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HomeMy WebLinkAbout02-0373#9429-SF MARTHA E. VON MARTHA E. VON 16 SOUTH LANS] PO BOX 457 LANSDOWNE, PA Attorney ID # ROSENSTIEL, ESQUIRE ROSENSTIEL, P.C. DOWNE AVENUE 19050 52634 Attorney for Plaintiff Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant(s) : COURT OF COMMON PLEAS : Cumberland COUNTY Case No : DoZ - 373 CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you 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. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant(s) Attorney for Plaintiff : COURT OF COMMON PLEAS : Cumberland COUNTY Case No: CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Secretary of Veterans Affairs, a corporation organized and existing under state law, with offices for the conduct of business at Wissahickon Avenue and Manheim Street, Philadelphia, PA 19101. 2. Defendants, Jesse R. Clark are the mortgagors and real owners of premises 1506 Boiling Springs Road, Boiling Springs, PA 17007, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Mortgage Investors Corp. on March 13, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1442, page 841, secured on premises 1506 Boiling Springs Road, Boiling Springs, PA 17007 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned in writing to the plaintiff, Secretary of Veterans Affairs on January 14, 2002, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 683, page 414. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 1, 2001 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $126,804.02 Interest from 05/01/01 to 01/18/02 At $24.32 per diem $ 6,409.31 Accrued late charges to 0 1/15/02 $ 290.32 Accrued Escrow deficit to 01/15/02 $ 1,277.12 Monthly Inspections from 06/01/01 To 01/01/02 at $15.00 per month $ 105.00 Attorney's Fee $ 6,300.00 Title Information Certificate $ 350.00 Photostats and Postage $ 45.00 Notarizations $ 10.00 TOTAL $141,590.77 9. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). plaintiff demands judgment for $141,590.77, plus per diem interest at $24.32 from 01/19/02 to the date of judgment plus monthly late charges of $36.29 from 02/15/02 to the date of judgment plus monthly escrow deposits of $159.64 from 02/01/02 to the date of judgment plus monthly inspection costs of $15.00 from 02/01/02 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff CHL # 5530900, Our File # 9429 VERIFICATION I verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. By: ?? !t? Title: ?o/16CLaSueE JpE??a/:5? Dated: DESCRIPTION TRACT NO. 1 ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a stake in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Churchtown Road); thence South eighty-nine degrees fourteen minutes thirty seconds West (S. 890 14' 30" W) along same a distance of one hundred (100.00') feet to a stake; thence North five degrees fifty- two minutes thirty seconds West (N 05° 52' 30" W) along the Eastern line of lands, now or formerly, of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.52') feet to a stake in the center of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty seconds East (N. 810 17' 30" E) along same a distance of ninety-nine and seventy-two hundredths (99.72') feet to a stake; thence South five degrees fifty-two minutes thirty seconds East (S 050 52' 30" E) along the western line of lands, now or formerly, of Lee W. Renshaw and Verle K. Renshaw, husband and wife, a distance of two hundred forty and forty-seven hundredths (240.47') feet to a stake in the center of Pennsylvania Traffic Route No. 174, the place of beginning. CONTAINING approximately .534 acres. TYE above description is according to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO. 2 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle prepared by Stephen G. Fisher, dated October 17, 1984, a copy of which was recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on January 30, 1985, in Plan Book 37, page 31, as follows: BEGINNING at a P.K. nail set in the original centerline of thirty-three (33') feet wide Township Road T-551, known as Lutztown Road, at the dividing line between Lots Nos. 1 and 2; thence from said P.K. nail at the Place of Beginning along said original centerline of thirty-three (33') feet wide Lutztown Road, North eighty-one degrees seventeen minutes thirty seconds East (N 81° 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16') feet to a P.K. nail at the Northwestern corner of said lot described in Deed Book 21 "Z", page 124; thence along the Western line of said lot described in Deed Book 21 "Z", page 124, South five degrees fifty-two minutes thirty seconds East (S 050 52' 30" E), a distance of two hundred twenty-six and sixty-two hundredths (226.62') feet to a P.K. nail set in the original centerline of L.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsylvania Route No. 174, South eighty-nine degrees fourteen minutes thirty seconds West (S 890 14' 30" W), a distance of twenty-five (25') feet to a P.K. nail set at the dividing line between said Lots Nos. 1 and 2; thence along said dividing line between said Lots Nos. 1 and 2, North five degrees fifty-six minutes six seconds West (N 05156' 06" W), a distance of two hundred twenty-three and fifteen hundredths (223.15') feet to a P.K. nail set in the original centerline of said Lutztown Road at the place of beginning. THE ABOVE described tract of land contains a net area of approximately 4246.63 square feet exclusive of the rights-of-way of Lutztown Road and of Pennsylvania Route No. 174, and is all of Lot No. 2 as shown on said Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle recorded as aforesaid and which lot of ground is conveyed as an addition to the lot of ground adjoining on the East described in Deed Book 21 "Z", page 124 and shall hereafter be considered a part of the same and said parts shall be a single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate government authorities shall determined otherwise. SO MUCH of the above described tract of land as lies within twenty-five (25') feet of the original centerline of Lutztown Road and within thirty (30) feet of the original centerline of Pennsylvania Route No. 174 has been dedicated as portions of the rights-of-way of said