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HomeMy WebLinkAbout02-3032HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff vs. DAVID L. JUMPER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0.2 .3,93.2- CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. DAVID L. JUMPER, CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof , is disputed., the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff vs. DAVID L. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 71o.0,z. 3091. 7, COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, is a Corporation, with an address of 8120 Nations Way, Jacksonville, Florida 32256. 2. Defendant, DAVID L. JUMPER, is an adult individual, whose last known address is 132 15TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. 3. On or about, September 21, 1995, the said Defendant, executed and delivered a Mortgage Note in the sum of $56,050.00 payable to BANCPLUS MORTGAGE CORP., which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1283, Page 363 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to BARNETT MORTGAGE COMPANY and recorded in the aforesaid County in Mortgage Book 524, Page 1155. Homeside Lending, Inc., is Successor by Merger to Barnett Mortgage Company. The Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 132 15TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on March 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $11.34 per day From 02/01/2002 To 07/01/2002 ( based on contract rate of 8.250%) Accumulated Late Charges Late Charges at $21.05 From 03/01/2002 to 07/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $50,181.96 $2,052.53 $84.20 $126.30 $0.00 $2,509.10 $54,954.09 "Together with interest at the per diem rate noted above after July 01, 2002 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.250% ($11.34 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's S4k and for foreclosure and sale of the property within described. By: PURCELL, KRUG 1 Leon P. Haller, Esquii Attorney for Plaintiff I.D. # 15700 1719 N. 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Case Kill, p!nsyivanie, defied October 5, ?`. to3a, es tolloes: . 9aanmsra at at polnb we the southwest are line of Fifteenth aereat, said point being eighty-taw and forty-two hundmath¦ (84.42) test aeethwut of Ltar 9traett thence through the oentar -of a partition .. wall seyerating seastses knew es NO. 179 and 117 Fifteenth Btrest and beyasd, 900th thiat r-¦iB (x oce hand.aa ?'-aegeeae ereo?lY±igpt_ (st) minutes Nast'. ._. -- - -_ -' ) ---. - -..ens a gaa.aj rest to a point on line of leads NOW ce late Of Richard Moses) thane aleta said lends Borth F... thuft 1:4 ja=. t+wety-al9it (29)_ Minataa safe, ona . tpltteon .y ''°`'?tive bmwtmdtps 61].9P) teat co a 'psiaf° ae tL .t. • aoaeaaeeearn we o!' Flttatllffi stmt) th,,ca along tha'- in of Fiftesnth 9trset, Borth fifty-two (32) dew as fifty-cis (sd) minutes Let, county-flea and tiny-nine hundredths (25.39), cwt to a palm, the Piece of mamalm. ' . l i COMPANY NAME: HsE IEUM, DE. =33M By HIGH TD MRIEIT KIUU?m m4my VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Dated JUNE 21. 2002 By Q Title Tracy Johnson Moe President cn to I.J 1 b x 11 r ' k N y, y Y, „ c r? f n W . = n? ?i -C SHERIFF'S RETURN - REGULAR CASE NO: 2002-03032 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMESIDE LENDING INC VS JUMPER DAVID L ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JUMPER DAVID L the DEFENDANT , at 1315:00 HOURS, on the 26th day of June , 2002 at 132 15TH STREET NEW CUMBERLAND, PA 17070 by handing to DAVID JUMPER 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 11.73 Affidavit .00 Surcharge 10.00 .00 39.73 Sworn and Subscribed to before me this day of ,Z A.D. P othonota j K, y So Answers: R. Thomas Kline 06/27/2002 PURCELL KRUG HALLER B? ?Y 11 ? 2f Deputy erif HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants DAVID L. JUMPER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $50,181.96 Interest $ 2,052.53 (Per diem of $11.34 from 2/1/02 to 7/1/02) Accumulated late charges $ 84.20 Late charges $ 126.30 ($21.05 per month to 7/02) Escrow Deficit $ 5% Attorney's Commission $ 2,509.10 TOTAL $54,954.09** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG &El By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K\MKPDOMCUMBERLAVUMPP HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on JULY 23, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA IND. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY Plaintiff VS. DAVID L. JUMPER Defendant DATE OF THIS NOTICE: July 23, 2002 TO: DAVID L. JUMPER 132 15TH STREET NEW CUMBERLAND, PA 17070-1104 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3032 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 PURCELL,KRUG & HALLER By LEON P HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before /ne this 1Q day of "A=2? 20,,,E o ary Pub c LEON P. HALLER, ESQUIRE NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Aug. 8, 2006 ?' e C) C7 V c_ r? K.. C r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 3032 HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, PLAINTIFF v5. DAVID L. JUMPER, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $54,954.09 Interest at $11.34 per diem to sale date $ 1,757.70 Late charges at $21.05 per month to sale date $ 84.20 Escrow Deficit $ 2,000.00 TOTAL $58,795.99* *SALE DATE: WEDS.,DEC. 4, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case Date: September 10, 2002 '11A Attorney for Plaintiff 6- 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. 415700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 132 FIFTEENTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. Date: PROTHONOTARY/CLERK CIVIL DIVI BY DEPUTY K WKF\DOCS\CUMBERLAWUMPER.W rj rv (?1 3U -f C c , ? c C w 1 ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof, prepared by Ernest J. Walker, Registered Engineer, Camp Hill, Pennsylvania, dated October 5, 1964, as follows: BEGINNING at a point on the southeastern line of Fifteenth Street, said point being eighty-four and forty-two hundredths (84.42) feet southwest of Water Street; thence through the center of a partition wall separating premises known as No. 128 and 132 Fifteenth Street and beyond, South thirty-six (36) degrees twenty-eight (28) minutes East, one hundred fourteen and twelve one-hundredths (114.12) feet to a point; thence South fifty-three (53) degrees thirty-two (32) minutes West, twenty-five and six-tenths (25.6) feet to a point on line of lands now or late of Richard Moses; thence along said lands North thirty-six (36) degrees twenty-eight (28) minutes West, one hundred thirteen and eighty-five hundredths (113.85) feet to a point on the southeastern line of Fifteenth Street; thence along the line of Fifteenth Street, North fifty-two (52) degrees fifty-six (56) minutes East, twenty-five and fifty-nine hundredths (25.59) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 132 FIFTEENTH STREET, NEW CUMBERLAND, PA 17070 BEING THE SAME PREMISES WHICH Cleo J. Spencer by deed dated 9/21/95 and recorded 9/22/95 in Deed Book 128 Page 696 granted and conveyed unto David L. Jumper. TO BE SOLD AS THE PROPERTY OF DAVID L. JUMPER ON JUDGMENT NO. 2002 3032. ASSESSMENT 426-23-0541-217 N it -Tj a .n :a, HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW Vs. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 132 FIFTEENTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070: 1. Name and address of the Owner(s) or Reputed Owner(s): David L. Jumper 132 Fifteenth Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 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: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. 415700 Purcell, Krug & Haller 1719 North Front Street DATE: September 10, 2002 C N f l d. I -, HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, DECEMBER 4, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 your property to be sold is: 132 FIFTEENTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $54,954.09 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 3032 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property i r. K iR1KFVpOCS\Q IMBERLAAJUMPER.NOS DAVID L. JUMPER 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 disb.irsed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. 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 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 Association 17013 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. After the Sheriff's Sale you may file a petition with the ,-curt of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. it a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof, prepared by Ernest J. Walker, Registered Engineer, Camp Hill, Pennsylvania, dated October 5, 1964, as follows: BEGINNING at a point on the southeastern line of Fifteenth Street, said point being eighty-four and forty-two hundredths (84.42) feet southwest of Water Street; thence through the center of a partition wall separating premises known as No. 128 and 132 Fifteenth Street and beyond, South thirty-six (36) degrees twenty-eight (28) minutes East, one hundred fourteen and twelve one-hundredths (114.12) feet to a point; thence South fifty-three (53) degrees thirty-two (32) minutes West, twenty-five and six-tenths (25.6) feet to a point on line of lands now or late of Richard Moses; thence along said lands North thirty-six (36) degrees twenty-eight (28) minutes West, one hundred thirteen and eighty-five hundredths (113.85) feet to a point on the southeastern line of Fifteenth Street; thence along the line of Fifteenth Street, North fifty-two (52) degrees fifty-six (56) minutes East, twenty-five and fifty-nine hundredths (25.59) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 132 FIFTEENTH STREET, NEW CUMBERLAND, PA 17070 BEING THE SAME PREMISES WHICH Cleo J. Spencer by deed dated 9/21/95 and recorded 9/22/95 in Deed Book 128 Page 696 granted and conveyed unto David L. Jumper. TO BE SOLD AS THE PROPERTY OF DAVID L. JUMPER ON JUDGMENT NO. 2002 3032. ASSESSMENT 426-23-0541-217 e> ? :? c_ _ ?., -, ? c .? ? z :,, f_ T? ?^J ?'_ ` J ..n % •n ?. ` ./ (?? 7 .K WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3032 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BARNETT MORTGAGE COMPANY, Plaintiff (s) From DAVID L. JUMPER, 132 FIFTEENTH STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $54,954.09 L.L. $.50 Interest AT $11.34 PER DIEM TO SALE DATE $1,757.70 LATE CHARGES AT $21.05 PER MONTH TO SALE DATE $84.20 Atty's Comm % Due Prothy $1.00 Atty Paid $111.73 Other Costs ESCROW DEFICIT $2,000.00 Plaintiff Paid Date: SEPTEMBER 11, 2002 CURTIS R. LONG Prothonota (Seal) Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on / -7 a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all l:ienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: David L. Jumper 132 Fifteenth Street New Cumberland, PA 17070 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 BY PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 JOHN W. PURCELL TELEPHONE (717) 234-4178 JOSEPH NISSLEY (1910-1982) HOWARD B. KRUG FORECLOSURE DEPT. FAX (717) 234-1206 ANTHONY DiSANTO LEON P. HALLER OF COUNSEL JOHN W.PURCELL.IR. BRIAN .I. TYLER HERSHEY JILL M. WINEKA 1099 GOVERNOR ROAD (717) 533--;836 NOTICE TO: David L. Jumper 132 Fifteenth Street New Cumberland, PA 17070 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. By: L? Leon P. Attorney you hold against the said and. that you have an any, by notified of 3aller PA I.D.15700 for Plaintiff HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BARNETT CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COMPANY, PLAINTIFF CIVIL ACTION - LAW VS. DAVID L. JUMPER, NO. 2002 3032 DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, DECEMBER 4, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 your property to be sold is: 132 FIFTEENTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $54,954.09 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 3032 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property KIM KFOOMCUMBERLAUUMPERNOS DAVID L. JUMPER 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 of this County thirty (30) day: 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 maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. 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 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof, prepared by Ernest J. Walker, Registered Engineer, Camp Hill, Pennsylvania, dated October 5, 1964, as follows: BEGINNING at a point on the southeastern line of Fifteenth Street, said point being eighty-four and forty-two hundredths (84.42) feet southwest of Water Street; thence through the center of a partition wall separating premises known as No. 128 and 132 Fifteenth street and beyond, South thirty-six (36) degrees twenty-eight (28) minutes East, one hundred fourteen and twelve one-hundredths (114.12) feet to a point; thence South fifty-three (53) degrees thirty-two (32) minutes West, twenty-five and six-tenths (25.6) feet to a point on line of lands now or late of Richard Moses; thence along said lands North thirty-six (36) degrees twenty-eight (28) minutes West, one hundred thirteen and eighty-five hundredths (113.85) feet to a point on the southeastern line of Fifteenth Street; thence along the line of Fifteenth Street, North fifty-two (52) degrees fifty-six (56) minutes East, twenty-five and fifty-nine hundredths (25.59) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 132 FIFTEENTH STREET, NEW CUMBERLAND, PA 17070 BEING THE SAME PREMISES WHICH Cleo J. Spencer by deed dated 9/21/95 and recorded 9/22/95 in Deed