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HomeMy WebLinkAbout01-2907FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD sUITE 1400 PHILADELPHIA, PA 19103-1814 (~lS) s~'~.7oon CHASE MANHA'I~fAN MORTGAGE CORPORATION 3415 VISION DRIVE, COLUMBUS, OH 43219-6009 TERM Plaintiff LILLIAN E. BUCKLES CHARLES A. BUCKLES, HI 424 BURGNER ROAD, CARLISLE, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. CUMBERLAND cOUNTY Defendant(s) CIVIl, COMPI ,AINT I~ **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE pREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must lake 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. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiffis: CHASE MANHATTAN MORTGAGE CORPORATION 341 $ VISION DRIVE, COLUMBUS, OH 43219-6009 The name(s) and last known address(es) of the Defendant(s) are: LILLIAN E. BUCKLES CHARLES A. BUCKLES, II1 424 BURGNER ROAD, CARLISLE, PA 17013 who is/are thc mortgagor(s) and real owner(s) of thc pwperty hereinafter described. On 12/11/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNION MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of cUMBERLAND County, in Mortgage Book No. 1505, Page 694. By Assignment of Mortgage Recorded 9/16/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mongaga Book No. 624, Page 1057. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 9/1/00 through 5/1/01 (Per Diera $~3.23) Attorney's Fees Cumulative Late Charges 12/11/98 to 511101 Cost of Suit and Title Search Subtotal $67,796.38 3,214.89 3,389.00 146.46 55fl fl0 $75,096.73 Escrow 0.00 Credit 51 o 43 Deficit ~; ~ I O 43 Subtotal TOTAL $75,616.16 7. Thc 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in mm Judgment against the Defendant(s) in the sum of $75,616.16, together with interest from 5/1/01 at the rate of $13.23 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /si Frank Ft.clerman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff VKRll~I~ATION CHRISTOPHER STUMP hereby states ~at ]]e/she is kK~'r]~$[~l$1'[~' of C~SE ~TTAN ~ORTGAGE CORPO~TION mo~gage s~c~g agent f~ Pla~ff in ~s ~, ~at h~she is aulho~z~ to t~e ~s Vedflcaion, ~d fha ~e staements made ~ the foregoing Civil Acti~ ~ Mo~gage Fo~lo~ ~e ~e md co~t to ~e best of ~s~ ~owl~g~ i~o~ation ~ beli~. ~e ~d~ed ~d~st~ds that ~s starcraft is m~e subject to ~e p~alties of 18 Pa. C.S. Sec. 49~ relafi~ ~ ~swom f~sification to au~odti~. · , who being duly ewor~ according to laW, a was served upon  the cu~e~la~d ~ a~ ~ ~0 -' E PA~ together with tZ~ 2~a atte~ the~eO~ ' ame time DOC~t ~ng .0 u Se~~ce ~0 · 00 A~idaVit .00 05/29/~00% SUrcharge ~r~Ot~ i Y · to before SWOrn and subscribed ~' day of ~e this ~ A.D. SHERIPF,S RETURN _ CAsE NO: 2001-02907 p REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTy OP CUMBERLAND VS Curmberland County, Pennsylvania; Sheriff or Deputy Sheriff of who being duly sworn according to law, says, the Within ~  was served Upon ~_E_E_E_E~__~ ~~~~ the ~, at ~ HOURs, at ~ on the 25_~th day of --' ~- ~UCKLEs a true and attested copy of .... ~ - MORT FORE together With NOTICE COMPLAINT _ and at the same time directing Hi___s attention to the contents thereof. 