HomeMy WebLinkAbout11-9391SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILEU-UF FiCE
Sheriff t°' T14E PROTHONOTARY
Jody S Smith
2012 JAN -6 AM 6: 4 9
Chief Deputy
Richard W Stewart CUMBERLAND COUNTY
Solicitor -PENNSYLVANIA
Orrstown Bank
Case Number
vs.
Timothy A. Moul (et al.) 2011-9391
SHERIFF'S RETURN OF SERVICE
12/28/2011 02:44 PM - William Cline, Corporal, who being duly sworn according to law, states that on December 28,
2011 at 1444 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Timothy A. Moul, by making known unto Eloise Moul, Wife of Defendant at
639 Glendale Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to her personally the said true and correct copy of the same.
/,7 s
I LIAM CLINE, DEPUTY
12/28/2011 02:44 PM - William Cline, Corporal, who being duly sworn according to law, states that on December 28,
2011 at 1444 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Eloise R. Moul, by making known unto herself personally, at 639 Glendale
Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
her personally the said true and correct copy of the same.
I LAM CLINE, DEPUTY
SHERIFF COST: $50.00
January 03, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
C t;ouui suty S". I T .osofl. L'.c.
ORRSTOWN BANK,
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS OF -r
CUMBERLAND COUNTY, PENNSYLVANIA -
CIVIL DIVISION
No.: 11-9391 CIVIL TERM -r-
ISSUE NUMBER:
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
I Hereby certify that the last known address
of Defendant(s) is/are:
639 Glendale ree
Carlisle, PA 13
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF:
Orrstown Bank, Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
A. Dietterick, Esquire Attorney for Plaintiff
JAMES, SMITH, DIETTERICK & CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
416.5o PO A` r'?
&# tig71
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CIVIL DIVISION
NO.: 11-9391 Civil Term
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Timothy A. Moul and Eloise R. Moul, in the amount of $161,688.36 which
is itemized as follows:
Principal $ 153,165.51
Interest through 3/29/2012 $ 5,854.86
Late Charges $ 957.99
Attorney's Fees $ 1,300.00
Title Costs $ 410.00
TOTAL $ 161,688.36
plus interest on the principal sum ($153,165.51) from March 30, 2012, at the rate of $21.27 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
,ged,premises.
attorneys' fees and costs and for foreclosure and sale of the mortga
JAMES
By: A Ell,,
Scott A. D' tt
Attorney for I" intiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
& CONNELLY LLP
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants are not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judament were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
Sworn to and subscribed before me
this 30th day of March, 2012.
riq 1? C . :s
Notary Public
My Commission Expires:
NOTARIAL SEAL
CHRISTINE L SPURLOCK
Notary Public
HUMMELSTOWN BORO, DAUPHIN COUNTY
My Commission Expires Jun 23, 2012
re
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Timothy A. Moul
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on 4
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $161,688.36
plus interest on the principal sum ($153,165.51) from March 30, 2012, at the rate of $21.27 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sal of the mortgaged premises.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Eloise R. Moul
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $161,688.36
plus interest on the principal sum ($153,165.51) from March 30, 2012, at the rate of $21.27 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale the mortgaged premises.
Rvfhwo4ari
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CIVIL DIVISION
NO.: 11-9391 Civil Term
IMPORTANT NOTICE
TO: Timothy A. Moul
639 Glendale Street
Carlisle, PA 17013
DATE OF NOTICE: March 16, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOT ICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE; YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
A. Timothy A. Moul
FECHA DEL AVISO:
CIVIL DIVISION
NO.: 11-9391 Civil Term
AVISO IMPORTANTE
March 16, 2012
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR TUNO, VAYA O LL. T\4E LA OFICi1NA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
JAMES SMITH IETTE CK & CONNELLY LLP
DATE: March 16, 2012 BY:
Scott A. Dietterick, Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280
cc: Gregory S. Hazlett, Esquire
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
TO: Eloise R. Moul
639 Glendale Street
Carlisle, PA 17013
CIVIL DIVISION
NO.: 11-9391 Civil Term
IMPORTANT NOTICE
DATE OF NOTICE: March 16, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TUTS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CIVIL DIVISION
NO.: 11-9391 Civil Term
AVISO IMPORTANTE
A. Eloise R. Moul
FECHA DEL AVISO:
March 16, 2012
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR TINO, VAYA O LLA?vIE LA OFICP\TA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
JAMESSMIT DIE TERI & CONNELLY LP
DATE: March 16, 2012 BY:
Sc A. iettenck, Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280
cc: Gregory S. Hazlett, Esquire
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Orrstown Bank
vs.
Timothy A. Moul (et al.)
??y?trttt, tli i?suu#t?r?rf?0
Case Number
2011-9391
SHERIFF'S RETURN! OF SERVICE
12128/2011 02:44 PM - William Cline, Corporal, who being duly sworn according to law, states that on December 28,
2011 at 1444 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Timothy A. Moul, by making known unto Eloise Moul, Wife of Defendant al
639 Glendale Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to her personally the said true and correct copy of the same.
LIAM CLINE, DEPUTY
12/28/2011 02:44 PM - William Cline, Corporal, who being duly sworn according to law, states that on December 28,
2011 at 1444 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Eloise R. Moul, by making known unto herself personally, at 639 Glendale
Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
her personally the said true and correct copy of the same.
I L AM CLINE, DEPUTY
SHERIFF COST: $50.00
January 03, 2012
SO ANSWERS,
RONl`V R ANDERSON, SHERIFF
N ?
