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HomeMy WebLinkAbout01-3769 F:\FILES\DA T AFILE\Gendoc.cuA7927. wrilI<:vival Created: 06/13/01 09:33:35 AM .' Revised: 06/13/0109:41:05 AM CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants f( O/-~,-~7 {o 9 C' VI' I NO. 94-5702 CIVIL TERM PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Issue a Writ of Revival of Judgment entered to No. 94-5702 of the Court of Common Pleas of Cumberland County and index it to the judgment index against Richard A. Coon and Elizabeth K. Coon in the amount of $20,000.00 with interest from October 5, 1994 as set forth in the Transcript Judgment. You are directed to return the Writ of Revival to the undersigned for service. MARTSON DEARDORFF WILLIAMS & OTTO By ~ Ivo V. Otto, III, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Dated: June ,5 ,2001 3' 3'5 -- ~"""ffAlW' O,t ~4L/5k ?4 /7o/S ~ ~~ ~~ Q ~<)..)~ :1)-0 ~ "'=""" ="'" 2~ -en C? o G --() ~61 ~.~ ~ -,-- --------- o ~ ~~-" -OC_.:.-' QT' ~ S~ .- I,:,"':: .~ ~~~ '~~2 -.P C; ~ -< c' L;:: ~~~ .-- .~ .- --- .' ,-' to IN THE COURT OF COMMON PLEAS OF ... CAROLINE NOLAN vs. CUMBERLAND C01:JNTY I PENNSYLVANIA CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON NO. 01-3769 CIVIL TERM ~ WRIT OF REVIVAL TO RTrHAFD A ("(Y)N ;mn PT.T7.ARF.'T'H K ("(Y)N' 11"\ HnllnwRrnnk nr; 'TA . r~rl;c::l~. Pll 170n You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO. 94-,707. c-rVTT, TERM ~ The plaintiff claims that the amount due and unpaid is $ $20,000.00 with interest from Octobp.r 5. 1994 You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this writ. If you fail to do so, judgment of revival will be entered. Costs $ S14.50 Pd Deff S15.00 Pd Atty $1. 00 Co. Due ~ ~~ .1 ',- PRO ONO~ Date June 19, 2001 ~- ~ fA)~ .,~ DEPUTY Seal Ivo V. Otto, III, Esa. : Martson Deardorff Williams & Otto Attorney for the Plaintiff Ten East Hi~h Street, Carlisle, PA 17013 ( 717) 243-3341 .. F:\FILES\DA T AFILE\Gendoc.cUI\7927 .appearance . Created: 06/13/01 09:33:35 AM RevISed: 06/13/01 09:41 :20 AM CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants /I 0/. 37 to 9 Civ/t NO. 94-5702 CIVIL TERM PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of CAROLINE NOLAN, Plaintiff in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO BY~.~ lvo V. Otto, III, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Dated: June 1 f5 ,2001 Cl C' .;: '-.,1 '::"\ _../" .i'.._~ U.) .~:: ~ ~,..... '. 5;~~ --- (~,,-.; \,;j :< :""...) CT' .. ., CERTIFICATE OF SERVICE I, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, Pennsylvania, first class mail, postage prepaid, addressed as follows: Richard A. Coon Elizabeth K. Coon 398 East High Street Carlisle, PA 17013 MA~TSON DEARDORFF WILLIAMS & OTTO \, By ~I " Ivo V. Otto, III, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: June 15 , 2001 i._.... c- \.:L,' ....) t.r" SHERIFF'S RETURN - REGULAR CASE NO: 2001-03769 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOLAN CAROLINE VS COON RICHARD A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon COON RICHARD the DEFENDANT , at 0856:00 HOURS, on the 28th day of June , 2001 at 335 HOLLOWBROOK DR CARLISLE, PA 17013 by handing to RICHARD COOK a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 r'~~ R. Thomas Kline 06/29/2001 MDW&O Sworn and Subscribed to before By: me this .:l.jA.A{ day of ~ ..A"-ul A.D. ~{2~~ r thonotary , . , SHERIFF'S RETURN - REGULAR CASE NO: 2001-03769 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOLAN CAROLINE VS COON RICHARD A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon COON ELIZABETH K the DEFENDANT , at 0856:00 HOURS, on the 28th day of June , 2001 at 335 HOLLOWBROOK DR CARLISLE, PA 17013 by handing to RICHARD COON a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r~"<~ R. Thomas Kline 06/29/2001 MDW&O Sworn and Subscribed to before By: me this ...<3-Ut.. day of ~ Jrol u-- (2. YJ~ I ~rothonotary ~ A.D. F:\FILES\DAT AFILE\Gendoc.cur\7927.writ.lIdrg ~ Created: 0511510209:48:13 AM Revised: 06I1J/0201:32:J6PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against Richard A. Coon and Elizabeth K. Coon, Defendants (3) execute against real property owned by Defendants and identified on attached listing Amount due $15,000.00 Interest to June 11,2002* $ 2,156.18 Plus Interest from Date of Filing at $2.67 per day $ Attomey Fees Costs $ 2,000.00 $ * Interest calculated at 6.5% per annum from 10/5/00 to date of filing. B David R. Gallowa l.D. Number 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: June 11,2002 F:\FILES\DAT AFILE\Gendoc.cur\7927-writ.lldrg . Created: 06I06/021l:40:S4AM Revised: O6J1110202:12:47PM 7927,\ WRIT NO. 01-3769 LEG~ DESCRIPTIONS 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 TRACT NO.1: ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the westem line of Reservoir Drive and at the northem line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B,"North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the westem line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 2212 Circle Road, Carlisle, Pennsylvania 17013 TRACT NO.2: ALL THAT CERTAIN piece or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, flk/a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the westem dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the westem dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/k/a Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B 0 0 0 ~ ...........bJ'-~ c f" "'f:J (.) ~ -lQ. ~ ;;:: ~ ::-1 ~ -;C~6':---:t-!'1 --ocr) c= :';:"If"Q Ii:. I ..... mrn z d ~8.-8068 Z.J:J nr-r, '1 B- " zs;; ,19 ~ 0 Cfl, 9,0 0 .