HomeMy WebLinkAbout02-2093VIRGINIA M. LILLIE,
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. O .,,2093 CXVn
IN MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L. Schorpp
I.D. No. 17495
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: April 2(~, 2002
VIRGINIA M. LILLIE,
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please enter judgment in favor of the Plaintiff and against Defendant in the amount of
$41,885.69, plus interest from April 30, 2002 until satisfaction in full at the rate of $8.73 per day,
plus costs, all for Defendant's failure to plead or otherwise respond to Plaintiff's Complaint.
I certify that notice, a copy of which is attached hereto, was served on Defendant by regular
mail on June 3, 2002.
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L. Schorpp, Esqffire
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
VIRGINIA M. LILLIE
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02 - 2093 CIVIL
1N MORTGAGE FORECLOSURE
TO: SCOTT A. DAVIS, Defendant
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DA'II~ OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A I-~ARING 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) 24%3166
MARTSON DEARDORFF WILL1AMS & OTTO
By ~~
Edward L. Schorpp, Esquire
I.D. No. 17495
Ten East High Street
Carlisle, PA 17013
(717) 243-33z[1
Attorneys for Plaintiff
Dated: June 3, 2002
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for 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, PA, first class mail, postage prepaid, addressed as follows:
Mr. Scott A. Davis
376 Burnt House Road
Carlisle, PA 17013
MARTSON DEARDORFF WILLIAMS & OTTO
Tricia D. Eckem:oad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated:
VIRGINIA M. LILLIE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0.2- &v 9.3 CIVIL
SCOTT A. DAVIS,
Defendant
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, comes the Plaintiff, VIRGINIA M. LILLIE, by and through her attorneys,
MARTSON DEARDORFF WILLIAMS & OTTO, and files this Complaint in Mortgage Foreclosure
upon the following:
1. Plaintiffis Virginia M. Lillie, a widow and adult individual who resides at 372 Burnt
House Road, Carlisle (Dickinson Township), Cumberland County, Pennsylvania 17013-7643.
2. Defendant is Scott A. Davis, an adult individual who resides at 376 Burnt House
Road, Carlisle (Dickinson Township), Cumberland County, Pennsylvania.
3. On May 25, 1994, Defendant, as Mortgagor, granted unto Plaintiff, as Mortgagee, a
certain Mortgage and entered into a certain Mortgage Note of the same date, for the repayment of
a principal debt of Fifty Thousand Nine Hundred Dollars ($50,900.00) pursuant to the terms and
conditions of said Mortgage and Mortgage Note, which obligation was secured by premises known
as and numbered 376 Burnt House Road; a copy of the Mortgage, as recorded in Cumberland County
Mortgage Book 1214, Page 880, is attached hereto, marked Exhibit "A" and incorporated herein by
reference.
4. The land subject to the Mortgage is known as and numbered as 376 Burnt House
Road in Dickinson Township, Cumberland County, Pennsylvania and is more particularly described
in Exhibit "A".
5. The Mortgage has not been assigned.
6. The Defendant is the real owner of the property and Plaintiff knows of no other
persons holding an ownership interest in the property.
7. Defendant is in default in the payment of his monthly payments in that he has not made
a payment since August 22, 2001, whereby there is now owing a principal balance, together with
accrued interest and attorney's fees as follows:
Principal Balance:
Interest from August 22, 2001
through April 30, 2002:
Late Payment Charges:
Attorney's Fees (5%):
Total Due:
$37,457.18
2,191.23
224.72
1,994.56
$41,885.69
8. The amount now due and owing from Defendant is the amount of Forty-One
Thousand Eight Hundred Eighty-Five and 69/100 Dollars ($41,885.69) plus interest from April 30,
2002 at the rate of Eight and 73/100 Dollars ($8.73) per day until paid in full, plus costs.
9. The Mortgage attached as Exhibit "A" is not a residential mortgage under the
provisions of the Act of January 30, 1974, P.L. 13, No. 6, § I01, etseq., 41 P.S. § 101, etseq., as
amended.