IN THE COURT OF CCM" PLEAS OF CCPMERL MD aX NI'Y, PEAII nVANIA
Orrstown Bank CIVIL DIVISION
File No. 11-9391 Civil Term
(Plaintiff) : Amount Due $ 161,688.36
V
• Interest from 3/30/2012 to ; 3,381.93
date of sale
Timothy A. Moul and Eloise R. : At ty' s Com,n
Moul
(Defendant(s) Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR 00=0N
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property crfi e.
defendant(s)
See Exhibit "A" attached. ? r r\)
PRAECIPE FOR ATTAMMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s)as
real estate of the defendant(s) described in the attached e
DATE: March 30, 2012
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Signature:
Print Name:
against
Address: James Smith Dietterick & Connelly LLP
P O Box 650, Hershey PA 17033
Attorney for: Plaintiff
Telephone: (717) 533-3280
Aa.a.5 &)P-
-50 LL
Supreme Court ID No.: 55650
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff,
VS. :
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
NO.: 11-9391 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe
for Writ of Execution was filed the following information concerning the real property
located at 639 Glendale Street, Carlisle, Pennsylvania 17013:
1. Name and Address of Owner(s) or Reputed Owner(s):
TIMOTHY A. MOUL 639 Glendale Street
Carlisle, PA 17013
ELOISE R. MOUL
639 Glendale Street
Carlisle, PA 17013
2. Name and Address of Defendant(s) in the Judgment:
TIMOTHY A. MOUL 639 Glendale Street
Carlisle, PA 17013
ELOISE R. MOUL
639 Glendale Street
Carlisle, PA 17013
.Z. M
3. Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
ORRSTOWN BANK Plaintiff
4
5
6.
Name and Address of the last record holder of every mortgage of record:
ORRSTOWN BANK
M&T MORTGAGE CORPORATION
Plaintiff
2270 Erin Court
Lancaster, PA 17604
and
P.O. Box 7628
Lancaster, PA 17604
MANUFACTURERS & TRADERS
TRUST CO.
One M&T Plaza
Buffalo, NY 14240
COMMERCE BANK/HARRISBURG N.A. 100 Senate Avenue
Camp Hill, PA 17011
Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX
CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
DEPARTMENT OF REVENUE
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
COMMONWEALTH OF PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best
of my personal knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
JAMES
& COT
DATED:. < 3 ?- BY:
Scott A
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CIVIL DIVISION
NO.: 11 -93 91 Civil Term
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Timothy A. Moul
639 Glendale Street,
Carlisle, PA 17013'-
771
TAKE NOTICE:'
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 11-9391 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Timothy A. Moul and Eloise R. Moul
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH, DIETV-RICKI' A CONNELLY LLP
DATED: BY:
Scott AV Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street
in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded
and described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the
line dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded
in Plan Book 14, Page 28; thence Southwardly along the East side of Glendale Street
South 04 degrees 55 minutes 50 seconds East 100 feet to a point which point is in the line
dividing Lots 60 and 61 as shown on the Plan of Section C of Heatherlands; thence North
85 degrees 04 minutes 10 seconds East 150 feet to a point; thence North 04 degrees 55
minutes 50 seconds West 100 feet; thence South 85 degrees 04 minutes 10 seconds West
150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639
Glendale Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,
by Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland
County, in Deed Book Volume 28-L, Page 390, granted and conveyed unto Timothy A.
Moul and Eloise R. Moul, His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CIVIL DIVISION
NO.: 11-9391 Civil Term
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Eloise R
Moul
=Fri
d ,
.
639 Glendale Street 1
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriff s Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 11 -93 91 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Timothy A. Moul and Eloise R. Moul
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, S
DATED: S- -o- I X BY:
& CONNELLY LLP
ck, Esquire
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
Pa. I.D. #55650
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street
in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded
and described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the
line dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded
in Plan Book 14, Page 28; thence Southwardly along the East side of Glendale Street
South 04 degrees 55 minutes 50 seconds East 100 feet to a point which point is in the line
dividing Lots 60 and 61 as shown on the Plan of Section C of Heatherlands; thence North
85 degrees 04 minutes 10 seconds East 150 feet to a point; thence North 04 degrees 55
minutes 50 seconds West 100 feet; thence South 85 degrees 04 minutes 10 seconds West
150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639
Glendale Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,
by Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland
County, in Deed Book Volume 28-L, Page 390, granted and conveyed unto Timothy A.
Moul and Eloise R. Moul. His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 11-9391 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ORRSTOWN BANK, Plaintiff (s)
From TIMOTHY A. MOUL and ELOISE R MOUL
(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: $161,688.36 L. L.: $.50
Interest from 3/30/12 to date of sale -- $3,381.93
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $189.50 Other Costs:
Plaintiff Paid:
Date: 4/2/12 bl
?
a"
David D. Buell, Prothonot
(Seal)
Deputy
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY, LLP
PO BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Ted ~._,,
_~ E:..~
~; ~~~ ~ -
_«. r`3
TIMOTHY A. MOUL and =~_=~~ °'=
ELOISE R. MOUL n ~~ "'
7 ,,lam
r°
. ~ ~~
Defendants. -~' ~~ = -
."
MOTION TO CONTINUE SHERIFF'S SALE WITH DEFENDANT'S CONS,~N~
AND NOW, comes the Movant Orrstown Bank, by and through its attorneys, James,
Smith, Dietterick & Connelly, LLP, and files this Motion to Continue Sheriff s Sale as follows:
Plaintiff obtained a default judgment in mortgage foreclosure against the
Defendants Timothy A. Moul and Eloise R. Moul ("Defendants") at the above-captioned term
and number ("Judgment").
2. Pursuant to said Judgment, the Plaintiff caused the Defendants' property subject
to the Judgment, which property is more specifically described in the Mortgage attached to
4_
`r-
~e:
°`j
r..~ "
Plaintiff s Complaint ("Premises"), to be scheduled for sale by the Sheriff on September 5, 2012.
3. Movant thereafter continued the Sheriff's Sale from September 5, 2012 to
December 5, 2012.
4. Plaintiff wishes to continue the sale again to March 6, 2013, due to the fact
Plaintiff is allowing Defendants additional time to sell the Premises and pay-off Plaintiff,
however, since the continuance would be more than 130 days from the original sale date,
Plaintiff needs an Order of Court allowing it to do so.
5. Pursuant to Pa.R.C.P. 3129.3(a), new notice is required to be given as required by
Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued, postponed or adjourned,
"except as provided in subdivision (b) or by special Order of the Court."