<~... ....... co ". ~O -0 ;;.r:..;.j IV ~ I I , i I I rJ ::J: 40 t- I I :'i>~ ~ om ~ ~ 't' ~ ~~~ ~ ?5 r-- '-< '-l ... ... '" ~ ~ :: ... , - -;ft "" . . ... ~ '" , '" F:\fILES\DAT AFJL.E\Oendoc.cur\7927-l1f[ IldrB Created: 06I05I0210:2l:56AM Revised: 06i1 1102 02:1 1:07PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 David R. Galloway, counsel for Caroline Nolen, 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 as described in the attached Exhibit: I. Name and address of owner(s) or reputed owner(s): Name Address Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon, Equitable Owners Janet M. Cook, alk/a Janet M. Shambaugh Legal Owner 1940 Reservoir Dr., Carlisle, Pennsylvania 2212 Circle Rd., Carlisle, Pennsylvania 335 Hollow Brook Dr., Carlisle, P A 17013 335 Hollow Brook Dr., Carlisle, PA 17013 2. Name and address of Defendants in the Judgment: Name Address Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Drive, Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Caroline Nolen Address c/o James Nolen, 4700 E. Reno St., Oklahoma City, OK 73117 4. Name and address of the last record holder of every mortgage of record: Name Address Cendant Mortgage Corporation Wells Fargo Home Mortgage, Inc. Financial Trust Company Commerce Bank/Harrisburg NA 6000 Atrium Way, Mt. Laurel, NJ 08054 P.O. Box 2026, Flint, MI 48501-2026 1415 Ritner Highway, Carlisle, PA 17013 Commercial Mortgage Department, 100 Senate Ave., Camp Hill, PA 17011 5032 Parkway Plaza Blvd., Bldg. 8, Charlotte, NC28217 217 North Middlesex Rd., Carlisle, P A 17013 GreenPoint Mortgage Corp. Janet M. Cook, alk/a Janet M. Shambaugh Legal Owner 5. Name and address of every other person who has any record lien on the property: ~ Address 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 Address Janet M. Cook, alk/a Janet M. Shambaugh 217 North Middlesex Rd., Carlisle, P A 17013 7. Name and address of every other person of whom Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address None. I verify the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4909 relating to unswom falsification to authorities. avid R. Galloway Attomey J.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: June 11,2002 F:\Frr.ES\DAT AFILE\Gendoc.cur\7927-wril.lIdrg Created: 06/06IQ211:40:S4AM Reviled: O6J11!0202:12:47PM 7927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the westem line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northem line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERT AlN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, fIkIa Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14,1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THA T CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the westem dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the westem dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, alkJa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23, 1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B (') 0 ~ 1',,) '--' ~ -n '- :::.:'"1 {BCO c::: r\:i;:!,-_' m :z Z:-.O . :z~ ~Ij~j ~Z I:; .1. !<CJ -';' ::~j~~ .;.:'~:U ~Q ::J: [..,.1 e) 5>g '-f! BIn '-'" ~ - ~ F:\FILES\oA T AFILE\Gcndoc.cun7927-nol.l/drg Created: 05124/02 11:15:22 AM Revised: 06I1Iro202:ll:54PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4,2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly 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 DESCRIPTION ATTACHED). THE LOCATION of the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, P A 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; b. Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; c. Richard A. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, P A 17013, Equitable Owners; and c. Janet M. Cook, aJkJa Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 ilie Sheriff within thirty (30) days after the sale, and distribution ofilie 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 ofilie 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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 ofiliese 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R. Thomas Kline, Sheriff F:\FILES\DAT AFlLE\GeGdoc.cur\'1927-writ. J/drS Crated: 06I06'0Z 1);40:54 AM 1lNIed: 06fJ 1102 02;12:41 PM 7921.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northem line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point atline of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, flk/a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14,1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGlNNlNG at an iron pin located on the westem dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place ofBEG1NNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/k/a Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 aild recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-0508 (') c ;;;::: -ocu !;2g] ZC~ (/).c'":~ ~6 ~o >2 ~ -'~~,1~'li_"]ll'W,-+ C'J N (... c:: z (") -on :...--::1 cti ;TI :,~~;P] ... 1 ~;: (j -.,.' ~T. 90 cjl n -I ?i5 -< -0 :x ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAROLINE NOLAN, Plaintiff (s) From RICHARD A. COON AND ELIZABETH K. COON, 1940 RESERVOIR DR., CARLISLE, PA, 2212 CIRCLE RD., CARLISLE, P A, AND 335 HOLLOW BROOK DR., CARLISLE, P A (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. NO 01-3769 Civil CIVIL ACTION - LAW (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) 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,000.00 L.L. $.50 Interest TO JUNE 11, 2002 (INTEREST CALCULATED AT 6.5% PER ANNUM FROM 10/5/00 TO DATE OF FILING) - $2.67 PER DAY - $2,156.18 Ally's Comm % Ally Paid $103.10 Plaintiff Paid Date: JUNE 11, 2002 Due Prothy $1.00 Other Costs $2,000. ATTY'S FEES CURTIS R. LONG Prothonotary, Civil Division <.....fly: ~O~ ., P. 7J;($)A~~)~ REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: MARTSON DEARDORFF WILLIAMS & OTTO TEN EAST HIGH STREET CARLISLE, P A 17013-3093 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ID No. 87326 F:\FILES\DA TAFILE\Gcndoc.cur\79271-aff. l/nlm Created: 07/08/02 02:15:46 PM Revised: 07/09/0202:40:12 PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3769 CIVIL TERM CIVIL ACTION-LAW RICHARD A. COON and ELIZABETH K. COON, Defendants AFFIDAVIT I, David R. Galloway, Esquire, counsel for the above-named Plaintiff, hereby certify that written notice the sale of real property together with legal descriptions of all tracks, was served upon the following: 1) Janet M. Cook, a/k/a Janet M. Shambaugh; 2) Cendant Mortgage Corporation; 3) Wells Fargo Home Mortgage, Inc.; 4) Financial Trust Company; 5) Commerce BanklHarrisburg N.A.; 6) GreenPoint Mortgage Corp.; 7) Richard A. Coon and Elizabeth K. Coon By regular mail at the addresses set forth in the Affidavit, with the return address of the Plaintiff appearing thereon. There is attached hereto and marked as Exhibit "A," Certificates of Mailing, U.S. Postal Service Form 3817, confirming mailing of each of said persons or entities. A copy of the Notice of Sale together with all legal descriptions, which w served upon each of the persons or entities named above is attached hereto and marke swo.m~, mill .ub1JJ':1;fure roo this ~ day of , 2002. NOTARIAL 8EAL BARBARA S. WII..DAY, Hot8ry Ptlb,,, CarlIle Bolo.. CumbeMnd ~ Mot Comnll8llon ExpIres Feb. 18, 2006 ClI ~ ~ (') ~ ~ .... ~ '" .." ID 0 3 0 ~ . ., ., t 3 1l. .... ~ IT '1:'" 3 ..... !II "- c.