6.00 heriff's Costs: )ocketing ]ervice ~ffidavit lurcharge .00 .00 10.00 ._.00 16.00 )rn and Subscribed to before this ~- -~- day of ~-~-~~ A.D. So AnSWers: ~ 05/29/2001 FEDERMAN & PHELAN meputy Sheriff - FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Ccmer at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CttASE MANHATTAN MOTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, O1t 43219-6009 Plaintiff VS. LILLIAN E. BUCKLES CHARLES A. BUCKLES,Ill 424 BURGNER ROAD CARLISLE, PA 17013 Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY COURT OF COMMON PLEAS :CIVILDIVISION NO. 01-2907 CIVIL TERM ; PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of thc Plaintiff and against LILLIAN E. · to file an Answer to BUCKLES and CHARLES A. BUCKLES~III, Defendant(s), for failure of thc Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 511101 TO 6/26/01 TOTAL $75,616.16 $754.11. $76~70.27 I hereby certify that (1) the addresses of thc Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE DAMAGES ARE HEREBY ASSESSED ~ AS INDICATED. , . DATE: ~..M,d.~..~-~,~g~ { **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAJNED WILL BE USED FOR THAT puRPOSE. IF VOl.[ HAVE pREVIOUSLY RECEIYED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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. ** FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 CHASE MANHATTAN MORTGA~ CORPORATION ATTORNEY FOR pLAINTIFF : cOURT OF COMMON PLEAS : CIVIL DIVISION vs. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III : CUMBERLAND COUNTY : NO. 01-2907 De f endant (s) TO: LILLIAN E. BUCKLES 424 BURG~ER ROAD CA~LISLE,PA17013 FILE DATE OF NOTICE: ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, ~ ~ INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT pURPOSE. IF YOU RAVE 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 AS ENFORCEMENT OF LIEN AGAINST PROPERTY. You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN ' Frank Federman, Esquire identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 CHASE MANT~TTAN MORTGAGE CORPORATION Plaintiff VS. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III ATTORNEY FOR PLAINTIFF : cOURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND cOUNTY :NO.01-2907 Defendant TO: CI~LES A. BUCKLES, III 424 BURG~ER ROAD C2~RLISLE,PA17013 FILE DATE OF NOTICE~ ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS 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 T~AT pURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT ~ SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (~215) 5634000 CltASE MANIIATTAN MORTGAGE CORPORATION Plaintiff LILLIAN E. BUCKLES CHARLES A. BUCKLES~III Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas : :CIVIL DIVISION NO. 01-2907 CIVIL TERM 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 of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended Co) that defendant LILLIAN E. BUCKLES is over 18 years of age and resides at 424 BURGNER ROAD, CARLISLE, PA 17013. (c) that defendant CHARLES A. BUCKLES,III is over 18 years of age, and resides at 4?.4 BURGNER ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FEDERb74AN Attorney for Plaintiff (Rule of Civil Procedure No. 236 -Revised) CHASE MANHATFAN MOTGAGE CORPORATION Plaintiff VS. LILLIAN E. BUCKLES CHARLES A. BUCKLES,III Defendant(s) : CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION NO. 01-2907 CIVIL TERM : : : : Notice is given that a Judgment in the above captioned matter has bccn entered against you on JUNE 2~'7 ,200Q. EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 {215) 563-7000. COLLECT A DEBT AND ANY **THIS FIRM IS A DEBT COLLECTOR A'I'I'EMPTING TO flr YOU HAVE PREVIOUSLY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. AND SHOULD NOT BE CON~'I'RU.E.i/ t u or., ."~.