HomeMy WebLinkAbout05-1547
PHELAN HALLINAN & SCHMIEG, LLP
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
ONE PENN CENTER PLAZA, SUITE 1400
PH[LADELPHIA, PA 19103
(215) 563-7000
WASHINGTON MUTUAl. BANK, FA
8120 NATIONS WAY
BUILDING 100
JACKSONVILLE, FL 32256
ATTORNEY FOR Pl.AINTIFF
COURT OF COMMON Pl.EAS
CIVIL DIVISION
Plaintiff
TERM
NO. 05 - /S''I7
Clu~L~~'I
v.
CUMBERl.AND COUNTY
ROBERT E. MOSES
454 SHED ROAD
NEWVILl.E, PA [7241
Dcfcndant
CIVIL ACTION - LA W
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
IIA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORM A nON ABOUT HIRING A LAWYER.
IF YOU CANNOT AffORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES
TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PAl 70 13
(800)990-9108
File#: 113492
Fill,!!: 113492
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DA YS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERI FICA TION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DA YS, YOU MAY OBTAIN AN EXTENSION OF
THA T TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND
RECEIVED A DISCHARGE, THIS IS NOT AN
ATTEMPT TO COLLECT A DEBT. IT IS AN
ACTION TO ENFORCE A LIEN ON REAL ESTATE.
1. Plaintiff is
WASHINGTON MUTUAL BANK, FA
8120 NATIONS WAY
BUILDING 100
JACKSONVILLE, FL 32256
2. The name(s) and last known addressees) of the Defendant(s) are:
ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, P A 17241
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 07/07/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to THE WASHINGTON SAVINGS BANK, FSB which mortgage
is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1824, Page: 1489. By Assignment of Mortgage recorded 08/03/2004 the mortgage
was Assigned To PLAINTIFF which Assignment is recorded in Assignment Of
Mortgage Book No. 710, Page 2151.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/01/2004 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 113492
6. The following amounts are due on the mortgage:
Principal Balance
Interest
10/01 /2004 through 03/18/2005
(Pcr Diem $16.75)
Attorney's Fees
Cumulative Late Charges
07/07/2003 to 03/1 8/2005
Cost of Suit and Title Search
Subtotal
$111,191.89
2,830.75
1,250.00
276.85
$ 550.00
$ 116,099.49
Escrow
Credit
Deficit
Subtotal
-2,125.17
0.00
$- 2,125.17
TOTAL
$ 113,974.32
7. The attorney's fees set forth above are in conformity with the mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs
Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be
charged.
8. Notice oflntention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by
said notiee has terminated because Defendant(s) has/have failed to meet with the Plaintiff
or an authorized consumer credit counseling agency, or has/have been denied assistance
by the pennsylvania Housing Finance Agency.
9. This action docs not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$ ] 13,974.32, together with interest from 03/18/2005 at the rate of $16.75 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale ofthc mortgaged property.
PHELAN HALLINAN & S.cHMIE<~JXP /~
By: L::::-
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
File#: 1[3492
ALL the following tract of land with the improvements thereon erected lying, being, and situated in
Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described as follows, to
wit:
BEGINNING at a point on the Center Line of Shed Road (T -412) at a couunon property comer of
Lot #6 and Lot #7 shown on the Preliminary/Final Subdivision Plan of Scenic View; thence from
said point of beginning along the Center Line of Shed Road (1'-412) by a curve, curving to the left,
having a radius of325.00 feet and an arc length of 133.97 feet (with a chord bearing of South 09
degrees 40 minutes 08 seconds East and a chord distance of 133.02 feet) to a point; thence
continuing along the Center Line of Shed Road (T -412) South 21 degrees 28 minutes 40 seconds
East, a distance of 26.36 feet to a point ata common property corner of Lot #7 and Lot #8; thence
through Shed Road (1'-412) and along Lot #8 North 82 degrees 20 minutes 08 seconds West, a
distance of 398.62 feet to an iron pin; thence continuing along Lot #8 and along Lot #9 South 24
degrees 46 minutes 22 seconds East, a distance of 621.0 1 feet to an iron pin at a common property
comer of Lot #7, Lot #9, and Lot #10; thence along Lot #10 and Lot #11 North 72 degrees 16
minutes 15 !>eCQnds West, a diS~Of.s75'47 feet to an iron pin at 11 common property comer of
Lot #7 and Lot #1..21. - ence alongt #1 ~NortM)V. dCllI'.ees.29 minutes 03 seconds West, a distan ce
of269.91 feet to lj1l n pin; the . n4}.uing alo.ng.,~e SolithA8degrees 34 minutes 21 seconds
West, adis~of .0.72 feet to . ir~t1!nata:~l1propertycornerofLot#7, Lot #12, and
Lot #13; ~nce ~o '1ft #1~}'l0~ 7zVd~s 54 minutes 08 seconds West, a distance of 424.67
feet to an IrOn.pm onun~ Pftlperty comer of Lot #7. lands now or formerly of lohn E. and
Vema 1. Karns, an ds not or late QfElwood R. Gutshall, Jr. and David W. Gutshall; thence
along lands now or _'ofElwood.R,.. GUlsha11, Jr. and David W. Gutshall and lands now or late of
Ray L. and Ann L. eW NortU23 ~egrees 44 minutes 42 seconds East, a distance of 930.72 feet to
~ __'~ :/l'! I
an iran pin at lands now or late of Charles L. and Helen R. Bear South 46 degrees 55 minutes 21
seconds East, a distance of 178.09 feet to an iran pin at a common property comer oCLot #5, Lot #6,
and Lot #7; thence along Lot #6 South 49 degrees 24 minutes 21 seconds West, a distance of89.26
feet to an iron pin; thence continuing along Lot #6 South 26 degrees 48 minutes 14 seconds West, a
distance of 45.52 feet to an iron pin; thence continuing along Lot #6 South 54 degrees 51 minutes 38
seconds East, a distance of 304.28 feet to an iran pin; thence continuing along Lot #6 and thtough
Shed Road (1"-412) South 82 degrees 20 minutes 08 seconds East, a distance of 753.09 feet to a
point an the Center Line of Shed Road, said point being the place of beginning.
PROPERTY BEING: 454 SHED ROAD
.
VERIFICATION
FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for
Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the
verification could not be obtained within the time allowed for the filing of the pleading,
that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that
the statements made in the foregoing Civil Action in Mortgage Foreclosure are based
upon information supplied by Plaintiff and are true and correct to the best of its
knowledge, information and belief. Furthermore, it is counsel's intention to substitute a
verification from Plaintiff as soon as it is received by counsel.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.
c. S. Sec. 4904 relating to unsworn falsifications to authorities.
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Francis S. Hallinan, Esquire
Attorney for Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01547 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
MOSES ROBERT E
VALERIE WEARY
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MOSES ROBERT E
t e
DEFENDANT
, at 1132:00 HOURS, on the 1st day of A ril
2005
at 454 SHED ROAD
NEWVILLE, PA 17241
by handing to
ROBERT E MOSES
a true and attested copy of COMPLAINT - MORT FORE
together ith
and at the same time directing His attention to the contents th reof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
9.62
.00
10.00
.00
37.62
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R. Thomas Kline
04/04/2005
PHELAN HALLINAN SCHMIEG
me this
;t day of JYl d
.;lo.o~--- A.D.
4C-P.: m~-~.....
U Prothonotary ~r ~
Sworn and Subscribed to before By:
,
,
PHELAN HALLINAN & SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
WASHINGTON MUTUAL BANK, FA
8120 NATIONS WAY, BUILDING 100
JACKSONVILLE, FL 32256
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 05-1547
ROBERT E. MOSES
Defendant(s).
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter an in rem judgment in favor of the Plaintiff and against ROBERT E. MOSES,
Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof
and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
Interest from 3/19/05 to 5/9/05
TOTAL
$113,974.32
$871.00
$114,845.32
I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached.
DAMAGES ARE HEREBY ASSESSED AS INDICATED. .. ~
DATE: ~,d..DoS ~A/(~} )12.
PRO PROTHY
,
PHELAN, HALLINAN AND SCHMIEG
By: Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Sclunieg, Esq., Id. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, P A 19! 03
(71,) ,~,_7000
WASHINGTON MUTUAL BANK, FA
Plaintiff
ATTORNEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
: CML DIVISION
Vs.
: CUMBERLAND COUNTY
ROBERT E. MOSES
Defendants
: NO. 05-1547
TO: ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, P A 17241
DATE OF NOTICE: APRn 22 2005
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOClA nON
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-9108
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FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
WASHINGTON MUTUAL BANK, FA
8120 NATIONS WAY, BUILDING 100
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 05-1547
ROBERT E. MOSES
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
200 .
By:
DEPUTY
If you have any questions concerning this matter, please contact:
/~oQ c. ~bnleo~
. " ey for Plaintiff- .
ONE PENN CENTER AT SUBURB N S ATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY."
.
PHELAN HALLINAN & SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN ST A nON
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK, FA
8120 NATIONS WAY, BUILDING 100
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
CIVIL DIVISION
v.
