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: IN MORTGAGE FORECLOSURE
VI.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACI'ION . LAW
: No.3' 3 CIVIL 1994
JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wife,
Plalntlffl
TANYA M. KEPPLEY,
Defendant
.
.
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 an attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR 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.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wife,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: CIVIL ACTION - LAW
: NO. CIVIL 1994
.
.
TANYA M. KEPPLEY,
Defendant
: IN MORTGAGE FORECLOSURE
COM.,Pl..AINT
NOW comes the plaintiff, by its attorneys, IRWIN, IRWIN & McKNIGHT, Esquires,
and files this complaint, representing as follows:
1, The plaintiffs are Jeffrey A, Heckman and Sheri S, Heckman, adult individuals residing
at 2 Briar Oak Lane, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Tanya M, Keppley, an adult individual residing at the Cumberland
County Prison, Claremont Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. On September 23, 1986, defendant executed and delivered an installment sales
contract, a copy of which is incorporated herein, attached hereto and made a part hereof as
Exhibit "A", to plaintiffs, secured upon the premises more particularly described in Exhibit "A".
4. That default has been made in the tenns and conditions of the mortgage in that
defendant has failed to pay installments of interest and principal due for March, 1993, to date,
failed to pay property taxes, failed to maintain homeowners' insurance coverage and failed to
maintain the property in proper condition, all in violation of the tenns of the agreement.
5, That the entire condition, money or sum of $17,000.00 has become due and payable,
together with interest at Ten and no/100 (10.00%) percent per annum and attorney's fees for the
collection of said sum in accordance with the tenns of the agreement, less such sums as have been
paid on account of principal of the agreement.
6, That no judgment has been entered upon said agreement in any jurisdiction.
7. That the defendant is not engaged in the federal services or on active or inactive duty in
the United States Anny, Navy, Coast Guard, Marine Corps nor is defendant an active member of
the anned forces of any state or territory of the United States of America, nor engaged in any way
which would bring the defendant within the provisions ofthe Soldiers' and Sailors' Civil Relief Act
approved October 18, 1940, as amended,
8. That the plaintiffs have complied with the requirements of the Act of Assembly dated
January 30, 1074, known as Act No.6, 1974, with respect to notice of intention to foreclose to
the defendant, and Act No. 91, 1984, with respect to credit counseling, and the defendant has
failed to reinstate the agreement in accordance with the provisions thereof.
9. That the following amounts are due on the agreement:
Principal of agreement
Interest to February 23, 1994
Unpaid Real Estate Taxes
Insurance Premiums
Maintenance
Attorney's fee
Total Due
512,596.06
1,259.61
2,472.03
294,00
34.97
750,00
517,406.67
WHEREFORE, plaintiffs demand judgment against defendant in the sum of Seventeen
Thousand Four Hundred Six and 67/100 (517,406,67) Dollars, plus interest, taxes, insurance and
maintenance expenses and costs from February 23, 1994,
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
(717) 249.2353
Supreme Court 10 No, 29920
JlERlnCA TION
The foregoing answer is based upon infonnation which has been gathered by my counsel
in the preparation of this lawsuit. The language of the document is the language of my counsel
and not my own. I have read the answer and to the extent that it is based upon infonnation which
I have given to my counsel, it is true and correct to the best of my knowledge, infonnation and
belief. To the extent that the content of the answer is that of counsel, I have relied upon counsel
in making this verification. I understand that false statements made herein are subject to the
penalties of 18 Pa,C.S.A. Section 4094, relating to unsworn falsification to authorities.
January :.25. 1994
, (/fLi:ci~1
JE
" ,
. '
INSTALLMENT SALES AGREEMENT
,
This agr~~m~nt is enlured into this t\', day of September,
I ~86, by and lJetlleen
JEFFREY A. HECKMAN
Middleton lownship,
called SELLERS; and
and SHEKI S, HECKMAN, his wife, of North
Cumberland County, Pennsylvani~, hereinafter
TAI/YA H. KEPPLEY, of North Middleton Township, Cumberland County,
Pennsylvania, h~reinafter called PURCHASER;
IT IS MUTUALLY AGREED AS FOLLOWS:
I. SELLERS agree to sell, grant and convey to the PURCHASER, and
PURCHASER agrees to purchase and accept the conveyance of the
real property located in I/orth Middleton Township, Cumberland
County, Pennsyl~ania, being known as 620 Conodoguinet Avenue,
Carlisle, Cumb~rland County, Pennsylvania 17013, and as described
in the attached Exhibit "A", which is incorporated herein by
reference.