~ ~.,. · ENFORCEMENT OF A !.IF~N AGAINST PROPERTY. y~,ECU'flON ' (MoRtGAGE FORECLOSURE) FOR V,/RI~ OF E~.R.C.p. 3150-3153 pR~CIpE Ct~MB~p..L~D cOU~'~Y dORI'G AGE CoRPORA'lION : No. 01-290'/ LILLIA-N E. BucKLES : Defendant(s)' TO THl~- DIRECTOR O~ THIS OFFIC~ OF THE pRoTHONOTARY: Issue writ of execution in ~h¢ abo~¢ raa~tor: 576,370.27 Amount Due Interest from 6/26/01 to 12/5/01 (per diem - 512.55) TOTAL 52,033.10 and Costs $78,403.37 Attorney for Plaintiff Note: pleaSe attach description of property.No. ALL THAT CERTAIN tract of land situate in Lower Frankford Township,'-CUmberland Co~nty,'- Pennsylvania, and described as follows: BEGINNING at a point at the northern line of the public road leading from Burgner's Bridge to Heishm~n's Bridge at line of property now or formerly of David R. Black; thence by said propewy, North 09 degrees East, $00 feet to a point; thence by property now or formerly of James W. Wogan, South 85-I/4 degrees East, 20&$ feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees $7 miuutes West, 500 feet to a point on the northern line of the said public road; thence by the n~rthem line of said public road, North 8§ degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and nUmbered as 424 Burgher Road, Carlisle, Penn~ylvnnln. Tax Parcel #14-06-0027-066 TITLE TO SAID PREMISES IS VESTED 1'51 Charles A. Buckles, ITI and Lfllian E. Buckles, His Wife by Deed from Dorothy $. Steele, Widow dated 12/11/1998, recorded 12/14/1998, in Deed Book 190, page 1044. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION : Plaintiff, : LILLIAN E. BUCKLES : CHARLES A. BUCKLES, III : Defendant(s). : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-2907 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: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ttomey for Plai~ iff CHASE MANHATTAN MORTGAGE CORPORATION : Plaintiff, : LILLIAN E. BUCKLES : CHARLES A. BUCKLES, HI : Defendant(s). : CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DMSION NO. 01-2907 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CHASE MANHATTAN MORTGAGE CORPORATION., Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real proper~y located at 424 BURGNER ROAD~ CARLISLE~ PA 17013 Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, PA 17013 CHARLES A. 424 BURGNER ROAD BUCKLES, 111 CARLISLE, PA 17013 Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above Name and 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 so indicate.) None Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so indicate.) None 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 so indicate.) None Name and address of every other person whom the plaintiff has 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 so indicate.) Tenant/Occupant 424 BURGNER ROAD CARLISLE, PA 17013 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 of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatior] / / August 1. 2001 . ~ J DATE /F R~NK F~E~I~I~ ~torney for Plak ~o authorities. [AN~, ESQUIRE tiff }RTGAGg coR~OI~2~EION LILLIA14_~ '. mlcY. LgS, 111 Be[endznt(u)' cuMBgV. LAND COU14T¥ 14o. August 29, 2001 CHARLES A. BucKLES, BI 4Z4 BURGNER ROAD TO: LILLIAN E. BUCKLES 424 BURGHER ROAD CARLISLE, PA 17013 A 17013 ' OR_M. ATIO14 c ~,RLISLE, I' ~gT A~D A~Y ~,~c~AgGE oB~ A~U w ~-.,~ ~HtS DEBt w ~ ~ BUT O~ ~ ~ ~" ~KRU~cY ~O coLLE~ ~ ucc-, · e C~b~l~d County CoughouSe, ~O BE ~N ~Eme t - BURGNER ROAD, c~ISLE' PA 17013is scheduled ~o be Your house (real estate) at 424 ~ ~0:00 a.mt x~ th __ ined by ~ e ...... DECEMBER S, ~e the cou~ ]ud~~ou If the S.c.ffs ~isted [or m~ ~-- ~, the p~pmr2 .... po~p~ ~, ~BLE TO pRE_VE~ ~~~ late charges, To prevent this Sheriffs bate, y', aee the back payments, you ma'., .... ~ ..... -ay to the mort.g g.._.,, much you must pay, . S6~-TOOO- c~tt. ~ ....... efifion ~ki~S m .... k the Cou~ to 2. You may v~_ j~e~t, iitBeju ~" pos~One the sale for good cause. You may also be able to stop ~e sale t~ou~ oth~ le~l proce~in~' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have o£ 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 ~FF'S SALE DOES TAKE PLACE. I. 