6. No parties-in-interest will be prejudiced by this continuance, as the Sheriff will
announce the continued sheriff sale date pending Court Order at the December 5, 2012 Sheriff's
Sale.
7. Consequently, Plaintiff requests the sheriff sale scheduled for December 5, 2012
be continued pursuant to Pa.R.C.P. 3129.3(a) to March 6, 2013, and the requirement that
advertisement be made and new notice be provided to Defendants, lienholders and other parties
of interest be waived.
8. Counsel for Defendants concurs with this Motion to Continue Sale.
WHEREFORE, Plaintiff requests this Honorable Court to enter a special Order of Court
pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for December 5, 2012 to March 6,
2013, and dispense with the requirement that advertisement be made and a new notice be
provided to Defendants, lienholders or other parties of interest.
JAMES, SMITH, DIETTERICK
& CONNELLY LLP
Dated: November 27, 2012 By:
Scott A. Dietterick, Esquire
PAID #55650
Kimberly A. Bonner, Esquire
PAID #89705
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, :
Plaintiff, :
vs.
TIMOTHY A. MOUL and
ELOISE R. MOUL, :
Defendants. :
CIVIL DIVISION
NO.: 11-9391 Civil Term
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion to
Continue Sheriff s Sale was served on the following this 27~' day of November, 2012 via First
Class U. S. Mail, Postage Pre-paid and via email:
Sheriff of Cumberland County
ATTN: Real Estate Department
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
Greg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
Timothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, Pennsylvania 17013
JAMES S IT DIE ERICK & CONNELLY
By:
Scott A. Dietterick, Esquire
Attorney I.D.#55650
Kimberly A. Bonner, Esquire
Attorney I.D. #89705
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
vs. - L
TIMOTHY A. MOUL and _ `-;
ELOISE R. MOUL, `� '
co
CD
Defendants. >L ' `
=CD
5
MOTION TO CONTINUE SHERIFF'S SALE WITH DEFENDANT'S CONSIUNTc-�
AND NOW, comes the Movant Orrstown Bank,by and through its attorneys, James,
Smith, Dietterick& Connelly, LLP, and files this Motion to Continue Sheriff's Sale as follows:
1. Plaintiff obtained a default judgment in mortgage foreclosure against the
Defendants Timothy A. Moul and Eloise R. Moul ("Defendants") at the above-captioned term
and number("Judgment").
2. Pursuant to said Judgment, the Plaintiff caused the Defendants' property subject
to the Judgment, which property is more specifically described in the Mortgage attached to
Plaintiff's Complaint("Premises"), to be scheduled for sale by the Sheriff on September 5, 2012.
3. Movant thereafter continued the Sheriff's Sale from September 5, 2012 to
December 5, 2012.
4. Movant thereafter continued the Sheriff's Sale from December 5, 2012 to March
6, 2013 per Order of Court.
5. Movant thereafter continued the Sheriff's Sale from March 6, 2013 to April 3,
2013, per Order of Court.
6. Plaintiff wishes to continue the sale again to June 5, 2013, due to the fact Plaintiff
is allowing Defendants additional time to sell the Premises and pay-off Plaintiff,however, since
the continuance would be more than 130 days from the original sale date, Plaintiff needs an
Order of Court allowing it to do so.
7. Pursuant to Pa.R.C.P. 3129.3(a),new notice is required to be given as required by
Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued,postponed or adjourned,
"except as provided in subdivision(b) or by special Order of the Court."
8. No parties-in-interest will be prejudiced by this continuance, as the Sheriff will
announce the continued sheriff sale date pending Court Order at the April 3, 2013 Sheriff's Sale.
9. Consequently, Plaintiff requests the sheriff sale scheduled for March 6, 2013 be
continued pursuant to Pa.R.C.P. 3129.3(a)to April 3, 2013, and the requirement that
advertisement be made and new notice be provided to Defendants, lienholders and other parties
of interest be waived.
10. Counsel for Defendants concurs with this Motion to Continue Sale.
WHEREFORE, Plaintiff requests this Honorable Court to enter a special Order of Court
pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for April 3, 2013 to June 5, 2013 and
dispense with the requirement that advertisement be made and a new notice be provided to
Defendants, lienholders or other parties of interest.
JAMES, SMITH, DIETTERICK NNELLY LLP
Dated: March 27, 2013 By:
Kimberly A. Bonner, Esquire
PA ID #89705
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion to
Continue Sheriff s Sale was served on the following this 27th day of March, 2013 via First Class
U. S. Mail, Postage Pre-paid and via email:
Sheriff of Cumberland County
ATTN: Real Estate Department
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
Greg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
Timothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, Pennsylvania 17013
JAMES SMITH DIETT IC CONNELLY
By:
Scott A. Dietterick, Esquire
Attorney I.D.#55650
Kimberly A. Bonner, Esquire
Attorney I.D. #89705
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
\
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS. :
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
ORDER OF COURT
AND NOW, this day of L— , 20 the Motion to
A9VA �
Continue Sheriff Sale by Orrstown Bank, and Defendants'Aconsent thereto, it is hereby
ORDERED, ADJUDGED and DECREED that the sheriff sale scheduled for April 3, 2013 is
continued to June 5, 2013, and the requirement that advertisement be made and new notice be
provided to Defendants, lienholders or other parties in interest under Pa.R.C.P. 3129.2 is hereby
waived.
BY THE O T:
J.
Thomas AF Placey
Common Pleas Judge
/✓ rSlte
C'7 r , _
rq
M °v
N
3
r
4�i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION rZ�
nrl-,11 -1.
C=
Plaintiff, NO.: 11-9391 Civil Tq*
M
VS. r
rn
TIMOTHY A. MOUL and
ELOISE R. MOUL,
=C)
Defendants.