> ". . !II !II g ." CD ~ !l- ii Received F,rom: - IT IT .... IT :-' ., a ID ~ "Martson Deardorff williams ID ..... iJ a. ::c Ii 3:. .... ~ :r ..... !!l - ., ~ ~ \Q III 10 East High Street IT :r ., - ~ \Q :I 0. 10 ~ ~ !!, .... en 0 CD . -:J IT ., Carlisle, PA 17013 CD a. '< ID a. 0 ., H\ 0 ii .... ID H\ (Xl (') i w ID ~ One pieCII of ordinary l1'tIIil addre.sed to: 0 0 IT \J\ ., !! ..... Ms. Janet M. Cook/Ms'. Janet otlo ~ .... .... ..... 217 N. Middlesex Road ~ i ..... Carlisle, 17013 g PA R" PS Form 3817, Mar. 1989 . u.S.GPO:'991-D-282,4041251 .~~_._.- --,--~- -, --.. ex if ~ ." f1;I "0 0 .... :3 '" 0 .... . i 0 ~ I I 3 ..... 0 .... I ., :J . .... .... ! IT w IT !II ..... !II CD 3' !l. !II 0 ." - D? .... IT :J iI :-' :3 >c l- ID ,~ 3l: H .a - ::c Ii !'l ~ . .... 0 < ~ \Q III - otlo '" ::c ~ :r ~ (Xl 0\ CD \J\ .... en CD ,~ I CD 0 -:J IT ., .... 0 ., H\ I iJ i .... m H\ '" W 0 IT '" ., It 0\ IT .. \Q & ID H :J n R_ From: Martson Deardorff williams & otto " 10 East High Street Carlisle, PA 17013 j, I" 'I One piece of ard""'rv moll odd...nd to: Conmerce Bank/Harrisburg, N.A. Commecial Mortgage Department 100 Senate Avenue Camp Hill, PA 17011 PS Form 3817, Mar. 1989 Received From: Martson Deardorff Williams & otto 10 East High Street Carlisle, PA 17013 l ! I i One piece of ordinlry meileddr...ed to: Green Point Mortgage Corporation 5032 Parkway Plaza Blvd., Bldg. B Charlotte, NC 28217 -i :J) '" m PS Form 3817, Mar. 1989 . U.S.GPO: 1991.0,282.404125: Ii Exhibit "A" '. ;}l ... 0 n 0 ~ 3 III :3::> :D Co> 1'1 1'1- ~ - I-' .1 n CD - - ..... := 1'1 < :-' Ul ';Jd- rt - 0 to. 3i: I-' I-' ..,..a III ... lD I-' oS! 0 a .. ~ 0 ;:I"l!. ::s ~ ;" ~ ~3 I - "d t:l lB > t>:t ~3 "d III ... 1'1 >!, > III 0 1'1 ...... 0 . - ~ to. ...... ;>;' to. ...... 0 0 ni ...... 1'1 ...... t:l 0- 0 t-h "" 1'1 0& ...... t-h ~ =s~ "" ~, .. III c: I-' in I-' Cl ..... I ~ ~ .. III ~ .;> .. .. 'l' . ~ !i! r I . r I' " ,ti .. -';"" " '" t ~ ~ ~=~ ~ P:\PIlJlS\DA T AI'I1J!I(leodoo.cun7927_11.... . CnIbd: Om4lO2l1:I':2ZAM _: 06/1I10202:II:54PM 7917.1 '. CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. RICHARD A. COON and ELIZABETII K. COON, Defendants () c:> 0 c: N "f1 -o~ t- :-:;j c:: cprn u:: i'~.i"1 ;JJ ~::J:l z~ "T)rn ~z ..'C? t~jc ~CJ " ,~j -c? ~o :x . '.-+1 .;20 :i>g w om ~ ~ -< NO. 01-3769 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4, 2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTIIOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly 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 DESCRIPTION ATTACHED). THE LOCATION of the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, P A 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; Richard A. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, P A 17013, Equitable Owners; and b. c. Exhbibit "B" " .. c. Janet M. Cook. alkJa Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R. Thomas Kline, Sheriff f:\fILIlSII)ATAfILll\Ooadoc."",m7-wriL I'.... ~ _11:40:54AM , . . ......, 06/I11Il211J:J2:47PM 7927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACf NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservorr Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 1 50 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.1, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 5 1, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, flk/a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 '. and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 41, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, alkJa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 liild recorded August 23, 1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife, TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B , " CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. and Mrs, Richard A. Coon 335 Hollow Brook Drive Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO BYNil~~::~fr Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: July 9, 2002 ,-,. C'''".: c,.-' \ ?: ~;\ . ;r" (I) .C;: '.'.,_=l ')CL. .'> C"") o : "- ~ (.'.':' " , " 5 Caroline Nolan VS Richard A. Coon and Elizabeth K. Coon In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3769 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney David Galloway. Sworn and subscribed to before me This q1& day of ~~ 2002, A.D. ~a ~,4Zi Sheriffs Costs: Docketing Surcharge Law Library Prothonotary Mileage Levy Advertising Posting Handbills Share of Bills Poundage Law Journal Patriot News Certified Mail Prothonotary 30.00 50.00 .50 1.00 13.80 45.00 45.00 45.00 25.20 300.00 270.05 171.35 14.23 $1011.13 paid by attorney 08/28/02 ~~~ R. Thomas Kline, Sheriff BY .Jo~ ~--/J, Real E te Deputy l.sV Ck.-- J ~lJV I !f...... ;.79;797 .;..~ r;:::-.--- (QS ~=:>) ~ F:\FILES\DAT AF~\GendDC.CUr\7927-aff.l/dll! Created: 06lOSI0210:21:56AM Revis~J: 06I11/0202:11:07PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM AFFIDAVIT PURSUANT TO Pa. R.c.P. 3129.1 David R. Galloway, counsel for Caroline Nolen, 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 as described in the attached Exhibit: I. Name and address of owner(s) or reputed owner(s): Name Address Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon Richard A. Coon & Elizabeth K. Coon, Equitable Owners Janet M. Cook, a/k/a Janet M. Shambaugh Legal Owner 1940 Reservoir Dr., Carlisle, Pennsylvania 2212 Circle Rd., Carlisle, Pennsylvania 335 Hollow Brook Dr., Carlisle, PA 17013 335 Hollow Brook Dr., Carlisle, PA 17013 2. Name and address of Defendants in the Judgment: Name Address Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Drive, Carlisle, P A 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Caroline Nolen Address c/o James Nolen, 4700 E. Reno St., Oklahoma City, OK 73 117 4. Name and address of