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HomeMy WebLinkAbout02-1619IN RE: TAX SALE OF 2001 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF STAMM'S BAR B Q, INC. aka MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO.: 40-10-0634-025 IN THE COURT OF COMMON pLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,O. 2002 PETITION FOR RULE FOR JUDICIAL SALF AND NOW, comes the Cumberland County Tax Claim Bureau, by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor, and files this Petition for Rule for Judicial Sale, of which the following is a statement: 1. Your Petitioner is the County of Cumberland thrOugh its Tax Claim Bureau, a Bureau created by the Real Estate Tax Sale Law. 72 P.S. §5860.101, et sic. 2. Pursuant to 72 P.S. §5860.610, your Petitioner respectfully represents as follows: Tax claim upon which the property was exposed for sale: 1999 through and including 2000 Cumberland County, Cumberland County Library and South Middleton Township real estate taxes. 1999-00 through and including 2000-01 South Middleton School District real estate taxes. Total amount of claim, including penalty and interest as of date of tax sale: $22,498.41. Neither the owner, his, her, their, or its heirs, successors, assigns, or legal representatives, or any lien creditor, or his, her, their or its heirs, successors or legal representatives, or any other person interested, has caused stay of sale, discharge of tax claim or removal from tax sale. The property was exposed to public sale pursuant to 72 P.S. §5860.601 on: September 27,2001. Before exposing the property to public sale the Bureau fixed 'the upset sale price, pursuant to 27 P.S. §5860.605, which upset price was $ 29,914.20. Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 1 Your Petitioner, the Bureau, was unable to obtain a bid at the public sale sufficient to pay the said upset price. 3. Attached hereto, marked Exhibit "A," and incorporated herein by reference as is fully set forth herein, is a copy of a title report received from a title searcher retained by the Bureau together with a reduced copy of the most recent deed for the subject premises, as of the date of the search. The tax parcel number of the property is 40-10-0634-025. The property is situate in the Township of South Middleton, Cumberland County, Pennsylvania, and is known as 51 Heisers Lane. 4. The names and addresses of all parties holding tax and municipal claims, liens, mortgages, ground rents, charges and estates against the property are as follows: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, Pennsylvania 17013 Delinquent taxes payable through April 30, 2002:$31,717.77. (Includes 1999 County & Township real estate tax through and including 2001-02 School real estate tax) Judy A. Campbell 6 Hope Drive Boiling Springs, PA 17007 2002 County and Township taxes at discount in the amount of $ 1,265.65 South Middleton Township 520 Park D rive Boiling Springs, pA 17007 Current and delinquent South Middleton Township real estate taxes. South Middleton School District 4 Forge Road Boiling Springs, PA 17007 Current and delinquent South Middleton School District real estate taxes. Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 2 Mid Penn Bank 349 Union Street Millersburg, PA 17061 Mortgage dated July 30, 1996 and recorded in Mortgage Book 1335, Page 974 in the amount of $250,000.00. Mortgage dated July 30, 1996 and recorded in Mortgage Book 1335, Page 991 in the amount of $50,000.00. Kevin Benton, CPA 401 E. Louther Street Carlisle, PA 17013 Judgement entered February 21, 1997 in the amount of $5,750.00. Docket #1997-00898 Michael Cherewka 3905 N. Front Street Harrisburg, PA 17110 Judgement entered February 21, 1997 in the amount of $28,750.00. Docket #1997-00899. Anne L. Zikorus 53 Heisers Lane Carlisle, PA 17013 Judgement entered February 21, 1997 in the amount of $402,500.00. Docket #1997-00900 James C. Bartoli, Inc. 325 S. Cemetery Avenue Carlisle, PA 17013 Judgement entered May 20, 1998 in the amount of $805.22. Docket # 1998-2825. PA Department of Revenue Bureau of Compliance Strawberry Square, 9th floor Department 280946 Harrisburg, PA 17128-0946 State Lien entered April 2, 1998 in the amount of $3,712.89. Docket #1998-01812. Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 3 5. The last known address of the owner of the property as set forth in the assessment records of Cumberland County is: Stamm's Bar B Q, Incorporated, 53 Heisers Lane, Carlisle, PA 17013. WHEREFORE, Your Petitioner prays your Honorable Court to grant a rule upon all interested parties, including those listed at paragraphs four and five of the within Petition, to show cause why a decree should not be made that the property be sold, freed and cleared of tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents, pursuant to Section 612 of the Real Estate Tax Sale Law. 72 P.S. §5860.612(a). Respectfully submitted, Date: Stephen D. Tiley, Esquire Assistant Cumberland County Solicitor 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D. # 32318 Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 4 VERIFICATION i, Melissa F. Mixell, Tax Claim Bureau Supervisor, depose and say that the facts set forth in the foregoing Petition for Rule for Judicial Sale are true and correct based partly upon personal knowledge and the remainder upon information and belief; I understand that this Verification is made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Dated: ~///~ Z.- i~elissa F. MixelI,Guper~isor Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 1701 (717) 240-6366 Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 5 '~RVEY P. MURRAY, JR., P.O. BOX 11, SELINSGROVE, PA 17870 .H~QME FAX: 570-374-4761 CUMBERLAND, PERRY, DAUPHIN, JUNIATA, SNYDER, UNION & NORTHUMBERLAND COUNTIES PERRY COUNTY COURT HOUSE (USUALLY THERE ABOUT 12:30 P.M. UNTIL 4 P.M.) PHONE: 717-582-3504 FAX: FAX TO HOME FAX: 570-374-4761 CUMBERLAND COUNTY COURT HOUSE (USUALLY THERE 9 A.M. UNTIL NOON) PHONE: 717-240-6374 and 6373 FAX TO HOME FAX: 570-374-4761 CAN LEAVE BRIEF MESSAGES WITH SEARCHERS AT EITHER COURT HOUSE. PREFER THAT ALL APPLICATIONS BE FAXED. SEARCHING SINCE 1965 AFFILIATED WITH CORNERSTONE LAND TRANSFER, INC., MECHANICSBURG, PA - T TLE INS. FOR: ORDER # OWNER TO BE SEARCHED: PREMISES: GRANTOR (S}: GRANTEE (S): DATE OF DEED: RECORDED: DEED BOOK: Cumberland County Tax Claim Bureau Melissa Mixell Stamm's Bar B Q, Inc. aka Mrs. Stamm's Bar B Q, Inc. Cumberland County, South Middleton Township 51Heisers Lane See Deed Book 129, Page 859 CONSIDERATION: $1.00 COVER DATE: Decemebr 30, 2001 (FROM 12/23/1963 via 21 B 618: $22,000) PURPOSE: PRESENT OWNER LIEN SEARCH (PROM ACTUAL CONSIDERATION) Lee Stamm MORTGAGE(S): $250,000.00; Mrs.