MOTION TO CONTINUE SHERIFF'S SALE WITH DEFENDANTS' CONSENT
AND NOW, comes the Movant Orrstown Bank,by and through its attorneys, James,
Smith,Dietterick& Connelly, LLP, and files this Motion to Continue Sheriff s Sale as follows:
I. Plaintiff obtained a default judgment in mortgage foreclosure against the
Defendants Timothy A. Moul and Eloise R. Moul ("Defendants")at the above-captioned term
and number("Judgment").
2. Pursuant to said Judgment,the Plaintiff caused the Defendants' property subject
to the Judgment,which property is more specifically described in the Mortgage attached to
Plaintiff s Complaint("Premises"),to be scheduled for sale by the Sheriff on September 5, 2012.
3. Movant thereafter continued the Sheriff s Sale from September 5,2012 to
December 5, 2012.
4. Movant thereafter continued the Sheriff's Sale from December 5, 2012 to March
6, 2013 per Order of Court.
5. Movant thereafter continued the Sheriff s Sale from March 6, 2013 to April 3,
2013,per Order of.Court.
6. Movant thereafter continued the Sheriff's Sale from April 3,2013 to June 5, 2013,
per Order of Court.
7. Plaintiff wishes to continue the sale again to September 4, 2013, due to the fact
Plaintiff is allowing Defendants additional time to sell the Premises and pay-off Plaintiff,
however, since the continuance would be more than 130 days from the original sale date,
Plaintiff needs an Order of Court allowing it to do so.
8. Pursuant to Pa.R.C.P. 3129.3(a),new notice is required to be given as required by
Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued,postponed or adjourned,
"except as provided in subdivision(b) or by special Order of the Court."
9. No parties-in-interest will be prejudiced by this continuance, as the Sheriff will
announce the continued sheriff sale date pending Court Order at the June 5,2013 Sheriff s Sale.
10. Consequently, Plaintiff requests the sheriff sale scheduled for June 5,2013 be
continued pursuant to Pa.R.C.P. 3129.3(a) to September 4,2013, and the requirement that
advertisement be made and new notice be provided to Defendants, lienholders and other parties
of interest be waived.
11. Counsel for Defendants concurs with this Motion to Continue Sale.
s ,
WHEREFORE, Plaintiff requests this Honorable Court to enter a special Order of Court
pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for June 5, 2013 to September 4, 2013
and dispense with the requirement that advertisement be made and a new notice be provided to
Defendants, lienholders or other parties of interest.
JAMES, SMITH, DIETTERICK& CONN Y LLP
Dated: May 23, 2013 By:
Kimberly A. Bonner, Esquire
PA ID #89705
Attorney for Plaintiff
P.O. BOX 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion to
Continue Sheriff's Sale was served on the following this 23rd day of May, 2013 via First Class U.
S. Mail, Postage Pre-paid and via email:
Sheriff of Cumberland County
ATTN: Real Estate Department
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
Greg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
Timothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, Pennsylvania 17013
JAMES TH IETTERICK& CONNELLY
By:
Scott A. Dietterick, Esquire
Attorney I.D.#55650
Kimberly A. Bonner, Esquire
Attorney I.D. #89705
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
lD
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
ORDER OF COURT
AND NOW, this?A day of , 2013, the Motion to
Continue Sheriff Sale by Orrstown Bank, and Defendants' consent thereto, it is hereby
ORDERED, ADJUDGED and DECREED that the sheriff sale scheduled for June 5, 2013 is
continued to September 4, 2013, and the requirement that advertisement be made and new notice
be provided to Defendants, lienholders or other parties in interest under Pa.R.C.P. 3129.2 is
hereby waived.
BY T COURT:
J.
Thomas A. Pia d
Common Pleas ] 9 e
�-I- -`
K• �7dIV/J� �t.�3 � �t„�.
� � _
5�24�/3 = �, -W.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION `;
Plaintiff, NO.: 11-9391 Civil xW
2: G5 z;
VS.
-<> rra c a
TIMOTHY A. MOUL and a 220
ELOISE R. MOUL, M7 =
Defendants. Lsa
MOTION TO CONTINUE SHERIFF'S SALE WITH DEFENDANTS' CONSENT
AND NOW, comes the Movant Orrstown Bank,by and through its attorneys, James,
Smith, Dietterick& Connelly, LLP, and files this Motion to Continue Sheriff's Sale as follows:
1. Plaintiff obtained a default judgment in mortgage foreclosure against the
Defendants Timothy A. Moul and Eloise R. Moul ("Defendants") at the above-captioned term
and number("Judgment").
2. Pursuant to said Judgment, the Plaintiff caused the Defendants' property subject
to the Judgment, which property is more specifically described in the Mortgage attached to
Plaintiff s Complaint("Premises"),to be scheduled for sale by the Sheriff on September 5, 2012.
3. Movant thereafter continued the Sheriff's Sale from September 5, 2012 to
December 5, 2012.
4. Movant thereafter continued the Sheriff's Sale from December 5, 2012 to March
6, 2013 per Order of Court.
5. Movant thereafter continued the Sheriff's Sale from March 6, 2013 to April 3,
2013,per Order of Court.
6. Movant thereafter continued the Sheriff's Sale from April 3, 2013 to June 5, 2013,
per Order of Court.
7. Movant thereafter continued the Sheriff s Sale from June 5,2013 to September 4,
2013,per Order of Court.
8. Plaintiff wishes to continue the sale again to October 2, 2013, due to the fact
Plaintiff is allowing Defendants additional time to sell the Premises and pay-off Plaintiff,
however, since the continuance would be more than 130 days from the original sale date,
Plaintiff needs an Order of Court allowing it to do so.
9. Pursuant to Pa.R.C.P. 3129.3(a),new notice is required to be given as required by
Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued,postponed or adjourned,
"except as provided in subdivision(b) or by special Order of the Court."
10. No parties-in-interest will be prejudiced by this continuance, as the Sheriff will
announce the continued sheriff sale date pending Court Order at the September 4,2013 Sheriff's
Sale.
11. Consequently,Plaintiff requests the sheriff sale scheduled for September 4, 2013
be continued pursuant to Pa.R.C.P. 3129.3(a) to October 2,2013, and the requirement that
advertisement be made and new notice be provided to Defendants, lienholders and other parties
of interest be waived.