the last record holder of every mortgage of record: Name Address . Cendant Mortgage Corporation Wells Fargo Home Mortgage, Inc. Financial Trust Company Commerce BanklHarrisburg N.A. 6000 Atrium Way, Mt. Laurel, NJ 08054 P.O. Box 2026, Flint, M14850l-2026 1415 Ritner Highway, Carlisle, P A 17013 Commercial Mortgage Department, 100 Senate Ave., Camp Hill, PA 17011 5032 Parkway Plaza Blvd., Bldg. 8, Charlotte, NC 28217 217 North Middlesex Rd., Carlisle, PA 17013 GreenPoint Mortgage Corp. Janet M. Cook, alk/a Janet M. Shambaugh Legal Owner 5. Name and address of every other person who has any record lien on the property: Address Name 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 Address Janet M. Cook, alk/a Janet M. Shambaugh 217 North Middlesex Rd., Carlisle, PA 17013 7. Name and address of every other person of whom Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address None. . I verify the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4909 relating to unsworn falsification to authorities. MARTSON DEARDORFF WILLIAMS & OTTO Date: June 11,2002 By David R. Attorne .D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attomeys for Plaintiff F:\FILES\DATAflLE\GendDc.wr\7927-writ.lldrg Created: 06I06I0211:40:S4AM Jlevijed: 06111102 02:12:47 PM 7927.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the westem line of Reservoir Drive and at the northem line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No.3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEINO the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, fIkIa Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and ElizabetIl Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the westem dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on tIle dividing line between Lots 6A and 7 A on tIle hereinafter mentioned Subdivision Plan; tIlence along tIle western dedicated right-of-way line of Hollow Brook Drive, SoutIl29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; tIlence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on tIle dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, SoutIl60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, tIle Place of BEGINNING. BEING Lot No. 7A on tIle Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a/kIa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 and recorded August 23,1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B C?2> ~.::?) ~ ~ . F:\FD...ES\DATAFILE\Gendoc.an\7927.not.lIdr) Created: OSI2410111:1S:22AM Revised: 06I1110202;11:S4PM 7927..1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RlCHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held on September 4, 2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly 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 DESCRlPTION ATTACHED). THE LOCATION of the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, P A 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; b. Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; c. Richard A. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, P A 17013, Equitable Owners; and c. Janet M. Cook, a/k/a Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R. Thomas Kline, Sheriff F:I,FILES\DATAFILE\Gendouur\7927..wril.lldfJ Crattd:~1I:40:S4AM ReWed: 0611 lto:z 02: 12:47 PM 79'11.1 WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the westem line of Reservoir Drive and at the northem line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feetto a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line ofResefVoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No. 3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, flk/a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the westem dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the westem dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feetto an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the westem dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No. 7A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, aIkIa Janet M. Shambaugh, by Articles of Agreement dated April 16,1999 aild recorded August 23, 1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3769 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAROLINE NOLAN, Plaintiff (s) From RICHARD A. COON AND ELIZABETH K. COON, 1940 RESERVOIR DR., CARLISLE, PA, 2212 CIRCLE RD., CARLISLE, PA, AND 335 HOLLOW BROOK DR., CARLISLE, PA (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 $15,000.00 1.1. $.50 Interest TO JUNE 11, 2002 (INTEREST CALCULATED AT 6.5% PER ANNUM FROM 10/5/00 TO DATE OF FILING) - $2.67 PER DAY - $2,156.18 Ally'S Corom % Ally Paid $103.10 Plaintiff Paid Date: JUNE 11, 2002 Due Prothy $1.00 Other Costs $2,000. ATTY'S FEES CURTIS R. LONG Prothonotary, Civil Division "-Jiy: ~~O 2. /i;~D~ REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: MARTSON DEARDORFF WILLIAMS & OTTO TEN EAST HIGH STREET CARLISLE, PA 17013-3093 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ID No. 87326 Real Estate Sale # 80 On June 18, 2002 the sherifflevied upon the defendant's interest in the real property situated in North Middleton Township and Middlesex Township, Cumberland County, P A known and numbered as 1940 Reservoir Drive, Carlisle; 2212 Circle Road, Carlisle; and 335 Hollow Brook Drive, Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 18, 2002 By: J 0 olct Jvui~ Real Estate Deputy ..1' ~ . I-~ ..j ~" " C:! Z/IIn( ~!Lj"~;. ~~,:~" I. j,LI) :..c,v "- '. ~ ''.,~~ " ~ '- F~O - REAL e5TATe 5ALe NO.W--- Writ No. 2001-3769 ClYlITerm Caroline Nolan vs Richard A. Coon and Elizabeth K. Coon Ally: David Galloway DESCRII'!ION TRACT NO. I: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013. ALL THAT CERTAlNtract of land with the improvements thereon erected situate in North Middleton Township; Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a P'lint on the western line of Reservoir Drive and at the northern line of Lot No.3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "8," on said Plan; thence by said Lot No. 26. Block "8," and Lot No. 25. Block "B," North 05 degrees West 133 feet to a point at line of Lot No.6, Block "B"; thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South OS degrees East 133 feel to the northern