~tamm,s Bar B Q, Inc. TO: Mid Penn Bank; dated July 30, 1996; recorded August 12 1 6 ' Book 13 , 99 in Mort a e 35, ~ge 974... closed-e ~. ~+ · . g g ¢%open end)- ndv~, ~ asszgne. $50'OO0'O0;~Mrs. StammCs Bar B Q , Inc. TO: Mid Penn Bank; dated July 30, 1996; recorded August 19, 1996 in Mortgage Book 1335, Page 991. not assign4. JUDGMENT (S): SEE ATTACHED SHEET ++++++++++++++++++ FEDERAL TAX LIEN (S): None TAX CLAIM BUREAU: 1999: SECURED TRANSACTIONS (RECORDER'S OFFICE. LIENS): 11,840.00+ None 2000: 11,079.55+ ASSESSMENR TAX PARCEL# 40-10-0634-025 land: 45,230 bldg: 536,470 DATE: December 31, 200~ PLEASE REM ¢0 TO: HARVEY P. MU~p,A~O' BOX 11, SELINSGROVE, PA 17870 THAK~N_~.~_U_ Cumberland County Tax Claim Burea~ STAMM'~S BAR'BQ, INC. matter continued JUDGMENTS: $5,750.00; Kevin Benton CPA vs. Mrs. Stamm's Bar B Q, Inc.; entered February 21, 1997 to # 1997-00898.~ $28,750.00; Michael Cherewka vs. Mrs. Stamm's Bar B Q Inc.; entered February 21, 1997 to # 1997-00899. ' $402,500.00; Anne L. Zikorus vs. Mrs. stamm's Bar B Q, Inc.; entered February 21, 1997 to # ~997-0.0900. $3,712.89; PA Bureau of Compliance vs. N. Lee Stamm,, Mrs. Stamm's Bar B Q, Inc.; entered April 2, 1998 to# 1~ 1998'01812. $805.22; James C.Bartoli, Inc. vs. Mrs. Stamm's Farm Bar B Q; entered May 20, 1998 to # ~998-.~. Exhibit "A" OPEN-END MORTGAGE AND SECURITY AGREEMENT 'WITH ASSIGNMENT OF LEASES AND RENT,~ T.h?s .MORTGAGE ("Mortgage") mode this ?~-~{,doy ot ~ , 19~6, by on~ between MRS. BTAMM S BAR B Q. INC.. a pennsylvania Corporation, with Ils principal place at business being located at 53 Helser's Lone, Carlisle, Pennsylvania t 70! 3, (herelnotter reterred lo os "MortGo0or,) and MID PENN BANK, o stole chartered bankln0 Institution or0onlzed and exist n under the lows at the Commonwealth at Pennsylvan a, 'with Ils principal place Gal' business located at 349 Union Street, MIIlersburg, Pennsylvania 170~t (hereinafter reterred to os "Moilgogee"). I ,WITNESSETH: WHEREAS, Mortgagee has extended fo Mortgagor, o'certoln $,50,000.00 Loon ("Loan") pursuant fo the terms at o certain Loen Agreement, doted at even dote hereot, by and between Mortgagor and Mortgagee ("Loon AGreement"); and WHEREAS, Mortgagor Is obligated to ModGogee under the Loon os evidenced by o certain Note in the principal amount at $50,000.00, deted at even dote hereof ("Note"). NOW, THEREFORE, In consideration or the Indebtedness evidenced by the Note and tar secu~lng the payment or the Obligations, as hereinafter defined, to Mortgagee and the pertormance ot the covenants and ogreemenls herelnetter expressed, Morlgagor does hereby giant, bargain, sell, pledge, assign, convey end mortgage unto Mortgagee, its successors and assigns, their fee simple estale, right. title and Interest In. lo and under the Mortgaged Premises, as he~elnatler defined. To have and to hold the Mortgaged Premises unto the Mortgagee to ifs own proper use, torever. Mortgagor hereby covenants and agrees with Mortgagee as follows: SECTION 1. FUTURE ADVANCES/OPEN~END ~4ORTGAGE' THIS MORTGAGE IS INTENDED TO BE AN *OPEN-END MORTGAGE* IN ACCORDANCE WITH 42 PA. CON. STAT ANN §§ 8143 AND 8t44 AND IS GIVEN TO SECURE THE OUTSTANDING PRINCIPAL BALANCE OF LOAN ADVANCES MADE IN ACCORDANCE WITH THE TERMS OF THE LOAN AGREEMENT IN THE MAXIMUM PRINCIPAL AMOUNT OF $5D,000.00, TOGETHER WITH ACCRUED AND UNPAID INTEREST ON ALL OTHER SUMS DUE AND OWING UNDER THE TERMS OF THE NOTE, THIS MORTGAGE. AND ANY OTHER LOAN DOCUMENTS, INCLUDING, BUT NOT LIMITED TO, PAYMENT OF TAXES, ASSESSMENTS, MAINTENANCE CHARGES, INSURANCE PREMIUMS OR COSTS INCURRED FOR THE PROTECTION OF THE MORTGAGED PREMISES OR THE LIEN OF THE MORTGAGE, EXPENSES INCURRED BY THE MORTGAGEE BY REASON OF DEFAULT BY THE MORTGAGOR UNDER THE MORTGAGE, OR ADVANCES MADE FOR PURPOSES FOR WHICH THE REVOLVING LOAN WAS ORIGINALLY MADE, WITH EACH SUCH LOAN ADVANCE OR INDEBTEDNESS SECURED BY THIS MORTGAGE AS IF MADE ON THE DATE HEREOF. 991' Exhibit "A" MORTGAGE AND SECURITY AGREEMENT ~WITH ASSIGNMENT OF LEASES AND RENTS b This MORTGAGE ("Mortgage') made this Y and between MRS SfAMM'$ B~D ..... ~ day of__,~/ , 199,~ principal place of bu~ne.'~elng ~ ~ ~:nnl~lv=n~O~r~lon, with ~; er's lane, Call,e, Pen~vanla I lO18, (her~nolter referred to os 'MorfgogoP) and MID PENN BANK, a state chodered banking Imllfullon organized and ex~ng under lhe laws of the Com~nwea~h or Penns~vanla, W~h Is prl~lpal place ol bmlness Iocaled at 849 Union Slreef, MIIlersburg, Pen~ylvanla 17~I (herelnaJter re~erred fo as "Mo~gagee*). ~ITNESSETN~ WHEREAS, Modgagee has extended to Mortgagor, a cedaln 8250,~.~ Loan ('Loan') pu~uanf to the terms of a cedaln Loan Agreement, dated of even date hereor, by and between Mortgagor and Mortgagee ('Loan Agreement.); and WHEREAS, Modgagor Is obligated fo Modgagee under the Loan qs evidenced by a cedaln Note In the Pdncl al a , ("Note") P mounl o~ ~2~ ~ ~ dated at even date hereo~ NOW, THEREFORE, in consideration of the Indebfe~ne~ evidenced by the Note and ~or securing the payment o~ the Obligations, as hereinafter defined, to Mortgagee and the performance o~ the Covenants and agree~nls herelnaOer expressed, Morlgagor does hereby grant, bargain, se~l, pledge, as~gn, convey and mortgage unto Modgagee, Its successors and assigns, their tee simple eslale, right, title and Interest In, fo and under the Modgoged P[eml~s, as he~elnolter dellned. To have and fo hold the Mortgaged Premises unto the Modgogee fo tls own proper u~, ~orever. Mortgagor hereby covenants and agrees with Mortgagee as follows: SECTION 1. ~ All the te~s used In this Modgage shall have the same meaning os u~d In the Note, except os oJhe~lse set [adh below or lofherwlse required by the context herein: (o) ~ - An event or ocouJrence described In R*~ragraph 10 herein. (b) Imgo~l~o~ - All real estale and personal propedy Jax~ aha other taxes and omessmenfs of any kind whatsoever (or payments In lieu thereof), water and sewer rents or charges, and all other govem~nfol charges, and any Interest, cost or penalties related thereto, and charges 1or any 974 Exhibit "A" Tax Parcel No. 40-10-0634-025 THIs DEED, made the 17th day of October, 1995; BETWEEN LEE STAMM a/k/a N..LEE STAMM, of 51 Heisers Lane,_ Carlisle, South Middleton Township, Cumberland County, Pennsylvania, herein designated as the Grantor; ~D MRS. STAMM'S BAR B Q, INC., a Pennsylvania Corporation with it principal place of business located at 53 Helsere Lane, Carlisle, South Middleton Township, Cumberland County, Pennsylvania, herein designated as the Grantee; WITNESs, that the Grantor, for and in consideration of ONE DOLLAR and No Cents ($1.00) lawful money of the United States of America, to the Grantor in hand well and truly paid by the Grantee, at or before the sealing and delivery of these presents, the receipt whereof is hereby acknowledged and the Grantor beingtherewith fully satisfied, does by these presents grant, bargain, sell and convey unto the Grantee, its successors and assigns' forever. AL5 T~AT CERT~.IN tract of land located in South Middleto~ Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BE~I~ at a point on the South side of township Road No. 514, approximately one-quarter of a mile east of the intersection of said Township Road with State Nighway Route No. 34, said beginning point being in line of lands now or formerly of Floyd Weibley; thence by said lands South 17 degrees Nest 70 1/4 perches to a point at line of lands now or formerly of S. Fred Naugle; thence by said lands North 65 1/4 degrees East 58.2 perches to a point; thenc~ by land now or formerly of Roy Weibley, North 17 1/2 degrees West 9.5 perches to a point on the South side of said Township Road; thence by the South sade of said Township Road, North 41 1/2 degrees West 44.8 perches. CONT/%ININ~ 10 acres and 10 perches. BEIN~ improved with a dwelling house, a concrete .block processing building and other buildings. BEING the same property which Walter Weibley and Gladys I. Weibley granted and conveyed to Lee Stamm and Mary F. Stamm by deed dated December 23, 1963 and recorded in the Office of the Recorder Exhibit "A" of Deeds for Cumberland County in Deed Book "B", Volume 21, Page 618. MARy F. STAMM, died on May 17, 1992, thereby vesting the entire fee ownership in her surviving spouse, LEE STAMM. Together with all and singular the buildings, improvements, ways, woods, waters, watercourses, rights, liberties, privileges, hereditamente and appurtenances to Che same belonging or in anyway appertaining; and the reversion and reversions, remainder and remainders, rents, issues and.profits thereof, and of every part and parcel thereof; AND ALSO all the,estate, right, title, interest, use possession, property, claim and demand whatsoever of the Grantor both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with'the appurtenances. To have and to hold all and singular the premises herein described together with the heredttaments and appurtenances unto,the Grantee and to the Grantee.s proper use and benefit forever. AND the Grantor covenants that he does and will specially warrant the lands and premises, hereditaments and appurtenances hereby conveyed. In all references herein to any parties, persons, entities or corporation, the use of any particular gender or the plural or singular number is intended to include the appropriate gender or number as the .text of the within instrument may require. Whenever in this instrument any party shall be designated or referred to by name or general reference, such designation is intended to and shall have the same effect as if the words "heirs, executors, administrators, personal or legal representatives, successors and assigns" had been inserted after each and every such designation. IN WITNESS WHEREOF, the grantor has hereunto set his hand and seal, the day and year first above written. SIGNED SEALED AND DELIVERED in the presence of or Attested by N. LE~ STAMM : ~ iii COMMONWEALTH OF PENNSYLVANIA} COUnTY OF CUMBERLAND} BE IT REMEmBErED, that on October 17th, 1995 before ms came Lee Stamm a/k/a N. Lee Stamm, known to ms (or satisfactorily proven} to he the person whose name is subscribed to the within deed and acknowledged that he executed the same for the,purposes therein contained. / Attor6~ for ~rantees CO~O~ OF P~S~V~A} CO~ OF C~E~ RECO~ED on this ~ ~ day o~ ~ -- A.D. 1995 the ~rder s Office of the said County, in Deed B s is Exhibit "A" ..... s,u,o ..... u,.~o~ See Reverse for Instructions I" ..... /(%.l-~-~~ Complme each se~ion and file in dap ca · w h R~co ~m of Deeds when el) Ihe ~ vatuelcons~eradon s no se fo~h In ~ deed, (2J when Ihe deed is withoul conslderalJon, or by gill or (3) a ax exmmplion is dalmed. A Slat.mom o~ Value ~ no r 5l Hetseg's Lane Carlisle PA 17013 51-53 Ilelser's Lane 606,000~ O0 $. MlddleCon . Carlisle PA 17013 South Middleton Township 40-10-0634-025 $606,000.00 [] Traa$1er to Jnduslrlal Development Agency. Under penallies of law, I declare that ! have examined Ibis Statement, including accompanying Infn,mallon, and Io the best of my knowledge FAIkl]iRE TO CO/VIP LE~HIS-I~'ORM PROPERLY OR ATTACH APPLICABLE DOCUMENTATION MAY RESULT IN ?I~S RE~:ORDEg'S REFUSAL Exhibit "A" IN RE: UPSET TAX SALE OF 2001 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF STAMM'S BAR B Q INCORPORATED a/ida MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO.: 40-10-0634-025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2002- )~1'~ ~,vi[ RULE TO SHOW CAUSE AND NOW, this )5~1~ day of ~:'~.