NO. 05-1547
ROBERT E. MOSES
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts,
to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant ROBERT E. MOSES is over 18 years of age and resides at ,
454 SHED ROAD, NEWVILLE, PA 17241.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
IEL G. SCHMI
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
WASHINGTON MUTUAL BANK, FA
Plaintiff,
v.
No. 05-1547
ROBERT E. MOSES
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$114,845.32
Interest from 5/9/05 to SEPTEMBER 7, 2005
(per diem -$18.88)
$2,284.48 and Costs
TOTAL
$117,129.80
<"
,
NIEL G. SCH G, ESQUIR
One Penn Center at Suburban Statio
1617 Jolm F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
IMPORTANT NOTICE: This property is sold at the direction of the
plaintiff. It may not be sold in the absence of a representative of
the plaintiff at the Sheriff's Sale. The sale must be postponed or
stayed in the event that a representative of the plaintiff is not
present at the sale.
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PHELAN HALLINAN & SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
ROBERT E. MOSES
NO. 05-1547
Defendant(s).
CERTIFICATION
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (5)
From ROBERT E. MOSES
(I) 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) thaI: (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $114,845.32 L.L. $.50
Interest FROM 5/9/05 TO 917105 (PER DIEM - $18,88) - $2,284.48 AND COSTS
Arty's Cornm % Due Prothy $1.00
Atty Paid $119.62
Plaintiff Paid
Date: MAY 16, 2005
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary ~
~~O/)-P . P /?/Y'l~-----
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
( -
"
WASHINGTON MUTUAL BANK, FA
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
ROBERT E. MOSES
CIVIL DIVISION
Defendant(s).
NO. 05-1547
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK. FA, Plaintiff in the above action, by its attorney, DANIEL G,
SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,454 SHED ROAD, NEWVILLE, PA
17241 .
I. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, PA 17241
2. Name and address ofDefendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
I -
"
4. Name and address oflast recorded holder of every mortgage ofrecord:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person ofwhom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
454 SHED ROAD
NEWVILLE, PA 17241
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Mav 9,2005
DATE
.....,
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W ASIDNGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
v.
No. 05-1547
ROBERT E. MOSES
Defendant(s).
May 9,2005
TO: ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, PA 17241
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at. 454 SHED ROAD. NEWVILLE, PA 17241, is scheduled to be
sold at the Sheriffs Sale on SEPTEMBER 7. 2005 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $114,845.32
obtained by WASHINGTON MUTUAL BANK. FA (the mortgagee) against you. In the event the sale
is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
I
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share ofthe money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days ofthe sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7 . You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
4i'
DESClUrrlON
ALL the following tract ofland with the imptm>ements thereon erected lying, being, and situate
in Lower Miffiin Township, Cumberland County, Pennsylvania bounded and c!es.-,;be<! .s
follows, to wit
BEGINNlNG at II point OIl the c.:nter Line of Sbtd Road (T 412) at a common property corner of
Lot #6 and Lot #7 shown on the PreliminarylFinal SubdIvision Plan of Scenic View; thence from
said point Qfbeginning a10ng the Center Line of Shed Road (T 412) by a cum:, curving to the
left, having a radiuso02S.oo fW and an arc length Qf133.97 teet (with a chord bearing of South
09 degrees 40 minutes OS seeonds East and a chord distance of 133.02 feet) to a point; thence
continuing Jlong the Center Line of Shed Road (T 412) Sooth 21 degrees 28 minutes 40 seconds
East, a distwoe of 26.36 feet to a point at a common property comer of Lot #7 and Lot fIfl; thence
through Shed Road (t-412) and along Lot 1* 8 North 82 degrees 20 minutes 0& SOCOIld$ West, a
distance of 39&.62 teet to an iron pin; thence eootinuing along Lot 118 and along Lot 119 South 24
degrees 46 minutes 22 seconds Bast, a distance of 621.0 I feet to an iron pin at a common
property comer of Lot 117, Lot #9, and Lot 1110; thence along Lot #10 lIlld LotI! II Nortb 72
degrees 16 minutes 15 seconds West, a distance of575.47 feet to an iron pin at aconunon
property corner of Lot 117 and Lot # 12, thence along Lot 1112 North 67 degrees 29 minutes 03
seconds West, a distance of269.91 feet tc> an iron pin; thence oontinuil1l: al<mg same South 48
degrees 34 minutes 21 seconds West, a dista11ceofl40.72 feet to an iron pin at a common
property comer QfLot #7, Lot #12 and Lot #13; thence along Lot #13 North 72 degrees 54
minutes 08 seconds West adislance of 424.61 feet to llIl mm pin at a e<>mmon property comer of
Lot 1f7, landsll()WDr formerly of John R.an<! VemaJ. Karm, and 1311dsnow or tate ofElwoodR..
Gutshall, IT. and David W. Gutahall; thence along 1andll now or late of Elwood R. Gutshall Jr and
David W. Gutshall and 1andll now or late of Ray L. and Ann L. Ilrehl North 23 degrees 44
mimrtes42 seconds East, a distanceof93.72 feet to an iron pin at Lands now or Late of Charles L.
and Helen R. Bear South 46 degrees 55 minutes 21 seconds East, a distance of 178.09 feet to an
iron pin at a common propm)' comer of Lot # 5, Lot #6, and lot #7; thence along Lot 116 South 49
degrees 24 minutes 21 seconds West, a distanCe of 89.26 feel to an iron pin; thence continuing
along Lot #6 south 26de~ 48 minutes 14 seconds West, a dist<mce of45.52 feet to an iron
pin; thence continuing along Lot 116 South 54 degrees 5 I minutes 38 seconds East, a distance of
304.28 feet to an iron pin; thence contitlUing along Lot 116 and through Shed Rood (r 412) south
82 degrees 20 minutes 08 seconds East, Ii diStaooe 0(753.09 feet to a p<>int on the Center Line of
Shed Road, said point being the place of Beginning.
SJ\ID lot containing 727,563.81 square feet or 16.7026 acres gross area, with a net acreage of
16.6109 acres to the Dtdicated Right-of-way Line.
BEINO identified as Lot # 7 as shown on a plan oflots prepared (orl<<:Iand,Inc. by Hoover
Engineering Services, Inc. dared March 30, 2000 md recorded July 25, 2000 in the Office of the
Recorder of Deeds in and for Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Shed Road, Newvtllc.
Pennsylvania 17241
TITLE TO SAID PREMSIES IS VESTED IN ~beT1 E. MO$eS, by Deed from William L
Mohn and Suzanne M. Moho, buslwld and wife, dated 7-7-03 and recorded 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, PA 17241
DESCRIPTION
ALL the following trnct ofland with tM improvements thereon erected lying, bcing, and situate
in Lower Mifflin Township, Cumberland Ccunty, Pennsylvania bounded and described as
follows, to wit:
BEGINNING at a point on the Center Line of Shed Road (f -412) at a conunon property corner of
Lot #6 and Lot #7 shown on the PreiiminarylFinal Subdivision Plan of Scenic View; thence from
said point of beginning along the Center Line of Shcd Rood (f -412) by a cum:, curving to the
left, having a radius 0025.00 (eet and an arc length of 133.97 feet (with a chord bearing of South
09 degrees 4() minutes ()8 seconds East and a chord distance of 133.02 feet) to a point; thence
conlinuingalong the Center Line of Shed Road (T-412) South 21 degrees 28 minutes 40 seconds
East, a distance 0(26.36 feet to a point at a common property comer of Lot If1 and Lot #8; thence
through Shed Road (t-412) and along Lot II 8 North 82 degrees 20 minutes 08 seconds West., a
distance of398.62 feet to an iron pin; thence continuing atong Lot #8 and along Lot #9 South 24
degrees 46 minutes 22 seconds East, a distance of62I.01 feet to an iron pin at a common
property comer of Lot # 7, Lot #9. and Lot II 10; thence atongLot #10 and Lot # II North 72
degrees 16 minutes 15 seconds Wcst, a distance of 575.47 feet to an iron pin at a common
property comer of Lot # 7 and Lot # 12, thence along Lot #12 North 67 dcgrees 29 minutes 03
secoods West, a distance of 269.91 feet lOan iron pin; thence continuing along same South 48
degrees 34 minutes 21 seconds West, a distance of 140.72 feet to an iron pin at a common
property comerofLot #7, Lot #12 and Lot #13; thence along Lot 1113 North 72 degrees 54
minutes 08 seconds West a distance of 424.67 feet to an iron pin at a C<lffiII1Oll property comer of
Lot #7, lands oowor formerlyoflohn E. and VemaJ. Karns, and lands now or late of Elwood R.