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 Sheriffthe full amount due in the sale. To find out it' 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. You 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 of thc money bid for your house will be filed by the Sheriffwithin 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. SHOULO TAU THIS PAPER TO YOUR LAW~ER AT ONCE. ~ YOU OO NOT HAVE ]°,~wy,~.R OR CANNOT A~O~ ONE,';O TO oRTE~_E~ONE THE OmCE LISTEO ~££~Jw :ro ~INn OUT WRE~ YOU CAN aET L~.aAC CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990.-9108 ALL TRAT CERT.MN tract of land situate in Lower Fraakford Township, Cumberl~d County. ,' pennsylvania, and describe~ as follows: BEGINNING at a point at the uorthern line of the public road leading ~om Burgner's Bridge to Heisl~man's Bridge at line of property now or formerly of David R. Blnc~; thence by said propert2~, North 09 degr~s East, 500 feet to a point; thenc~ by property now or formerly of James W. Wogan, South 85-1/4 degrees East, 1108.5 feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees 57 minutes West, 500 feet to a point ou the northern line of the said public toad; thence by the n~rthern line of said public road, North 85 degrees West, 209 feet to the place of BEGIHNI~G. CONTAINING 2.~9~ ~tes. ' I-L~VING TItEREON ERECTED a one gory frame dwelling house know ami numbered as 424- Burgher Road, Carlisle, p~nsylvania. Tax parcel #14-06-0D27-066 TITLE TO SAID PREMISES IS VESTED IN Charles A. Buckles, III a~d Lillian £. Buckles, His Wife by De~l from Dorothy 3. Steele, Widov, d~gd 12/11./1998, recorded 12/t4/1995, in Deed Book 190, page 1044. AFFIDA¥IT OF SERVICE pLAINTIFF DEFENDANT(S) CHASE MANHATTAN MORTGAGE coRPORATION LILLIAN E. BucKLES cHARLES A. BucKLES~ HI sERVE LILLIAN E. BUCKLES AT 424 BURGNER ROAD cARLISLE, PA 17013 cuMBERLAND coUNTY No.01-2907 Type of Action . Notice of Sheriff's Sale Sale Date: DECEMBER 5, 2001 SERVED C~-I%~,"S ~'~. _, Commonwealth of Pennsylvania, in the manner described below: Defendant personally served' is ~Adult family ~mber with whom Defen~nt(s) reside(s). Relationship' Adult in charge of Defendan~S)'s ~sidence who ~sed to give ~me or ~lationship. e oflod lng in which Defen~n~s) ~side(s). ~ ~Ma~ger/Clerk o~ plac g ........ ~ce or us~l ph~ of business. Agent or ~on m charge of Dexe~sI an officer of said Def~dan~s)'s company. .Other: . Description: Age .... ~ose and state t~t I pe~o~lly ~nded ~ ...... 1_ C,g~, ~g, a co~gnt adult, being duly swo~ac~, ~. ;-=,,ed ~ ~e captioned case on the ~te and at ~. a~ess i~icated above. On fl~c day of ,200 , at o'clock .m., Defen~nt NOT FOUND because: _ Vacant ~ _ Move~ .~ _ U~o~_ No~swer Other: Sworn m and subscribed before me this ~- day of____ _, 200 _. Notary: By: Attorn for Plaintiff Frank Federnmn, Esquire - i.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) S63-7000 AFFIDAVIT OF SERVICE PLAINTIFF DEFENDANT(S) CHASE MANHATTAN MORTGAGE cORPORATION LILLIAN E. BucKLES CHARLES A. BUCKLES, II1 SERVE CHARLES A. BUCKLES, I11 AT 424 BuRGNER ROAD cARLISLE, PA 17013 cUMBERLAND couNTY No.01-2907 Type of Action = Notice of SheriiTs Sale Sale Date: DECEMBER S, 2001 SERVED of p~sylvinia, in thc ~cr d~scdhed ~low: U~f~in{ p~rso~lly s~rwd. Adult fa~ly me~ with whom Ucfen~t(s) ~side(s). Relafions~p is _ e of Defen~t(s)'s ~si~ce who reused W sire ~w~ or relafions~p. ~=nsaer/Clcrk of place ol loagms m .... , ......... I -l~e of business. --"'--= ___- :~ cherae ofDefen~nl(s) s omce ~- r Agent or per~o~, ,- o an officer of said Def~d~s)'s co.any. ~. / day o, 001, __, Commonwealth Other: _ - , .