-~ 2002 upon consideration of the within Petition, a Rule to Show Cause is issued upon all interested parties to appear and show cause why a decree should not be made that the property which is the subject of the within Petition be sold freed and cleared of all tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents. Service of this Rule shall be made to all parties listed at paragraphs four and five of the within Petition in the manner provided by Section 611 of the Real Estate Tax Sale Law. 72 P.S. §5860.611. This is not a summons, you are not required to appear before the court, however you must appear if you desire to preserve your right to any interest or value in the real estate which is the subject of this proceeding. If you do not appear you may lose any ownership interest in the property or any right to any lien or other security interest in the property. Rule returnable '~x.~ IO ~ at Cumberland County Pennsylvania. ,2002 at ii~..~ AJvl./P.M in Courtroom Number Courthouse, ~,~house Square, Carlisle, . - IN RE: TAX SALE OF 2001 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF STAMM'S BAR B X INCORPORATED a/Ida MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO.: 40-10-0634-025 ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1619 AND NOW, this 10rn day of June, 2002 after Hearing on the Rule to Show Cause filed pursuant to the Petition for Rule for Judicial Sale of the Cumberland County Tax Claim Bureau, it is Ordered and Decreed that the property which is the subject of the within Petition be sold freed and cleared of all tax and municipal claims, liens, -mortgages, charges and estates, except separately taxed ground rents, to the highest bidder at a sale to be held on July 26, 2002 at 2:00 p.m. in the Courtroom, 2nd Floor, of the Old Courthouse Building of the Cumberland County Courthouse, and that the purchaser at such sale shall take and thereafter have an absolute title to the property free and clear of all tax and municipal claims, mortgages, liens, charges and estates of whatsoever kind, except ground rents, separately taxed. Advertisement of such sale need only be advertised by one (1) insertion in two (2) newspapers of general circulation in Cumberland County, and by one (1) insertion in the Cumberland County Law Journal. Such advertisement shall appear at least thirty (30) days prior to the sale date and shall include the purpose, ~ time, the place and the terms of such sale with a reference to the prior ady. eFds~h: ~.~2 P.S. § 5860.612). Edgar B. Bayley, J. IN RE: UPSET TAX SALE HELD SEPTEMBER 27, 2001 BY THE CUMBERLAND COUNTY TAX CLAIM BUREAU PROPERTY OF: STAMM'S BAR B Q INCORPORATED a/k/a MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO. 40-10-0634-025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1619 CIVIL TERM CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the Rule to Show Cause, pursuant to Order of Court dated April 15, 2002, with its attached Petition was served upon the hereinafter named parties via personal service by the Cumberland County Sheriff's Office, and the Dauphin County Sheriff's Office. Judy A. Campbell 6 Hope Drive Boiling Springs, PA 17007 Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 South Middleton Township 520 Park Drive Boiling Springs, PA 17007 Michael Cherewka 3905 N. Front Street Harrisburg, P A 17110 South Middleton School District 4 Forge Road Boiling Springs, PA 17001 Anne L. Zikorus Stamm 51 Heisers Lane Carlisle, PA 17013 Mid Penn Bank 349 Union Street Millersburg, PA 17061 Lee Stamm 44 E. High Street Carlisle, PA 17013 Kevin Benton, CPA 401 E. Louther Street Carlisle, PA 17013 James C. Bartoli, Inc. 325 S. Cemetary Avenue Carlisle, PA 17013 PA Department of Revenue Bureau of Compliance Strawberry Square, 9th Floor Department 280946 Harrisburg, PA 17128-0946 Dated: June 1 O, 2002 .~/~elis~a F. ~ix~Jl~ '/ ' Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, Pennsylvania 17013 SHERIFF' S RETURN - REGULAR CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPOP~ATED Parcel 40-10-0634-025 CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PETITION was served upon CUMBERLAND COUNTY TAX CLAIM BUREAU the WITNESS , at 0805:00 HOURS, on the 26th day of April at ONE COURTHOUSE SQ , 2002 C~LRLISLE, PA 17013 JULIE KURTZ, STAFF ASST. a true and attested copy of PETITION by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this ~ day of ~ ~/~ 2~ A.D. ; /Prothonotary So Answers: R. Thomas Kline 05/13/2002 //~ Deputy ~erif f ~ SHERIFF'S RETURN - CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM' S BAR B Q INCORPORATED CPL MICHAEL BARRICK REGULAR Parcel 40-10-0634-025 Cumberland County, Pennsylvania, says, the within PETITION CAMPBELL JUDY A Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 1515:00 HOURS, at 6 HOPE DRIVE CARLISLE, PA 17013 JUDY CAMPBELL on the 29th day of April , 2002 by handing to a true and attested copy of PETITION together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 20.14 Sworn and Subscribed to before me this ~ day of ~ 0~;2~ A.D. ! 'Prothonotary So Answers: R. Thomas Kline 05/13/2002 COUNTY OF CUMBERLAND ff eputy S~ff ~ SHERIFF' S RETURN - REGULAR CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM' S BAR B Q INCORPORATED Parcel 40-10-0634-025 RONALD HOOVER Cumberland County, Pennsylvania, says, the within PETITION SOUTH MIDDLETON TOWNSHIP , Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 0859:00 HOURS, on the 26th day of April at 520 PARK DRIVE , 2002 BOILING SPRINGS, PA 17007 SANDY QUICKEL, SECRETARY a true and attested copy of PETITION by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 20.14 Sworn and Subscribed to before me this Y~ day of A.D. ~ ;Prothonotary' ' ' So Answers: R. Thomas Kline 05/13/2002 COUNTY OF CUMBERLAND Deputy Sheriff ' SHERIFF' S RETURN - CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPOP~ATED RONALD HOOVER REGULAR Parcel 40-10-0634-025 Cumberland County, Pennsylvania, says, the within PETITION SOUTH MIDDLETON SCHOOL DIST Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 0927:00 HOURS, at 4 FORGE ROAD BOILING SPRINGS, PA 17007 TINA SNARE, BUSINESS MANAGER a true and attested copy of PETITION on the 26th day of April , 2002 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 20.14 Sworn and Subscribed to before me this ~ day of  e~z~ ~2~3D 2~ A.D. / ; Prothonotary/ ! / So Answers: R. Thomas Kline 05/13/2002 COUNTY OF CUMBERLAND Deputy Sheriff SHERIFF' S RETURN CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPORATED - OUT OF COUNTY Parcel 40-10-0634-025 R. Thomas Kline duly sworn according to law, says, that he made and inquiry for the within named WITNESS MID PENN BANK but was unable to locate Them deputized the sheriff of DAUPHIN serve the within PETITION Sheriff or Deputy Sheriff who being a diligent search and , to wit: in his bailiwick. County, He therefore Pennsylvania, to On June 3rd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 50.00 .00 75.00 06/03/2002 So answers: R: Thomas KilnS- Sheriff of Cun~berland County COUNTY OF CUMBERLAND Sworn and subscribed to before me this ~ day of ~ ~.z, A.D. ! ! ProthonOtary Mary Jane Snydex Real Emate Deputy William T. Tully Solicitor Dauphin County Han'isburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chiefl~uty Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AND NOW:May 14, 2002 RULE TO SHOW CAUSE MID PENN BANK to ANNA KITCHEN, of the original PERSON IN CHARGE RULE TO SHOW CAUSE : UPSET TAX SA3~E OF 2001 : CHEREWKAMICHAEL Sheriff's Return No. 1088-T - -2002 OTHER COUNTY NO. 02-1619 at i:00PM served the within upon by personally handing i true attested copy{ies) and making known to him/her the contents thereof at 349 UNION ST MILLERSBURG, PA 17061-0000 Sworn and subscribed to before me this 28TH f PROTHONOTARY So AI1swers, Sheriff's Costs: $50.00 PD 05/02/2002 RCPT NO 163775 MYLNEK In The Court of Common Pleas of Cumberland County, Pennsylvania Upset Tax Sale of 2001 VS. Stain's Bar B Q Incorporated et al SERVE: Mid Penn Bank NO. 02 1619 civil NOW, April 26, ~ 2002 , I, SHEPJFF OF CUM~E~ COUNTY, PA, do hereby deputize the Sheriff of Bauglain County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriffof Cumberland County, PA Affidavit of Service within ,20 , at o'clock M. served the upon by handing to a and made !(nown to copy of the original So answers, the contents thereof. Sworn and subscribed before me this., day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT SHERIFF'S RETURN - REGULAR CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUMTY TAX CLAIM VS STAMM'S BAR B Q INCORPORATED Parcel 40-10-0634-025 BRIAN BARRICK Cumberland County, Pennsylvania, says, the within PETITION BENTON KEVIN CPA , Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 1450:00 HOURS, on the 29th day of April at 401 EAST LOUTHER STREET , 2002 CARLISLE, PA 17013 KATHY HUNTZINGER, ASST a true and attested copy of PETITION by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this ~ day of ~ ~o 2_~ A.D. · t~rothonotary · So Answers: R. Thomas Kline 05/13/2002 COUNTY OF C~ER__LAND ~ By: ~~· ~~ Deputy She~if f SHERIFF'S R~TURN - OUT OF COUNTY CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAjVLM'S BAR B Q INCORPORATED Parcel 40-10-0634-025 R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named WITNESS , to wit: CHEREWKA MICHAEL but was unable to locate Him deputized the sheriff of DAUPHIN serve the within PETITION in his bailiwick. County, He therefore Pennsylvania, to On June 3rd , 2002 attached return from DAUPHIN Sheriff,s Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 06/03/2002 COUNTY OF CUMBERLAND Sworn and subscribed to before me this ~ ~ day of ~ ~/~ 2~ A.D. ~ ~ Prothonotary this office was in receipt of the So answ_Drs: R. Thomas Kline Sheriff of Cumberland County Mary Jane Snydea: Real Estate Deputy William T. Tully Solicitor Dauphin County H~arrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : UPSET TAX SALE OF 2001 County of Dauphin : CHEREWKA MICHAEL Sheriff' s Return No. 1088-T - -2002 OTHER COUNTY NO. 02-1619 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for CHEREWKA MICHAEL the DEFENDANT named in the within RULE TO SHOW CAUSE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, May 21, 2002 DEFENDANT H~%S NOT LIVED AT 3905 N. FRONT ST., HBG. FOR 3 YEARS. NEED A BETTER ADDRESS. Sworn and subscribed to before me this 21ST day of MAY, 2002 t PROTHONOTARY So Answers, Sheriff of DauPhin County, Pa. By Deputy Sheriff Sheriff's Costs: $50.00 PD 05/02/2002 RCPT NO 163775 SHERIFF' S RETURN - REGULAR CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVA~NIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM' S BAR B Q INCORPORATED Parcel 40-10-0634-025 KENNETH GOSSERT Cumberland County,Pennsylvania, says, the within PETITION ZIKORUS AIqNE L , Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 0920:00 HOURS, on the 1st day of May at 51 HEISERS LANE 2002 CARLISLE, PA 17013 ANNE L ZIKORUS STAMM a true and attested copy of PETITION by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this y ~ day of ~ ~ A.D. ! Prothonotary ~ ' ~ So Answers: R. Thomas Kline 05/13/2002 0oUNTYBy: OF/ D uty SHERIFF'S RETURN - REGULAR CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPOP~ATED Parcel 40-10-0634-025 CPL MICHAEL BARRICK Cumberland County,Pennsylvania, says, the within PETITION JAMES C BARTOLI INC , Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the WITNESS , at 1531:00 HOURS, on the 29th day of April at 325 SOUTH CEMETERY AVENUE , 2002 CARLISLE, PA 17013 JAMES BARTOLI, OWNER a true and attested copy of PETITION by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this ~ ~ day of ~,~, ~ ~ A.D. ! ; grotAonotar~ ' So Answers: R. Thomas Kline 05/13/2002 COUNTY OF CUMBE~LAiqD ,~ // SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERL/LND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPORATED Parcel 40-10-0634-025 R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named WITNESS , to wit: PA DEPARTMENT OF REVENUE BUREAU OF COMPLIANCE but was unable to locate Them deputized the sheriff of DAUPHIN serve the within PETITION in his bailiwick. County, He therefore Pennsylvania, to On June 3rd , 2002 attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 06/03/2002 COUNTY OF CUMBERLAND Sworn and subscribed to before me this Y~L~- day of / ~.?