Gutshall, Jr. and David W. Gutshall; thence along lands !lOW or late of Elwood R. Gutshall Jr and
David W. Gutshall and lands now or lale of Ray L. and Ann L. Brehl North 23 degrees 44
minutes 42 seconds East, a distance of93.72 feet to an iron pin at lands now or late of Charles L.
and Helen R. Bear South 46 degrees 55 minutes 21 seconds East, a distance of 178.09 feet to an
iron pin at a common property COlllCl'ofLot liS, Lot f/(), and lot #7; thence along Lot 116 South 49
degrees 24 minutes 21 seconds West, a distance of 89.26 feet to an iron pin; thence continuing
along Lot f/() south 26 degrees 48 minutes 14 seconds West, a distance of 45.52 foct to an iron
pin; thence continuing along Lot 116 South 54 degrees 51 minutes 38 seconds East, a distance of
304.Ul feet to an iron pin; thence continuing along Lot f/() and through Shed Road (f -412) south
82 degrees 20 minutes 08 seconds Esst, a distlln<1e of753.09 feet to a point on the Center Line of
Shed Road. said point being the place of Beginning.
SAID lot containing 727.563.81 square feet or 16.7026 acreS gross area, with a net acreage of
16.6109 acres to the Dedicated Right-of-way Line.
BEING identified as Lot II 7 as shown on a plan oflots prepared for Reland, Inc. by Hoover
Engineering Services, Inc. dated March 30, 2000 and recorded July 25, 2000 in the Office of the
Recorder ofD<:eds in and for Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Shed Road, Newvillc,
Pennsylvania 17241
TITLE TO SAID PREMSIES IS VESTED IN Robert E, Moses, by Deed from William L
Molin and Suzanne M. Maim, husband and wife, dated 7-7'()3 and rerorded 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, PA 17241
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL V AN]A)
COUNTY OF CUMBERLAND)
NO 05-]547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
Frorn ROBERT E. MOSES
(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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $] 14,845.32
L.L. $.50
Interest FROM 5/9/05 TO 917105 (PER DIEM - $18.88) - $2,284.48 AND COSTS
Arty's Comm % Due Prothy $1.00
Atty Paid $119.62 Other Costs
Plaintiff Paid
Date: MAY 16, 2005
CURTIS R. LONG
(Seal)
prothoa Q ~ /
~. ~ /l/2-cE.
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
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PHELAN HALLINAN & SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PIDLADELPIDA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
W ASIDNGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
ROBERT E. MOSES
NO. 05-1547
Defendant(s).
CERTIFICATION
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
o an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
J
WASHINGTON MUTUAL BANK, FA
CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
v.
ROBERT E. MOSES
CIVIL DIVISION
Defendant(s).
NO. 05-1547
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by its attorney, DANIEL G.
SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,454 SHED ROAD, NEWVILLE, P A
17241 .
I. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, PA 17241
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
p
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
454 SHED ROAD
NEWVILLE, PA 17241
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
Commonwealth of Pennsylvania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Mav 9. 2005
DATE
"
W ASIDNGTON MUTUAL BANK, FA
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
ROBERT E. MOSES
CIVIL DIVISION
Defendant(s).
NO. 05-1547
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
WASHINGTON MUTUAL BANK. FA, Plaintiff in the above action, by its attorney, DANIEL G.
SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,454 SHED ROAD, NEWVILLE, PA
17241 .
I. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, P A 17241
2. Name and address of Defendant(s) in thejudgmenl:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
,
1
WASHINGTON MUTUAL BANK, FA
Plaintiff,
CUMBERLAND COUNTY
v.
No. 05-1547
ROBERT E. MOSES
Defendant(s).
May 9,2005
TO: ROBERT E. MOSES
454 SHED ROAD
NEWVILLE, PA 17241
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at. 454 SHED ROAD, NEWVILLE. PA 17241, is scheduled to be
sold at the Sheriffs Sale on SEPTEMBER 7, 2005 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $114,845.32
obtained by WASHINGTON MUTUAL BANK. FA (the mortgagee) against you. In the event the sale
is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
,
,
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out ifthis has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened,
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days ofthe sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7, You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
,
DESCRIPTION
ALL !be following tnIct ofland with !be improwmmts thereon erected lying, being. and $itualc
in Lower Mifflin Township, Cumberland County, Pennsylvania bounded and OOlcribed as
follows, to wit:
BEGJNNJNG al II poiot on !beO:.nter Line ofSbedRoad (f-412) at a common property cOftler of
Lot 116 and Lot tf7 shOWll on tbe Pre1iminaryIFmal Subdivision Plan of Scenic View; thence from
said point of beginning along !be Ccoter Line of Shed R04Id (f -412) by II ctlnoe, curving to lbe
left, having a n\dius 0025.00 feet and an are length of 133.97 reet (with a chord bwina of South
09 degrees 40 minutes 08 seconds East and a cIumI disC_ of \33.02 feet) to a point; thence
continuing 1lI0ng the Center Line of Shed Road (f -412) South 21 dcill=' 28 minutes 40 seconds
Bast, II distance of 26.36 feet to II point at II oommoo property corner of Lot tf7 and Lot #8; Ihence
through Shed Road (t-4\2) and a\ooll Lot # 8 North 82 dcsrees 20 minutes 08 seconds West:. a
distance of 398.62 feet to an iron pin; thence oontinuing along Lot #8 and along Lot 119 South 24
degrees 46 minutes 22 seconds But, a distance of 62 1.0 I feet to an iron pin at a common
property comer of Lot # 7, Lot 119, and Lot # 10; thence along Lot #10 and Lot # II NOIt'th 72
degTees 16 minutes 15 seconds West, adistanoo of575.47 feet to an iron pin at a oommon
property corner of Lot ,. 7 and Lot II 12, thence along Lot #12 North 61 degrees 29 minutes 03
secoods West. II distance f)f 269.9t feet to an iron pin; thence continuing along same South 48
degrees 34 minutes 2\ seconds West, II distlwce of 140.72 feet to an iron pin at a conunon
property comer of Lot #7, Lot #\2 and Lot #13; Ihence along Lot #\3 North 72 degrees 54
rninu<<os 08 seconds West II distance of 424.67 feet to an iron pin at II rommon property comer of
Lot tf7, lands now or funnerly ofJoIm Eo and Vema J. Karns, and lands now or late of Elwood R..
Gutshall, Jr. and n..Yid W. GutsMII; thence along lands now 01' late of Elwood R.. Gutsball Jr and
David W. Gutshall and lands now or Iale of Ray L. and Ann L. BrehI North 23 degrees 44
minutes 42 seconds East, a distance of93.72 feel to an iron pinal lands now or late of Cbarles L.
and Helen R. Bear Sooth 46 des=s 55 minutes 21 ~nds East, a distance of 178.09 feet to an
iron pin at a common property COIlIa" of Lot # 5, LoIIK>, IlIld 101 #7; Ihence along Lot #6 South 49
degrees 24 minutes 21 secoods West, a distance of 89.26 feet to an iron pin; theooe continuing
along Lot #6 south 26 degrees 48 minutes 14 seCOtlds West, II distance of 45.52 feel 10 an iron
pin; thence continuing along Lot #6 South 54 degrees 51 minutes 38 seconds East, a disfanee of
304.28 feel to an iron pin; theooe COIDtinuing along LolII6 and through Shod Road (f -412) south
82 degrees 20 minutes 08 seconds Ea$!, II distance of753.09 feel to a point on the Center Line of
Shed Road, said point being the place of Beginning.
SAID lot conlaining 727,563.8\ square feet or 16.1026 acres gross area, with a nel acreage of
16.6109 acres 10 the Dedicated Ri8lrt-of-way Line_
BEING identified as LoI II 1 as shown on a plan OflOlS prepared for Roland. Inc. by Hoover
Engineering Services, Inc. daled Marcb 30, 2000 and recorded July 25, 2000 in the Ot1ioe of the
Recorder ofo-ts in and fur Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Shed Road, NewVll1e,
Pennsylvania 11241
TITLE TO SAID PREMSlES IS VESTED IN Robert E. Mo$es, by Deed from William L
Molm and SU2lIIlt1C M. Mohn, husband ami wife; dated 7-7-03 and recorded 7-22-ll3 in Deed
Boole 258, page 1l45.