2. PURCHASER agrees to pay the sum of $22,000.00 to SELLERS,
payable as follows: $5,000.00 on the signing of this agreement,
receipt of which sum is her~by acknowledged, and the balance of
the purchase price being $17,000.00, in monthly installments of
SlB2.69 beginning on October t.l...., 1986, payments being applied
first to interest at the rate of 10.007. per annem and then to
pdncipa1. Said monthly installments shall conti/lue to be due on
t he \.l~ day of each month thereafter unt i 1 September 1.1",
20CII, unless said timl' is l'xtl'nded in writing, at which time
PURCHASER ag,','0 tn pay any remaining balance of the purchase
price and any interest in full and SELLERS Shill convey the
premises to PURCHASER in fee simple, by general warranty deed,
frlle and clear of all encumttrances, excl!pt eds~ments, visible or
of record, and building and use restrictions. PURCHASER shall
have the opt ion at any time before the balance is paid in full to
pay the entire balance due and receive a deed as provided above,
or may make additional payments of principal on the due date of
dny installment.
3. PURCHASER agrees to pdy the taxes for 1986 and succeeding
years and to keep thl' prl'mises in a good state of repair. The
PURCHASER agrees not tu mJke any substantial alterations in the
cl1ndi: ion of thl' pr!'misl'S I~ithout first securing the written
consent of the SELLERS, and all transfl:I' tdxe~ tu be shared
equally at ttll! time of final settll!/1II!nt, except that in the event
PURCHASER sells the premises before taking title herself, SELLERS
shall pay no transfer taxes.
4. PURCHASER shall be entitled to possession of the premises
im::,ediately.
5. PURCHASER assumes all risk and responsibility for accidents,
injury or damage to persons or property and to herself and others
on said premises and agree to indemnify and hold harmless SELLERS
from all liability therefrom. PURCHASER shall procure and
maintain general homeowners insurance coverage in the amount of
at least $17,000.00 and naming SELLERS as loss payee.
6. On defdul: of .ny monthly installments or in performance of
any other ob1igdtions under this agreement, for over thirty days,
SELLERS may declar(' this ilgr('rm~nt to be ended, rl'taining all
payments made tv thdt time as liquidated damages and in such
event, the prothonotary or any attorney of dny court of record of
Cumberland County is hereby authorized to appear for and to
confess judgment in an amicclble act ion of ejectment against said
PURCHASER, her heirs, dssigns, executors, administrators or
lessees, dnd in lavor of SELLERS, their heirs, successors or
assigns, for the premises h~rein described, and to direct the
immediate issuing iJf a writ of possession ~lith writ of execution
for costs, includIng attornlY fees without notice and without
asking leaVE of Court, or at the option of the SELLERS, said
prothonotal'y Lr attorney is authorized to confess a judgment
against the PURCHASER dnd in fovor of SELLERS for the entire
unpaid balance of thl' purchase price, together with costs,
interest, ins~rdnc( payments, etc., and attorney fees.
7. The interest of the PURCHASER in this contract shall not be
assignable by sale, assignment, lease, subleasing or otherwise,
in whole or in part, without the prior written consent of
SELLERS, vnct if such assiglllnent is attempted, the rights
stipulated In ~aragraph six shall accrue to SELLERS. Passing of
tItle by will or by intestacy shall not be regarded as a
fDrbidden assignm~nt. SELLERS agree not to unreasonably withhold
d requested consent.
,'~ ",,~_. '. . "~."".'-
"
8. In the event SELLERS are unable to give title to PURCHASER as
set forth above, PURCHASER shall have the option of taking such
title as the SELLERS can give without abatement of price or of
being repaid all monies paid on account by PURCHASER to SELLERS
and in the latt~r event, there shall be no further liability or
obligation by either of the parties, one to the other, and this
agreement shall become null and void and of no effect.
9, Failure of SELLERS to insist on strict performance by
PURCHASER of the terms of this agreement shall not be construed
as a waiver, releasL' or relinquishment thereof.
10. This agreement shall inure to and be binding upon the heirs,
executors, administrators and assigns of the parties hereto.