WHEREFORE, Plaintiff demands of the Defendant the sum of Forty-One Thousand Eight
Hundred Eighty-Five and 69/100 Dollars ($41,885.69) plus interest at the rate of Eight and 73/100
Dollars ($8.73) per day from April 30, 2002, plus her costs in this action.
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. No. 17495
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: April ~q, 2002
Exhibit A
MORTGAGE
MADE this ,~e-% of May, 1994,
BETWEEN
SCOTF A. DAVIS, single man, of Dickinson Township, Cumberland County, Pennsylvania,
(hereinafter, whether one or more, oiled 'Mortgagor')
And
VIRGINIA M. LII.LIIr~ widow, of Dickinson Township, Cumberland County, Pennsylvania,
(hereinafter, whether one or more, called "Mortgagee")
WHEREAS, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note
(hereinafter called the 'Note') of even date herewith, payable to the order of Mortgagee in the princ~
sm of Fifty Thousand Nine Hundred Dollars ($50,900.00), lawful money of the United States of ~
America, and has provided therein for payment of any additional monies loaned or advanced thereufl~r
by Mortgagee, together with interest thereon at the rate provided in the Note, in the manner and at the
times therein set forth, and containing certain other terms and conditions, all of which are specifically
incorporated herein by reference;
NOW TI~k':REFORE, Mortgagor, in consideration of said debt or principal sam and as security
for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or
under the terms of the Note, does grant and convey unto Mortgagee, its successors and assigns:
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Dickinson
Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a P.K. nail in Township Road T-545, known as Burnt House Road, said point being in
the Northwest corner of other lands now or formerly of Sidney J. and Virginia M. Linie; thence along
the lands now or formerly of Lillie, South 37 degrees 11 minutes 21 seconds West 177.60 feet to an iron
pin in the line of lands now or formerly of John D. and Darlene S. Tyler; thence along the lands now or
formerly of Tyler and continuing along the lands now or formerly of Robert L. and Nancy D. Thompson,
North 80 degrees 36 minutes 19 seconds West 413.61 feet to an iron pin in the line of lands now or
formerly of Luther A. and Anna Mae Monntz; thence along the lands now or formerly of Mountz, North
00 degrees 5 minutes ~0 seconds West 73.72 feet to an iron pin in the line of lands now or formerly of
Lillie; thence along the lands now or formerly of Liliie, the following three courses and distances: North
52 degrees 32 minutes 41 seconds East 85.77 feet; North 62 degrees 16 minutes 27 seconds logit 95.78
feet; and South 86 degrees 38 minutes 50 seconds East 277.31 feet to a P.K. nail set in Burnt House
Road; thence m Burnt House Road South 44 degrees 46 minutes 00 seconds East 73.66 feet to a P.K.
nail; thence continuing in Burnt House Road South 50 degrees 32 minutes 20 seconds East 43.99 feet to
a P.K. nail, at the place of BEGINNING.
CONTAINING a total of 2.0 acres and being Lot No. 2 as shown on the Preliminary Final Subdivision
Plan prepared by Stephen O. Fisher, R.S., dated ,April 9, 1990, and recorded in Cumberland County Plan
Book 60, Page 103.
BEING the same premises which Virginia M. Lillie, widow, by her deed dated May .,ffC1994, and
recorded in the Off]ce of the Recorder of Deeds in and for Cumberland County immediately prior to the
recording of this mortgage, granted and conveyed unto Scott A, Davis, single man.
Exhibit "A"
UNDER AND SUBJECT, HOWEVER, to the rights of Sidney J. Lillie and Virginia M. Lillie, their
successors and assigns, to use a macadam driveway which crosses said lot and is more particularly set
forth on the Plan recorded in Plan Book 60, Page 103, for the purpose of ingress, egress and regress to
Lot No. I as shown on the previously referred to Plan.
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To have and to hold the same unto Mortgagee, his heirs and assigns, forever.
Provided, however, that if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate
hereby granted and conveyed shah become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for
any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times
hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and
advances shall be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shaH: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the
debt secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and
discharge all meehahics' liens which may be filed against said premises and which shall or might have
priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or
other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the
Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary
premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from
time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged
premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interest may
appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the
foregoing charges; provided, however, that Mortgagee may at his option require that sums sufficient to
discharge the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good
and substantial repair, as determined by Mortgagee, Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or
fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost
thereof to the principal debt secured hereby, and collect the same as a part of said principal debt.