~ A.D. / ~ Prothonotafy l this office was in receipt of the So answers: R. Thomas Kline Sheriff of Cumberland County Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax:(717)255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AI~D NOW:May 2, 2002 RULE TO SHOW CAUSE PA DEPARTMENT OF REVENUE BUREAU OF COMPLIANCE to DEBRA KELLER, SECRETARY of the original : UPSET TAX SALE OF 2001 VS : CHEREWKA MICHAEL Sheriff's Return No. 1088-T - -2002 OTHER COUNTY NO. 02-1619 at 2:30PM served the within upon by personally handing 1 true attested copy(les) RULE TO SHOW CAUSE and making known to him/her the contents thereof at STRAWBERRY SQUARE 9TH FLOOR DEPT 280946 HBG, PA 17101-0000 Sworn and subscribed to before me this 28TH day of MAY, 2002 PROTHONOTARY SO Answers, Sheriff of Dauphin County, Pa. Deputy She~ Sheriff's Costs: $50.00 PD 05/02/2002 RCPT NO 163775 LINCOLN SHERIFF'S RETURN CASE NO: 2002-01619 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUMBERLAND COUNTY TAX CLAIM VS STAMM'S BAR B Q INCORPORATED KENNETH GOSSERT - REGULAR Parcel 40-10-0634-025 Cumberland County, Pennsylvania, says, the within PETITION STAMM'S BAR B Q INCORPORATED Sheriff or Deputy Sheriff of who being duly sworn according to was served upon the RESPONDANT , at 0845:00 HOURS, at 44 EAST HIGH STREET CARLISLE, PA 17013 LEE STAMM on the 1st day of May , 2002 by handing to a true and attested copy of PETITION together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6 00 3 45 00 10 00 00 19 45 Sworn and Subscribed to before me this ~ day of ~ ~ A.D. ~z~othonot ary ~ So Answers: R. Thomas Kline 05/13/2002 CO=T /~De~ty~f~ ~[n The Court of Common Pleas of Cumberland County, Pennsylvania Upset Tax Sale of 2001 VS. St~a~,'s Bar B Q Incorporated et al SERVE: Michael Cherewka NO. 02 1619 civil NOW, April 26, ,2002 , I, SHERIFF OF CUNflBERLAND COUNTY, PA, do hereby deputize the Sheriffof Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service NOW, within ,20 ., at o'clock M. served the upon at by handing to and made !/nown to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20 Sheriff of County, PA COSTS SERVICE IVlILEAGE AFFIDAVIT in The Court of Common Pleas of Cumberland County, Pennsylvania Upset Tax Sale of 2001 VS. Stamp's Bar B Q Incorporated et al SERVE: PA Department of Revenue Bureau of Co'upliance No. 02 1619 civil NOW, April 26, ~2002 , I, SHERrFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within Affidavit of Service ,20 ,at o'clock M. served the upon by handing to a and made !(nown to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20 Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA IN RE: UPSET TAX SALE OF 2001 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF STAMM'S BAR B Q INCORPORATED a/k/a MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO.: 40-10-0634-025 AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'FY, PENNSYLVANIA RULE TO SHOW CAUSE ~-'~'¢) dayof ~ 2002 upon consideration of the within Petition, a Rule to Show Cause is issued upon all interested parties to appear and show cause why a decree should not be made that the property which is the subject of the within Petition be sold freed and cleared of all tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents. Service of this Rule shall be made to all parties listed at paragraphs four and five of the within Petition in the manner provided by Section 611 of the Real Estate Tax Sale Law. 72 P.S. §5860.611. This is not a summons, you are not required to appear before the court, however you must appear if you desire to preserve your right to any interest or value in the real estate which is the subject of this proceeding. If you do not appear you may lose any ownership interest in the property or any right to any lien or other security interest in the property. Rule returnable~,,¢l~ ,/~ ,2002 at);~OA.M./P.M in Courtroom Number ~ at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. [RUE COPY FROM RECORD Testimony wl~ereof, I here unto set my heo0. . L, JI ,,d of said coo. ri_a_ arlisle.. _... _ IN RE: TAX SALE OF 2001 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF STAMM'S BAR B Q, INC. aka MRS. STAMM'S BAR B Q, INC. TAX PARCEL NO.: 40-10-0634~025 IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY, PENNSYLVANIA NO. 2002 - PETITION FOR RULE FOR JUDICIAL SALF AND NOW, comes the Cumberland County Tax Claim Bureau, by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor, and files this Petition for Rule for Judicial Sale, of which the following is a statement: 1. Your Petitioner is the County of Cumberland through its Tax Claim Bureau, a Bureau created by the Real Estate Tax Sale Law. 72 P.S. §5860.101, etsic. 2. Pursuant to 72 P.S. §5860.610, your Petitioner respectfully represents as follows: Tax claim upon which the property was exposed ~or sale: 1999 through and including 2000 Cumberland County, Cumberland County Library and South Middleton Township real estate taxes. 1999-00 through and including 2000-01 South Middleton School District real estate taxes. Total amount of claim, including penalty and interest as of date of tax sale: $22,498.41. Neither the owner, his, her, their, or its heirs, successors, assigns, or legal representatives, or any lien creditor, or his, her, their or its heirs, successors or legal representatives, or any other person interested, has caused stay of sale, discharge of tax claim or removal from tax sale. The property was exposed to public sale pursuant to 72 P.S. [}5860.601 on: September 27,2001. Before exposing the property to public sale the Bureau fixed the upset sale price, pursuant to 27 P.S. §5860.605, which upset price was $ 29,914:20. Petition for Judicial Sale (Parcel No. 40-17-0634-025) Page 1 e. Your Petitioner, the Bureau, was unable to obtain a bid at the public sale sufficient to pay the said upset price. 