line of Lot No.3, Block "B," on said Plan, the Piace of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No, 1, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book. 11, Page 51, and being improved with, a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Vlctoria Siar Burger, single man, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Eli~abeth Karen Coon, husband and wife. TO BE SOLD as the property of Richard A, Coon and Elizabeth K, Coon on judgment entered at the above number and term. TAX PARCEL: 29-16-1094-13L TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013. ALL THAT CERTAIN piece or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described u follows, to wit: . BEING Lot No. 62 on the Plan If Creek VieW Heights,Section 'C," as recorded in the Office of he Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the Hest along Circle Road; containing 145 feet along the North along Lot No. 63 on said PlIIl; containing 90 feet along the East along Lot No, 13 on said Plan; the containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate of the Late Judith Nordberg Egger, flk/a Judith O. Nordberg, and Frank C, Egger, widower, by deed dated December 14, 1998 and recorded in the Office of the Recooier of Deeds in and for Cumberland COUDl)', Pennsylvania, in Deed Book 191, Page 441. granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, hu.l,and and wife. TO BE SOLD as the property of Richard A_ Coon and Elizabeth K. Coon on judgment entered at the above number and term. TAX PARCEL NO.: 29-16-1094-342. TRACT NO.3: 335 Hollow Brook Drive, C8diIIo. Pennsylvania 17013. ALL THAT CERTAIN piece or pan:etalillll situate in Middlesex Township, .' ,.'f. Cumberland C"'DIy, Pennsylwnia.. .. . described as follows to wit: BEGINNING at an iron pin located on the'" dedicated right-of-way line of Hollow~"" Drive, said iron pin being located on the IViding line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right- of-way line of HolloW Brook Drive, South 29 degrees 32 nn.s 26 seconds West, 336.21 feet to an iron pin;tbcDce North 2\ degrees 47 minutes 30 secondl West. 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A'on the hereinafter mentioned Subdivision PlaD.j thence along said dividing line, South 60 ~21 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-WIY line of Hollow Brook Drive, the Place of BEGINNING, BEING Lot No.7 A on the Preliminary IDd._Pinal Subdivision Plan of 10.6755 acres for lOOn M~ Knaub, said Plan being recorded in tho Cumberland County Recorder of Deeds Office in Plan Book 47, Page 101). BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which lone! M. Coo~ a1k1a Jauet M. Shambaugh, by Articles 01 Agreement dated April 16, 1999 and tecorded. August 23, 1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable'title unto Richard A, Coon and Elizabeth K, coon.lmsband and wife. TO BE SOLD as the equitable interest ofRicbard A. Coon and Elizabeth K. Coon 01, jOdgmcDt entered at the above number and tenn. TAX PARCEL NO.: 2I-05-0431-050B, 10m , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and~ Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 23rd of July 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #80 Notarial Seal T eny L Russell. NoIatyPublic City Of Harrisburg, Dauphin COUnty My Commission Expnes June 6. 2006 Member, Pennsylvania AssociatiOn Of Notaries My commission expires June 6, 2006 CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 169.60 1.75 171.35 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... r , I PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYLVANIA : 55. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. SO Writ No. 2001-3769 Civil Caroline Nolan vs. Richard A Coon and Elizabeth K. Coon Atty.: David Galloway LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle. Pennsylvania 17013. r7?rJl/AA- Roger M. Morgenthal, Editor " SWORN TO AND SUBSCRlBED before me this 9 day of AUGUST. 2002 AU. 1llAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township. Cumberland County. Pennsylvania. bounded and de- scribed as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No.3. Block wE," as shown on the herein- after mentioned Plan of Lots; thence by the latter. South 85 degrees West 150 feet to a point in the middle of Lot No. 26. Block -B: on said Plan: thence by said Lot No. 26. Block "E." and Lot No. 25. Block wB." North 05 degrees VIlest 133 feeL to a point at line of Lot No.6. Block wB;" thence by the same. North 85 de- grees East 150 feet to a ~oint. on the western line of ReservOIr Drive; thence by the same, South 05 de- grees East 133 feet to the northern line of Lot No.3. Block wB." on said Plan. the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No.1. Block WE." of Noll Manor. as recorded in the Office of the Recorder of Deeds for Cumber- land County In Plan Book II. Page 51. and being improved with a dwelling known as 1940 Reservoir Drive. Carlisle. Pennsylvania. BEING the same property which Victoria Star Burger. single woman. by deed dated March 31. 1989. and recorded March 31. 1989. in the "V """'. NOT. Di. ; LOIS E. SNYDER, No8y NlIIc Car1lsIe Bolo, CurnbeI1and CotIlIy My CoI........., Exp/r8I MllR:h 5. 2ClO5 r~c- EI<TYOFRICHARDA.-COONliNu ELIZABETH K. COON ON JUDG- MENT ENTERED AT TIlE ABOVE NUMBER AND TERM. TAX PARCEL: 29-16-1094-131. TRACf NO.2: 2212 Circle Road. Carlisle, Pennsylvania 17013. ALL THAT CERTAIN piece or par- cel of land situate in North Middleton Township. Cumberland County, Pennsylvania. bounded and de- scribed as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights. Section "c," as recorded in the Office of the Re~ corder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan: containing 90 feet along the East along Lot No. 73 on said Plan: and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg. Executor of the Es- tate of the Late Judith Nordberg Egger. f/k/ a Judith o. Nordberg. and Frank C. Egger, widower, by deed dated December 14, 1998 and recorded in the Office of the Re- corder of Deeds in and for Cum- berland County. Pennsylvania. in Deed Book 191. Page 441. granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS TIlE PROPER- TY OF RlCHARD A. COON AND ELIZABETH K. COON ON JUDG- MENT ENTERED AT THE ABOVE NUMBER AND TERM. TAX PARCEL NO.: 29-16-1094- 342. TRACf NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013. ALL TIlAT CERTAIN piece or par- cel of land situate in Middlesex Township, Carlisle. Cumberland Count,y. Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin lo- cated on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter men- tioned Subdivision Plan; thence along the western dedicated right- of-way line of Hollow Brook Drive. South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West. 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned SubdMsion Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hol- low Brook Drive, the Place of BE- GlNNING. BEING Lot No. 7A on the Pre~ liminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook. a/k/a Janet M. Shambaugh. by Articles of Agree- ment dated April 16, 1999 and re- corded August 23. 1999. In the Of- fice of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622. Page 1090, granted and con- veyed equitable title unto Richard A Coon and Elizabeth K. Coon, hus- band and wife. TO BE SOLD AS THE EQUI- TABLE lNTEREST OF RICHARD A. COON AND ELIZABETIl K. COON ON JUDGMENT ENTERED AT TIlE ABOVE NUMBER AND TERM. TAX PARCEL NO.: 21-05-0431- F:IFILESIDA T AFILEIGendoc.curl 792 7-praecipejudgment CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants REVIVAL OF JUDGMENT DOCKET NO. 01-3769 CIVIL TERM PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants in the amount of $20,000.00, plus interest and costs, for failure to plead to Writ of Revival issued on June 19, 200l. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to the Defendants on December 12,2001, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON DEARDORFF WILLIAMS & OTTO \\ \\ (\ BY'> i)J \l~ Iv~tto, 1II LD. No. 27763 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff ~ f.;'-;:; I L~~~~,; (c3) ~,-'""J (S?) F:\FILESIDA T AFILEIGelldoG_cur\ 7927 .default CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants NO. 01-3769 CIVIL TERM TO: RICHARD A. COON and ELIZABETH K. COON, Defendants DATE OF NOTICE: December 12,2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARDORFF WILLIAMS & OTTO ~\i,~~ By Ivo V. Otto, III 1..0. No. 27763 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RICHARD A. COON and ELIZABETH K. COON, Defendants REVIV AL OF JUDGMENT DOCKET NO. 01-3769 CIVIL TERM COMMONWEAL TH OF PENNSYLVANIA : ss COUNTY OF CUMBERLAND Ivo V. Otto, III, Esquire, being duly sworn accordingly to law, deposes and says that he is an employee of MART SON DEARDORFF WILLIAMS & OTTO, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of Default against the Defendants was mailed to them on December 12, 2001, by certified mail, return receipt requested (copies of the return receipts are attached hereto). "~..... \ .f. . . \J ....j,1 Ivo V. Otto, In: Esquire Sworn to and s~bscribed before this ~ day of February, 2002. (~~~n l(l~ 'S. it )c&lCLL) Notary Public U NOTARIAL SEAL BARBARA S. WILDAY, Notary Public Carlisle Bore., Cumberland County My CO.~!!1ission Expires Feb. 18. 2002 ... II) 't:J Ui Cl Complete items 1 andlor 2 for additional services. II) Complete ilems 3. 4a. and 4b. ~ Cl Print your name and address on the reverse of this form so that we can return this ~ card 10 you. l!! Cl Allach this form to the fronl oflhe mai/piece, or on the back if space does not II) permit. ;; Cl Wrile 'Return Receipt Requested' on the mailpiece below the article number. i: Cl The Return Receipt will show 10 whom the article was delivered and the date o delivered_ 't:J 3. Article Addressed to: .! II) ii E o I.) SENDER: CJ n.J r:[J fT1 CJ r-'I fT1 ....... Postage $ Certified Fee ....... ru CJ CJ Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) CJ CJ -D CJ Total Postage & Fees $ Recipient's Name (Please Print Clearly) (to be comp Ms. Elizabeth K. Coon /'.' 'S!," !~i: -". '.;" 'r-f' 0 "Box-' 0:" -. ,. - -.' ,. n'" -- -." -. - - '.,~-- 00-- n -- - -: '."<''<:'''' -, -'".. 'j.jj I!fol ow ~rook Drive "c,i)1" siai,; -zv;:;;j" " '.n.. ,- h_" - '_n.h__. moo __.n.hn' -- n_, - - - -.",. - - '-,.,.-, - -, -.,. tar11sle, PA 17013 CJ CJ CJ ....... PS Fur!l1 .3800 Fpbr.lJ.ry'JOOO Sep Revc>r5e for InstructIons I also wish to receive the follow- ing services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery 4a. Article Number 7000 0600 0027 7310 3820 Ms. F,1 i '7:=\hPth K_ Coon 335 Hollow Brook Drive Carlisle, PA 17013 4b. Service Type ./ o Registered E1 Certified o Express Mail 0 Insured o Retum Receipt for Merchandise 0 COD 7. Date of Delivery I .2-1 LJ- () 8. Addressee's Address (Only if requested and fee is paid) PS Form 3811, December 1994 102595-99-8-0223 Domestic Return Receipt <Ii u 'S ~ CD II) c.. 'q; u Q) a: i: ~ ::J a; a: m c Ui ::J .2 ::J o >- ~ c .0 s:; to- I"'- ", cO ", o M ", I"'- Postage $ Certified Fee l"'- N o o ,0 o ..D o Return Receipt Fee (Endorsement Required) Restricted Deliver)' Fee (Endorsement Required) Total postage & Fees $ Rec~t~ Rrch~dri~_~:~~~~~_~~_~~~~:_~~~~::~:::__._______________ -sire<.i:Ajit:-No.;-or-pa-a-OX-No. 0 335 Hollow Brook D!.~Y~.~_~n._~__.__~__n______________~__ -C;iY~;ff~\~~---PA---i7-o13 o o ,0 I"'- P:-. h 111\ ~KOO .....;:;,.brtlJ.f'/ "000 S<>e R:ver:e for Instructions roo ell '0 'jji 0 Complete ~ems 1 ami/or :2 lor add~ional services. ell Complete items 3, 4a, and 4b. ~ 0 Print your name and address on the reverse of this Iorm so that we can return this > card to you. ~ 0 AUach this lorm to the troot of the mailpiece. or on the back if space does not CD permit. s: 0 Write "Return Receipt Requested" on the mailpiece below the amcle number. ... 0 The Return Receipt will show to whom the article was delivered i;!nd the date g delivered. -g 3. Article Addressed to: '&i Mr. Richard A. Coon ~ 335 Hollow Brook Drive g Carlisle, PA 17013 t/) SENDER: I also wish to receive the follow- ing services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery 4a. Article Number 7000 0600 0027 7310 3837 4b. Service Type o Registered o Express Mail o Return Receipt tor Merchandise 7. Date of Deliv g{ertified D Insured DeOD 1/14-0 8. Addressee's Address (Only if requested and fee is paid) GO u 0> .. II) rn Q. Qi u II) a: c :s - & a: c:n c: "in ::s .. .2 ::s o >- .:0: c: ClI .s:: .... PS Form 3811, December 1994 102595-99-8-0223 Domestic Return Receipt CERTIFICATE OF SERVICE I, Jacqueline A. Decker, an authorized agent of Marts on Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Richard A. Coon 335 Hollowbrook Drive Carlisle, P A 17013 Ms. Elizabeth K. Coon 335 Hollowbrook Drive Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO Dated: February 14,2002 ~Jj(~ ~ ~___D; 8 \' )b ~ ::U ~ t F: ~ ~ ~ --( , - - . -- . :.....