roads as shown on said Final Minor Subdivision Plan recorded as aforesaid. Parcel #22-29-2478-002 December 5, 2001 TO: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLANIANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Jesse R. Clark PROPERTY ADDRESS: 1506 Boiling Springs Road, Boiling Springs, PA 17007 LOAN ACCOUNT NO: CHL # 5530900 ORIGINAL LENDER: CURRENT LENDER/SERVICER: COUNTRYWIDE HOME LOANS HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. -IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, -IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND -IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowners Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application NIUST be tiled or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. Thev will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 1506 Boiling Springs Road, Boiling Springs, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the The following months and the following amounts are now past due: Monthly payments 6/1/01 to 12/1/01 at $641.96 per month $ 4,493.72 Accrued Late Charges to 12/1/01 $ 224.70 Escrow Payment $ 1,117.43 Escrow Balance (- S 625.33 ) TOTAL AMOUNT PAST DUE S5,210.57 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,210.57, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by cash, cashier's check, certified check or monev order made pavable and sent to: COUNTRYWIDE HOME LOANS. 6400 LEGACY DRIVE, PLANO TX 75024 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately 8 months from the date set forth in this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS Address: 6400 LEGACY DRIVE, PLANO TX 75024 Phone Number: 972-608-6000 Contact Person: Samantha Burks EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney" fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: -TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTEHR LENDING INSTITUTION TO PAY OFF THIS DEBT. -TO HAVE THIS MORTGAGE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF -TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). -TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. -TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. -TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Peansylva.nia, Inc. 2000 Lingiestown Road Harrisburg, PA 11102 (717)' 641-1757 Cuban League of Metropolitan Ha--;zsbu s IN;. 6th Screet Harrisburg, PA 17101 (717) 234-5925 FA-Y (717) 234-9459 CT--MBEPj.LN7D COU'YrL Community Action Comm of the Capital Region 1514 Der-y Street Fiar-isburg, P.A. 17104 (717) 232-9757 FAUX (717) 234-2227 Financial Cau Selig Ser-rrces of Frank: 31 West 3rd Sleet Waynesboro, PA 17253 (717) 762-32S5 YWCA of Carlsle 301 G St eet Carlisle, PA 17 013 (717) 243-3818 F.A.Y (717) 731.9569 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P-k 17325 (717) 3341518 F.iLv, (717) 334-8325 ru M tr' Postage $ Q' Certifed Fee ' • - Ull Postmark I Return Receipt Fee Here Q (Endorsement Required) C3 p Restricted Delivery Fee (Endorsement Required) / C3 Total Postage & Few M L.n entTo ra Jesse R. Clark ---- --- ----------------- C3 c3 °- ....__.... Apt. No.; or PO Box No. 1506 Boiling Springs Road r r61 iniz prinRs,. PA 17007 (9429SF ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Jesse R. Clark 1506 Boiling Springs Roa Boiling Springs, PA 1700 n c `o c E m m m m m.5 m b c ` 0 "mmm ^ R8 10 00 50 D b33 Ef_ <B° ? 91 6 4 ? Eo 0 _:?: Dcwr,_. oa 1 9 0: 0 r 70 r Z W ?W O ° U t\ a 'C O f WW u ro O o lr? z en ¢ Q' r•-i ° w w Z z 4 Cl) DO Q MW G G s = G GL WW = rn z S •ri ? n O z O ? ? J 0 0 QI Cn Q N W r,; ° m x to b? U O = z a S4 r I 1--• J m CU CO •? rn ?1 f ° ¢ ¢ E U •.•a CL > I-q U) OZ a 4 O bo E o PQ W ¢ LL `m O 7 W c m W ?O r-I W W a1 > 'm m n 0) lf1 'rl Q ¢ 2, ° A. Received SS Eby (Pl?pse Print I I l?1ey( ?ry Te C. Signnnpppture ?, / _ ? Agent ?%? ?l. ? Addressee D. Is delivery address different from Rem 1? ? Yes If YES, enter delivery address below: ? No 3 ert Type ? Certified Mail 13 Express Mail Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes z. ?d)U bffr OM el"n69 1232 09429-Act 91 Notice) SF M M 00 M E o U N a PS Form 3811, July 1999 Domestic Return Receipt 102595-00•M•0952 ? CLa r..J A #9429-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term TO THE PROTHONOTARY: PRAECIPE Enter judgment in the sum of $143,474.83 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Defendants: 1506 Boiling Springs Road Boiling Springs, PA 17007 Martha E. Von Rosenstiel Attorney for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants : No: 02-373 Civil Term ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint $141,590.77 Additional interest on unpaid balances from 01/19/02 to 03/20/02 at $24.37 per diem $ 1,462.20 Additional late charges from 02/15/02 to 03/15/02 at $36.29 per month $ 72.58 Additional escrow deposit 02/10/02 to 03/01/02 at $159.64 per month $ 319.28 Additional monthly inspections from 02/01/02 to 03/01/02 at $15.00 per month $ 30.00 Total assessment $143,474.83 a E. Von Rosenstiel ,, ( Attorney for Plaintiff AND NOW, to wit, this Ac"'`d'aq-of , 2002, damages are assessed as above. Pro Prothy , Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Department of Veterans Affairs Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 No: Oa - J73- C 1 ?/z- 7-F1eP7 Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF Samantha Burks, being duly sworn according to law deposes and says that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; That Jesse R. Clark is over 21 years of age and resides at 1506 Boiling Springs Road, Boiling Springs, PA 17007. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. ? DA, 11.E L -irXA%1 Foreclosure Specialist Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on February 27, 2002, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff DATED: March 20, 2002 #9429-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant TO: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Attorney for Plaintiff : COURT OF COMMON PLEAS : Cumberland COUNTY Case No: 02-373 Civil Term • y Date of Notice: February 27, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY ---aTS. YOU SHOULD TAKE THIS .S. POSTAL SERVICE CERTIFICATE OF MAILIN Affix fee here in stamps HAVE A LAWYER OR CANNOT MAY RE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT orlgeter-?o?age and PROVIDE FOR INSURANCE-POSTMASTER pcon ?SdD Inquire of CNG OFFICE TO FIND OUT Received FRARTHA E. VON ROSENSTIEL, P.C. 16 S. LANSDOWNE AYE. P. 0. BOX 457 ?O 1ANSDOWNE, A 19 50 J ???ffw2?'p7' ce0% One piece of ordinary mail addressed to: L°vL O Jesse R. Clark L °2G 1506 Boiling Springs Road Boiling Springs, PA 17007 PS Form 3817, Mar. 1989 PY4Ly-L.i / Notice-sF Por4gsj(!1 f% current few ? f!1 >? cuMrro 3ociation s, O ' L3 -M -0 iI7 OCI` tr ENO _el , -4 -4 O 0 tnC1W O N W CW i V r f ?? K (? 