan Book 58, Page
62, and as more particularly described on As-Build Plan of Section 1, Hunter's Ridge, dated November
7, 1989, and recorded in Plan Book 59, Page 83.
TOGETHER with the right to use any Limited Common Area appurtenant to the lot being conveyed
herein pursuant to the Declaration, the Amended Final Plan for Hunter's Ridge, the As-Built Plan
referenced herein, and the Declaration of Assignment of Limited Common Area for Hunter's Ridge, dated
May 10, 1990, and recorded in Miscellaneous Book 380, Page 519.
UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of
way of record or visible upon inspection of premises.
HAVING erected thereon a dwelling known as 1786 Weatherburn Drive, New Cumberland, PA 17070.
PARCEL NO. 13-25-0068-237.
BEING the same premises which Jason M. Kanovich, single man, by Deed dated 11 /29/2007 and recorded
12/04/2007, in the Recorder's Office of Cumberland County, Pennsylvania, Instrument No. 200745055,
granted and conveyed unto R. Jacob Johns, single man.
FILED-OFFICE
0C TI'» PROTHONOTARY
2@11 FEB -2 PM 12: Tao
CUMBERLAND COUNT``
IN THE COURT OF COMMON PLEAS OF CUMBERLAND.r 8M ,WNNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION,
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Mortgage, et al, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real property located at 1786 Weatherburn
Drive, New Cumberland, PA 17070.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
R. Jacob Johns 1083 Huron Drive, Apt. D
Harrisburg, PA 17111
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 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:
Address (Please indicate if this
cannot be reasonably ascertained)
Hunters Ridge Homeowners Association
P.O. Box 454
New Cumberland, PA 17070
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
NONE
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on the
property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Lower Allen Township
c/o Bonnie K. Miller
Lower Allen Township
c/o Beverly Putric
Pennsylvania Department of Revenue
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
Court of Common Pleas of
Cumberland County
Domestic Relations Division
PA Dept. of Sheriff Sales
Bureau of Compliance
2233 Gettysburg Road
Camp Hill, PA 17011
2233 Gettysburg Road
Camp Hill, PA 17011
Office of Chief Counsel
PO Box 281061
Harrisburg, PA 17128
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Dept. #281230
Harrisburg, PA 17128-1230
ry
Tenant/Occupant
1786 Weatherburn Drive
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
January 27, 2011
Date
SWORN TO and subscribed
before me this 27th day
of January, 2011.
ouis P. Vitti, Esquire
Attorney for Plaintiff
AIA A'tA
Notary Publ c
NOTARIAL SEAL
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expires May 15, 2011
FILED-OFFICc
,0THONOT.RY
OF THE PP
2011 FEB _2 PM 12: BU
CUMBERLAND COUNT
PENNSYLVAHI A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL
ASSOCIATION,
Plaintiff, NO: 10-7715 Civil
vs
R. JACOB JOHNS,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, hereby certify that as representative of PNC Mortgage, et al, am familiar with the
above-captioned case and various servicing activities related thereto and that the provisions of the laws
of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the
above-captioned case.
It C itti, , Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 27th day
of January, 2011.
J, lk? J?' , - X,
Notary Pub CC
NOTARIAL SEAL
SHERRY L HOUSE
Notary Public
CITY OF PITTSBURGH, ALLEGHENY COUNTY
My Commission Expires May 15, 2011
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
C 7)
TO: R. Jacob Johns Ca
?rn
- -n
n
r
1083 Huron Drive r-
Apt. D N C")
Harrisburg, PA 17111 r--
CD
? --4c:
x
AND: ALL LIEN HOLDERS rD
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Cc;?t o Cor ion
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on June 1, 2011 at 10:00 A.M., the
following described real estate, of which R. Jacob Johns are owners or reputed owners:
Lower Allen Twp, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 1786 Weatherburn Drive, New
Cumberland, PA 17070. Parcel No. 13-25-0068-237.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of PNC
Mortgage, et al vs. R. Jacob Johns at 10-7715 in the amount of $129,477.83.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your property from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriff s Sale and -the loss of your property. In order to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right, you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriff s
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriff s Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the S ff.
Louis P. Vitti, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN 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 COLLECT A DEBT, BUT ONLY ENFORCEMENT
OF A LIEN AGAINST PROPERTY.**
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith naArr At t+ur+?t?ry? ! j Ov T G 0
Chief Deputyx
le,
i F i
L [ A r
Richard W Stewart
-?'? P'Solicitor QFP ICE C r TW E ' rEP?'<F l k,' I
'i ,? , i''t i
PNC Mortgage
vs.
R. Jacob Johns
Case Number
2010-7715
SHERIFF'S RETURN OF SERVICE
03/09/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: R. Jacob Johns, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
03/10/2011 08:41 PM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 1786 Weatherburn Drive, New Cumberland, PA 17070, Cumberland County.
03/17/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of
Dauphin County upon R. Jacob Johns, personally, at 1083 Huron Drive, Harrisburg, PA 17111. So
Answers: W. Conway, Deputy Sheriff.
05/31/2011 As directed by Louis P Vitti, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/7/2011
09/08/2011 Ronny R. Anderson, Sheriff, 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
Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m..
He sold the same for the sum of $1.00 to Attorney Louis P. Vitti, on behalf of, PNC Mortgage, et. al. , of,
3232 Newmark Drive, Miamisburg, OH 45342
SHERIFF COST: $1,475.05
October 19, 2011
SO ANSWERS,
RON . R ANDERSON, SHERIFF
tlf -CCU ',d -
e?z X39 /1)
.i tj 6 ;1 a a-
(cl ,-?ountySuile Shenff. Te!K,,soft. Inc.