~ :.>. .-.; c ,- - ..---t , F:IFILESIDA T AFILEIGendoc.curl79271 -aff I/nlm Created: 07/08/02021546 PM Revised: 07/09/020240: 12 PM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3769 CIVIL TERM CIVIL ACTION-LAW RICHARD A. COON and ELIZABETH K. COON, Defendants AFFIDA VIT I, David R. Galloway, Esquire, counsel for the above-named Plaintiff, hereby certify that written notice the sale of real property together with legal descriptions of all tracks, was served upon the following: 1) Janet M. Cook, a/k/a Janet M. Shambaugh; 2) Cendant Mortgage Corporation; 3) Wells Fargo Home Mortgage, Inc.; 4) Financial Trust Company; 5) Commerce Bank/Harrisburg N.A.; 6) GreenPoint Mortgage Corp.; 7) Richard A. Coon and Elizabeth K. Coon By regular mail at the addresses set forth in the Affidavit, with the return address of the Plaintiff appearing thereon. There is attached hereto and marked as Exhibit "A," Certificates of Mailing, U.S. Postal Service Form 3817, confirming mailing of each of said persons or entities. A copy of the Notice of Sale together with all legal descriptions, which wa persons or entities named above is attached hereto and marke By SWO.ffi tp, and SUbc;:;~et ;erore me this .!1:-- day of , 2002. . ~ ) ( a NOTARfAL SEAl BARBARA S. WILDAY, Notary Put.", Carll8le Boro., Cumberland Coun..... My CommIssion expires Feb. 18. 2006 . . , , n \&1 ::~-~~:~~r;I~APfR ['~hi bit A .. " (I) '-n o 3 w <Xl ... :oJ 3: !!! "tl CIl " o , 3 w CD ... -..J :3: rT 0\ o o o 3=>' rT l'1 ...... g () 0 CD :> :J ,"; g ~. rT ~ o ~ ~ l'1 !!l rT ; ~ ~ lQ .. CD ~ ;; () : o [ r") .. '8 ~ l'1 1lI rT ...... o :J 't"' PI g ro I-' CD <Xl CD e ~ ...:; o CD o U\ ob b? t1 I-' ...... l'Jl I-' CD I-' o tr:I 1lI en rT ::r: ...... '0 \.0 3=>' ::r CIl rT l'1 CD CD rT I-' ~ o I-' W :3: 3J ~~!= 1lI ~ ~-<!" ~ ~ till:~ " CD "'CUI en 0. "UI-I g' a ~a'~ ..... i! ~c; ~ '-' C:D~ m :gn l'1 z:!: "' a. ~rn o I ::I Ii ~o /'1'l UI)> n /'1'l -Iz m :!:o ::a )>--t ~z_ g:~ ::!! z(") )>~ ::I-t ~m )> r- :!:"11 ~~ o~ :il? UI- zZ oQ -I ~ ...... I-' I-' ...... ~ t1l In I'rJ I-' ...... ~ '0 . o . ~ ~ I-' '0 I-' ii' en lil I'rJ ~ ~ 1 l.O i' o < 3 g: ~ -2 i ;; ~ I l'1 .. 2" ~ 1lI \.Q CD s: ~ :3: H tJ:I o X N o N 0\ CD CD CD ob CD U1 o I-' I N o N 0\ () I-' 1lI 0 Ii I-' t'l ...... 1lI tIl to I-' rt m , ::r: .....- ~ 'g. I-' CIl ~ rT o l'1 I-' CD W CD rT H :J o . --.. 3: :21 J~c 1lI ~ ~-<!" l'1 ~. till: ~ ft [ ~c ~ o " OUl)> :J a 3JSr- t1 i! ~c;~ C:D CD ~o, n ~ ~~m 0. m, rn o ,,::1 l'1 00 Hl UI)>n Hl -Iz m :!:o ::a )>--t ~z_ m ;;1"11 :D~ n )>~ ::I.... ~m )> r- :!:"11 ~~ o~ :il? UI- zZ oQ -I ~ .....- I-' I-' ...... DI ffi R'> U.S. POSTAL SERVICE CERTIFICATE OF MAILING MA Y BE USED FOR DOMEsnc AND INTERNA TIONAl MAil, DOES NOT '..., - PROVIDE FOR INSURANCE-POSTMASTER . -'" -, Received !'rom: 'Martson Deardorff Williams 10 East High Street Carlisle, PA 17013 ~- i. .,\, J i Ona piaca of ordinary mail addressed to: .' . ~.~L n c:: '. er~ " c:: :D Shamba4.~.... ~:z -"fl"tlr . t _ut 0--.1......:0 -. c::WC(f)......" w-...J ~. .i:i~O~ 6CJ"1 ~;, iJ N :D C"l IT1 Ms. Janet M. Cook/Ms'. Janet M. 217 N. Middlesex Road Carlisle, PA 17013 PS Form 3817. Mar. 1989 . U.S.GPO: 1991.0.282.4041251 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC 'AND INTERNA TlONAl MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: "~(:I I ,-. _ '~; ~'-~,'-"--:,:l,_ c.O#.....<.~.~..I'_....~......~.'..... .-. ~.::,....~~\ ' \ ~ ,"J)~I -,1?':-::'>~"'F'-~"~".p: .; "-..." q~: C-+';c n c:= g.f:A. :r>~ ~... ~ Uit::) ~_-C~' __ C~(I:h""''' u:;-...J ~. .w~051 bCJ"1 ~;, i: N ::0 C"l IT1 Martson Deardorff williams & otto 10 East High Street Carlisle, PA 17013 One piece of ordinery mail addressed to: Commerce Bank/Harrisburg, N.A. Commecial Mortgage Department 100 Senate Avenue Camp Hill, PA 17011 PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Receivad From: Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 , I One pieca of ordinary mail addressed to: Green Point Mortgage Corporation 5032 Parkway Plaza Blvd., Bldg. 8 Charlotte, NC 28217 PS Form 3817, Mar. 1989 . U.S. GPO: 1991.0.282'404125~ ~ Exhibit "A" "U 'V 3: c (J) -n 0 :D ~~iIl (") VJ :::::~ (") ~ CD 0 " < . 3 ll> VJ 1'1-0 ll> CD -gJ'V 1'1 VI . i' 1'1 1'1 .r Orn 0 CD rn C l/I t-' " t-' rt 0. W CD ...l/I.... CD ~ ::Il ~o I-'- {jl ... Om> ~ {jl 0 1-'.... {jl 0 a :Do :-' t-' I-' n~ t-' :::I ~ Z... (II CIl I-' ::J'B CIl (110 ::II 3: 0 IU~ t::I c:D < :Do - ~ ~ 1'1~ CIl >00 "d 0..3 "d ll> z3: rn I ~ :J> ~ tJ> 1'1 ~lJl CD CD 1'1 tJ>= 0.. I::! CD 0 . [ 0 CD ~o ...... 0 0. ...... 1'1 (II)> (') -...J ~ (")$ ........ I-t\ ....zm 0 0= 0 rn 3: 0 :XI ...... t::I O[ ...... ~z -t VJ 1'1 :::1-- UJ ~ ~ -t. ... ~ ~ 1-" rn,"~ I-' ::11:11- (tI I-' Z >)> :ol- 1-" ::!-t c ~ in ~m i;) en ~O " ~ s::~ ~ Il' Fi: .., ~ 0 0)> ~ 0- ... J . In !: '" -,m Z .. 0 PI G) .. ~ zO-SII~bO 06.0$ INnOWl::l lOt'SO lnf" lOLl l::ld'31jI1Hl::lJ o \:ld r 3nl::llSOd 's'n ~ .. . } !' '(J;- '- . ... ~ ---------- .' " " ' - ~ (Qb ~j) ~ F:\Fn.ESIDAT AFILEIGcndoc.curI7927.nol.l/drs . C.wed: OS/241021l:1S:22AM Revised: 06/11/02 02: 11 :S4 PM 7927.1 " CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W RICHARD A. COON and ELIZABETH K. COON, Defendants (") c s: -0 fD rn rn z :"7) -:7 < .- ,.c.... l_ St",:-.; r::C'-; .1> -: zt) bel -~ ~ o f...,) o 'ft :::::l (- c:: -:-.