Book 128 Page 696 granted and conveyed unto David L. Jumper. TO BE SOLD AS THE PROPERTY OF DAVID L. JUMPER ON JUDGMENT NO. 2002 3032. ASSESSMENT #26-23-0541-217 Re: HS vs. Jumper Cumberland 12/4/02 U. S. POSTAL SERVICE: CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: David L. Jumper 132 Fifteenth Street New Cumberland, PA 17070 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage; 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Y J l Y ? s rr??OtR `' D C? c _- ,? ri` i _._, iI_ Ci -- _.J ?i! =? v -? ? ,? - , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Homeside Lending Inc merger to Barnett Mtg Co is the grantee the same having been sold to said grantee on the 4th day of Dec A.D., 202002, under and by virtue of a writ Execution issued on the 11th day of Sept, A.D., 2002\, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3032, at the suit of Homeside Lending Inc against David L Jumper is duly recorded in Sheriff's Deed Book No. 255, Page 1265. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ff day of 3 " , A.D. 2002 Recorder of Deeds Recorder of Deeds, Cumberland Caftle, PA My Canmission Expires the First M ?y of Jan. 2006 Homeside Lending, Inc. successor by In The Court of Common Pleas of Merger to Barnett Mortgage Company Cumberland County, Pennsylvania VS Writ No. 2002-3032Civil Term David L. Jumper Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 9, 2002 at 6:40 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: David L. Jumper, by making known unto David L. Jumper, at 15 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 3:50 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of David L. Jumper located at 132 Fifteenth St., New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: David L. Jumper, by regular mail to his last known address of 15 Rockaway Drive, Camp Hill, PA 17011. This letter was mailed under the date of October 10, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon P. Haller for Homeside Lending, Inc. successor by merger to Barnett Mortgage Company. It being the highest bid and best price received for the same, Homeside Lending, Inc. successor by merger to Barnett Mortgage Company of 8120 Nations Way, Building 100, Jacksonville, FL 32256, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $885.28, it being costs. Sheriffs Costs: Docketing 30.00 Poundage 17.36 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.01 Certified Mail 5.11 Levy 15.00 Surcharge 20.00 Law Journal 325.85 Patriot News 289.75 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $885.28 Sworn and Subscribed to Before Me rs- This io " Day o _ R. Thomas Kline, Sheriff 2002, A.D. , Prothonotary B? 0 Real Estate Deputy ?o OD a st' THE PATRIOT NEW THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss to law, deposes and says: Frank J. Epler being duly sworn according Controller of The Patriot News Co., a corporation o sneanized ss ata8a2e1to 1818 Ma ket Street, of That he is the the Commonwealth of Pennsylvania, with its principal office and place of ublat 81 of The Patriot-News and The of Dauphin, State of Pennsylvania, owner and p City of Harrisburg, County general circulation, printed and published at 812 to 818 Market Street, in the Sundav Patriot-News newspapers of Patriot-News were established March 4th, City, County and State aforesaid; that The Patriot -News and The Sunday and all have been continuously published ever since; 1854, and September 18 , 1949, respectively, ublished in That the printed notice or publication which is sacuea edtton the 22ndoand 29th1 day(s) of printed a f October said and printed the h ed their regular daily and/or Sunday/ Metro editions which PP is interested in the subject matter o P 5th day(s) of November 2002. That neither he nor said Company place and character of notice or advertising, and that all of the allegations of this statement as to the time, p publication are true; and personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this That he hasvirtue and pursuant to a resolution unanimously passed and statement on behalf of The Patriot-News Co. aforesaid by by the stockholders and d board of directors of the said Company and subsequently duly recorded in ty of Dauphin in Miscellaneous adopted severally office for the Recording of Deeds in and for said Coun Book "M", the Volume 14, Page 317. ............. .......: .... ....................... PUBLICATION is 14th day f Nov er 2002 A.D. COPY Sworn to and subscribed before m ,00 Notarial Seal ?? ??!