__ - Height -~ld~ Weight ~ Race ~ ~ Sex ~ ~ ~ . . DescnpUou: Age ~- ~ ...... n~-o~ ~d s~te t~t I ~mo~lly ha~aea dult being duly sworn accorat~ to aw, ~-p . on the ~ ~a at . ,~,,~, ~ ~,acompetenEa . , ....... ,Fo ~in, issuedmt~captlonedc~ ~ o~t cony of ~ ~ot~c · ' ' a ~e and c . ~ ~ ad.ess indicated above. On ~e ..... - - Vac~ Other: Sworn to and subscribed before me this__ . day ., 200 _. or'_ _ Nota~ff: By: Attorne for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (2~5) 563-7000 SALE DATE: DECEMBER $ 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHASE MANHATTAN MORTGAGE CORPORATION No.: 01-2907 VS. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III AFFIDAVIT pURSUANT TO RULE 3129.1 AND RETURN OF SERVICE pURSUANT TO pa. R.C.P. 405 OF NOTICE OF SALE Plaintiffin 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 loca~-,d at: _424 BURGNER ROAD, CARLISLE, PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. November 30, 2001 CUMBERLAND COUNTY CHASE MANHATTAN MORTGAGE CORPORATION No.: 01-2907 VS. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 2) Plaintiff in the above action, by its attorney, Frank Federman, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD, CARLISLE, PA 17013: 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) 4. Name and address of last recorded holder of every mortgage of record: Last Known Address (if address cannot be Name reasonably ascertained, please indicate) CHY~E MANHATT~aN MOR?GAGE coRPORATION :: PlaintifL : LILLIA~N E. BucKLES CHARLES A. BUCKLES, III Defendant(s). cUMBERLAND coUNTY coURT OF coMMON PLEAS CIVIL DIVISION NO. 01-zg0? AFFIDAVIT pURSUANT TO RULE 3129 (Affidavit No. 1) ~TAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER _ROAD, CARLISLE, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): LAST KaNOWN ADDRESS (If address cannot be NAME reasonably ascertained, please so indicate.) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, PA 17013 CHARLES 3, BUCKLES, !II 424 BURGNER ROAD CARLISLE, PA 17013 Name and address of Defendant(s) in the judgment: LAST KNOWN ADDRESS (If address cannot be NAIvlE reasonably ascertained, please so indicate.) Same as 3bove Name and 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 so indicate.) Name and address of the last recorded holder of every mortgage of record: NAME LAST IONOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so indicate.) None 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 so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: LAST KNOWN ADDRESS (If address cannot be N.&ME reasonably ascertained, please so indicate.) Tenant/Occupant 424 BURGNER ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County. 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 [ verify that thc 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 , authorities. penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsificat7 DATE Itomey for Plai~ £SQUU e :iff DATE: August I, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) LILLIAN E. BUCKLES CHARLES A. BUCKLES, III PROPERTY: 424 BURGNER ROAD CARLISLE, PA 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on DECEMBER $, 2001 at 10:00 a.m. in Cumberland Count5' Courthouse~ South Hanover Street~ Carlisle~ PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriffon a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH STATE OF PENNSYLVANIA, ss. COUNTY OF CUMBF LAND Robert P Zie$1er - - - .............................................................................. Kecorder~ Deeds in and for said County and State do'hct~b~ ccfllfy that thc Sheriff's Deed in which ................ Chase Nanhattan Htg Gorp k thc grantee the stme havlnE been sold to said Krantec mi the ............................................... day d Dec O1 ......................... A, D., ." ..... , under and by vlrtuc of a writ .............. ............... 