Premises: 454 Shed Road, Newville, PA 17241
;.,.,;
~'"
Dl<:SCRIPTION
ALL the following tnIct of land with the improwmalts thereon erected lying, being, and situate
in Lower Miffiin Township, Cumberland County, Pennsylvania bounded and described as
follows, to wit:
BEGINNING at 8 point 00 the Center Lint of Shed Road (f -412) at a COlt1fl1l)Q property comer of
Lot #6 and Lot #7 shown on the PreliminarylFinai Subdlvision Plan of Soet1ic View; thence from
said point of beginning along thc Colter Line of Shed Road (f-'I12) by a curve, curving to the
left, haviIlg 8 radius of 325,00 ~ and an ate length of 133.97 feel (wit/u ehotd b<:aring of South
09 degrees 4Q minutes OIl ~ East and a ehotd dislance of 133.02 feet) to a point; tben<:e
conUnuing along the c.:nrer Line of Shed Road (f -412) South 21 degrees 28 minutes 40 seconds
Eut, a distance of26.36 feel tl> a poittt at . C01WllOl\ properly comer of Lot #7 and Lot till: thence
through Shed Road (t-412) and oIong Lot It- 8 North 82 degrees 20 minutes OIl seconds West, a
distance of 398.62 feet to an iron pin; thence COlltillt1iug akms; Lot #8 and along Lot #9 South 24
degroes 46 minutes 22 scoonds Bast, a di.slaooe of 621.0 I feet to an iron pin at a oommon
property comer of Lot # 7. Lot #9, and loU 10; l!mlce along Lot #10 and Lot II 11 North 72
degrees 16 minu1c8 15 seconds West, a distance of575.47 feet to an iroo pin at a COIl1IOOn
property cOlller of Lot It 7 and Lot II t2, thence along Lot #12 North 67 degrees 29 minutes 03
seconds West, ulistance of 269.91 feet to an iron pin; thence continuing along same South 48
degrees 34 minutes 21 seconds West, a dillblllCO of 140.72 feet to an iron pin at a =nman
property comer nf Lot #7, Lot #12 and Lot 1113: Iherttc a1nng Lot #13 North 72 de~ 54
minutes 08 _OIlds West. distance of 424.67 feet to an iron pin lit . common property comer nf
Lot 1n,I8ndsoowor limn<<lyofJolm E. and Vema J. Karns, and land$nowor late ofElwoodR.
Gutshall, Ir. and o.Md W. Gutshall; thence along Ianda 1\l)W or late of Elwood R. Gutsball Ir and
David W. Gutshall and lands now or late of Ray L. and Ann L. BrebI NIlftb 23 degrees 44
minutes 42 seconds East, a dis1ance of 93.72 feet to an iron pin at bnds !lOW or late of Charles L.
and Helen Il Bear Soulh 46 de~ 55 minUteS 21 seconds East, a distance of 178.09 fc!tl to an
iron pin at a romn:lOn property comet" of Lot # 5, Lot #6, IlIld ]otll7; thence along Lot #6 South 49
degrees 24 minutes 2 t seoond$ Wes~ a distance of 119.26 feel to an iron pin; thence oontinuing
alnng Lot #6 soulb 26~ 4S mmutes 14 seconds West, a dislaneeof4S.S2 feet toatl iron
pin; thence continuing along Lot #6 South 54 degrees 51 minUteS 38 seconds Bast, a distance of
304.28 feet to an iron pin; thence cootinuiIlg along Lot #6 and through Shed Road (T -412) s"uIb
82 degrees 20 minUteS 08 SO;)(lOd$ East, a diSlall<le of753.09 feet to a point on the Center Line of
Shed Rood, said point being the place of Beginning.
SAID lot containing 727,563.81 squarefeet or 16.7026 acres gross area, with . net acreage of
16.6109 acre. to the Dedieated Right-<:lf-way Line.
BEING identified as Lot # 7 as shown 00 a plan of lotS prepared for Reland, Inc. by Hoover
Engineering Services, Inc. dated Man;h 30, 2000 and recorded July 25, 2000 in the Office of the
Recorder of Deeds in and fOf Cwnberland county, Pet\I1llylvlInia in Plan Book 8 [ at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Shed Road, Newville.
Pennsylvania 17241
1'lTI.E TO SAID PRP.MSlES IS VESTED IN R<:>bert E. Mom;, by Deed livm William L
Mohn and SU2lIIlIIe M. MoOO, huahand and wife, dated 7-7-03 and recorded 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
DESCRIPTION
ALL the following tract of land with. tile improvements thereon erected lying, being. and situate
in Lower Miffiin Township. Cumberland County, Pennsylvania bounded and described as
follows, to wit:
BEGINNING at a point 00 the Center L~ Q{ Shed Road (f -412) at a common property comer of
Lot 1/6 and Lot If7 shown on the PreliminaryJFlnal Sobdlvision 1>lan of Soeoic View; thence from
said point ofbtlginning along the Cciltcr Line Q{ Shed R.oad (T -412) by a curve, CIlf'I'ing to the
left, having a radius of 325.00 feet and an arc length oft33.97 feet (with a chotd beating of South
09 degrees 40 minutes OIl seconds East and a chord dislance 0( 133.02 feet) to a point; thence
continuing along the O:ttter Line of Shed Road (T -412) South 2 t defll"'!$ 28 minutes 4t) seconds
Bast, .. diliIluwe 0( :16,36 fClllto a point at a common property comer of Lot If7 and Lat #8; thence
lbrougb Shed Road (1412) and aloog Lot" 8 North 82 degr= 20 minutes OIl secoods Wes!' a
distance of 398.62 feet to an iron pin; th.ence ooatiIllling along Lot #8 and along Lot #9 South 24
de~ 46 mimrtcs 22 _ds Bast, a distanoe of621.01 feet to an iron pin at a common
JlI'Oll"fly comer of Lot /I. 7, Lot #9, aod Lot /I. 10; thence along Lot tHO and Lot /I. 11 Notth 12
de~ 16 minutes 15 seconds West, a distance ofS7S.47 feet to an iron pin at a C01IUIlQJl
property oomer of loU 7 and Lot /I. 12. thence along Lot #12 North 67 degr= 29 minutes 03
secoods West, adistan<:e of 269.91 feel to an iron pin; thenceoonliDulllll along same SOIIlh48
degrees 34 minutes 21 seoond& West, a distallC>> of 140.12 feet to an iron pin lit a \:OlIlJOOl1
property comer ofLollf7, Lot #12 8lId Lot #13; theooe along Lot #13 North 12 degrees 54
minu~s 08 seconds West a distance of 424.67 fClllto lIIl iron pin at a common property comer of
Lot In, lands now at formerly o( 101m Ii and Vema J. Karns, and lands now or late of Elwood R..
Olltsl1aU, I.. and {)avid W. Gutsl1al1; thence along lands MW or late of Elwood R. 0utsba\1 J. and
David W. Gutsl1aU and lands now or late of Ray L. and Ann t. Brehl North 23 degrees 44
mimJ1es 42 secoods East, a distance of 93.72 feet to an iron pin at lands now or late of Charles L.
and Helen R.. &at SouIh 46 degrees 55 minutes 21 secoods Ellst, a distaMe o( 17&.09 feet to an
iron pin ata common propertycomec of Lot # 5, Lot 1/6, and lot In; thence alOllg Lot #6 Sooth 49
degrees 24 min~te. 2 t _ds West, a distance of 89.26 feet to an iron pin; thellee continuing
along Lot #6 south 26 degree$ 4S minutes 14 seconds West, Il di$lance of 45.52 feet to an iron
pin; thence continuing along Lot 1/6 South 54 degrees 51 minutes 38 seconds East, a distance of
304-U feet to an iron pin; thence continuing along Lot #6 and through Sbed Road (T -412) south
82 degrees 20 minutes 08 Sl:COOds East, a dJslance of 753.09 feet to a point OIl tbe Center L~ of
Shed Road, said point being the place of Beginning.
SAID lot containing 721,563.81 square feet or 16.7026 acres gross area, wi1h. net acreage of
t6.6109 acres to the I:blicaled Right-of-way line.
BEING idctttUlCd as Lot # 7 as shown 00 a plan of lots prepared for Reland. Inc. by Hoover
Bogineering Services, Inc. dated Match 30,2000 lllld recorded July 25, 2000 in the Office (lfthe
Reoorder ofn-ts in and (or Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling kn<lwn and numbered as 454 Sbed Road, Newville,
PelUlsylvania 11241
TITLE TO SAID PREMSlES IS VBSTBD IN R.:>bcti E. M~ by Deed from Willi_ L
MoIm and SIl2tlnIIC M. MOM, busband and wife, dated 7-7.()) and recorded 7..22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
DESCRIPTION
ALL the fullowing tnIcl of land with the improvements tbereon erected lying, being, and $ilUllte
in Lower Miftlin Township, Cumberland County. Pennsylvania bounded and described as
follows, to wit
BEGINNING ala point 00 the Center Line ofShM Road (f-412) al a common property comer of
Lot #6 and Lot If1 shown OIl the PreliminarylFinal SubdIvision Plan of Scenic View; thence from
$llid point ofl>eginning along the Ccotcr Line of Shed Road (f -412) by a curvc. eumng to the
left. having a radius of n5.oo ftet and an arc Ien8th of 133.97 feet (with a chord bearing of South
09 degrees 40 minutes 08 seconds East and a cltord distanoe of 133.62 feet) to a point; thence
continuing along theCalU:rUnc ofSbed Road (f-412) Sooth 21 degrnes 28 minlltCS 40 seconds
East, a distance of 26.36 feet to a point al a common propmy comer of Lot #7 and Lot fI&; thence
through Shed Road (t-412) and along Lot # 8 North 82 degrees 20 minutes 08 seconds West, a
distance of 398.62 feet to an iron pin; thence coatinuitIg atOllS Lot #8 and along Lot #9 South 24
de~ 46 minutes 22 seconds East. a distaooe of 62t .01 feet 10 an iNn pin at a common
JXllllertY comer of Lot # 7. Lot #9, and Lot # 10; tbence along Lot #10 llDd Lot # 11 North 72
degrees 16 minutes IS seconds West, adi&tanceof575A7 feet toM iron pin atacolllmon
property comer of Lot It 7 and Lot # 12, thence along Lot #12 North 67 degrees 29 minutes 03
secoods West, a <listance <)f269.91 feet to an iron pin; thence oontinuing alOll8: same Sooth 48
degrees 34 minutes 21 seoond& WCllt, adi$lADCC of 140.72 feet to lID iron pin at llQ)DUllOtl
property comernfLot#'1, Lot #12 and Lot #13; thencealong Lot #13 North 72 degrees 54
minutes 08 seconds Weal a dislance of 424.67 feet IV III iron pin at a common property comer of
Lot In, bndsoowOt fbrmetlyof1olm E. and VemaJ. Karns, llDdlandsoow or late ofElwoodR.