• S A L E #45 Terry L. Russell, Notary Public tnCounty NOTARY PUBLIC Writ No. 2002-3032 city of Harrisburg, Dau une 6, 2006 REAL ESTATE SALE No. 45 My commission Expires t commission expires June 6, 2006 Clvll Term Member. Pennsylvania Association of Notaries Homeslde Lending, Inc., successor b Mortgage ger CUMBERLAND COUNTY SHERIFFS OFFICE to Barnett Mortg CUMBERLAND COUNTY COURTHOUSE Company vs CARLISLE, PA. 17013 David L. Jumper Any: Leon p. Haller Costs DESCRIPTION Statement of Advertising ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, To THE PATRIOT-NEWS CO., Dr. Cumberland County, Pennsylvania bounded and 288.00 described in accordance with a survey and plan For publishing the notice or publication attache $ thereof, prepared by Ernest ]. Walker, Registered hereto on the above stated dates Engineer, Camp Hill, Pennsylvania, dated Notary Fee(s) Probating same $ 289.75 October , as follows: 1 .75 BEGINNING G a at a point on the southeastern line Total of Fifteenth Street, said point being eighty-four and forty-two hundredths (84.42) feet southwest of water street; thence through the center of a Cost partition wall separating premises known as No. Publisher's Receipt for Advertising The 4undav Patriot s, newspapers of general The Patriot News Co., publisher of The Patriot-News and reb acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have circulation, he y been duly paid. By .................................................................... 128 and 132 Fifteenth Street and beyond, Somu thirty-six (36) degrees twenty-eight (28) minutes East, one hundred fourteen and twelve one- hundredths (114.12) feet to a point; thence South fifty-three (53) degrees West, thirty-two (32) minutes twenty-five and six-tenths (25.6) feet to a point on line of lands now or late of Richard Moses; thence along said lands North thirty-six (36) degrees twenty-eight (28) minutes West, one hundred thirteen and eighty-five hundredths (113.85) feet to a point on the southeastern line of Fifteenth Street; thence along the line of Fifteenth minutes Street North fifty-two (52) degrees fifty-six (56) East, twenty-five and fifty-nine hundredths (25,59) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 132 Fifteenth Street, 17070. New Cumberland, PA BEING THE SAME PREMISES WHICH Cleo J. Spencer by deed dated 9/21195 and recorded 9/22/ 95 in Deed Book 128 Page 696 granted and conveyed unto David L. Jumper. TO BE SOLD AS THE PROPERTY OF David L. Jumper on Judgment No. 2002 3032. ASSESSMENT #26-23-0541-217. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND • : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, vn?qx l'), 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. 45 Writ No. 2002-3032 Civil Homeside Lending, Inc., successor by merger to Barnett Mortgage Company vs. David L. Jumper Atty.: Leon P. Haller ALL THAT CERTAIN piece or par- cel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described in accordance with a sur- vey and plan thereof, prepared by Ernest J. Walker, Registered Engi- neer, Camp Hill, Pennsylvania, dated October 5, 1964, as follows: BEGINNING at a point on the southeastern line of Fifteenth Street, said point being eighty-four and forty-two hundredths (84.42) feet southwest of Water Street; thence through the center of a partition wall Roge . Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 _day of NOVEMBER. 2002 NOTARIAL SEAL !/ LUIS E. SNP R, Notary PWk Cerlisle Boro, C;umberEarid Cotg* My Cwmbsioa Expires March 5; separating premises known as No. 128 and 132 Fifteenth Street and beyond, south thirty-six (36) de- grees twenty-eight (28) minutes East, one hundred fourteen and twelve one-hundredths (114.12) feet to a point; thence South fifty-three (53) degrees thirty-two (32) minutes West, twenty-five and six-tenths (25.6) feet to a point on line of lands now or late of Richard Moses; thence along said lands North thirty-six (36) degrees twenty-eight (28) minutes west, one hundred thirteen and eighty-five hundredths (113.85) feet to a point on the southeastern line of Fifteenth Street; thence along the line of Fifteenth Street, North fifty- two (52) degrees fifty-six (56) min- utes East, twenty-five and fifty-nine hundredths (25.59) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 132 FIFTEENTH STREET, NEW CUMBERLAND, PA 17070. BEING THE SAME PREMISES WHICH Cleo J. Spencer by deed dated 9/21/95 and recorded 9/22/ 95 in Deed Book 128 Page 696 granted and conveyed unto David L. Jumper. TO BE SOLD AS THE PROPER- TY OF DAVID L. JUMPER ON JUDG- MENT NO. 2002 3032. ASSESSMENT #26-23-0541-217. p 114r?