10ch Exe.'ut ~o.n_ ................................ issued on thc ..................................... Sept 01 d~yof .......................... A.D. .... .~ out d thc Canrt of Comman Pleas of sold County'ss of Civil O1 Te~'m ...... 2907 Chase Manhattan HOg Corp Number .............. ~ at the suit o~ ............................................................... Llllian E Buckles & Charles A III ................................... a~inst .................................................... h 2~9 3389 duly ~soorded in Shcrlf~s Deed Book No ............. , Page ............. IN TESTIMONY WHEREOF, I bye hereunto set my hand and seal of said office this ...J.~ ..... day of .....~ ........... A. D., Chase Manhattan Mortgage Corporation VS In The Court of Common Pleas of Cumberland County, pennsylvania Writ No. 2001-2907 Civil Term Lillian E. Buckles and Charles A. Buckles, III Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2001 at 10:21 o'clock P.M., E.D.S.T., she served a true copy of the within Real Estate Walt, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lillian E. Buckles, by making known unto Charles Buckles, adult in charge, at 424 Burguer Rd., Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested coPY of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2001 at 10:21 o'clock P.M., E.D.S.T., she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Charles A. Buckles, III, by making known unto Charles Buckles, at 424 Burguer Rd., Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Shannon Sunday, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 2, 2001 at 9:09 P.M., E.D.S.T., she posted a true copy of the within Real Estate Writ, Notico, Poster and Dascdption, in the above entitled action, upon the property of Lillian E. Bueklas and Charles A. Buckles, III located at 424 Burgher Rd., Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notico of the pendency of the action to one of the within named defendants to wit: Lillian E. Buckles, by regular mail to her last known address, 424 Burguer Rd., Carlisle, PA 17013. This letter was mailed under the date of Octnher 3, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Charles A. Buckles, III, by regular mail to his last known address, 424 Burgher Rd., Carlisle, PA 17013. This letter was mailed under the date of October 3, 2001 and never returned to the ShefiWs 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, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, pennsylvania, on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Frank Federman for Chase Manhattan Mortgage Corporation. It being the highest bid and best price received for the same, Chase Manhattan Mortgage Corporation of 3415 Vision Drive, Columbus, OH 43219-6009, being the buyer in this execution paid ShefiffR. Thomas Kline the sum of $660.68, it being costs. Sheriff's Costs: Docketing $30.00 Posting Handbills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 7.80 Certified Mail 4.53 Levy 15.00 Surcharge 30.00 Postpone Sale Law Journal 242.15 Patriot News 169.59 Share of Bills 25.66 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 Poundage 12.95 $ 660.68 Sworn and subscribed to bcforc me This ;b~ day of~ 2001, A.D.~~''' · ~ R. Thomas Kline, Sheriff BY CHASE MANHATTAN MORTGAGE CORPORATION : Plaintiff, : LILLIAN E. BUCKLES : CHARLES A. BUCKLES, IIl : Defendant(s). : CUMBERLAND cOUNTY cOURT OF cOMMON PLEAS CML DIVISION NO. 01-2907 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiffin'the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD~ C.