1 PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Secretary of Veterans Affairs V. NO. 02-373 Civil Term Jesse R. Clark Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $143,474.83 INTEREST from 03/21/02 to SALE DATE At $24.37 per diem $ (Costs to be added) Martha E. Von Rosenstiel Attorney for Plaintiff 'q r &? c8 Y ` 07 h ? V A w ? }? ?1 'w 1 f?. i ?` f7 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any false statements given herein. M a . Von Rosenstiel Attorney for Plaintiff Dated: March 20, 2002 ;- C rv n7f; ?- „? _ t''?'' ?? ? ?J - ; GO__:: fl?? a .__ - i ; -? -.._ -{ f?? -< Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants No: 02-373 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the 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 1506 Boiling Springs Road, Boiling Springs, PA 17007. 1. Name and address of owners(s) or reputed owner(s) Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 2. Name and address of defendant(s) in the judgment: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 1506 Boiling Springs Road, Boiling Springs, PA 17007. 1. Name and address of owners(s) or reputed owner(s) Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 2. Name and address of defendant(s) in the judgment: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare 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. Section 4904 relating to unworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 March 20, 2002 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount of Judgment: $143,474.83 Date of Judgment: March 20, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 02-373 Civil Term Plaintiff: Secretary of Veterans Affairs Defendants: Jesse R. Clark Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 1506 Boiling Springs Road Boiling Springs, PA 17007 will be sold by the Sheriff of Cumberland County on September 4, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Jesse R. Clark. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely Martha MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 March 20, 2002 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount of Judgment: $143,474.83 Date of Judgment: March 20, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 02-373 Civil Term Plaintiff. Secretary of Veterans Affairs Defendants: Jesse R. Clark Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 1506 Boiling Springs Road Boiling Springs, PA 17007 will be sold by the Sheriff of Cumberland County on September 4, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Jesse R. Clark. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel n r z ?: v r, ?1 a DESCRIPTION TRACT NO. 1 ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a stake in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Churchtown Road); thence South eighty-nine degrees fourteen minutes thirty seconds West (S. 890 14' 30" W) along same a distance of one hundred (100.00') feet to a stake; thence North five degrees fifty- two minutes thirty seconds West (N 05° 52' 30" W) along the Eastern line of lands, now or formerly, of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.52') feet to a stake in the center of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty seconds East (N. 81° 17' 30" E) along same a distance of ninety-nine and seventy-two hundredths (99.72') feet to a stake; thence South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" E) along the western line of lands, now or formerly, of Lee W. Renshaw and Verle K. Renshaw, husband and wife, a distance of two hundred forty and forty-seven hundredths (240.47') feet to a stake in the center of Pennsylvania Traffic Route No. 174, the place of beginning. CONTAINING approximately .534 acres. TYE above description is according to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO. 2 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle prepared by Stephen G. Fisher, dated October 17, 1984, a copy of which was recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on January 30, 1985, in Plan Book 37, page 31, as follows: BEGINNING at a P.K. nail set in the original centerline of thirty-three (33') feet wide Township Road T-551, known as Lutztown Road, at the dividing line between Lots Nos. 1 and 2; thence from said P.K. nail at the Place of Beginning along said original centerline of thirty-three (33') feet wide Lutztown Road, North eighty-one degrees seventeen minutes thirty seconds East (N 81° 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16') feet to a P.K. nail at the Northwestern corner of said lot described in Deed Book 21 "Z", page 124; thence along the Western line of said lot described in Deed Book 21 "Z", page 124, South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" E), a distance of two hundred twenty-six and sixty-two hundredths (226.62') feet to a P.K. nail set in the original centerline of L.