Gutshall,Ir.1\lid P\l.vid W. Gutshall; lbenoe along lands now or late of Elwood R. Outsball Ir I\lid
David W. Outshallllld lands \\OW or laIe of Ray L.1\lid Ann L. Brehl North 23 degrees 44
minutes 42 seconds East, a distance of93.72 feet to an iron pin at IJmds now or lale of Charles L
and Helen R. Boar South 46 degt'C<< 55 minutes 21 secon<ls EMt, a distance of I 78.W feet to an
iron pin at It common property comer of Lot /I 5, Lot 116, and lot 111; theoce alOllg Lot 116 South 49
degrees 24 minutes 21 seconds West, a distance of 89.26 feet t<> an iron pill; thence continuing
along Lot 116 80uIb 26 ~ 48 minutes 14 seeouds We$!, It dislance of 45.S2 foot to an iron
pin; thence ~ontinu:ing along Lot 116 South 54 dcgNes 51 minutes 38 seconds East, It distance of
304.21l feet to an iron pin; thence cootinuing alOllg Lot 116 and through Sbed Road (f -412) south
82 degreeIl20 minutes OS secoodlJ "'91. a disumoe of753.W feet to a pOint on tbe Center Line of
ShM Road, said point being the place of Beginning.
Si\ID lot containing 727,563.81 squsrc feet or 16.7026 acres gross area, with a net acreage of
16.6109 acres to the Dedicated Right-of-way Line.
BElNO identitied as Lot /I 7 as shown on a plan of IOIS prepared for ReIland, Inc. by Hoover
Engineering Services, Inc. dated Maroh 30. 2000 and recorded July 25, 2000 in the Office of the
Recorder of Deeds in and foc Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling known and mnnbered as 454 Shed Road, Newville,
Penn&ylvania 17241
Tnl.E TO SAID PREMSIES IS VESTED IN lWlxrt E. Mo$es, by Deed from William L
Molm and Suzanne M. Mo1m.1msband I\lid wife. dated 7.7-03 and reccrded 7.2M3 ill Deed
Book 258, page tl4S.
Premises: 454 Shed Road, Newville, P A 17241
DESCRIPTION
ALL the fuUowing tnKll oftand with the impt<l\'eltllmlll drereon erected lying, being, and siltlilte
in Lower Miffiin Township, Cumberland County, Pennsylvania bounded and described as
fullows, to wit:
BEGINNlNG at a point on the Center Line or Sb<:d Road (f -412) at a common property comer of
Lot It(, and Lot Ifl shown on the PreliminarylFinal SubdIvision plan of Scenic View; thence from
$aid pQint ofbeginning along the Center Line of Shed Road (T -412) by a c;urve, ewving to the
left, having a radius or 325.00 feet and an arc lenjlth of133.97 feet (with a chord bearing ofSoutb
09 degrees 40 minut<:s 08 seconds East and a chord discance of 133.02 feet) to a point; theooe
conlinu.ing ebtg the Center Une of Shed Road (T -412) South 21 degrees 28 minutes 40 seconds
&ist, a distatwe of 26.36 feet 10 a point at a common properly comer of Lot fn and Lot #8; thence
through Shed Road (t-412) aDd along Lot If 8 North 82 deer~ 20 minutes 08 secoods W cst, a
distance of 398.62 feet to an iron pin; thetlCe cootinuing along Lot #8 and along LoI #9 SOllth 24
degrees 46 minutes 22 seconds East, a distance of 621.0 I feet to an iron pin at a common
property comer of Lot If 7, Lot 119. and Lot If 10; thence along Lot #10 and Lot If II North 72
degrees 16 minuleS IS seconds West, a distance of 515.47 feet to an iron pin at a common
property comerofLot#7 and Lot # 12. thence along Lot #12 North 67 degrees 29 minutes OJ
secoods West, a distance 0069.91 feet to an iron pin; thence continuing along same Sooth 48
degrees 34 minutes 21 seoond& Wetl:, a distance of 140.72 feet to an iron pin atacommon
property comer ofLotfn, Lot 1#12 and Lot 1#13; thenceebtg1At#t3 North 72 depeeg 54
minutes Oil_owls West a diatance of 424.61 feet to lIll iron pin at a cammon property comer of
Loltn, huIds IlOwor furmerlyof1o/m E. and Vemal. Karns, and laudsnow or late. of Elwood It
Gutshall, Ir. and Do.Yid W. Gublhalt; thence along 1ands now or late of Elwood R. OutsballIr and
David W. Gutshall and 1ands now or late oCRay L. and Ann L. BrehI North 23 degrees 44
minutes 42 seconds East, a distance of 93.12 feet to an iron pin at lands now or latc of Charles L.
and Helen R. Bear South 46 degrees 55 minutes 21 $eCOll<Js East, a distance of 118.09 feet to an
iron pin at a conunon property comer of Lot "' 5, Lot #6, and lollfl; thence along Lot It(, South 49
degrees 24 minuter. 2t seconds West, a distance of 89.26 fcello an iron pin; thence continuing
along Lot 116 south 26 degrees 48 mmutils 14 secoods West, a distance of 45.52 feet to an iron
pin; thence continuing along Lot #6 South 54 degrees 5 I minutes 38 seconds East, a distance of
304.28 feet to an iron pin; thence continuing along LolII6 and through Shed Road (T -411) south
82 degrees 20 minutes 08 seconds &st. a diillanOe <>(753.09 feet to a Jl(>int on the Center Line of
Shed Road, said point being the place of Beginning.
SAID lot containing 121,563.81 square feet or 16.7026 acres gross area, with a nelacreagc of
16.6109 acres to the DediClited Righto()f-way Line.
BEING identified as Lot # 7 as shown on a plan of lots prepared for Rcland. Inc. by HooveT
Bngineering Services, Inc. dati!d Mar(:h 30, 2000 and recorded July 25, 2000 in the Office of tile
Recorder of Deeds in and rO!' Cumberland county. Pennsylvania in Plan Book 81 at Page 93 and
baving thereon erected a residential dwelling known and numbered as 454 Shed Road, Newville,
Pennsylvania 17241
1TI'LE TO SAID PR:RMSlES IS VESTED IN Ro~ E. Mos.:s, by Deed from William L
Mobn and SIl2llIIlle M. Mom, husband and wife, dated 7-1..03 and reoonled 7.22..()3 in Deed
Book 2511, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
DESCRIPTION
ALL the fullowiDg trnct ofl!llld with the impr_lB thereon erected lying, being, and srtuate
in La~ Milllin Township, Cumberl!1lld County, Poonllylvania bounded and described as
follows, to wit
BEGINNING lit II point 00 the Center Line ofSbcdRoad (f-412) lit a common propcrty cOl'f\Cl' of
Lot /If> and Lot #7 shown OIl \be PreliminarylFinal Subdivision l'lan of Scenic View; thence from
$/lid point ofboginning along the Center Line of Shed Rood (T -412) by a C\U"VC, curving to the
left. having II radius of 32SJ)() feet and an are length of 133.97 feet (with a chord ~ of South
09 degrees 40 minutes 08 seconds East and a oI1ord discanoe of 133.02 f~) to a point; thence
continuing a10ng the Center Line of Shed Road (T -412) South 21 degroc:s 28 minutes 40 llOCOnds
East, II distanoe of26.36 feet 10 a point at a common property comer of Lot #7 aod Lat ft; thence
through Shed Road (t-412) and along Lot /I 8 North 82 de8='l20 minutes 08 seconds West, a
distance of 398.62 feel to an iron pin; lhmce ooatinuing aloog Lot ft and along Lot 119 South 24
degroc:s 46 minu\C$ 22 seconds Bast, a di.stance of62t.O 1 feet to llll iron pin at a oommon
property _of Lot # 7, Lot 1/9, and Lot # 10; thence along Lot #10 l\lld Lot # II Nor1lt 72
degroc:s 16 minuleS IS seconds West, adistanceof575.47 feel lOan iron pin at a common
property com<< ofIM /I 7 ancl Lot II 12, theru:e along Lot #12 N<l<!h 67 dellfOCS 29 minutes 03
seooods West, a distan<;e 0069.9\ feet: 10 an iron pin; thence continuing llloog same South 48
degrees 34 minutes 21 sc:conds West, a di.stance of 140. n fcellO an iron pin lit II common
property comer of Lot #7, Lot #12 and Lot #13; theDC'utong lot #13 North 72 degrwl54
minutes 08 seconds West a distance of 424.67 feet to lI1l iron pin lit a oommon property comer of
Lot #7, lands now or lIlrIn<<ly of 101m R. and Vema I. Karns, and lauds now or late of Elwood R.