~RL][SLE~ PA 17013 Name and address of Owner(s) or reputed Owner(s): NAME LAST IO~OWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, PA 17013 CHARLES A. BUCKLES, 11I 424 BURGNER ROAD CARLISLE, PA 17013 Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If addrass cannot be reasonably ascertained, please so indicate.) Same as above Name and 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 so indicate.) None Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so indicate.) None Name and address of every other person who has any record interest in the pwperty and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiffhas knowledge who has any interest in the property, which may be affected by the sale: LAST KNOWN ADDRESS (If address cannot be NAME reasonably ascertained, please so indicate.) Tenant/Occupant 424 BURGNER ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfaro PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the ~ authorities. penalties ofl$ Pa. C.S. Sec. 4904 relating to u~wom falsiI~at7 DATE ttomey for Plai~ ~ ESQUIKE :iff August 29, 2001 F~. BiICICLES 47,4 BUt~ c~tLiSLE' i~A LILLI~G~R ROAD ~O: U ' o~;oD . ~EBT coLLU~ L~, m~OSE, tr ~ ~15 ~S ~u ~OBEANAtt~" , ,-state)at41~_, 2O0tatl0:~ ' :.~entobt~n~ · ~ ~* *~e Shefitrs a~,~ -,:-re ~A ~Ut ~0~ (thc mo~;~s Sale. South H~ M~c~ ~' pOStpOu~' pvcv~t this Shcfi~s Sale, you must ~ ~- thc mo~gag~ To -' ~ if you pay to e le willbe c~ce~.~m fees ~ue. To n I. cos~ ~ ~e · call: ~ sale by filing a petition asking t . --~ the Cou~ to pos~On¢ the sale for sale t~u~ oth~ legal you may also be able to stop the , ' --act one, the more chance · . er oU COPt '._ our, ts. oob,in att° eY') You ma~ nc~:_, the sale. 15ce you w~B have of stop~u,~ ' You may _..~ find you may be able to petition %he Cou~ to set aside ~he sale. ~o . -' o the value of your pwPe~Y, full ~ount due m ~equate comP=~ t , .' e bu er pays the Sh~ff the find out if th~s h~ ~PP ~o ~he She~ff, ~ou will rema~ ~he owner of the ~. ff the amount due from the Buyer is ~ot pa~d _ hav~ene& - e is ~ai~ ~o the 5he~ff -.v as if the sal~ never -- ,. -'il the ~11 amount ou , ~...din~ to evict 5. You ha~ - - thc buyer. ~ ~"" ........ thc _ ~d the Sheriff gives a deeu to ou e which w~ paid for your house. A schedule of. 6 You may be _.. r~. -our hOUSe w~,, ~u~ money will be para _ _ m~a with the GISLLiu~ ...... who Will v~ ~-- ~ .~g n~poS~ W~cfiff within ten (10) days ant or wa~ of getting your home You may also have other d~ ~d defenses, 7. DO NOT HAV} ~mmedia~clY a~er the sale. ER AT ONCE. IF yOU ~ THIS pAPER TO yOUR LA~ CE LISTED x~ ~i-~ ~ caNNOT ~e~., ~ ~ GET LE~A~ cUMBE~AND COUNTY ATTO~EY cUMBEreD COUNTY BAR AssOCIATION . , ERTY AVENUE 1 LIB _~.,~v OURTHOUSE ~,,~BE~AND Cuu~'l~ ~2~13 (~1~ 249-3166 (800] 990-9108 ALL TI-La, T CERT.MN tract of land situate in Lower Frankford Township, Cumberland ~;tm.w,' Pennsylwni~, and descn'oed as follows: BEGINNING at a point at the northern line of the public road leading from Burgner's Brid~e m Hei~m..'s Bridge at line of property now or formerly of David R. Blacl~; thence by said l~ropert~., North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W. Wogan, South 85-I/4 degrees East, 208.$ feet to a point; thence by line of property now or formerly of Manha E. Nickel, .South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public mad; thence by the n~rthera line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAI~'NG 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and vumbered as 424 Burgher Road, Carlisle, Penusylvnni~. Tax Parcel//14-06-0027-066 TITLE TO SAID PREMISES IS VESTED IN Charles A. Buckles, 1II and Lillian E. Buckles, His Wife by Deed from Dorothy $. Steele, Widow dated 12/ll/1998, recorded 12/14/1998, in Deed Book 190, page 1044. WRIT