12. Counsel for Defendants concurs with this Motion to Continue Sale.
WHEREFORE, Plaintiff requests this Honorable Court to enter a special Order of Court
pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for September 4, 2013 to October 2,
2013 and dispense with the requirement that advertisement be made and a new notice be
provided to Defendants, lienholders or other parties of interest.
JAMES, SMITH, D T I
& CONNELLY LL'
Dated: August 20, 2013 By:
Scott A. i squire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650 i
Hershey, PA 17033
(717) 533-3280
r +
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 11-9391 Civil Term
VS. :
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion to
Continue Sheriff's Sale was served on the following this 20a'day of August, 2013 via First Class
U. S. Mail, Postage Pre-paid and via email:
Sheriff of Cumberland County
ATTN: Real Estate Department
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
Greg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
Timothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, Pennsylvania 17013
JAMES SMIT IETT I K&CONNELLY
By:
S tt . ietterick, sq re
orney I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff,
NO.: 11-9391 Civil Tenn
VS.
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
ORDER OF COURT
AND NOW,this day of 2013.the Motion to
Continue Sheriff Sale by Orrstown Bank, and Defendants' consent thereto, it is hereby
ORDERED, ADJUDGED and DECREED that the sheriff sale scheduled for September 4, 2013
is continued to October 2,2013, and the requirement that advertisement be made and new notice
be provided to Defendants, lienholders or other parties in interest under Pa.R.C.P. 3129.2 is
hereby waived.
BY THE �,C�RT:
01-ACC4
C- a>
M C. IF
.;:o Z 5 r—
CA
=CD
CD
IN THE COURT OF COMMON PLEAS OF rJ -pi
CUMBERLAND COUNTY, PENNSYLVANIA -c-r
rn w cn :,..:=
ORRSTOWN BANK,
• CIVIL DIVISION r— �..) ^? °
r
Plaintiff, NO 11-9391 CIVIL TERM 'CD - 5-i
• ISSUE NO.: w .'vs. •r.^ t
TIMOTHY A. MOUL and • TYPE OF PLEADING:
•
ELOISE R. MOUL,
Defendants. • Pa.R.C.P.RULE 3129.2(C)
• AFFIDAVIT OF SERVICE OF
DEFENDANTS/OWNERS AND
• OTHER PARTIES OF INTEREST
• CODE:
• FILED ON BEHALF OF:
• Orrstown Bank, Plaintiff
•
• COUNSEL OF RECORD FOR THIS
PARTY:
•
•
• Scott A. Dietterick, Esquire
• Pa. I.D. #55650
• Kathryn L. Mason, Esquire
• Pa. I.D. #306779
•
JAMES, SMITH, DIETTERICK&
• CONNELLY LLP
• P.O. Box 650
• Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, : CIVIL DIVISION
Plaintiff, • NO.: 11-9391 Civil Term
vs.
•
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
Pa.R.C.P. RULE 3129.2(c)AFFIDAVIT OF SERVICE OF
DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST
I, Scott A. Dietterick, Esquire, attorney for Orrstown Bank, Plaintiff, being duly sworn
according to law depose and make the following Affidavit regarding service of Plaintiffs Notice
of Sheriffs Sale of Real Property in this matter on Defendants/Owners and Other Parties of
Interest as follows:
1. Defendants, Timothy A. Moul and Eloise R. Moul, are the record owners of the
real property.
2. On or about June 23, 2012, Defendants, Timothy A. Moul and Eloise R. Moul,
were served with Plaintiffs Notice of Sheriff's Sale of Real Property Pursuant to Pa.R.C.P.
3129, via certified mail, return receipt requested, at the address of the mortgaged premises,being
639 Glendale Street, Carlisle, Pennsylvania 17013. True and correct copies of said Notices and
certified mail receipts are marked Exhibit"A", attached hereto and made a part hereof.
3. On or about June 22, 2012,Plaintiff's counsel served all other parties in interest
with Plaintiff's Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to Rule
3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and
correct copies of said Notices and Certificates of Mailing are marked Exhibit `B", attached
hereto and made a part hereof.
Finally, the undersigned deposes and says that Defendants/Owners and all Other Parties
of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance
with Pa. R.C.P. 3129.2.
JAMES, SMIT , iI ► 'III &CONNELLY LLP
\f/
Dated: q,J9- 13 BY: All._ _.....aliii.,
S . t A`I ietterick, Esquire
'a. I.D. #55650
Kathryn L. Mason, Esquire
Pa. I.D. #306779
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Attorneys for Plaintiff
Sworn to and subscribed before me this
24th day of September, 2013.
Notary Public
MY COMMISSION EXPIRES:
NOTARIAL SEAL
CHRISTINE L SPURLOCK
Notary Public
HUMMELSTOWN BORO,DAUPHIN COUNTY
My Commission Expires Feb 2,2017
EXHIBIT "A"
U.S. Postal Service,,,,
Er CERTIFIED MAILTL RECEIPT
U.S. Postal Service N (Domestic Mail Only;No Insurance Coverage Provided)
Iv CERTIFIED MAIL, RECEIPT in For delivery information visit our website at www.usps.com.,
rn (Domestic Mail Only;No Insurance Coverage Provided)
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I ) For delivery information visit our website at www.usps.com 9 ..-p -Ct....3, t .�, A.
.J3 L, �t 1 r.- Arl....i N Postage $ i LI • 4
(L1 C, ` r 3 Certified Fee /
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i r-i Certified Fee Ci ` i iJ 7 p (Endorsement Required) ° C„, Here WO 4.,
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\.4 PS Form 3800.August 2006 See Reverse for Instructions
Will � � � ;
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
vs. •
•
•
TIMOTHY A. MOUL and
ELOISE R. MOUL, •
•
Defendants. •
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Timothy A. Moul
639 Glendale Street
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriffs Sale of Real Property(Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 11-9391 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Timothy A. Moul and Eloise R. Moul
A SCHEDULE OF DISTRIBUTION,being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact,be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013,before presentation of the petition to
the Court.