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsylvania Route No. 174, South eighty-nine degrees fourteen minutes thirty seconds West (S 89° 14' 30" W), a distance of twenty-five (25') feet to a P.K. nail set at the dividing line between said Lots Nos. 1 and 2; thence along said dividing line between said Lots Nos. 1 and 2, North five degrees fifty-six minutes six seconds West (N 050 56' 06" W), a distance of two hundred twenty-three and fifteen hundredths (223.15') feet to a P.K. nail set in the original centerline of said Lutztown Road at the place of beginning. THE ABOVE described tract of land contains a net area of approximately 4246.63 square feet exclusive of the rights-of-way of Lutztown Road and of Pennsylvania Route No. 174, and is all of Lot No. 2 as shown on said Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle recorded as aforesaid and which lot of ground is conveyed as an addition to the lot of ground adjoining on the East described in Deed Book 21 "Z", page 124 and shall hereafter be considered a part of the same and said parts shall be a single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate government authorities shall determined otherwise. SO MUCH of the above described tract of land as lies within twenty-five (25') feet of the original centerline of Lutztown Road and within thirty (30) feet of the original centerline of Pennsylvania Route No. 174 has been dedicated as portions of the rights-of-way of said roads as shown on said Final Minor Subdivision Plan recorded as aforesaid. Parcel #22-29-2478-002 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY No: 02-373 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Your house and/or real estate at 1506 Boiling Springs Road, Boiling Springs, PA 17007 is scheduled to be sold at Sheriff's Sale on September 4, 2002 at 10:00 a.m. to enforce the court judgment of $143,474.83 obtained by Secretary of Veterans Affairs against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Secretary of Veterans Affairs the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 610 623-2660. 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 a 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 the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Secretary of Veterans Affairs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Jesse R. Clark Commonwealth of Pennsylvania: County of No. 02-373-Civil Term No Term, 20---- E.D. Term, 20-_ _ -A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount Due Interest from 03/20/02 to Sale Date @ $24.37 per diem Attorney's fees Costs Total as endorsed. Dated (SEAL) $143,474.83 By: Prothonotary, Common Pleas Court of Cumberland County, Penna. Deputy 0 N H M n M N 0 z Q wl 0 N z Q 06 z a cn U) O ?z ? °z y O c) H 04 0 ¢ O 0 U a a: to ti z o E•-? m U O Ww O ? 0 U o b a ti U ° c o N .. w an ? ? QI m W ?] ? co? J) A QJ fir .'y o bQ ? ?. rn 0 N m Q ¢ O a 110 O a W M 3 Cd N rA o °4 b cq3 a a DESCRIPTION TRACT NO. 1 ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a stake in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Churchtown Road); thence South eighty-nine degrees fourteen minutes thirty seconds West (S. 890 14' 30" W) along same a distance of one hundred (100.00') feet to a stake; thence North five degrees fifty- two minutes thirty seconds West (N 050 52' 30" W) along the Eastern line of lands, now or formerly, of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.52') feet to a stake in the center of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty seconds East (N. 81° 17' 30" E) along same a distance of ninety-nine and seventy-two hundredths (99.72') feet to a stake; thence South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" E) along the western line of lands, now or formerly, of Lee W. Renshaw and Verle K. Renshaw, husband and wife, a distance of two hundred forty and forty-seven hundredths (240.47') feet to a stake in the center of Pennsylvania Traffic Route No. 174, the place of beginning. CONTAINING approximately .534 acres. TYE above description is according to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO. 2 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle prepared by Stephen G. Fisher, dated October 17, 1984, a copy of which was recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on January 30, 1985, in Plan Book 37, page 31, as follows: BEGINNING at a P.K. nail set in the original centerline of thirty-three (33') feet wide Township Road T-551, known as Lutztown Road, at the dividing line between Lots Nos. I and 2; thence from said P.K. nail at the Place of Beginning along said original centerline of thirty-three (33') feet wide Lutztown Road, North eighty-one degrees seventeen minutes thirty seconds East (N 81° 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16') feet to a P.K. nail at the Northwestern corner of said lot described in Deed Book 21 "Z", page 124; thence along the Western line of said lot described in Deed Book 21 "Z", page 124, South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" E), a distance of two hundred twenty-six and sixty-two hundredths (226.62') feet to a P.K. nail set in the original centerline of L.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsylvania Route No. 174, South eighty-nine degrees fourteen minutes thirty seconds West (S 890 14' 30" W), a distance of twenty-five (25') feet to a P.K. nail set at the dividing line between said Lots Nos. 1 and 2; thence along said dividing line between said Lots Nos. 1 and 2, North five degrees fifty-six minutes six seconds West (N 050 56' 06" W), a distance of two hundred twenty-three and fifteen hundredths (223.15') feet to a P.K. nail set in the original centerline of said Lutztown Road at the place of beginning. THE ABOVE described tract of land contains a net area of approximately 4246.63 square feet exclusive of the rights-of-way of Lutztown Road and of Pennsylvania Route No. 174, and is all of Lot No. 2 as shown on said Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle recorded as aforesaid and which lot of ground is conveyed as an addition to the lot of ground adjoining on the East described in Deed Book 21 "Z", page 124 and shall hereafter be considered a part of the same and said parts shall be a single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate government authorities shall determined otherwise. SO MUCH of the above described tract of land as lies within twenty-five (25') feet of the original centerline of Lutztown Road and within thirty (30) feet of the original centerline of Pennsylvania Route No. 174 has been dedicated as portions of the rights-of-way of said roads as shown on said Final Minor Subdivision Plan recorded as aforesaid. Parcel x22-29-2478-002 (7 CD 0 C rJ =n -TI .jJ 7r am. J f? 4 t) q #9429-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff VS. Jesse R. Clark No: 02-373 Civil Term 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129. 