(5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or an part of
the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien
of this Mortgage.
881
(6) In case default is made for the space of thirty (30) days in the payment of any installment of
principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of
the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum,
additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or
this Mortgage, together with unpaid interest thereon, shah at the option of Mortgagee and without
notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on
this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together
with cost of suit and an attorney's commission for collection of five percent (5%) of the total
indebtedness or $200.00, whichever is the larger amount, Mortgagor hereby forever waives and releases
all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of
payment, agrees to condemnation of any property levied upon by virtue of any such execution, and
waives all exemptions, from levy and sale of any property that now is or hereafter may be exempted by
law.
(7) Transfer of the Property; Assumption. If aH or any part of the Property or an interest
therein is sold or transferred by Mortgagor without Mortgagee's prior written consent, excluding (a) the
creation of a lien or encumbrance subordinate to this Mortgage, Co) the creation of a purchase money
security interest for household appliances, (c) a transfer of devise, descent or by operation of law upon
the death of a joint tenant or (d) the grant of any leasehold interest of three years or less not containing
an option to purchase, Mortgagee may, at Mortgagee'a option, declare at! the sums secured by this
Mortgage to be immediately due and payable, Mortgagee shah have waived such option to accelerate if
prior to the sale or transfer, Mortgagee and the person to whom the property is sold or transferred
reach agreement in writing that the credit of such person is satisfactory to Mortgagee and that the
interest payable on the sums secured by this Mortgage shall be at such rate as Mortgagee shall request.
If Mortgagee has waived the option to accelerate provided in this paragraph, and if Mortgagor's
successor in interest has executed a written assumption agreement accepted in writing by Mortgagee,
Mortgagee shall release Mortgagor from all obligations under this Mortgage and the Note.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the
benefits thereof shall inure to, the respective parties hereto and their respective heirs,executors,
administrators, successors and assigns, and if this Mortgage is executed by more than one person, the
undertakings and liability of each shall be joint and several.
Witness the due execut~ereof the
/OMMON~OF PENNSYLVANIA
COUNTY OF CUMBE~D
day and year first above written.
Scott A. Davis
)
:SS.
)
(SEAL)
On this, the ~5'''a' day of ~'~._.~ , 19 ~ff , before me, the
undersigned officer, personally appeared SCOTT A. DRVIS, satisfactorily proven to me to be the person
whose name is subscribed to the within Mortgage, and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
I _.__ t. en[xM, n~r~y
Certificate of Residence of Mortgagee
I do hereby certify that the precise rqsidence, and complete post office_address o~ $he within
named Mortgagee is: ~.
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
and the seal of the said Office, the date above written.
· , in the Recorder's Office
, Page~O . Given under my hand
, Recorder
VERIFICATION
The foregoing Complaint in Mortgage Foreclosure is based upon information which has been
gathered by my counsel in the preparation of the lawsuit. The language of the document is that of
counsel and not my own. I have read the document and to the extent that it is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have relied
upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
F:hClLES/DATAFILE\Gendoc cur/I0603 pta 2/tde
Created06/17/O20227:31PM
Revised 06/18/02 12:4938 PM
10603 i
V~GINIAM. LILL~,
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
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 Scott A. Davis;
(4) execute against real property owned by the Defendant and identified on
attached listing.