11. This agreement contains the entire agreement between the
parties and there are no other terms, obligations, covenants,
representations, statements or conditions, oral or otherwise, of
any kind whatsoever concerning this sale. The provisions of this
agreement supercede any and all prior writings between the
parties. Any changes or additions to this agreement must be made
i~ writing and Er.ecuted by the parties hereto.
12. Time is hereby declared to be of the essence.
13. All payments, notices and documents require by this
a~r~em~nt shall be sufficiently delivered if mdiled by certified
mail, postag~ prepaid, return receipt requested, or personally
delivered to one of the parties to this agreement as follows:
A. Mil. AllO IIRS. JEFFREY A. HECKMAN
2 Briar Oak Lane
Carlisle, Pennsylvania 17013
B. lANYA M. KEPPLEY
620 Conodoguinet Avenue
CARLISLE, PA 17013
i~
,
"
or at such olh~r address at which either party notifies the other
in writ ing.
IN WITNESS WHEREOF, the parti~s have hereunlo set their hands and
spals th~ day dnd yedr first above wrilten.
W\TNE~SEU BY:
0Zcr0cL
EAl)
~~.w
~'M-Jlt__~n ~rAl)
TfUY A '110. KEPPLE
STATE OF PENNSYLVANIA:
SS:
CUUNTY OF CU~:SERLArW :
Personally appeared bl'fof(' '"~ a notary publ ic. on Septem:"cr
U~. 1986, J~ffrey A. Heckman, Sheri S. Heckman, his I/ife, and
Ihnya S. Keppley, knol/n to me or satisfactorily proven to be the
persons who executed the above agreement and who acknowledged
that they executed the above agreement for the purposes therein
contained.
~
No .a."y
ROGER ,IR IN, r:OTARY PUClIC
CARLISLE B . CUMBERlAND COUNlY
IIY COMMISSION EXPIRES OCI. 3, 1988
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SHERIFF'S RETURN
CCl>1MONWEAL'IH OF PENNSYLVANIA:
COUNl'Y OF CLMBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 313 Civil Term 1994
Complaint in Mortgage Foreclosure
and Notice
Jeffrey A. Heckman and
Sheri S. HeckMan, his wife
VS
Tanya M. Keppley
J. Michael Ickes
, ~Kf{Jb1t Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within Complain t in Mortgage Foreclosure and Notice
upon TAnya M. Keppley
, the defendant, at
1:50
o'clock
P.M. EST I JeXlZX, on the
31
day of January
, 1994 at
1101 Claremont Road, Carlisle (Cumberland
County Prison)
Pennsylvania, by handing to Tanya M. Keppley
, Cumberland County,
a true and attested copy of the Complaint in Mortgage Foreclosure and Nqtice
and at the same tllne directing
her
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
14.00
2.80
-' ~/4
t..~'..-~.... .. ., ..... ::??"" .-:...
.rfdJ.<","',-,;,,~~ /, ~
R. Thanas Kline, Sheriff
2.00
18.80 Pd. by Atty.
2-01-94
by
J 11t~IaJ 4iM
,;/
Deputy Sheriff
Sworn and subscribed to before me
this S ~
day of j-l.t....~...~"
f
19 1'( A.D.
(+!-'- () 111.}C,.
Prothonotary
I...~P./7'
; -,
.'
JEFFREY A. HECKMAN and
SHEW S. HECKMAN, his wife
Plain tilT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
: CIVIL ACTION - LAW
vs.
: NO. 313 CIVIL 1994
TANYA M. KEPPLEY,
Defendant
: IN MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Please enter a default judgment against the defendant in the above matter for failure to
respond to the complaint within twenty days of service thereof. Enter judgment for the following:
Principal
Interest thru June 8, 1994
Unpaid Real Estate Taxes
Insurance Premiums
Maintenance
Attorney Fees
TOTAL
$12,596,06
1,627.04
2,829.42
294,00
34,97
750.00
$18,131.49,
plus costs of this action,
February 21,1994
mWIN, mWIN & McKNIGHT
aM>---zi/
BY:
HAROLD S. mWIN,
Attorney for Plaintiff
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court ID No, 29920
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IRWIN, IRWIN & ~rcJ{NIGlIT
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JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wife,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
VS.
: NO, 313 CIVIL 1994
TANYA M. KEPPLEY,
Defendant
.
.