1, in the above matter was made on the defendants via certified mail, return receipt requested and by regular first class mail (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of owners(s) or reputed owner(s) Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 2. Name and address of defendant(s) in the judgment: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Family Court/Domestic Relations Office ? One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare ? 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. Section 4904 relating to unsworn falsification to authorities. Marffa- E. Von Rosenstiel Attorney for Plaintiff M" Postage nl r Certified Fee 0 -0 Return Receipt Fee C3 PKIMement Require it O tR C3 Restricted Delivery Fee O Total Post"* a Fees s Ir nt o r9 stiae4 ApL jly-j wPOBar/YO, BOII C3 C3 Dw U.S. POSTAL SERVICE CERTIFICATE F MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received FrafIARTHA E. VON ROSENSTIEL, P.C. ?Y? 16 S. LANSDOWNE AVE. R 0. BOX 457 t AMCI1f WNE nn ? n ^ 'r a , rT'c - C O One place of ordinary mail addressed to: z? 4% 11 1506 Boiling Springs Road U boiling Springs, qN mot" P*Btage and c4o I Affix fee here in stamps Pgpt qWk. Inquire of i PaMtteralor current N i ilV cS C ell m l C W r Do a - 00 ?O N ?1 O 0? V1 0 W , ONW ¦ Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to Jesse R Clark 1506 Boiling Springs Road Boiling'Springs, Pa. 17007 A Sign ? Agent ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address diMerent from Item 1? ? Yes If YES, enter delivery address below: ? No I 3. rvice Type Certified Mail ? Express Mail Iff Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (transfer from service label) PS Form 3811, August 2001 t Domestic Return Receipt 'pr ,l wzs95-01-M•zspa l For Accountable Mail Q - No CL d --` O to OD V 0) CT A W N m ED D 7 0 a j d a' z CL CL n y3 m ?j fD ? N CL O ` D ?m C m 2) a) 1° °?r- -o w p? o-n wow > mym M f n m3 0 '4 H Cow x N DOcO o0 CD 7 D o ° 8 c 3 f c0 d a D m d f° ?M V4 m?°c 3 m o? < V W O Opw Z u°, c 0M c ?cn ?D O ?m °< m L" m oc a um, O ° m m i N z m CD G w a m m o m m r 3 W m m m ' w ? (A ._' . G 3 0 M 3 j > v 00009 MOE o ° o m m m c CD '3 (D ai- (D - I m as m? CL n m (A ? ? m CL o ?c o ? 3 41 1 O CL mo89m ' ' 0 2 mma o i _ m c . _ c m O CO H o. 5 CL - m - m38 m a d obi am g 3 0' y 3??;060 a o _m 2,2' Cg 3 C m m v Zwm 3'0'Cc d c R?oa v =M. d 3 N N m `G < , c N 0 O w 'D m O o m v m m O CT S 7 O m N O ' G C ?. N N d 3`m_coN3Rm6 m a o (0 t ? 3ID z- O - o a a. W N'O N O O o n? ° W'0 *' d o> > 0 3 d _ d C 4) N C m oac O m m OD S00 o,Qo2 = = hpmQmoS,;o AIW a?D d m M m j j 0 m -m ?'W3?B CS H w^ o o 3 37o r y 0 (D Q O N c d' 0 ??11 7"7 N d N'd" D i . < O w 3??3od T (A Bx C ?? a w 'c o W d c% 4 N N _ C I G m'?ga 0= z '0N-i !n mz°,y = z 3 O O V10W k ° ? H p ONW - a f m a T m m O j O 02' m ? ? ? -?? i ?' ? y - .__ rr-s? C' , 1 ,._. 4Yr L r. (Ci '? ;: ?-t ? 1 ?,? e f? 4 #9429-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff vs. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129. 1, in the above matter was made on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Monroe Township Municipal Authority ? 1220 Boiling Springs Road Mechanicsburg, PA 17055-9794 I verify that the statements made in this affidavit personal knowledge or information and belief. I unders subject to the penalties of 18 Pa. C.S. Section 4904 reYat E. Von Rosenstiel rtrue and correct to the best of my that false statements herein are made to unsworn falsification to authorities. Attorney for Plaintiff r? For Accountable Mafl 9 N O r ? CL ! O (0 c Z Co V O) V7 ? W m M 0 CO c N m a, ?'0 2 A N O N ' C O _ J 0 CL 1 0) O m 0 2 0m 0 . m Cr o Co f (D -o Cl) 0 0 D ' N N 0 5-0 On _ y V;? 2H (D 00- Cn 2) S2. CLo ay 0 3 m y c o 0 0 Ca 0 o d y 0 0 3 aa ?yo 3c?335 m 3>> O 3 C 03 C N 3 3CL(=p -mD?i3mo ZIC 3 fc N ow- 7 p C j a.myvi3fo'?c O O N CL wCA46S ? r = 0 p 3 01 0L 0O W053 3OOM w O.N. d tom°(o £3a uu?,??po 0 3 n m?.000. uc-0v?0? p CD 3. N 0 > 0. Oz N a '(D 00 0 O o m = 9'c`D3oo_d a(D0(D 3d9.rs3n0a m 0 0 0 a g 3 d O-0 3m ? 'm- c 0o °q q" a Co 0 M 3 a a m 01 m^_$ m F20 y' CL o N -I CL o 4s 0 0 R m y D ? o CL IU (D ?w a W ? w IWV dM CA D CL W CD ?q'4D maim O of > o ? ?fz ° < O m z 1 m r n f0 o m UN ??M M?7 n (D ON 0m . m O C D> ? (D 7 " N (0 m O. a N N N 13 to 'O 13 (D a (D 0 Z ?( O c ? " : =r 2) O (p 7 N O '? ' N d (a (D N 9 C a 3 0 Dy CL 13 [1 ;D e 0 ?ss? C ... ti N 'D ? CL o ? < 0 D j O C go _ D; c C !n 0 p? Cr ?o 00 j 0 mm O p 7c r•0DW *. O T? D 5 ?(gn a. 9l ? Ty O 9 SDI ?'Q 3 $o m (? m I r ?T T N B2 O 0 N ?n-C "` C ° t n W r$.CDM.. H N N m Ip? O O ON -I O D` Vi0W O N W C? i C,1 C7 j C L7 ',- N a U p U COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Secretary of Veteran Affairs is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2002, under and by virtue of a writ Execution issued on the 22nd day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 373, at the suit of Secretary of Veteran Affairsit against Jesse R Clark is duly recorded in Sheriff's Deed Book No. 255, Page 4353. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this •Z J? day of A.D.2003 of Deeds b??? Secretary of Veterans Affairs VS Jesse R. Clark In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-373 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2002 at 2:37 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jesse R. Clark, by making known unto Sandy Nelson, adult in charge, at 80 Potato Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2002 at 1:20 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jesse R. Clark located at 1506 Boiling Springs Rd., Boiling Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Jesse R. Clark, by regular mail to his last known address of 80 Potato Road, Apt. #7, Carlisle, PA 17013. This letter was mailed under the date of July 17, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Martha E. Von Rosenstiel for Secretary of Veteran Affairs. It being the highest bid and best price received for the same, Secretary of Veteran Affairs of 5000 Wissahickon Street, Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $1,576.47, it being costs. Sheriffs Costs: Docketing 30.00 Poundage 30.91 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 20.00 Law Library .50 Prothonotary 1.00 Mileage 19.32 Certified Mail 2.29 do` 30 1 00 ax)'- '.50 U 34S77 Levy 30.