Amount due $41,885.69
Plus interest from 4/30/02 at
the rate of $8.73 per day $
Costs $
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
WRIT NO. 02-2093
LEGAL DESCRIPTIO~
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Dickinson
Township, Cumberland County, Pennsylvania, more particulaxlybounded and described as follows:
BEGINNING at a P.K. nail in Township Road T-545, known as Burnt House Road, said point being
in the Northwest comer of other lands, now or formerly of Sidney J. and Virginia M. Lillie; thence
along the lands now or formerly of Lillie, South 37 degrees 11 minutes 21 seconds West 177.60 feet
to an iron pin in the line of lands now or formerly of John D. and Darlene S. Tyler; thence along the
lands now or formerly of Tyler and continuing along the lands now or formerly of Robert L. and
NancyD. Thompson, North 80 degrees 36 minutes 19 seconds West 413.61 feet to an iron pin in the
line of lands now or formerly of Luther A. and Anna Mae Mountz; thence along the lands now or
formerly of Mountz, North 00 degrees 5 minutes 50 seconds West 73.72 feet to an iron pin in the
line of lands now or formerly of Lillie; thence along the lands now or formerly of Lillie, the
following three courses and distances: North 52 degrees 32 minutes 41 seconds East 85.77 feet;
North 62 degrees 16 minutes 27 seconds East 95.78 feet; and South 86 degrees 38 minutes 50
seconds East 277.31 feet to a P.K. nail set in Burnt House Road; thence in Burnt House Road South
44 degrees 46 minutes 00 seconds East 73.66 feet to a P.K. nail; thence continuing in Burnt House
Road South 50 degrees 32 minutes 20 seconds East 43.99 feet to a P.K. nail, at the place of
BEGINNING.
CONTAINING at total of 2.0 acres and being Lot No. 2 as shown on the Preliminary Final
Subdivision Plan prepared by Stephen G. Fisher, R.S., dated April 9, 1990, and recorded in
Cumberland County Plan Book 60, Page 103.
BEING IMPROVED with a dwelling house and other improvements known as and numbered 376
Bumt House Road.
BEING the same premises which Virginia M. Lillie, widow, by her deed dated May 25, 1994 and
recorded in the Office of the Recorder of Deeds in and for Camberland County in Deed Book 105,
Page 1080, granted and conveyed unto Scott A. Davis.
UNDER AND SUBJECT, HOWEVER, to the rights of Sidney J. Lillie and Virginia M.
Lillie, their successors and assigns, to use a macadam drivexvay which crosses said lot and is more
particularly set forth on the Plan recorded in Plan Book 60, Page 103, for the purpose of ingress,
egress and regress to Lot No. 1 as shown on the previously referred to Plan.
TO BE SOLD AS THE PROPERTY OF SCOTT A. DAVIS ON JUDGMENT ENTERED
AT THE ABOVE NUMBER AND TERM.
TAX PARCEL: 08-10-0630-001A
O~ c=~
VIRGINIA M. LILLIE,
Plaintiff
SCOTT A. DAVIS,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1
Edward L. Schorpp, attorney for 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:
1. Name and address of owner or reputed owner:
Name .Address
Scott A. Davis 376 Burnt House Road
Carlisle, PA 17013
2. Name and address of Defendant in the judgmem:
Name Address
Scott A. Davis 376 Burnt House Road
Carlisle, PA 17013
Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Address
N/A
Name and address of the last recorded holder of every mortgage of record:
Name Address
Larry L. Warner 414 East Old York Road
Carlisle, PA 17013
Pennsylvania State Bank One North Hanover Street
Carlisle, PA 17013
Name and address of every other person who has any record lien on the property:
Name
Cumberland County Tax Claim Bureau
and whose interest may be affected by the sale.
Name
N/A
Address
One Courthouse Square
Carlisle, PA 17013
Name and address of every other person who has any record interest in the property
Address
7. Name and address of every other person of whom the Plaintiffhas knowledge who
has any interest in the property which may be affected by the sale.
.Name Address
Lisa M. Davis a/k/a Lisa M. Rodkey 376 Burnt House Road
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4909 relating to unsworn falsification to authorities.
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L. Schorpp', Esquire
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: ~5~- 32 ~ .~:::> ~
VIRGINIA M. LILLIE,
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CWIL ACTION - LAW
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SAI,E
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 December 4, 2002 in
the COMMISSIONER'S HEARING ROOM, 2nd Floor, CUMBERLAND COUNTY
COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time.