JAMES, SMITH, DIE � RIC A CONNELLY LLP
viiirawri
DATED: 3 ' BY: � 1�
Scott • i Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street
in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded
and described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the
line dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded
in Plan Book 14, Page 28; thence Southwardly along the East side of Glendale Street
South 04 degrees 55 minutes 50 seconds East 100 feet to a point which point is in the line
dividing Lots 60 and 61 as shown on the Plan of Section C of Heatherlands; thence North
85 degrees 04 minutes 10 seconds East 150 feet to a point; thence North 04 degrees 55
minutes 50 seconds West 100 feet; thence South 85 degrees 04 minutes 10 seconds West
150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639
Glendale Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,
by Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland
County, in Deed Book Volume 28-L, Page 390, granted and conveyed unto Timothy A.
Moul and Eloise R. Moul, His Wife.
Parcel No. 04-22-0481-034
Exhibit"A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
•
Plaintiff, •: NO.: 11-9391 Civil Term
vs.
•
•
TIMOTHY A. MOUL and
ELOISE R. MOUL,
•
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Eloise R. Moul
639 Glendale Street
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 11-9391 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Timothy A. Moul and Eloise R. Moul
A SCHEDULE OF DISTRIBUTION,being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held,to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH, l')IE ' 'RIC' & CONNELLY LLP
1
DATED: . ��(�'I BY: AtLP'
Scotttterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717)533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street
in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded
and described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the
line dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded
in Plan Book 14, Page 28; thence Southwardly along the East side of Glendale Street
South 04 degrees 55 minutes 50 seconds East 100 feet to a point which point is in the line
dividing Lots 60 and 61 as shown on the Plan of Section C of Heatherlands; thence North
85 degrees 04 minutes 10 seconds East 150 feet to a point; thence North 04 degrees 55
minutes 50 seconds West 100 feet;thence South 85 degrees 04 minutes 10 seconds West
150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639
Glendale Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,
by Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland
County, in Deed Book Volume 28-L, Page 390, granted and conveyed unto Timothy A.
Moul and Eloise R. Moul, His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
EXHIBIT "B"
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•
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
•
vs.
•
TIMOTHY A. MOUL and •
•
ELOISE R. MOUL,
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: M&T Mortgage Corporation
2270 Erin Court
Lancaster, PA 17604
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the •
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten(10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIETTERICK&
f
CONNELL LLP
Dated: 6/22/2012 By: ��u111
Sco /�D�. •' , Esquire
PA ID #556
Attorney for�`' intiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
•
Plaintiff, : NO.: 11-9391 Civil Term
vs. .
•
TIMOTHY A. MOUL and .
ELOISE R. MOUL, .
•
Defendants. .
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: M&T Mortgage Corporation
P.O. Box 7628
Lancaster, PA 17604
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten(10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIE TERICK&
CONNELLY LL ' I
\I.
Dated: 6/22/2012 By:
Scott A. Diet , ire
PAID #55e 0
Attorney for Phi iff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
•
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
Plaintiff, : NO.: 11-9391 Civil Term
vs.
•
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
Defendants. •
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Manufacturers &Traders Trust Co.
One M&T Plaza
Buffalo, NY 14240
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
•
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIETTERICK&
CONNELLY LLP 7
,,,t
i�
Dated: 6/22/2012
By: Las
Scott Diett�� k, E'� ire
PA ID #556G�
Attorney for.'laintif
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit"A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
Plaintiff, : NO.: 11-9391 Civil Term
•
vs.
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
•
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Commerce Bank/Harrisburg,N.A.
100 Senate Avenue
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DI TERICK&
CONNELLY LLP
Dated: 6/22/2012 By:
Scott Die - c , Esquire
PAID #556
Attorney for Pl. ntff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
•
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
•
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, : CIVIL DIVISION
Plaintiff, • NO.: 11-9391 Civil Term
vs.
•
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
•
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Cumberland County Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX.NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, I rl, TERICK&
CONNELLY LLP
Dated: 6/22/2012 By: 10/��
Scott A. Dietteric.1, , i e
PA ID #55650
Attorney for Plain ff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, : CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
vs.
•
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
•
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Department of Revenue
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX.NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DI !ERICK &
CONNELLY L IP
Dated: 6/22/2012 By: �/1110101
Scott A. D'e f ric • ire
PA ID #556;I
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, : CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
vs.
•
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
•
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Commonwealth of PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DI A ERICK&
CONNELLY _ 4
Dated: 6/22/2012 By: i
Scott A D 1,rVEs. ire
PA ID •' •
Attorney for Plkntiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife,by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
vs.
•
TIMOTHY A. MOUL and
•
ELOISE R. MOUL,
•
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: Cumberland County Domestic Relations Office
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Timothy A. Moul
and Eloise R. Moul are the owners or reputed owners and on which you may hold a lien or have
an interest which could be affected by the sale of:
639 Glendale Street
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
TIMOTHY A. MOUL and ELOISE R. MOUL,
Defendants.
at EX. NO. 11-9391 Civil Term in the amount of$161,688.36, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriff's Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMIT 1 IETTERICK&
CONNELLY 'P
i'
Dated: 6/22/2012 By: Ill
Scott A. D'ett:.Ir• , D.• ire
PA ID #55650 G
• Attorney for ' aintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground located on the East side of Glendale Street in the
Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and
described as follows:
BEGINNING at a point on the East side of Glendale Street which point is in the line
dividing Lots 61 and 62 as appears on the Plan of Section C of Heatherlands recorded in Plan
Book 14, Page 28; thence Southwardly along the East side of Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet to a point which point is in the line dividing Lots 60 and 61
as shown on the Plan of Section C of Heatherlands; thence North 85 degrees 04 minutes 10
seconds East 150 feet to a point; thence North 04 degrees 55 minutes 50 seconds West 100 feet;
thence South 85 degrees 04 minutes 10 seconds West 150 feet to the place of BEGINNING.