: IN FORECLOSURE
(iFFIDA VIT
Harold S. Irwin, nI, attorney for the plaintiffs in this action, does hereby certii}' that I
served a copy of the notice of Sheriff Sale upon all lienholders and mortgage holders and upon
every other person who has any interest in or record lien, as of the date of the filing of the writ of
execution in this matter, on the property located at 620 Conodoguinet Road, Carlisle, Cumberland
County, PeMsylvania. The persons or entities so notified are as provided on the attached
AFFIDAVIT PURSUANT TO RULE 3129, and a copy of the NOTICE OF SHERIFF SALE
provided to each of the above is also attached hereto, Further a copy of the signed receipt
evidencing service of the aforesaid notice to said persons or entities is also attached.
IR','~WIN & M.CKNIGHT
{J<!J/llY-u1-
Harold S. Irwin, m
Attorney for plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle. PA 17013
(717) 249-2353
Supreme Court ID NO. 29920
Sworn to and S~ribed
before me this day
o~ 1994.
1D1 '\.
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Caltl:Jo,;- [;':-,7,. C.;-n':(."~.;.i(A:xI:1:Y
MyCOHnll-:,CIl E:..;~,..t. ['1:';, 1!1. 19r\1
MonlblJr, PI.'flnS'/f:'.:JOld/~~ICf No'.a::.c.J
TANYA M KEPPLEY
1101 CLAREMONT RD
CARLISLE PA 17013
I a110 wish to ruceive the
following services lIor an IX".
f..):
1, 0 Add........ Add....
6 IK1 R..trict.d D.liv.rv.:)
Consult ostmalter 'Of tee.
40. Article Number
P 282 342 259 ~ ;
4b. Servico Type ~ :
o R.gl.t.r.d 0 In.u..d '" !
l!!I C.llifi.d 0 CDD " ,
o bp.... Mail 0 R.turn R.c.ipt f.. !l,
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JEFFREY A HECK/oIAN
2 BRIAR OAK LANE
CARLISLE PA 17013
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AFFIDAVIT PURSUANT IQRULE 3129
HAROLD S, mWIN, m, attorney for the plaintiff in the above action, sets fonh as of
the date of the praecipe for the writ of execution was filed the following information concerning
the real propeny located at 620 Conodoguinet Avenue, Carlisle, Cumberland County. PA 17013.
1. Name and adress of owner{s) or reputed owner{s):
Name:
Address:
A. leffieyA. Heckman
Sheri S. Heckman
2 Briar Oak Lane
CarlislePA 17013
B. Tanya M. Keppley
I 101 Claremont Road
Carlisle PA 17013
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A. Tanya M, Keppley
1101 Claremont Road
Carlisle PA 17013
3. Name a"d Address of f!1.e1'J'judgment creditor Il'II0sejudgment is a record lien on the real
property to be sold:
Name:
Address:
A. leffiey A. Heckman
Sheri S. Heckman
2 Briar Oak Lane
Carlisle, PA 17013
4. Name and address of the last recorded 1/OIder of f!1'e1'J.mortgage of record:
Name:
Address:
NONE
S. Name and address of el'el)' other person who has,'an)' interest in or record lien on the
pro perf)' and wllose interest may be affected b)' the sale:
Name:
Address:
NONE
6. Name and address of e1'el)' other person of wi IOtII the plaintiff has knowledge who has any
interest in the pro perf)' wllich may be affected by the sale:
Name:
Address:
NONE
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or infonnation and belief. I understand that false statements made herein are
made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
March 9, 1994
IRWIN, IRWIN & McKNIGHT
BY~~~
Attorney for plaintiff
60 West Pomfret Street
Carlisle, PA 17013
(717) 249.2353
VS.