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 711.80 Patriot News 500.95 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1576.47 Sworn and Subscribed to Before Me So Answers: This ZJ '- Day of R. Thomas Kline, Sheriff 2003, A.D. qV5 ro honotary BY?O?aYlwca`i Real Estate Deputy SHERIFF'S RETURN - REGULAR CASE NO: 2002-00373 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SECRETARY OF VETERANS AFFAIRS VS CLARK JESSE R BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLARK JESSE R DEFENDANT the , at 0927:00 HOURS, on the 28th day of January , 2002 at 1506 BOILING SPRINGS ROAD BOILING SPRINGS, PA 17007 JESSE R. CLARK by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 nn Sworn and Subscribed to before me this AK day of ru-r dv)d? A.D. Pr h notary So Answers: ??++ R. Thomas Kline 01/29/20 MARTHA V By: a Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff vs. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 02-373 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 1506 Boiling Springs Road, Boiling Springs, PA 17007. 1. Name and address of owners(s) or reputed owner(s) Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 2. Name and address of defendant(s) in the judgment: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia PA 19101 Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 02-373 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 1506 Boiling Springs Road, Boiling Springs, PA 17007. 1. Name and address of owners(s) or reputed owner(s) Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 2. Name and address of defendant(s) in the judgment: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare 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. Section 4904 relating to unworn falsification to authorities. MarVia E. Von Rosenstiel Attorney for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 March 20, 2002 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount of Judgment: $143,474.83 Date of Judgment: March 20, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 02-373 Civil Term Plaintiff: Secretary of Veterans Affairs Defendants: Jesse R. Clark Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 1506 Boiling Springs Road Boiling Springs, PA 17007 will be sold by the Sheriff of Cumberland County on September 4, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Jesse R. Clark. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 March 20, 2002 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount of Judgment: $143,474.83 Date of Judgment: March 20, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 02-373 Civil Term Plaintiff: Secretary of Veterans Affairs Defendants: Jesse R. Clark Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 1506 Boiling Springs Road Boiling Springs, PA 17007 will be sold by the Sheriff of Cumberland County on September 4, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Jesse R. Clark. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue Attorney for Plaintiff P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Secretary of Veterans Affairs Wissahickon Avenue and Manheim Street Philadelphia, PA 19101 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff VS. Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Defendant No: 02-373 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jesse R. Clark 1506 Boiling Springs Road Boiling Springs, PA 17007 Your house and/or real estate at 1506 Boiling Springs Road, Boiling Springs, PA 17007 is scheduled to be sold at Sheriff's Sale on September 4, 2002 at 10:00 a.m. to enforce the court judgment of $143,474.83 obtained by Secretary of Veterans Affairs against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Secretary of Veterans Affairs the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 610 623-2660. 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 a 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 the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Secretary of Veterans Affairs vs. Jesse R. Clark Commonwealth of Pennsylvania: County of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, 02-373-Civil Term No. Term, 20---- E.D. Term, 20- - _ -A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 1506 Boiling Springs Road Boiling Springs, PA 17007 Amount Due interest from 03/20/02 to Sale Date @ $24.37 per diem Attorney's fees Costs Total as endorsed. Dated (SEAL) $143,474.83 C g? By: Prothonotary, Common Pleas Court of Cumberland County, Penna. Deputy I 0d z 0 N 0 N ? ¢ > a ? z O W H O z U O u u it) ?A ? 4-4 G N O d O ? C; z w? ,? U rn I U W W ti a? O ? o U X O O H rl '-+ O 3 ?- 0 U w °o rts ^fJ p. N w , U v a C4e) b4 C> U2 a. O > N O N M Cry ? o '" b DESCRIPTION TRACT NO. 1 ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a stake in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Churchtown Road); thence South eighty-nine degrees fourteen minutes thirty seconds West (S. 890 14' 30" W) along same a distance of one hundred (100.00') feet to a stake; thence North five degrees fifty- two minutes thirty seconds West (N 050 52' 30" W) along the Eastern line of lands, now or formerly, of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.52') feet to a stake in the center of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty seconds East (N. 81° 17' 30" E) along same a distance of ninety-nine and seventy-two hundredths (99.72') feet to a stake; thence South five degrees fifty-two minutes thirty seconds East (S 050 52' 30" E) along the western line of lands, now or formerly, of Lee W. Renshaw and Verle K. Renshaw, husband and wife, a distance of two hundred forty and forty-seven hundredths (240.47') feet to a stake in the center of Pennsylvania Traffic Route No. 174, the place of beginning. CONTAINING approximately .534 acres. TFE above description is according to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO. 2 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle prepared by Stephen G. Fisher, dated October 17, 1984, a copy of which was recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on January 30, 1985, in Plan Book 37, page 31, as follows: BEGINNING at a P.K. nail set in the original centerline of thirty-three (33') feet wide Township Road T-551, known as Lutztown Road, at the dividing line between Lots Nos. 1 and 2; thence from said P.K. nail at the Place of Beginning along said original centerline of thirty-three (33') feet wide Lutztown Road, North eighty-one degrees seventeen minutes thirty seconds East (N 81° 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16') feet to a P.K. nail at the Northwestern corner of said lot described in Deed Book 21 "Z", page 124; thence along the Western line of said lot described in Deed Book 21 "Z", page 124, South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" E), a distance of two hundred twenty-six and sixty-two hundredths (226.62') feet to a P.K. nail set in the original centerline of L.