Gul$hall, Ir. ancl OIlvid W. Gutslta11; thence along lands now or late of Elwood R. Gutshall Ir and
David W. Gutshall 8IId lauds !lOW 01' late of Ray L. aod Ann L. Brehl North 23 degl-ees 44
minutes 42 secoods East, a distance of 93.72 feet to 811 iron pin at lands now or late of Charles L.
and Helen R. Bear South 46 delll'eeIl 55 minutes 21 seooods Easl, a dlslaMe of 17&.09 feet: to an
iron pin at a oommon property comer ofLat /I 5, Lot /If" llI1d lot #7; thence aloog Lot /If, South 49
degrees 24 minutes 21 _ds West, a dlstanec of 89.26 teet to an iron pin; thence oontinuing
along Lat /If, soulb 26 d(!gree$ 48 min\lles t4 secoodis West, a dls1ance of 45.52 feet to an iron
pin; thew:e continuing along Lot #6 South 54 degrees 51 minutes 38 seconds East, a distance of
304.28 feet to an iron pin; thence continuing along Lot /If, ancl througll Shed Road (T -412) south
82 degJ:eeIl20 minutes 08 sccoods East, a distlInce of753.09 feel to a point on the Center Line of
Shed Road, said point being \be place of Beginning.
SAID lotcontainins 727.563.81 square teetoc 16.7026_ gross area. wilh a net acreage of
t6.6109 acres to the Dedic:aled Right-of-way Une.
BEING ideulified as Lot /I 7 as shown OIl a plan oClots pceparcd tot R.eland, Inc. by Hoover
Ellgineering Services, Inc. ~d Match 30. 2000 and ",corded Iuly 25, 2000 in \be O{fioe of the
Rccorderofn-ls in ancl for Cumberland county, Pennsylvania in Plan Book 81 atPage 93 and
having thereon erected a residential dwelling known aod numbered as 454 Shed Road, Newville.
Pennsylvania 17241
TITLE TO SAID PRRMl'llES IS VBSTBD IN Robert E, Moses, by Deed lWm William L
MoImandSuzanMM. Molin, bUllband ancl wife, dated 7-7-03 andreoonled 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
~
DESCRlmON
ALL the fuUowing tn\<lt onand with the improvcmmus thereon erected lying, being, and situate
in Lower Miffiin Township, Cumberland County, Pennsylvania bounded and described as
follows, lO wit:
BEGINNING at II point on the Omter Line of Shed Road (f.412) at a common property comer of
Lot 116 and Lot tI7 shown on the PreliminarylFinal Subdivision plan of Sceoic View; thence from
said point ofbcginningalorig the Center Line of Shed Road{T -412) by a curve, CW"Ying lO the
Jeft, having a radius of 325.00 feet and an are \cnsthof133.97 feet (with a chotd bearing of South
09 degrees 40 minutes 08 seconds East and a cI10nl dislanc:e of 133.02 feet) to a point; thence
continuing along the Caller Line of Shed Road (T -412) South 21 degrocs 28 minutes 40 secoods
wI, a distance of 26.36 feet to a point alII common property comer of Lot tI7 and Lot #8; thence
through Shed R.oad (t-412) aDd along Lot # 8 North 82 degrees 20 minutes 08 seconds West. a
distance of 398.62 feel to an iron pin; thence eontinuing along Lot #8 and along Lot /19 South 24
degrees 46 minutes 22 seconds Bast, a distance of 62t .0 \ feet to an iron pin al a common
property oomer of Lot # 7,Lot 119, and Lot # \0; tbencealong Lot #10 and Lot # 11 North 72
degrees \6 minutes 15 seconds West, adlstanceof515.41 fcellO l\Il iron pin at a common
property corner of Lot 1F7 and Lot II 12, thence aIoog Lot 1112 North 67 dcgrocs 29 minutes 03
seconds West, a distance of 269.91 feet. to an iron pin; thence continuing along same South 48
degrees 34 minutes 21 seoondlI West, II di8t>lDCCl of 140.72 feel to an iron pin at a common
property comer afLot tI7, Lot flI12 and Lottl13; tI1erx>>alongLotl/'t3 North 72degr<<s 54
minutes 08 _onds West 8 distance of 424.67 feet to 1m iroo pin at a common property comer of
Lottl7,lartdsoowortbnncrlyofJo/m Rand Vema]. K.8ms,and \lmd$oow or late ofmwood R..
Gutshall, Jr. and David W. GUlshalI; thence along lands now or late of Elwood R. Gutshall ]r and
David W. Gutsha1l8lld lands now or late arRay L. and Ann L. BrebI North 23 degrees 44
millUtes42 seconds Bast, a distanceof93.n feet lO an iron pin at lands now or lale afChaeles L-
and Helen R. Bear South 46 degrees 55 minUtes 21 seconds WI, a distance of 178.09 feet to an
iron pin at a oommon property oomer ofl..ot It 5, Lot 110, and 101 tI7; thence along lot 110 South 49
degrees 24 minutes 21_ds West, a distance of 89.26 feet to an iron pin; thenoe continuing
along Lotf/6 south 26degft\eS 48 minutes 14 secoods West, adiSlance of45.52 feet 10 an iron
pin; thence continuing along Lot 110 South 54 degrees 5 I minutes 38 seconds East, a diSlance of
304.28 feet to an iron pin; thence OOlItinuing along Lot #6 and through Sbed Road (T -412) south
82 degrees 20 minUtes 08 secoods &st, a diSlance 0053.09 feet to a poinl on the Center Line of
Shed Road, said point being the place of Beginning.
SAJD lot cootainin,g 727,563.81 BqIl8l"e feet. or 16.7026 acres gross area, with a net acreage of
16.6109 acres to the 1kdicaled Right-of-way Line.
nElNG identified as Lot I/' 7 as sbov.n on a plan of lots prepared for Roland, Inc. by Hoover
Engineering Services, Inc. dared Maroh 30, 2000 and recorded ]uly 25, 2000 in the Office of the
Recorder of Deeds in and fO(' Cumberland county, Pennsylvania in Plan Book 81 at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Shed Road, NewviUe,
Pennsylvania 17241
Tm..E TO SAID PRBMSIBS IS VESTED IN R(lben E. Mom<, by Deed u_ William L
Mobil and Suzanne M. Molin, ltusband and wife, dated 7-7-03 and reconled 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, PA 17241
,.y
~Ji
DESClUI'TION
ALL the following 1nlcI oftand with the imprO'llMlmlt:S Ihcteon erected lying, being, and situate
in Lower Miftlin Township, Cumberland Ccunty, Pennsylvania bounded and de<icribed as
follows, to wit:
BEGINNING at II point on the Center Line ofSht:d Road (1'412) at II COllUOOll property comer of
Lot /16 and Lot #7 shown on the PreliminarylFtnal Subdivision Plan of Scenic View; thence !Tom
saidpoinlof~alanll theCcmcr Line of Shed Rood (1'-412) by II curve., curving to !be
left, having II radius of lZS.oo feet and an arc length of 133.97 feet (with II chord bearing of Sooth
09 degrees 4() minutes 08 seconds East and a chord dislan<:e of 133.Q2 feet) to a point; thence
continuing along the Calter Line GfSbcd Road (1'-412) South 21 degrees 28 minutes 40 seamds
East, lldistanoc:of26.36 feet 10 II point at a _ property comer of Lot #7 and Lot #8; 1ltcnce
lhrougb Shed Road (t-412) and aJong Lot 1# 8 North 82 degrees 20 minutes 08 seconds We$t, II
distance af 398.62 feet to an iron pin; thence oootinuinll along Lot #8 and along Lot 119 South 24
degfeC$ 46 minull's 22 acconds Bast, a dis1attoc of 621.0 I feet to an iron pin al a oomrnon
property _afLoI# 7.1.01 #9, andI..otI# 10; thence along LoI#IO and Lot 1# 11 North 72
degrees 16 minutes IS sccOllds WesI., adlstanceof575.47 feet to IIIl iron pin ata common
property oomer ofI..ot # 7 and Lot 1# 12, 1bcnce along Lot #12 North 67 degrees 29 minutes 03
seooods West. a ~ of 269.91 feet 10 an iron pin; thence !lODtinuing along same Sou1lt 48
degrees 34 minutes 21 seoonds West:, II dlstance of 140.72 feet to an iron pin at II <:ammon
property eomer of Lot #7. Lot #12 and Lot #13; thence aIcn1g Lot #13 North 72 degrees 54
minutes 08 accOllds West a distance of 424.67 feet to lilt in)n pin at II COOlt1lOl\ property comer of
Lot #7,Iands_or lbrmeriyof1<lJm E..lltld VemaJ. Kams,lltld lands now or late of Elwood R.