THE PROPERTY TO BE SOLD is 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 property to be sold is:
376 Burnt House Road, Carlisle (Dickinson Township), Cumberland County,
Pennsylvania
THE JUDGMENT under or pursuant to which the property is being sold is docketed to: 02-
2093 Civil Action Law - In Mortgage Foreclosure, Cumberland County C.C.P., Pennsylvania.
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS PROPERTY IS:
Scott A. Davis.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part o£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 Sheriffwithin 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 o£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
WRIT NO. 02-2093
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Dickinson
Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a P.K. nail in Township Road T-545, known as Burnt House Road, said point being
in the Northwest comer of other lands, now or formerly of Sidney J. and Virginia M. Lillie; thence
along the lands now or formerly of Lillie, South 37 degrees 11 minutes 21 seconds West 177.60 feet
to an iron pin in the line of lands now or formerly of John D. and Darlene S. Tyler; thence along the
lands now or formerly of Tyler and continuing along the lands now or formerly of Robert L. and
Nancy D. Thompson, North 80 degrees 36 minutes 19 seconds West 413.61 feet to an iron pin in the
line of lands now or formerly of Luther A. and Anna Mae Mountz; thence along the lands now or
formerly of Mountz, North 00 degrees 5 minutes 50 seconds West 73.72 feet to an iron pin in the
line of lands now or formerly of Lillie; thence along the lands now or formerly of Lillie, the
following three courses and distances: North 52 degrees 32 minutes 41 seconds East 85.77 feet;
North 62 degrees 16 minutes 27 seconds East 95.78 feet; and South 86 degrees 38 minutes 50
seconds East 277.31 feet to a P.K. nail set in Burnt House Road; thence in Burnt House Road South
44 degrees 46 minutes 00 seconds East 73.66 feet to a P.K. nail; thence continuing in Burnt House
Road South 50 degrees 32 minutes 20 seconds East 43.99 feet to a P.K. nail, at the place of
BEGINNING.
CONTAINING at total of 2.0 acres and being Lot No. 2 as shown on the Preliminary Final
Subdivision Plan prepared by Stephen G. Fisher, R.S., dated April 9, 1990, and recorded in
Cumberland County Plan Book 60, Page 103.
BEING IMPROVED with a dwelling house and other improvements known as and numbered 376
Burnt House Road.
BEING the same premises which Virginia M. Lillie, widow, by her deed dated May 25, 1994 and
recorded in the Office of the Recorder of Deods in and for Cumberland County in Deed Book 105,
Page 1080, granted and conveyed unto Scott A. Davis.
UNDER AND SUBJECT, HOWEVER, to the fights of Sidney J. Lillie and Virginia M.
Lillie, their successors and assigns, to use a macadam driveway which crosses said lot and is more
particularly set forth on the Plan recorded in Plan Book 60, Page 103, for the purpose of ingress,
egress and regress to Lot No. 1 as shown on the previously referred to Plan.
TO BE SOLD AS THE PROPERTY OF SCOTT A. DAVIS ON JUDGMENT ENTERED
AT THE ABOVE NUMBER AND TERM.
TAX PARCEL: 08-10-0630-001A
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-2023 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VIRGINIA M. LILLIE Plaintiff (s)
From SCOTT A. DAVIS, 376 BURNT HOUSE ROAD, CARLISLE PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 376 BURNT HOUSE ROAD, CARLISLE PA 17013 ( SEE ATTACHED LEGAL
DESCRIPTION).
(2) You are also directed to at/ach 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 pr°petty °f 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 $41,885.69
L.L. $.50
Interest FROM 4/30/02 ~ $8.73/diem
Atty's Comm %
Atty Paid $104.14
Plaintiff Paid
Date: AUGUST 27, 2002
(Seal)
REQUESTING PARTY:
Name EDWARD L. SCHORPP, ESQ.
Address: TEN EAS HIGH ST
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: 717 243-3341
Supreme Court ID No.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Protho~fqtary / 1 ·
~/ ~/eputy (2/
SHERIFF'S RETURN -
CASE NO: 2002-02093 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LILLIE VIRGINIA M
VS
DAVIS SCOTT A
REGULAR
BRIAN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
DAVIS SCOTT A the
DEFENDANT , at 2001:00 HOURS,
at 376 BURNT HOUSE ROAD
CARLISLE, PA 17013
SCOTT DAVIS
on the 9th day of May , 2002
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 4.14
Affidavit .00
Surcharge 10.00
.00
32.14
Sworn and Subscribed to before
me this /~-~ day of
/ ~rothonotary
So Answers:
R. Thomas Kline
05/13/2002
MDW&O
By:
Deputy S~eri'f f
Virginia M. Lillie
VS
Scott A. Davis
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-2093 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Edward Schorpp.