The lot described above is Lot No. 61 as shown on the said plan of Section C of
Heatherlands.
HAVING thereon erected a dwelling house being known and numbered as 639 Glendale
Street, Carlisle, Pennsylvania 17013.
BEING the same premises which John S. Fecko, Jr. and June E. Fecko, His Wife, by
Deed dated May 18, 1979 and recorded on May 31, 1979 in and for Cumberland County, in Deed
Book Volume 28-L, Page 390, granted and conveyed unto Timothy A. Moul and Eloise R. Moul,
His Wife.
Parcel No. 04-22-0481-034
Exhibit "A"
r '
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
Plaintiff, NO 11-9391 Civfrm
vs. • -,.. -o
•
1 .
TIMOTHY A. MOUL and •
ELOISE R. MOUL, c
•
,
Defendants.
MOTION TO CONTINUE SHERIFF'S SALE WITH DEFENDANTS' CONSENT
AND NOW, comes the Movant Orrstown Bank, by and through its attorneys, James,
Smith, Dietterick& Connelly, LLP, and files this Motion to Continue Sheriffs Sale as follows:
1. Plaintiff obtained a default judgment in mortgage foreclosure against the
Defendants Timothy A. Moul and Eloise R. Moul ("Defendants") at the above-captioned term
and number("Judgment").
2. Pursuant to said Judgment,the Plaintiff caused the Defendants' property subject
to the Judgment, which property is more specifically described in the Mortgage attached to
Plaintiffs Complaint("Premises"), to be scheduled for sale by the Sheriff on September 5, 2012.
3. Movant thereafter continued the Sheriffs Sale from September 5, 2012 to
December 5, 2012.
4. Movant thereafter continued the Sheriffs Sale from December 5, 2012 to March
6, 2013 per Order of Court.
5. Movant thereafter continued the Sheriffs Sale from March 6, 2013 to April 3,
2013,per Order of Court.
6. Movant thereafter continued the Sheriffs Sale from April 3, 2013 to June 5, 2013,
per Order of Court.
r
7. Movant thereafter continued the Sheriff's Sale from June 5, 2013 to September 4,
2013, per Order of Court.
8. Movant thereafter continued the Sheriff's Sale from September 4, 2013 to
October 2, 2013, per Order of Court.
9. Plaintiff wishes to continue the sale again to March 5, 2014, due to the fact
Plaintiff is allowing Defendants additional time to sell the Premises and pay-off Plaintiff,
however, since the continuance would be more than 130 days from the original sale date,
Plaintiff needs an Order of Court allowing it to do so.
10. Pursuant to Pa.R.C.P. 3129.3(a), new notice is required to be given as required by
Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued, postponed or adjourned,
"except as provided in subdivision(b) or by special Order of the Court."
11. No parties-in-interest will be prejudiced by this continuance, as the Sheriff will
announce the continued sheriff sale date pending Court Order at the October 2, 2013 Sheriff's
Sale.
12. Consequently, Plaintiff requests the sheriff sale scheduled for October 2, 2013 be
continued pursuant to Pa.R.C.P. 3129.3(a) to March 5, 2014, and the requirement that
advertisement be made and new notice be provided to Defendants, lienholders and other parties
of interest be waived.
13. Counsel for Defendants concurs with this Motion to Continue Sale.
WHEREFORE, Plaintiff requests this Honorable Court to enter a special Order of Court
pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for October 2, 2013 to March 5, 2014
and dispense with the requirement that advertisement be made and a new notice be provided to
Defendants, lienholders or other parties of interest.
JAMES, SMITH, h ETTE'
& CONNELLY L '
j,
Dated: September 27, 2013 By: �,
S'
Scott A. I ietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
•
Plaintiff, • NO.: 11-9391 Civil Term
vs. •
•
TIMOTHY A. MOUL and •
ELOISE R. MOUL, •
•
Defendants. •
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Motion to
Continue Sheriff's Sale was served on the following this 27th day of September, 2013 via First
Class U. S. Mail, Postage Pre-paid and via email:
Sheriff of Cumberland County
ATTN: Real Estate Department
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
Greg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
Timothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, Pennsylvania 17013
JAMES SMI, H Atilt CK & CONNELLY
By: I
ietterick, Esquire
Attorney I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
C
�J
a
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, • CIVIL DIVISION
Plaintiff, - • NO.: 11-9391 Civil Term
•
vs.
•
•
TIMOTHY A. MOUL and
ELOISE R. MOUL,
Defendants.
ORDER OF COURT
AND NOW, this or day of 0G-D , 2013, the Motion to
Continue Sheriff Sale by Orrstown Bank, and Defendants' consent thereto, it is hereby
ORDERED, ADJUDGED and DECREED that the sheriff sale scheduled for October 2, 2013 is
continued to March 5, 2014, and the requirement that advertisement be made and new notice be
provided to Defendants, lienholders or other parties in interest under Pa.R.C.P. 3129.2 is hereby
waived.
BY THE COURT:
J.
aex ies inat.1-CtL
—_4
Y • CTl CD r-rl
Atly 0. 16.31'f
-7';;Ate)44y etziti trzoak =c)
/o/a//3
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
•
V.
•
TIMOTHY A. MOUL AND
•
ELOISE R. MOUL,
DEFENDANTS : 11-9391 CIVIL TERM
ORDER OF COURT
AND NOW, this day of November, 2013, the sheriff sale
scheduled for March 5, 2014, is cancelled and rescheduled to March 12, 2014, and the
requirement that advertisement be made and new notice be provided to Defendants,
lienholders or other parties in interest under Pa.R.C.P. 3129.2 is hereby waived.
By the Court,
Albert H. Masla d, J.
Scott A. Dietterick, Esquire
P.O. Box 650
Hershey, PA 17033
.Areg Knight, Esquire
2 Northfield Way
Mechanicsburg, PA 17050
mothy A. Moul and Eloise R. Moul
639 Glendale Street
Carlisle, PA 17013
Sheriff of Cumberland County - L r t;v �� ='
rnco z -.