Gul$haU, Jr. and Pavid w. GutshaJI; thence along lands I\OW or late of E1wood R. Oulsball Jr and
David W. GutshaUand lands now or laleofRay L. and AnnL. BrehlNortb 23 degrees 44
minutes 42 seconds East, a distance of93.72 feet to an iron pin at lands now or tate of Charles L.
and Helen It- Bear Sooth 46 dcfll.'Wl5S minutes 21 seconds East, a distance of 178.09 ftel to an
iron pin at a common property corner of Lot 1# 5, Lot /16, llIId lot #7; thence along Lot /16 South 49
degrees 24 minutes 21 seconds West, a distanc<O of 89.26 feet to IIIl iron pin; then<:<: continuing
along Lotf16 sou1lt 26 degrees 48 minutes 14 seconds We$!, adiSlance of45.52 feet to an iron
pin; 1ltence continuing alOQg Lot /16 South 54 degrees S I minutes 38 sectmds East, a distance of
304.211 feet 10 an iron pin; thence cootinuing along Lot tI6 and through Shed Road (1'412) south
82 degrees 20 minutes 08 socoilds East. a ~ of753Jl9 feet to a pQint on thc Center Line of
Shed Road, said point being the place of Beginning.
SAID lot containing 727.563.81 square feet or 16.7026 acres gross area, with a net acreage of
16.6109 acres to the Dedicated lUgbt-<lf-way Line.
BEING identified as Lot /I 7 as shown 00 a plan oflOlS prepared foc Reland, Inc. by Hoover
Engineering Services, Inc. dated M$'Qb 30, 2000 and recQrded July 25, 2000 in the Office of the
Recorder ofDocds in and for Cumbc:rland county, PennsylVllOia in Plan Book 8 I at Page 93 and
having thereon erected a reside:ntial dwelling known and numbered as 454 Sbed Road, Newvillc,
Pennsylvania 17241
TITl.E TO SAID PREMSIES IS VESTED IN IWbc:.1 E. ~ by ~d fr<ll1l William L
Molm and Suzanne M. MOM, btlsballd and wife, dated 7-7433 I\1\d recorded 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
DESCRIPTION
ALL the fuUowing tnIct ofland with Ill<.'> improvemenm thereon erected lying, bcing,lUld .ilUllte
in tAwer Mimin Township, Cumberland County, I'onnllylvania bounded and described as
fullows, to wit:
BEGINNlNG at a poilll 00 the Center Line ofSbed Road (f ..412) at a eom.mon property comer of
Lot /I(, and Lot 111 shown on the PreliminarylFmai Subdivision l'lan of Sceoic View; thence tTom
$llid point ofbqinning along the <:mtcr Line of Shed Road (f..412) by" cut'\'C, curving to the
left. having a radius of32S.00 teet and an ate \c:nsth of133.97 teet (with a chord bearing of South
09 degrcc:s 40 minutes Oll seconds East and a oI1ord dlSllln<:e of 133.02 feet) to a point; thence
continuing along the Center Line of Shed Road (f..4 12) South 2 t degrees 28 minutes 40 se.:onds
East, "dislanoe of 26.36 feet to a point at a common property comer of Lot #1 and Lot ml; thence
througb Shed Road (t..412) aud along Lot (# 8 North 82 degrees 20 minutes 08 seconds West, a
distance of 398.62 feet to an iron pin; thence continuing along Lot tIS and "long Lot #19 South 24
degrees 46 minutes 22 SCCOIlds EaBt, a distance of621.01 Wet to an iron pin at a 00lWl10tl
JlfOPCrIY oomerofLot# 7, Lot #9, and Lot # \0; thence along tAt #10 and Lot # 11 NO<th 72
degrees 16 minulCS 15 seconds West, s distance of 575.47 feet to an iron pin at a oonunon
property c:omer ofLm It 7 and Lot # 12, thence along Lot #12 North 67 degroes 29 minutes 03
seooods West, a distance of 269.91 feet to an iron pin; thence cootinulng along same South 48
degrees 34 minutes 21 seconds West, a di_ of 140.72 feet 10 an iron pin at a =nmon
property comer of Lot #7, Lot #12 and Lot #13; them:e along tAt #13 North 72 de~ 54
minu~s 08 seconds Weill a distance of 424.67 feel 10 lID iroo pin at a cammon property comer of
Lot /f1,lands now or furn:lerly ofJo/m E. and Vema J. Karns, and W\d$ now or late of Elwood It
Gutshall, Jr. and Oavid W. GutllhaIl; thence along lands MW or late of Elwood R. Outsball Jr an<!
David W. Gutshall and lands now or lale of Ray L and Ann L. BrehI North 23 degroes 44
minutes 42 seconds East, a distance of93.72 feel to an iron pin at lands !lOW or late of Charles L
and Helen It Bear Sooth 46 ~_ 55 minUlCS 21 secoods East, a distMce of I 78.{J9 feet III an
iron pin at a common property comet" of Lot # 5, Lot 110, and lot Ifl; thence along Lot 110 Sooth 49
degrees 24 minutes 21 seconds West, a distance of 89.26 feet to SII iron pin; thence oontinuing
along Lotf16 south26~ 48 minutes 14 seconds We$\, . distance of45.52 feel to an iron
pin; thence oolllinuing along Lot 116 South 54 degl"ees 51 minutes 38 seconds East, a distance of
304.2ll feel to an iron pin; thence cootinuing along Lot 116 and through Shed Road (T ..412) south
82 degrees 20 minutes 08 seconds &lat,. distanoe of7S3.09 feet to a point on the Center Line of
Shed Road, said point being the place of Beginning.
SAID lot containing 727,563.81 square teet or 16.7026 acres gross area, with a Detacreage of
16.6109 acres to the Dedicalc:d Right-of-way Line.
BEING identif1ed as Lot # 7 as shown on a plan oflota prepared for Roland, Inc. by Hoover
Engineering Services, Inc. daretl MJ\tch 30, 2000 lllld recorded July 2S, 2000 in the Office of the
Recorder of Deeds in and for Cumberland county, PetltIsylvania in Plan Book 81 at Page 93 and
bllVing thereon erected a residential dwelling known and numbered as 454 Shed Road, Newville,
Pennsylvania 17241
TrI'LE TO SAID PRRMllIES IS VESTED IN Robert E. M~ by D~d !fOOl Willil!lll L
Moho and Suzanne M. Moho, huabarld and wife, dated 7.74)3 and recorded 7-22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, P A 17241
~.
DE.'lCIUI'TION
ALL the following tract ofUmd with the ~lS thereon erected lying, being, and situate
in Lower Miffiin Township, Cumberland County, P""""Y1vania bounded and described as
follows, to wit
BEGINNING at 1\ point 00 the Center Lint ofSbtd Road (f ..412) at a common property corner of
Lot It6 and Lot #7 shown on the PreliminaryJFina1 Subdivision plan of Seemc View; thern;c from
$/lid poinl ofboginning along the Ccrttcr Line of Shed Road (f -412) by a ~ curving to \be
left. having a radius of 325.00 feet and an ate length of 133.97 feet (with a chord beating of South
09 degrees 40 minutes 08 soconds East and a oI1ord dislan<:e of 133.02 feet) to a point; \hen(:e
continuing along tbe Catter Line ofSbed Road (T-412) South 21 degrees 28 minutes 4G seconds
East, II distanoe of 26.36 feet to a point at a conumn properly comer of Lot tn and Lot t#l; thence
through Shed Road (t-4t2) and along Lot It 8 North 82 degrees 20 minutes OS seconds West, a
distance of 398.62 feet to an iron pin; theoce ooatinuitlg alObg Lot #8 and along Lot 119 Sooth 24
degrees 46 tninu"'$ 22 seconds Bast, a dislan<:e of 621.01 feet to an iron pin al a common
property comer ofLoI # 7, Lot 119, and Lot # 10; tbeMe along Lot #10 and Lot It II North 72
~ 16 miml1cs 15 seconds West, a distance of575.47 feet to an iron pin at a conuoon
property comer of Lot # 7 and Lot # 12, Ihcncealong Lot #12 North 67 degr= 29 minutes 03
_ds West, a dilllance of 269.91 feet \() an iron piD; tllence continuing along same Sooth 48
~ 34minu1es 21 seconds Weot,adistanceofl4O.n feet to an iron pin lItal;<)DUll(JU
propeny comer of Lot tn, Lot #12 and Lot #13; thenculongLot#13 North 72 degrees 54
minutti 08 _onds West a distanoe of 424.67 feet \Q lID iron pin lit a comIOOIl property comer of
Lot (f7,l$tdsnow or fi:lrmt!rlyofJalm E. and Vernal. Karns, and ilmdsnow or late oflllwood It.