Sheriff's Costs:
Docketing 30.00
Surcharge 20.00
Law Library .50
Prothonotary 1.00
Mileage 6.90
Levy 15.00
Advertising 15.00
Posting Handbills 15.00
Share of Bills 25.20
Poundage 10.29
Law Journal 156.90
Patriot News 219.35
Certified Mail 9.75
$ 524.89 paid by attorney
11/20/02
Sworn and subscribed to before me
This d-~.,~tday of
2002, A.D. k,,_
Prothonotary
So Ans~ver~
R. Thomas Kline, Sheriff
Real EstMe Deputy
1.5O
VIRGINIA M. LILLIE,
Plaintiff
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1
Edward L. Schorpp, attorney for 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:
1. Name and address of oxvner or reputed o~vner:
Name Address
Scott A. Davis 376 Burnt House Road
Carlisle, PA 17013
2. Name and address of Defendant in the judgment:
Name Address
Scott A. Davis 376 Burnt House Road
Carlisle, PA 17013
Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Address
N/A
Name and address of the last recorded holder of every mortgage of record:
Name
Larry L. Warner
Pennsylvania State Bank
Address
414 East Old York Road
Carlisle, PA 17013
One North Hanover Street
Carlisle, PA 17013
Name and address of every other person who has any record lien on the property:
Nalne
Cumberland County Tax Claim Bureau
and whose interest may be affected by the sale.
Name
Address
One Courthouse Square
Carlisle, PA 17013
Name and address of every other person who has any record interest in the property
Address
N/A
7. Name and address of every other person of whom the Plaintiff has knowledge who
has any interest in the property which may be affected by the sale.
Name
Lisa M. Davis a/k/a Lisa M. Rodkey
Address
376 Burnt House Road
Carlisle, PA 17013
I verify that the statements made in this Affidavit are tree and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4909 relating to tmswom falsification to authorities.
Date:
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L Schorpp, Esquire
Ten East High Street
Carlisle, PA 17013-3093
(717) 243 -3341
Attorneys for Plaintiff
VIRGINIA M. LILLIE,
Plaintiff
V.
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
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 December 4, 2002 in
the COMMISSIONER'S HEARING ROOM, 2na Floor, CLrMBERLAND COUNTY
COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 a.m., prevailing local time.
THE PROPERTY TO BE SOLD is 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 property to be sold is:
376 Burnt House Road, Carlisle (Dickinson Township), Cumberland County,
Pennsylvania
THE JUDGMENT under or pursuant to which the property is being sold is docketed to: 02-
2093 Civil Action Law - In Mortgage Foreclosure, Cumberland County C.C.P., pennsylvania.
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS PROPERTY IS:
Scott A. Davis.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and
to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff 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 fi.om 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 fights to prevent your property from being taken. A lawyer can advise you more specifically
of these fights. If you wish to exercise your fights, 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
WRIT NO. 02-2093
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Dickinson
Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a P.K. nail in Township Road T-545, known as Burnt House Road, said point being
in the Northwest comer of other lands, now or formerly of Sidney J. and Virginia M. Lillie; thence
along the lands now or formerly of Lillie, South 37 degrees 11 minutes 21 seconds West 177.60 feet
to an iron pin in the line of lands now or formerly of John D. and Darlene S. Tyler; thence along the
lands now or formerly of Tyler and continuing along the lands now or formerly of Robert L. and
Nancy D. Thompson, North 80 degrees 36 minutes 19 seconds West 413.61 feet to an iron pin in the
line of lands now or formerly of Luther A. and Anna Mae Mountz; thence along the lands now or
formerly of Mountz, North 00 degrees 5 minutes 50 seconds West 73.72 feet to an iron pin in the
line of lands now or formerly of Lillie; thence along the lands now or formerly of Lillie, the
following three courses and distances: North 52 degrees 32 minutes 41 seconds East 85.77 feet;
North 62 degrees 16 minutes 27 seconds East 95.78 feet; and South 86 degrees 38 minutes 50
seconds East 277.31 feet to a P.K. nail set in Burnt House Road; thence in Burnt House Road South
44 degrees 46 minutes 00 seconds East 73.66 feet to a P.K. nail; thence continuing in Burnt House
Road South 50 degrees 32 minutes 20 seconds East 43.99 feet to a P.K. nail, at the place of
BEGINNING.