On March 3, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA,
Known and numbered as, 1786 Weatherburn Drive,
New Cumberland, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: March 3, 2011
By:
Real Estate Coordinator
L cj.Z d E- (3J HOZ
CUMBERLAND LAW JOURNAL
Writ No. 2010-7715 Civil
PNC Mortgage
VS.
R. Jacob Johns
Atty.: Louis P Vitti
ALL that certain lot or parcel of
land situate in Lower Allen Township,
Cumberland County, Commonwealth
of Pennsylvania, more particularly
bounded and described as follows,
to wit:
BEGINNING at a point, said point
being the following eight courses and
distances from Perimeter Coordinate
3 as shown on the As-Built Plan ref-
erenced herein: 1) by a curve to the
right having a radius of two hundred
fifty-six and forty-eight hundredths
(256.48) feet, an arc distance of two
hundred seventy-seven and thirty-
one hundredths (277.31) feet to a
point at the intersection of Capitol
View Drive and the centerline of
Weatherburn Drive; 2) along the
centerline of Weatherburn Drive
aforementioned, South eighty-eight
(88) degrees thirty-eight (38) minutes
forty-five (45) seconds East, a dis-
tance of one hundred eighteen (118)
feet to a point; 3) North thirty-two
(32) degrees fifty-six (56) minutes
eighteen (18) seconds East, a dis-
tance of seventy-eight and fifty-five
hundredths (78.55) feet; 4) North
fifty-seven (57) degrees three (03)
minutes forty-two (42) seconds West,
a distance of fifty (50) feet to a point
at the corner of Lot No. 72 (Building
"O"); 5) North thirty-two (32) degrees
fifty-six (56) minutes eighteen (18)
seconds East, a distance of forty-
eight (48) feet; 6) North fifty-seven
(57) degrees three (03) minutes forty-
two seconds West, a distance of two
(02) feet; 7) North thirty-two (32) de-
grees fifty-six (56) minutes eighteen
(18) seconds East, a distance of sixty-
six (66) feet; 8) North fifty-seven (57)
degrees three (03) minutes forty-two
(42) seconds West, a distance of four
(04) feet to a point on the dividing line
between Lot No. 67 and Lot No. 68,
said point being the point and place
of beginning; thence along the said
dividing line and passing through
the centerline of a party wall dividing
units 67 and 68, North fifty-seven
(57) degrees three (03) minutes forty-
two (42) seconds West, a distance of
thirty-two (32) feet to a point; thence
North thirty-two (32) degrees fifty-six
(56) minutes eighteen (18) seconds
East, a distance of five (05) feet to a
point; thence South fifty-seven (57)
degrees three (03) minutes forty-two
(42) seconds East, a distance of eight
(08) feet to a point; thence North
thirty-two (32) degrees fifty-six (56)
minutes eighteen (18) seconds East,
a distance of twenty-one (21) feet
to a point; thence South fifty-seven
(57) degrees three (03) minutes forty-
two (42) seconds East, a distance
of twenty-four (24) feet to a point;
thence south thirty-two (32) degrees
fifty-six (56) minutes eighteen (18)
seconds West, a distance of twenty-
six (26) feet to the point and place of
beginning.
BEING Lot No. 67 as shown on
Amended Final Plan of Hunter's
Ridge, recorded in Plan Book 58,
Page 62, and as more particularly
described on As-Build Plan of Section
1, Hunter's Ridge, dated November
7, 1989, and recorded in Plan Book
59, Page 83.
TOGETHER with the right to
use any Limited Common Area ap-
purtenant to the lot being conveyed
herein pursuant to the Declaration,
the Amended Final Plan for Hunter's
Ridge, the As-Built Plan referenced
herein, and the Declaration of As-
signment of Limited Common Area
for Hunter's Ridge, dated May 10,
1990, and recorded in Miscellaneous
Book 380, Page 519.
UNDER AND SUBJECT, never-
theless, to easements, restrictions,
reservations, conditions and rights of
way of record or visible upon inspec-
tion of premises.
HAVING erected thereon a dwell-
ing known as 1786 Weatherburn
Drive, New Cumberland, PA 17070.
40
CUMBERLAND LAW JOURNAL
PARCEL NO. 13-25-0068-237.
BEING the same premises which
Jason M. Kanovich, single man, by
Deed dated 11/29/2007 and record-
ed 12/04/2007, in the Recorder's
Office of Cumberland County, Penn-
sylvania, Instrument No. 200745055,
granted and conveyed unto R. Jacob
Johns, single man.
41
The Patriot-News Co.
2020 Technology Pkwy
Suito 390 - '
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
of Patr1*otwXews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she 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.
This ad ran on the date(s) shown below:
04/22111
04129111
ape A. Lacer )X k'4
tst
3 ee" by Sworn to and subscribed be ore me this 2?3 day of May, 2011 A.D.
a Of two
'---?----
t2?t3tsna?e, Notary Public
++'' 1 COMMONWEALTH OF PENNSYLVANIA
c , Notarial Seel
klkE a l Sherrie L KWw, Notary Public
det?Kaei i18)bee! 1 Lower Pmemn Twp., DwpWn County
toe, , My Commkolm Bp % Nov. 26, 2011
Member. Pennsylvanla Assodatbn of NczOn-
of
fa1B21
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which PNC Mortane is the grantee the same having been sold to said grantee on
the 7 day of September A.D., 202011, under and by virtue of a writ Execution issued on the 2 day of
February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010
Number 7715, at the suit of PNC Mortgage against R. Jacob Johns is duly recorded as Instrument
Number 201128971.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this c2 day of
A.D.
6 --?y
C r ?c?
?Yre R?rt Yonder d Jm 2014