Gutshall, Ir. and n.vid W. GuWIalI; tllence along lands now or late of Elwood R. Gutshall Ir and
n.vid W. Gutshall and lands now or late of Ray L and Ann L. 8rehI North 23 ~ 44
minutes 42 seconds East, a distance of 93.12 feet to an iron pin at lands now Or late of Charles L.
and Helen R. Bear South 46 degrees 55 minutes 21 seeon<l$ East, a distance of 178m feet \() an
iron pin at a ronunon property _ of Lot # 5, Lot iI6, and lot #7; thence along Lot #6 South 49
degteCs 24 minutes 21 seconds West, a distance of 89.26 feel to an iron pin; thenee continuing
along Lot fI6 soulb 26 degr;les 48 minutes 14 seooods West, a disW1ce of 45.52 feet \() an iron
pin; Ihcnce continuing along Lot 116 South 54 degrees 51 minutes 38 seconds East. a distance of
304.28 feet to an iron piD; thenee eootinuing along Lot #6 and through Shed Rood (f -412) south
82 degrees 20 minutes 08 seconds East, a dislanoe of153,09 feel to a pOillt on the Center Lm.; of
Shed Road. said point being the place of Beginning.
Si\ID lot containing 727,563.81 sqllllfC fcetor 16.7026 acres gross area, wilb a tl<lt acreage of
16.6109 acres to the Dedicaled Right-of-way Line.
BEING identified as Lot # 1 as sho\m 00 a plan oflocs prepared for Roland, Inc. by Hoover
Engineering Services, Inc. dated M1Iil)h 30, 2000 lIlId recorded July 25, 2000 in the Office Qfthe
Recorder of Deeds in and for Cumberland county, Pennsylvania in Plan Book: 81 at Page 93 and
having thereon erected a residential dwelling known and numbered as 454 Sbed Road, Newville,
Pennsylvania 17241
TITLE TO SAID PRBMSIES IS VESTED IN R<>b<rt E. Moses, by Deed from William L
Mohnan<! Su2anne M. MOM, husband and wife, dated 7-7-03 and recorded 7.22-03 in Deed
Book: 258, page 1145.
Premises: 454 Shed Road, Newville, PA 17241
;,;
DESCRIPTION
ALL the rouowing tmcl ofland with the impmvmncnm thereon erected lying, being. and situate
in Lower Mifflin Township, Cumberland County, Pennsylvania bounded and described as
fullows, to wit:
BEGINNING at. point on the Center Line ofShcd Road (T -412) at. commotl property comer of
Lot /16 and Lot #1 shown on the Preliminary/Fmal Suhd/vision Plan of Scenic View; thence from
$IUd point ofbeginning along the Center Line of Shed Road (T-4 12) by a <;UI"VC, CW"Ving to the
left, baving a radius of 325.00 feet and an arc length of 133.91 teet (willi a chord beIaring of South
09 degrees 40 minutes 08 seoonds East and a chord dlil1anee of 133.02 feet) to a point; thence
cnntinu.ing a1<:mg the Center Line ofSbed Road (T-412) South 21 degrees 28 minutes 40 seconds
Bast, II dlstanoe of 26.36 feoll to a point at a 00_ propcl1y comer of Lot #7 and Lot fI8; thence
through Shed Rood (t-412) and along loU 8 North 82 degrees 20 minutes 08 secoods West, II.
distance of 398.62 feet to an iron pin; thence 00lltinuing along Lot fI8 and along Lot 119 South 24
degrees 46 minutes 22 seconds East, a distance of 621.0 I fuel to llII iron pin at a common
property comer ofLot#1. Lot #9, and Lot # 10; lhence along Lot #10 and Lot it 11 North 12
degrees 16 minutes 15 s.xonds West, a distance of 575.47 feet to an iron pin at a cammon
property _of Lot II 7 and Lot # t2, theneealottg Lot #12 North 67 degrees 29 minutes 03
seeoods West, a disWtce of 269.91 feet to an iron pin; thence oontinulng along same South 48
degrees 34 minutes 21 seconds Wcst,adlstanee of 140.72 feet to an iron pin at a cammon
property comer of Lot #7, Lotitl2and Lot 1113; tbence along Lot #13 North 72 degrees 54
minutes 08 seconds West a distance of 424.61 feet to tm iron pin at a common property comer of
Lot #7, latldsoowO[ tlmnmyofJohn Rand VemaJ. Karns, and lal1dsoow or late ofElwoodR.
aulllhaU, Jr. w David W. GuIsIWl.; lbence aIottg lands now Q[' late o( Elwood R. (lutsball Jr and
David W. Gutsbl>U llIId lands now or \ale orRay L. and Ann L. BrehI North 23 deil=s 44
minutes 42 seconds East, a distanceof93.72 feet 10 an iron pinal lands now or late of Cbarles L.
and Helen R. Bear South 46 degrees 55 minutes 21 ~ East, II diSlllll<:e of 118.09 feoll to an
iron pin at a common property COI"IlOf" of Lot If 5, Lot /16, llI1d lot ff7; thence along Lot #6 South 49
degrees 24 minutes 21 seconds West, a dista.nee of 119.26 feet to an iron pin; thence cootinulng
along Lot fib south 26 degtllell48 minutes 14 seconds West, II distance of 45.52 feet to an iron
pin; thence continuing along Lot #6 South 54 degrees 51 minutes 38 seconds East, a distaru;e of
304..28 feet to an iron pin; thence continuing along Lot /16 and through Shed Road (T -412) south
82 degrees 20 minutes 08 seconds East, a distance of153.09 feet to a point on the Clll\ter Line of
Shed Road. $lIid point being the plaoe of Beginning.
SAID lot oontaining 727,563.81 square feet or 16.7026 acres gross area, with a not acreage of
t6.6109 acres to the Dedicated Right-of-way Line.
BEING i<kntified as Lot # 7 as shown on a plan of 1000prqmed for ~Iand, Inc. by Hoover
Engineering Services, /nc. dated Mat;;h 30, 2000 and recorded July 25, 2000 in the Office of the
Recorder of Deeds in and (or Cumberland county, Pennsylvania in Plan Book 8\ at Page 93 and
having thereon ereete<l a residential dwelling known and numbered as 454 Shed Rood, Newville,
PelUlsylvania 17241
TIlLE TO SAID PREMSIES IS VESTED IN ~bcn E. Moses. by Deed from Willmn L
Mohn and SlIZ8IIlIe M. Molm, lma'-d and wife, dated 7-704J3 and recorded 7.22-03 in Deed
Book 258, page 1145.
Premises: 454 Shed Road, Newville, PA 17241
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From ROBERT E. MOSES
(I) You are directed to levy upon the property of the defendant (s)and to selI 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 gamishee(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) Ifproperty ofthe derendant(s) not levied upon an subject to attachment is found in the possession
or anyone other than a named garnishee, you are directed to notify himiher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $114,845.32
L.L. $.50
Interest FROM 5/9/05 TO 9/7/05 (PER DIEM - $18.88) - $2,284.48 AND COSTS
Atty's Cornrn % Due Prothy $1.00
Arty Paid $119.62
Plaintiff Paid
Other Costs
Date: MAY 16,2005
CURTIS R. LONG
(Seal)
prothon~ p ~ ~
'ay. o/)- t1 _. '/],,('1 A
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court 1D No. 62205
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From ROBERT E. MOSES
(I) You are directed to levy upon the property of the defendant (.)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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garoishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $114,845.32
LL $.50
Interest FROM 5/9/05 TO 9/7/05 (PER DIEM - $18.88) - $2,284.48 AND COSTS
Arty's Comm % Due Prothy $1.00
Arty Paid $1 19.62 Other Costs
Plaintiff Paid
Date: MAY 16, 2005
CURTIS R. LONG
(Seal)
prothon~ e ~
~ f2.r--P ~ C9 & ~----------~
Deputy
REQUESTING PARTY:
Narne DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attoroey for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From ROBERT E. MOSES
(I) 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 gamishee(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 $114,845.32 L.L. $.50
Interest FROM 5/9/05 TO 917105 (PER DIEM - $18.88) - $2,284.48 AND COSTS
Atty's Comm % Due Prothy $1.00
Atty Paid $119.62 Other Costs
Plaintiff Paid
Date: MAY t6, 2005
CURTIS R. LONG
(Seal)
pr~th~ P tfm -
'-av. ~o.. ~L~
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
T~;'~-;"~" ..~ ~ ~.~~/ ,,~
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1547 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From ROBERT E. MOSES
(I) 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) thaI: (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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $114,845.32 L.L. $.50
Interest FROM 5/9/05 TO 9/7/05 (PER DIEM - $18.88) - $2,284.48 AND COSTS
Atty's Cornm % Due Prothy $1.00
Atty Paid $119.62 Other Costs
Plaintiff Paid
Date: MAY 16, 2005
CURTIS R. LONG
(Seal)
Prothonotary 2 7"f!:
'-Bv: ~O/)-J? . . -y;1/UY. r----
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
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