CONTAINING at total of 2.0 acres and being Lot No. 2 as shown on the Preliminary Final
Subdivision Plan prepared by Stephen G. Fisher, R.S., dated April 9, 1990, and recorded in
Cumberland County Plan Book 60, Page 103.
BEING IMPROVED with a dwelling house and other improvements known as and numbered 376
Burnt House Road.
BEING the same premises which Virginia M. Lillie, widow, by her deed dated May 25, 1994 and
recorded in the Office of the Recorder of Deeds in and for Cttrnberland County in Deed Book 105,
Page 1080, granted and conveyed unto Scott A. Davis.
UNDER AND SUBJECT, HOWEVER, to the rights of Sidney J. Lillie and Virginia M.
Lillie, their successors and assigns, to use a macadam driveway which crosses said lot and is more
particularly set forth on the Plan recorded in Plan Book 60, Page 103, for the purpose of ingress,
egress and regress to Lot No. 1 as shown on the previously referred to Plan.
TO BE SOLD AS THE PROPERTY OF SCOTT A. DAVIS ON JUDGMENT ENTERED
AT THE ABOVE NUMBER AND TERM.
TAX PARCEL: 08-10-0630-001A
WRIT OF EXECUTION. and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-20~3 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VIRGINIA M. LILLIE Plaintiff (s)
From SCOTT A. DAVIS, 376 BU1LNT HOUSE ROAD, CARLISLE PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 376 BURNT HOUSE ROAD, CARLISLE PA 17013 ( SEE ATTACHED 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 garmshee(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 $41,885.69
L.L. $.50
Interest FROM 4/30/02 ~ $8.73/diem
Atty's Comm %
Atty Paid $104.14
Plaintiff Paid
Date: AUGUST 27, 2002
(Seal)
REQUESTING PARTY:
Name EDWARD L. SCHORPP, ESQ.
Address: TEN EAS HIGH ST
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: 717 243-3341
Supreme Court ID No.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Protho~'~tary
TRUE COPY FROM RECORD
;n T~tlmony whereof, I here unto set my hah6
Real Estate Sale # 23
On September 6, 2002 the sherifflevied upon the
defendant's interest in the real property situated in
Dickinson Township, Cumberland County, PA
known and numbered as 376 Burnt House Road, Carlisle
more fully described on Exhibit "A" filed with this
writ and by this reference incorporated herein.
Date: September 6, 2002
Real Estate Deputy
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
: SS.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of thc 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 o£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:
OCTOBER 25, NOVEMBER 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 23
Writ No. 2002 2093 Civil
Virginia M. Llllie
vs.
Scott ,~ Davis
Atty.: Edward Schorpp
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of la-nd
with the hnprovements thereon
erected situate in Dickinson Tova~
ship, Cumberlmad County. Pennsyl-
vania, more particularly bounded
and described as follows:
BEGINNING at a P.K. nail in
Township Road T 545, known as
Burnt House Road, said point be-
ing in the Northwest corner of other
lands, now or formerly of Sidney J.
and Virginia M. Lfllie; thence along
the lands now or formerly of Lillie.
South 37 degrees 11 minutes 21
seconds West 177.60 feet to an iron
pin in the lille of Lin,ds now or for
merly of John D. and Darlene S.
Tyler; thence along the lands now
SWORN TO AND SUBSCRIBED before me this
8 day of NOVEMBER, 2002
~lhe; thence along
the lands now or lbrmerly of Lillie,
South 37 degrees 11 minutes 21
seconds West 177.60 feet to an Iron
pin in the llile of lands now or for
merly of John D. and Darlene S.