~ .i:~_ NO. 01-3769 CIVIL TERM i:-;-~'j~~ rn c:) -v C:, l-:.g )---' C5~~?' --I )>- :D -< NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129 "."'1""'" ...Jr.... w TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held on September 4,2002 in the COMMISSIONER'S HEARING ROOM, 2nd FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time. THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly 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 DESCRIPTION ATTACHED). THE LOCATION of the properties to be sold are: a. 1940 Reservoir Drive, Carlisle, Pennsylvania; b. 2212 Circle Road, Carlisle, Pennsylvania; and c. 335 Hollow Brook Drive, Carlisle, PA 17013 THE JUDGMENT under or pursuant to which the property is being sold is docketed to: NO. 01-3769 Civil Term, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THESE PROPERTIES ARE: a. Richard A. Coon and Elizabeth K. Coon, 1940 Reservoir Dr., Carlisle, Pennsylvania; Richard A. Coon and Elizabeth K. Coon, 2212 Circle Rd., Carlisle, Pennsylvania; RichardA. Coon and Elizabeth K. Coon, 335 Hollow Brook Dr., Carlisle, PA 17013, Equitable Owners; and b. c. Exhbibit "B" " c. Janet M. Cook, a/k/a Janet M. Shambaugh, 335 Hollow Brook Dr., Carlisle, PA 17013, Legal Owner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, (717) 240-6100. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTIES OR PROPERTY RIGHTS. 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R. Thomas Kline, Sheriff , . F:\PILES\DA T AFlLE\Gcodoc.cur\7927-writ lId'll CteaIelI; 06IIlCW2 II :40:54 AM . Reviled: 0611111I202:12:47 PM 7927.1 , , WRIT NO. 01-3769 LEGAL DESCRIPTIONS TRACT NO.1: 1940 Reservoir Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the western line of Reservoir Drive and at the northern line of Lot No. 3, Block "B," as shown on the hereinafter mentioned Plan of Lots; thence by the latter, South 85 degrees West 150 feet to a point in the middle of Lot No. 26, Block "B," on said Plan; thence by said Lot No. 26, Block "B," and Lot No. 25, Block "B,"North 05 degrees West 133 feetto a point at line of Lot No.6, Block "B;" thence by the same, North 85 degrees East 150 feet to a point on the western line of Reservoir Drive; thence by the same, South 05 degrees East 133 feet to the northern line of Lot No. 3, Block "B," on said Plan, the Place of BEGINNING. AND BEING Lots Nos. 4 and 5 on the Plan No. I, Block "B," of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, Page 51, and being improved with a dwelling known as 1940 Reservoir Drive, Carlisle, Pennsylvania. BEING the same property which Victoria Siar Burger, single woman, by deed dated March 31, 1989, and recorded March 31, 1989, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Deed Book "W," Volume 33, Page 252, granted and conveyed to Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON nIDGMENTENTERED AT THE ABOVE NUMrnER AND TERM TAX PARCEL: 29-16-1094-131 TRACT NO.2: 2212 Circle Road, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 62 on the Plan of Creek View Heights, Section "C," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 25, Page 49; containing 90 feet along the West along Circle Road; containing 145 feet along the North along Lot No. 63 on said Plan; containing 90 feet along the East along Lot No. 73 on said Plan; and containing 145 feet along the South along Lot No. 61 on said Plan of Creek View Heights. BEING the same premises which Erik Nordberg, Executor of the Estate ofthe Late Judith Nordberg Egger, f/k/a Judith O. Nordberg, and Frank C. Egger, widower, by deed dated December 14, 1998 '. and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 191, Page 441, granted and conveyed unto Richard A. Coon and Elizabeth Karen Coon, husband and wife. TO BE SOLD AS THE PROPERTY OF RICHARD A. COON AND ELIZABETH K. COON ON mDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 29-16-1094-342 TRACT NO.3: 335 Hollow Brook Drive, Carlisle, Pennsylvania 17013 ALL THAT CERTAIN piece or parcel ofland situate in Middlesex Township, Carlisle, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at an iron pin located on the western dedicated right-of-way line of Hollow Brook Drive, said iron pin being located on the dividing line between Lots 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along the western dedicated right-of-way line of Hollow Brook Drive, South 29 degrees 32 minutes 26 seconds West, 336.21 feet to an iron pin; thence North 21 degrees 47 minutes 30 seconds West, 538.11 feet to an iron pin located on the dividing line between Lot Nos. 6A and 7 A on the hereinafter mentioned Subdivision Plan; thence along said dividing line, South 60 degrees 27 minutes 34 seconds East, 420.15 feet to an iron pin on the western dedicated right-of-way line of Hollow Brook Drive, the Place of BEGINNING. BEING Lot No.7 A on the Preliminary and Final Subdivision Plan of 10.6755 acres for John M. Knaub, said Plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 47, Page 100. BEING improved with a dwelling house known as 335 Hollow Brook Drive, Carlisle. AND BEING the same property which Janet M. Cook, a!kJa Janet M. Shambaugh, by Articles of Agreement dated Apri116,1999 aild recorded August 23, 1999, in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Miscellaneous Book 622, Page 1090, granted and conveyed equitable title unto Richard A. Coon and Elizabeth K. Coon, husband and wife. TO BE SOLD AS THE EQUITABLE INTEREST OF RICHARD A. COON AND ELIZABETH K. COON ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM TAX PARCEL NO.: 21-05-0431-050B ~ CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. and Mrs. Richard A. Coon 335 Hollow Brook Drive Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO By / i Ju1J L/J t'lWt.A--- NlChole L. Myers 0 Ten East High Street Carlisle, PAl 7013 (717) 243-3341 Dated: July 9, 2002 (~) \,L} ".> ._,~Tt cS ~ (l)J FIFILESIDA T AFlLEIGendoc.curI7927-pra.l/drg Created 07/25/0209:45:52 PM Revised. 08/06102083854 AM 7927.1 CAROLINE NOLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3769 CIVIL TERM CIVIL ACTION-LAW RICHARD A. COON and ELIZABETH K. COON, Defendants PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment entered in the above captioned case satisfied and released. ~ND. EftRD-l.~O . X I . ( / / By - . . DavId R. Galloway I.D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 6, 2002 CERTIFICATE OF SERVICE I, David R. Galloway, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy ofthe foregoing Praecipe to Settle and Discontinue was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Richard A. Coon & Elizabeth K. Coon 335 Hollow Brook Dr. Carlisle, P A 17013 vp;~ Dated: August 6, 2002 C) r<) ~ o ~ ~'~ -c if; lil'-'- ~~S~ ~() ~i.Q j:; ~d \._- -7 ~ -< I.,..; .,.- :::;) t c:r\ (,) ---~