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsylvania Route No. 174, South eighty-nine degrees fourteen minutes thirty seconds West (S 89° 14' 30" W), a distance of twenty-five (25') feet to a P.K. nail set at the dividing line between said Lots Nos. 1 and 2; thence along said dividing line between said Lots Nos. 1 and 2, North five degrees fifty-six minutes six seconds West (N 050 56' 06" W), a distance of two hundred twenty-three and fifteen hundredths (223.15') feet to a P.K. nail set in the original centerline of said Lutztown Road at the place of beginning. THE ABOVE described tract of land contains a net area of approximately 4246.63 square feet exclusive of the rights-of-way of Lutztown Road and of Pennsylvania Route No. 174, and is all of Lot No. 2 as shown on said Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle recorded as aforesaid and which lot of ground is conveyed as an addition to the lot of ground adjoining on the East described in Deed Book 21 "Z", page 124 and shall hereafter be considered a part of the same and said parts shall be a single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate government authorities shall determined otherwise. SO MUCH of the above described tract of land as lies within twenty-five (25') feet of the original centerline of Lutztown Road and within thirty (30) feet of the original centerline of Pennsylvania Route No. 174 has been dedicated as portions of the rights-of-way of said roads as shown on said Final Minor Subdivision Plan recorded as aforesaid. Parcel #22-29-2478-002 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-373 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SECRETARY OF VETERANS AFFAIRS, Plaintiff (s) From JESSE R. CLARK, 1506 BOILING SPRINGS ROAD, BOILING SPRINGS, PA 17007 (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 $143,474.83 L.L. $.50 Interest FROM 3/21/02 TO SALE DATE AT $24.37 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $104.14 Other Costs Plaintiff Paid Date: MARCH 22, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ID No. 52634 Real Estate Sale # 26 On May 13, 2002 the sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA known and numbered as 1506 Boiling Springs Road, Boiling Springs, more fully described on Exhibit "A" tiled with this writ and by this reference incorporated herein. Date: May 13, 2002 By: ?i6? Real Estate Deputy o? r? PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. R er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST, 2002 LOIS E. SNYDER. Notary Pd* Caili b Boro, Ctanberlsnd IN CmaMm Eras ki" 5, RZAL NOTATE SALE NO. 26 Writ No. 2002-373 Civil Secretary of Veterans Affairs VS. Jesse R. Clark Atty.: Martha E. Von Rosenstiel DESCRIPTION TRACT NO. 1 ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a stake in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Church- town Road); thence South eighty- nine degrees fourteen minutes thirty seconds West (S. 89° 14' 30" W) along same a distance of one hun- dred (100.00') feet to a stake; thence North five degrees fifty-two minutes thirty seconds West (N 05° 52' 30" W) along the Eastern line of lands, now or formerly of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.521 feet to a stake in the cen- ter of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty seconds East (N. 81° 17' 30" E) along same a distance of ninety-nine and seventy-two hundredths (99.729 feet to a stake; thence South five degrees fifty-two minutes thirty sec- onds East (S 05° 52' 30" E) along the western line of lands, now or formerly of Lee W. Renshaw and Verle K. Renshaw, husband and wife, a distance of two hundred forty and forty-seven hundredths (240- AT) feet to a stake in the center of Pennsylvania Traffic Route No. 174, the place of beginning. CONTAINING approximately.534 acres. THE above description is accord- ing to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO. 2 ALL THAT CERTAIN tract of land situate in Monroe. Township. Cum- berland County, Pennsylvania, bounded and described in accor- dance with Final Minor Subdivision Plan for Robert C. and Kathryn M. Trostle prepared by Stephen G. Fisher, dated October 17, 1984, a copy of which was recorded in the Office of the Recorder of Deeds in and for Cumberland County, Penn- sylvania, on January 30, 1985, in Plan Book 37, page 31, as follows: BEGINNING at a P.K. nail set in the original centerline of thirty-three (33') feet wide Township Road T-551, known as Lutztown Road, at the dividing line between Lots Nos. 1 and 2; thence from said P.K. nail at the Place of Beginning along said original centerline of thirty-three (33') feet wide Lutztown Road, North eighty-one degrees seventeen min- utes thirty seconds East (N 811 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16') feet to a P.K. nail at the Northwestern cor- ner of said lot described in Deed Book 21 "Z", page 124; thence along the Western line of said lot described in Deed Book 21 "Z". page 124, South five degrees fifty-two minutes thirty seconds East (S 05° 52' 30" I,), a distance of two hundred twen- ty-six and sixty-two hundredths (226.62') feet to a P.K. nail set in the original centerline of L.