Zr' cc n
:sal ;m -rft
' 173 „C:
fiait ket, <
cy
/! 1413 � ,
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF:10E OFD E SH.E SIF
TAE PRO THONO
D 1 lr 112 18 fk;1 (4 1
CUMBERLAND COUNTY
PENNSYLVANIA
Orrstown Bank
vs.
Timothy A. Moul (et al.)
Case Number
2011 -9391
SHERIFF'S RETURN OF SERVICE
06/19/2012 07:22 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 639 Glendale Street, Carlisle Borough, Carlisle, PA 17013, Cumberland
County.
08/10/2012 Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice
and Description, in the above titled action, by making known its contents and at the same time personally
handing a true copy to a person representing themselves to be Karen Stodghill (Daughter), who
accepted as "Adult Person in Charge" for Eloise R. Moul at 639 Glendale Street, Carlisle, Cumberland
County.
08/10/2012 Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice
and Description, in the above titled action, by making known its contents and at the same time personally
handing a true copy to a person representing themselves to be Karen Stodghill (Daughter), who
accepted as "Adult Person in Charge" for Timothy Moul at 639 Glendale Street, Carlisle, Cumberland
County.
08/17/2012 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/5/2012
12/04/2012 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013
03/05/2013 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013
04/02/2013 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013
05/31/2013 As directed by Scott Dietterick, Attorney for the Plaintiff, Sheriff's Sale Continued to 9/4/2013
08/30/2013 As directed by Scott Dietterick, Attorney for the Plaintiff, Sheriff's Sale Continued to 10/2/2013
10/02/2013 As directed by Scott Dietterick, Attorney for the Plaintiff, Sheriff's Sale Continued to 3/5/2014
11/05/2013 As directed by Scott Dietterick, Attorney for the Plaintiff, Sheriff's Sale Continued to 3/12/2014
03/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed ",
per letter of instruction from Attorney.
SHERIFF COST: $895.89 SO ANSWERS,
March 14, 2014 RONNY R ANDERSON, SHERIFF
c} Cioun,ySu: e Sheriff.'T'eleosoft, Inc.
- 9-S po[ • Ca.
SV LL p1 •
9,S-
la" 30307i/
On April 16, 2012 the Sheriff levied upon the defendant's
interest in the real property situated in Carlisle Borough,
Cumberland County, PA, known and numbered 639
Glendale Street, Carlisle, PA 17013 more fully described
on Exhibit "A" filed with this writ and by this reference
incorporated herein.
Date: April 16, 2012
By: 01 CoLd.A---- 61-0L646.&7
Claudia Brewbaker, Real Estate Coordinator
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CUMBERLAND LAW JOURNAL
Writ No. 2011 -9391 Civil Term
Orrstown Bank
vs.
Timothy A. Moul
Eloise R. Moul
Atty.: Scott A. Dietterick
ALL THAT All that CERTAIN lot
of ground located on the East side
of Glendale Street in the Borough of
Carlisle, Cumberland County, Penn-
sylvania, more particularly bounded
and described as follows:
BEGINNING at a point on the
East side of Glendale Street which
point is in the line dividing Lots 61
and 62 as appears on the Plan of
Section C of Heather lands recorded
in Plan Book 14, Page 28; thence
Southwardly along the East side of
Glendale Street South 04 degrees
55 minutes 50 seconds East 100 feet
to a point which point is in the line
dividing Lots 60 and 61 as shown on
the Plan of Section C ofHeatherlands;
thence North 85 degrees 04 minutes
10 seconds East 150 feet to a point;
thence North 04 degrees 55 minutes
50 seconds West 100 feet; thence
South 85 degrees 04 minutes 10
seconds West 150 feet to the place
of BEGINNING.
The lot described above is Lot No.
61 as shown on the said plan of Sec-
tion C of Heatherlands.
HAVING thereon erected a dwell-
ing house being known and num-
bered as 639 Glendale Street, Carl-
isle, Pennsylvania 17013.
BEING the same premises which
John S. Fecko, Jr. and June E.
Fecko, His Wife, by Deed dated May
18, 1979 and recorded on May 31,
1979 in and for Cumberland County,
in Deed Book Volume 28 -L, Page 390,
granted and conveyed unto Timothy
A. Moul and Eloise R. Moul, His Wife.
Parcel No. 04 -22- 0481 -034.
73
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, 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 27, August 3, and August 10, 2012
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.
sa Marie Coyne, Etor
SWORN TO AND SUBSCRIBED before me this
da of Au l ust 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
` d •
The Patriot -News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717- 255 -8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
hc PatriotXews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and /or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M ", Volume 14, Page 317.
2011 -9391 Chill Term
Orrstown Bank
Vs
Timothy A. Moul
Eloise R. Moul
Arty: Scott A Dletterlck
ALL THAT Alf that CERTAIN lot
of ground located on the East side of
Glendale Street in the Borough of Carlisle,
Cumberland County, Pennsylvania, more
particularly bounded and described as
follows:
BEGINNING at a point on the East side
of Glendale Street which point is in the
line dividing Lots 61 and 62 as appears
on the Plan of Section C of Heather
lands recorded in Plan Book 14, Page 28;
thence Southwardly along the East side
of Glendale Street South 04 degrees 55
minutes 50 seconds East 100 feet to a point
which point is in the line dividing Lots 60
and 61 as shown on the Plan of Section C
ofHeatherlands; thence North 85 degrees
11
04 minutes 10 seconds East 150 feet to a
Point; thence North 04 degrees 55 minutes
• 50 seconds West 100 feet; thence South 85
degrees 04 minutes 10 seconds West 150
feet to the place of BEGINNING.
This ad ran on the date(s) shown below:
07/27/12
08/03/12
08/10/12
COMMONWEALTH OF PENN
Notarial Seal
Sherrie L. Owens, Notary Public
Lower Paxton Twp., County
My Commission Expires Nov. 26, 2015
EMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
V