3. Attached hereto, marked Exhibit ,A," and incorporated herein by reference as is fully set forth herein, is a copy of a title report received from a title searcher retained by the Bureau together with a reduced copy of the most recent deed for the subject premises, as of the date of the search. The tax parcel number of the property is 40-10-0634-025. The property is situate in the Township of South Middleton, Cumberland County, Pennsylvania, and is known as 51 Heisers Lane. 4. The names and addresses of all parties holding tax and municipal claims, liens, mortgages, ground rents, charges and estates against the property are as follows: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, Pennsylvania 17013 Delinquent taxes payable through April 30, 2002: $31,717.77. (Includes 1999 County & Township real estate tax through and including 2001-02 School real estate tax) Judy A. Campbell 6 Hope Drive Soiling Springs, PA 17007 2002 County and Township taxes at discount in the amount of $ 1,265.65 South Middleton Township 520 Park D rive Boiling Springs, PA 17007 Current and delinquent South Middleton Township real estate taxes. South Middleton School District 4 Forge Road Soiling Springs, PA 17007 Current and delinquent South Middleton School District real estate taxes. Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 2 Mid Penn Bank 349 Union Street Millersburg, PA 17061 Mortgage dated July 30, 1996 and recorded in Mortgage Book 1335, Page 974 in the amount of $250,000.00. Mortgage dated July 30, 1996 and recorded in Mortgage Book 1335, Page 991 in the amount of $50,000.00. Kevin Benton, CPA 401 E. Louther Street Carlisle, PA 17013 Judgement entered February 21, 1997 in the amount of $5,750.00. Docket #1997-00898 Michael Cherewka 3905 N. Front Street Harrisburg, PA 17110 Judgement entered February 21, 1997 in the amount of $28,750.00. Docket #1997-00899. Anne L. Zikorus 53 Heisers Lane Carlisle, PA 17013 Judgement entered February 21, 1997 in the amount of $402,500.00. Docket #1997-00900 James C. Bartoli, Inc. 325 S. Cemetery Avenue Carlisle, PA 17013 Judgement entered May 20, 1998 in the amount of $805.22. Docket # 1998-2825. PA Department of Revenue Bureau of Compliance Strawberry Square, 9th floor Department 280946 Harrisburg, PA 17128-0946 State Lien entered April 2, 1998 in the amount of $3,712.89. Docket #1998-01812. Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 3 .5. The last known address of the owner of the property as set forth in the assessment records of Cumberland County is: Stamm's Bar B Q, Incorporated, 53 Heisers Lane, Carlisle, PA 17013. WHEREFORE, Your Petitioner prays your Honorable Court to grant a rule upon all interested parties, including those listed at paragraphs four and five of the within Petition, to show cause why a decree should not be made that the property be sold, freed and cleared of tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents, pursuant to Section 612 of the Real Estate Tax Sale Law. 72 P.S. §5860.612(a). Respectfully submitted, Date: Stephen D. Tiley, Esquire Assistant Cumberland County Solicitor 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D. # 32318 Petition for Judicial Sale (Parcel No. 40-10-0634-025) Page 4 VERIFICATION I, Melissa F. Mixell, Tax Claim Bureau Supervisor, depose and say that the facts set forth in the foregoing Petition for Rule for Judicial Sale are true and correct based partly upon personal knowledge and the remainder upon information and belief; I understand that this Verification is made subject to the penalties of 18 Pa. C.S. t~,4904, relating to unswom falsification to authorities. Dated: ~///¢ Z- '" -~-'-'~/ - ' ' ,//k.>' / - ' Melissa F. Mixell,~uperCisor Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 1701 (717) 240-6366 Petition for Judicial Sale (Parcel No. 40~10-0634-025) Page 5 '\RVEY P. MURRAY, JR., P.O. BOX 1!. SEL!NSGROVE, PA 17870 iHOME FAX: 570-374-4761 CUMBERLAND, PERRY, DAUPHIN, JUNIATA, SNYDER, UNION & NORTHUMBERLAND COUNTIES PERRY COUNTY COURT HOUSE (USUALLY THERE ABOUT 12:30 RM. UNTIL 4 P.M.) PHONE: 717-582-3504 FAX: FAX TO HOME FAX: 570-374-4761 CUMBERLAND COUNTY COURT HOUSE (USUALLY THERE 9 A.M. UNTIL NOON) PHONE: 717-240-6374 and 6373 FAX TO HOME FAX: 570-374-4761 CAN LEAVE BRIEF MESSAGES WITH SEARCHERS AT EITHER COURT HOUSE. PREFER THAT ALLAPPLICATIONS BE FAXED. SEARCHING SINCE 1965 AFFILIATED WITH CORNERSTONE LAND TRANSFER, INC., MECHANICSBURG, PA - TITLE INS. FOR: ORDER # Cumberland County Tax Claim Bureau Melissa Mixell OWNER TO BE SEARCHED: PREMISES: GRANTOR(S): GRANTEE(S): DATE OF DEED: Stamm's Bar B Q, Inc. aka Mrs. Stamm's Bar B Q, Inc. Cumberland County, South Middleton Township 51 Heisers Lane See Deed Book 129, Page 859 RECORDED: DEED BOOK: CONSIDERATION: $1 · O0 COVERDATE: Decemebr 30, 2001 (FROM 12/23/1963 via 21 B 618: $22,000) PURPOSE: PRESENT OWNER LIEN SEARCH (FROM ACTUAL CONSIDERATION) Lee Stature MORTGAGE (S): $250,O00.00; Mrs.¢tamm's Bar B Q, Inc. TO: Mid Penn Bank; dated July 30, 1996; recorded Augus~ 12, 1996 in Mortgagee(open end); Book 1335, Page 974.. closed-ended, not assignA· $50,000.00; Mrs. Stamm's Bar B Q , Inc· TO: Mid Penn Bank; dated July 30, 1996; recorded August 19, 1996 in Mortgage Book 1335, Page 991. not assignS. JUDGMENT (S): SEE ATTACHED SHEET FEDERAL TAX LIEN (S): None TAX CLAIM BUREAU: 1999: 11,840.00+ SECURED TRANSACTIONS (RECORDER'S OFFICE-LIENS): None 2000: 11,079.55+ ASSESSMENT: TAX PARCEL# 40-10-0634-025 land: 45,230 btdg: 536,470 DATE: December 31, 2001 /_ PLEASE REM~_~¢ ¢0 TO: HARVEY P. MUERxRi~A~,O. BOX 11, SELINSGROVE, PA 17870 THANK Y~ Cumberland C~unty Tax Claim STAMM~'S BAR BQ, INC. matter continued JUDGMENTS: $5,750.00; Kevin Benton CPA vs. Mrs. Stamm's Bar B Q, Inc.; February 21, 1997 to # 1997-00898. $28,750.00; Michael Cherewka vs. Mrs. Stamm's Bar B Q, Inc.; February 21, 1997 to # 1997-00899. $402,500.00; Anne L. Zikorus vs. Mrs. Stamm's Bar B Q, Inc.; February 2~, 1997 to # 1997-00900. entered entered entered $3,712.89; PA Bureau of Compliance vs. N. Lee Stamm~, Mrs. Stamm's Bar B Q, Inc.; entered April 2, 1998 to# I~ ~99~-01812. $805.22; James C.Bartoli, Inc. vs. Mrs. Stamm's Farm Bar B Q; entered May 20, 1998 to # 1998-.