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsvlvania Route No. 174, South eighty-nine degrees fourteen minutes thirty see onds West (S 89° 14' 30" W1, a dis- tance of twenty-five (25') feet lu a P.K. nail set at the dividing line oe- tween said Lots Nos, 1 and 2: thence along said dividing line be- tween said Lots Nos. ' and 2. North five degrees fifty-six minutes six seconds West (N 05° 56' 06" W). a distance of two hundred twenty-three and fifteen hundredths (223.1.5') feet to a P.K. nail set in the original centerline of said Lutztown Road at the place of beginning. THE ABOVE described tract of land contains a net area of approxi- mately 4246.63 square feet exclu sive of the rights-of-way of Lutztotivn Road and of Pennsylvania Route No. 174, and is all of Lot No. 2 as shown an said Final Minor Subdivision Plan for Robert C. and Kathrvn M. Trostle recorded as aforesaid and which lot of ground is conveyed as .in addi tion to the lot of ground adjoining on the East described in Deed Book 21 "Z". page 124 and shall hereafter be considered a part cf the same and said parts shall be at single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate gov ernment authorities shall deter mined otherwise SO MUCH of the .ii>ove ut scribed tract of land as ties within twenty-five (25) feet of the original centerline of Lutztown Road and within third,- ;30) feet of the original centerline of Pennsvlvania Route No. 174 has been dedicated as portions of the rights-of-way of said roads as shown on said Final Minor Sub- division Plan recorded as aforesaid. Parcel #22-29-2478-002. 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published 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 July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#26 A a ........... ......... .............................................................. Sworn to and subscribed before me this 14th day of u9u,002 A.D. ( Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County MY Commission Expires June 6, 2006 Member, Pennsylvania Association Notar NO ARY PUBLIC commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 499.20 Probating same Notary Fee(s) $ 1.75 Total $ 500.95 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .............................................................. REAL ESTATE SALE No. 26 W PH NW 200473 ClVN T &M Secretary of WWWrans Affairs va Jests R. Clark Von, IEsI DESCRIPTION K TRACT NO. I: ALL THAT CERTAIN tract of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and desc;ribcd as follows: BEGINNING at a stakes' in the center of Pennsylvania Traffic Route 174 (the Boiling Springs to Churchtown Road); thence South eighty-nice degrees fourteen minutes thirty seconds West (S. 89 14' 30'' W) along same a distance of one hundred (100.00') feet to a stake; thence North five degrees fifty-two minutes thirty seconds West (N 05 52' 3W W) along the Eastern line of lands, now or formerly, of Lee W. Renshaw and Verla K. Renshaw, husband and wife, a distance of two hundred twenty-six and fifty-two hundredths (226.52) feet to a stake in the center of Pennsylvania Township Road No. 551; thence North eighty-one degrees seventeen minutes thirty, seconds East (N ISLIT 30" E) along same a distance of ninety-nine and seventy- two hundredths (99.72) feet to a stake; thence South five degrees fifty-two minutes thirty seconds East (S 05 52'30" E) along the western line of lands, now or formerly, of Lee W. Renshaw and Vede K. Renshaw, husband and wife, a distance of two hundred forty and forty- seven hundredths (240.47) fact to a stake in the center of Pennsylvania Traffic Route No. 174, the place of BEGINNING. CONTAINING approximately .534 acres. THE ABOVE description is according to a survey by Thomas A. Neff, Registered Surveyor, dated March 5, 1966. TRACT NO.2: ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Minor Subdivision Plan for Robert C. and ryn M. Trostle prepared by Stephen G, FWr.4 Bawd October 17, 1984, It c" of Wj*? rm aa4arla I * Ak 131iet of fiat bo"dait of a" is ad for ftetbww ow J*M*%WA 10 momy 3% Ila; in "OUST, $w 31, 011490: $ WR4ING at a P.K. nail set in the 01*tW ctatefliue of thirty- three (33) feet wide Townrd4 Faml T-551, known as Lutrbowr Road. at the wwrdmg iuic oetween Lots Nos. i and t, tpe„?x from said P.K, nail at the Place of Beginning along said original centerline of thirty-three 03'; feet wide Lutztown -Road, North eighty-one degrees seventeen minutes thirty seconds East (N 81 17' 30" E), a distance of twenty-five and sixteen hundredths (25.16) feet to a P.K. nail at the Northwestern comer of said lot described in Deed Book 21 7', l1age 124; thence along the Western line of said lot described in Deed Book 21 "T' page 124, South five degrees fifty-two minutes thirty seconds East N 05 52' 30" E), a distance of two hundred twenty-six and sixty-two hundredths (226.62) feet to'a'P.K. nail set in the original centerline of L`.R. 507, known as Pennsylvania Route No. 174; thence along said original centerline of said Pennsylvania Route No, 174, South eighty-nine degrees fourteen minutes thirty seconds West (S 89 14' 30" W), a distance of twenty-five (25) feet to a P.K. nail set at the dividing line between said Lots No. 1 and 2: thence along said dividing line between said Lott Nos. I and 2, North five degrees fifty-six minutes six seconds West (N 05 56' 06" W), a distance of two hundred twenty-three and fifteen hundredths (223.15) feet to a P.K. nail set in the origrnai centerline of said Lutztown Road at the place of BEGINNING. THE ABOVE described tract of land contains net area of approximately 4246.63 square feet exclusive of the rights-of-way of Lutztown Road and of Pennsylvania Route No. 174, and is all m Lot No.2 as shown on said Final Minor Subdivision Plan for Robert C. and Kathryn M. Troste recorded as aforesaid and which lot of ground is conveyed as an addition to the lot of ground adjoining on the East described in Deed Book 21 "Z", page 124 and shall hereafter be considered a part of the same and said pans shall be a single lot for purposes of Monroe Township zoning and subdivision regulations until such times as appropriate government authorities shall determine otherwise. SO MUCH of the above described tract of land as lies within twenty-five 25) feet to the original centerline of Lutztown Road and within thirty (30) feet of the original centerline of Pennsylvania Route No. 174 has been dedicated as portions of the fights-of-way of %W roads as abown on said Final Minor Subdivision Plan recorded as aforesaid. Parcel #22-29-24784102.