OF EXECUTION and/or A'n'ACHMENT COMMONWEALTH OF PENNSYLVANIA) CO'JNTY OF CUMBERLAND) NO. 01-2907 c'rv~. CIVIL CIVIL ACTION - LAW TO THE SHERIFF OF Ct~berland .COUNTY: To satisfy Ihe debt, interest and costs due Chase Manhattan Nortgacje Co~ooration PLAINTIFF(S) Imm ' ' kles Charles A. Buckles_~_, III 424 Bur~qner Rc~d, Carlisle, Pa. 17013 DEFENDANT(S) (1) You are directed lo levy upon the properly of the defendant(s) and to sell lisle Pa. 17013 (2) You are also directed to attach the properly of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of Ihe defendant(s) and from delivering any propa~y of the defendant(s) or otherwise disposing thereof; (3) If Pr°POrIy °f Ihe defendant(s) nol levied upon an subject to attachment is found in the possession of anyoneolher than a named garnishee, you are directed to notify him/her Ihat he/she has been added as a garnishee and is enjoined as above staled. Amount Due $7R. q70.27 Atty's Comm Airy Paid Plaintiff Paid to 12/5/01 (per diem - $12.55) ~, .... 10 % 12n 44 L.L. $n:SN Due Pmthy $1__ q9 Other Cosls Date: A-De,~nh~' 10. 2001 REQUESTING PARTY: Address: n~e Penn ~en('Rl' a~ Su~n Station A~orney for:. P~tiff Telep~ne: Supreme Cou~ ID No. by: Curtis R. Long Prothonotary, Civil Division / / Depu~ Suite 1400 REAL ESTATE SALE No. On September 17, 2001, the sherifflevied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA, known and numbered as 424 Burgner Road, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 17, 2001 By: q~ ~ ~ ~t l~eal Estate Dep y PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthnl, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since J'anuary 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. RY. AL ~TAT~ ~ NO. ~ Writ No. 2001-2907 Civil Chase Manhattan Mort?~e Corporation VS. Lillinn E. Buckles and Charles A. Buckles. HI Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in Lower Frank/'ord Town- ship, Cumberland County, Pennsyl- van/a, and described as follows: BEGINNING at a point at the northern line of the public mad lead- lng front Bur~er's Brid~e to Hel~h- man'a Bridge at line of property now or formerly of David R. Black; thence by said property. North 09 degrees East, 500 feet to a point: thence by property now or formerly of James W. ~)gan, South 85-1/4 SWORN TO AND SUBSCRIBED before me this 26 .day of OCTOBER. 2001 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, N~proved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly swom according to taw, deposes and says: That he is the Aeounts Receivable Manager of The Patriot News Co., a corporation organized end existing under the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The ~,atrlot-News and The Sunday Patriot-News newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is Interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severafly 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 M~;~celleneous Book Volume 14, Pegs 317- ~ ~/ PUBLICATION .............................. ....... ........................ .......................... Sworn ,o and subscril~d before,~rtis 19th ~/~/xo' ~rtber 2001 A.D. COPY Ha;~,;, ~.l~n ~.~'~- I I~TARY PUBLIC My Co~r~smo~ E~l June 6 I Member, Penna,~rlla AeaQ(~IU00 Oi ~J~SBJ'';i68 Of~ expires June 6, 2002 CUMBERLAND COUNIY SHERIFFS OFFICE U~. ~ CUMBER[AND COUNTY COURTH(XJBE CIt~ & ~,a CARLISLE, PA. 17013 Statement of Advertising Costs Jam= W. NN~pn, Seuth 8,5-i~ d[~unm Eut, To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 168.09 Probating same Notary Fee(s) $ 1.50 Total $ 169.59 Publisher's Receipt for Advertising Cost The Patriot News Co., pubflsher of ~.-.E.~and ~.~,~;iE,~[~, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.