~. Exhibit "A" OPEN-END MORTGAGE AND SECURITY AGREEMENT ~WITH ASSIGNMENT OF LEASES AND RENT8 This MORTGAGE ('Mortgage') made this '~J~day of 3f~ 1996, by (3nd between MRS. STAMM'B BAR B Q, NC.. a p®nnJylv(3nla iCmp'oraRon, with Its p~lnclp(31 pl(3ce at business being located at53 Helser s Lane. C(3 lisle, Pennsylvania 17013, (hereinafter referred to as'Mo~'Ig(3gor.) and MID PENN BANK, (3 state chartered banking Institution org(3nzed and existing under the laws o the Commonwealt Pennsylvania, 'with lis principal pl(3ce of business located at 349 Union Strehe~l MIIlersburg, Pennsylvania f 7061 (hereinafter referred to as "Moitgogee"), W TNESSETH: WHEREAS, Mortgagee has extended to Mortgagor. o'c~rtoln $50.000.00 Loan ('Loan') pursuant to the terms of (3 certain Loan Agreement, dated of even date hereof, by and between MoUgagor and Mortgagee ("Loan Agreement"): and WHEREAS, Mortgagor Is obllgaled ~o Mortgagee under the Loon as evidenced by a certain Note in the principal amount at $50,000,00 d(3tecl o even date hereol ("Note"). NOW, THEREFORE, In consideration at the indebtedness evidenced by the Note and for securing the payment of the Obligations, os hereinafter defined, fo Mortgagee and the performance of the covenants and agreements hereinafter expressed, Mortgagor does hereby grant, bargain, sell, pledge, assign, convey and mortgage unto Mortgagee, its successors and assigns, lhelr fee simple estate, right, title and Interest in, to and under the Mortgaged Premises, as herelnarter defined, TO have and to hold the Mortgaged Premises unto the Mortgagee to Its own proper use, forever. Mortgagor hereby covenants and agrees with Mortgagee as follows: SECTION 1, FUTURE ADVANCES/OPEN-END MORTGAGF THIS MORTGAGE IS INTENDED TO BE AN "OPEN-END MORTGAGE" IN ACCORDANCE WITH 42 PA. CON, STAT ANN §§ 8143 AND 8144 AND IS GIVEN TO SECURE THE OUTSTANDING PRINCIPAL BALANCE OE LOAN ADVANCES MADE IN ACCORDANCE WITH THE TERMS OF THE LOAN AGREEMENT IN THE MAXIMUM PRINCIPAL AMOUNT OF 850,000.00, TOGETHER WITH ACCRUED AND UNPAID INTEREST ON ALL OTHER SUMS DUE AND OWING UNDER THE TERMS OF TtIE NOTE, THIS MORTGAGE, AND ANY OTHER LOAN DOCUMENTS, iNCLUDING, BUT NOT LIMITED TO. PAYMENT OF TAXES, ASSESSMENTS, MAINTENANCE CHARGES, INSURANCE PREMIUMS OR COSTS INCURRED FOR THE PROTECTION OF THE MORTGAGED PREMISES OR THE LIEN OF THE MORTGAGE, EXPENSES INCURRED BY THE MORTGAGEE BY REASON OF DEFAULT BY THE MORTGAGOR UNDER THE MORTGAGE. OR ADVANCES MADE FOR PURPOSES FOR WHICH THE REVOLVING LOAN WAS ORIGINALLY MADE, WITH EACH SUCH LOAN ADVANCE OR INDEBTEDNESS SECURED BY THiS MORTGAGE AS iF MADE ON THE DATE HEREOF, 991' Exhibit "A" MORTGAGE AND SECURITY AGREEMENT .WITH ASSIGNMENT OF LEASES AND RENT~ This MORTGAGE a~o~o ("Mortgage") made this ~, day of , by end between MRS. STAMM'S BAR B a, INC., ~ P~nnsylva~i ration, wlt~t6; principal place o~ bus,ness being located at 55 Heist's Lone, CQrllsle, Penns~vania ~ 7013, (hereinafter referred to as "Mortgagor~) and MID PENN BANK, a state chadered banking Imlfiutlon organized and existing under the laws of the C~monwealth of Pennsylvania. w~h Its prlncIpa~ place of b~lne~ localed af ~9 Union street, MIIlersburg, Pennsylvania 17~I (hereinafter referred fo as 'Mortgagee.). ~ITNESSETH: WHEREAS, Mortgagee has extended fo Mortgagor, a cedaln $25~,0~.~ Loan ("Loan") pumuanl to the terms of a cedaln Loan Agreement, dated of even date hereo~, by and between Mortgagor and Mortgagee ("Loon Agreement"); and WHEREAS, Moflgagor Is obllgaled fo Moflgagee under the Loan ~s evidenced by a certain Note In the principal am0unf of $2~.~.00, dated or even ~ate boreal ("Note"). NOW, THEREFORE, In consideration of the Indebtedne~ evl~enced by the Note and /or secu~ng the payment o[ the Obligations, as herelna/ter defined, to Mortgagee and the performance of the cove~ants and agreements herelna[ter expressed, Mortgagor does hereby grant, bargain, sell, pledge, assign, convey and mortgage unto Mortgagee, Its successors and a~lgns, their tee ~mple estate, ~lght, title and Interest In, fo and under the Moflgaged P~emlses, as herelnalfer defined, To have and fo hold the Modgaged Premises unto the Morlgagee to Ifs own proper use, forever. Mortgagor hereby covenants and agrees with Mortgagee as [olJows: SECTION ~. ~ All the te~s used In this Modgage shall haYe t~ same meaning m used In the Note, except os otherwise set fodh below orlotherWlse required by the context herein: (o) Events of De~qu~ - An event or occurrence ae~c~lbed In R~3ragraph 10 herein," (b) Imoosltlo~ - A real estate and pemonal property taxes and other taxes and a~essments of any kind whafs~ver (or payments In lieu thereof), wafer and sewer rents or charges, and all other governmental charges, and QRy Interest, cost or penalties related thereto, and charges for any 974 Exhibit "A" Tax Parcel NO. 40-10-0634-025 THIS DE~D, made the 17th day of October, 1995; BETWEEN LEE STAMM a/k/a N. LEE ST~4M, of 51 Heisers Lane, . Carlisle. South Middleton Township, Cumberland County, Pennsylvania, herein designated as the Orantor; AND MRS. ETAN~4.S BAR B Q, INC., a Pennsylvania Corporation with 1= designated as the Grantee; WIT~'ESE, that the Grantor, for and in consideration of ONE DOLLAR and NO Cents ($1.00) lawful money of the United States of America, to the grantor in hand well and truly paid by the Grantee, whereof is hereby acknowledged and the Grantor being therewith fully being in line of lands now or formerly of Floyd Weibley; thence by of lands now or formerly of S. Fred Naugle; thence by said lands North 65 1/4 degrees East 58.2 perches to a point; thence by land now or formerly of Roy Weibley, North I7 1/2 deprees West 9.5 perches to a point on the South side of said Township Road; thence by the South side of said Township Road, North 41 1/2 degrees West processing building and other buildings. BEINg the same property which Walter Weibley and Gladys I. Weibley granted and conveyed to Lee Stamm and Mary F. Stamm by deed dated December 23, 1963 and recorded in the Office of the Recorder 129 r~cr EXhibit-A- of Deeds for Cumberland County in Deed Book "B", Volume 21, Page 618. N. LE~ STAMM /; , /-/ .'~1 hereby uertify that the ng address of the / 'Aet0rfi~ for Grantees RECORDED on Chis /~ day of~>~ A.D. 1995, in the ~c_~rder,s Office Of the said County, in Deed Book Psge~_______, Given %ulder my hand and ~he seal of the Waid~ ~{{l~;':9~ice, ~e date above wr}tten. -- . Exhibit "A" REALTY TRANSFER TAX Carlisle, PA 17013 . Carlisle PA 40-10-0634-025 = $606,000.00 17013