Tyler; thence along the lands now
or forn~erly of Tyler and continuing
alollg the lands now or formerly of
Robert L. and Nancy D. Thompson,
North 80 degrees 36 minutes 19
seconds West 413.61 feet to an iron
pin in the line of lar~ds now or ibr
merly of Luther A. and A~lna Mae
Mountz; thence along the lands now
or formerly of Mountz, NorLh 00 de-
grees 5 minutes 50 seconds West
73.72 feet to aul iron pin in the line
of lands now or formerly of Lillie;
thence along the laxlds now or form-
erly of Lillie. the following three
courses and dista~lces: North 52 de
grees 32 minutes 41 seconds East
85.77 feet; North 62 degrees 16
minutes 27 seconds East 95.78 feet;
and South 86 degrees 38 minutes
50 seconds East 277.31 feet to a
P.K. nail set in Burnt House Road;
thence in Burnt House Road South
44 degrees 46 minutes 00 seconds
East 73.66 feet to a P.K. nail; thence
continuing in Burnt House Road
South 50 degrees 32 minutes 20
seconds East 43.99 feet to a P.K.
nail. at the place of BEGINNING.
CONTAINING at total of 2.0 acres
and being Lot No. 2 as shown on
the Preliminary Final Subdivision
Plan prepared by Stephen G. Fisher,
R.S., dated April 9, 1990, and re
corded in CumberLand County Plan
Book 60, Page 103.
BEING IMPROVED with a dwell
lng house and other hnprovements
known as auld numbered 376 Burnt
House Road.
BEING the sZane premises which
Virginia M. Lillie, widow, by her deed
dated May 25, 1994 and recorded
in the Oil]ce of the Recorder of Deeds
in arid for Cumberland County in
Deed Book 105, Page 1080, grarlted
and conveyed unto Scott A. Davis.
UNDER AND SUBJECT, HOW-
EVER, to the rights of Sidney J.
Lillie auld Virginia M. Lillie, their suc
danl driveway which crosses said
lot arid Is more particularly set forth
on the Plan recorded in Plan Book
60, Page 103, for the purpose of in
gress, egress and regress to Lot No.
fen'ed to Plan.
TO BE SOLD AS THE PROPER
TY OF ScoqT A. DAVIS ON JUDG
MENT ENTERED AT THE ABOVE
NUMBER AND TERM.
TAX PARCEL: 08-10-0630-001A.
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Frank J, Epler being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the
City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-New~ 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 Mamh 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October 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 Sworn to and .~,Jh~.rih~r,I hal ..... t
- - - - - ..,. :his~.l.4th da~ of Noverryber/~00 .....
S A L E #23 Notarial Seal ~ -'- J / / /
City Of Harrisburg, Dauphin County _
My Commission Expires June 6, 2006I' NOTA,~ ~p/u BLiC
Member, Pennsytvania Association Of No. ties 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
$ 217.60
$ 1.75
$ 219.35
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The ~, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
AMENDED RETURN
Virginia M. Lillie
VS
Scott A. Davis
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-2093 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Edward Schorpp.
Sheriff's Costs:
Docketing 30.00
Surcharge 20.00
Law Library .50
Prothonotary 1.00
Mileage 6.90
Levy 15.00
Advertising 15.00
Posting Handbills 15.00
Share of Bills 25.20
Poundage 925.51
Law Journal 156.90
Patriot News 219.35
Certified Mail 9.75
$1440.11
paid by attorney
12/02/02
Sworn and subscribed to before me
Thisj~'~' dayof K~,~.~.,w
2002, A.D.~..~j&,,~ (.~ ~h.~,~. ,, ~
Prothonotary
R. Thomas Kline, Sheriff
Real Estate Deputy
F:~ILES\DATAFILE\Gendoc.cur\ 10603-judgment.sat
VIRGINIA M. LILLIE,
Plaintiff
Vo
SCOTT A. DAVIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-2093 CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the judgment in the above captioned case satisfied and issue a certificate
reflecting the same.
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L. SchorppYEsqui e~
I.D. Number 17495
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: October ~7~, 2002