TANYA M. KEPPLEY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTI', PENNSYLVANIA
: NO. 313 CIVIL 1994
JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wife,
Plaintiff
: IN FORECLOSURE
NOTICE OF SHERIFF SAI,E OF REAl, PROPERTY
PURSUANT TO PENNSl'LI'ANIA RULE OF CIVIL fROCEDURE 3129
- -
TAKE NOTICE:
That the sheriffs sale of real property (real estate) will be held on June 8, 1994. in the
COMMISSIONERSI HEARING ROOM, CUMBERLAND COUNTY COURTHOUSE,
CARLISLE, PENNSYLVANIA, at 10:00 A.M" prevailing local time,
THE PROPERTI' TO BE SOLD IS described in detail in a legal description mainly
consisting of a statement of the measured boundaries of the propeny, 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:
620 Conodoguinet Road
Carlisle PA 17013
THE JUDGMENT under or pursuant to which the propeny is being sold is docketed to:'
313 CIVIL 1994
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS PROPERTY IS:
Jeffrey A, Heckman and Sheri g, Heckman (Legal Owners)
Tanya M, Keppley (Equitable Owner)
A SCHEDULE OF DISTRIBUTION, being a list of the persons andlor governmental or
corporate entities or agencies being entitled to receive pan of the proceeds of the sale received
and to be disbursed by the sheriff (for example, to banks that hold mongages and municipalities
that are owed taxes) \\ill be filed by the sheriff within (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact. be made unless someone objecls
by filing exceptions to it \\ithin ten days of the date it is filed, lnfonnation about the schedule of
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distribution may be obtained from the sheriff of the COurt of Common Pleas of Cumberland
County, Courthouse, Carlisle, PA,
THIS PAPER ~ A NOTICE QE 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 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 TillS PAPER TO YOUR LAWYER AI ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
- - ----
CAN !ill FREE LEGAL ADVICE:
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240.6200
THE LEGA L RIGHTS YOU MAY HA VE dBE.;,
I. You may file a petition with the Court of Common Pleas of Cumberland 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 a petition \vith the same court if you are aware
of a lega] 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
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
The 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 Cumberland County at one of the
court's regularly scheduled business sessions, The petition must be served on the attorney for the
creditor or on the creditor at least two (2) business days 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, Cumberland County Courthouse,
Carlisle, Pennsylvania, before presentation the petition to the court.
A copy of the writ of execution is attached hereto.
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fjlAEClPE FOR WIfIT OF EXECUTION. (MONEY .(UnGMENT~
P.R.CP. NO. 3101 TO 3149 ETC
JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wife,
Plaintiff
VS.
TANYA M. KEPPLEY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNlY, PENNSYLVANIA
: Writ No. 313 CIVIL 1994
: No. 313 CIVIL 1994
: Amount Due: S 17,381.49
: Atty's Comm: S__ 7S0.00 _;", 111'., ~ 131 ,LA
: Costs: S 839.30
: Total: S 18,970.79
: PLUS COSTS AND INTEREST AT 10%
: PER ANNUM UNTIL DATE OF PAYMENT
To the Prothonotary of said Court: ISSUE WRIT OF EXECUTION IN THE ABOVE
MA TIER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) Against Tanya M. Keppley, defendant; and
(3) Index this writ against Tanya M. Keppley, defendant.
(4) Execute against the real estate of defendant located at 620 Conodoguinet Avenue, Carlisle,
Cumberland County, Pennsylvania 17013.
(5) Exemption has been waived.
March 9,1994
IRWIN, IRWIN & McKNIGHT
I~ 'Vt
HAROLD S. IRW
for plaintiff
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JEFFREY A. HECKMAN and
SHERI S. HECKMAN, his wire,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
TANYA M. KEPPLEY,
Derendant
: NO. 313 CIVIL 1994
: IN FORECLOSURE
NOTICE OF SHERIFF SAI.E OF REAL PROPERTY
PUR.'i..UANT m PENNSYLVANIA RUI.E OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the sherift's sale of real property (real estate) will be held on June 8. 1994, in the
COMMISSIONERS' HEARING ROOM, CUMBERLAND COUNTY COURTHOUSE,
CARLISLE, PENNSYLVANIA, at 10:00 A.M., prevailing local time.
THE PROPERTY TO BE SOLD ]S described 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:
620 Conodoguinet Road
CarlislePA 17013
THE JUDGMENT under or pursuant to which the property is being sold is docketed to:
313 CIVIL 1994
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS PROPERTY IS:
Jeffrey A. Heckman and Sheri S. Heckman (Legal Owners)
Tanya M. Keppley (Equitable Owner)
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 (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 days of the date it is filed. Information about the schedule of
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
~ ,
distribution may be obtained from the sheriff of the Court of Common Pleas of Cumberland
County, Courthouse, Carlisle, PA.
THIS PAPER IS!! NOTICE OF THE TIME AND PLACE QE THE SALE QE
YOUR PROPERTY. ]t has been issued because there is a judgment against you. It may cause
your property 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 !!I ONCE. !ill IQ
OR TELEPHONE :rm; OFFICE SET fORTH BELOW TO FIND OUT WHERE YOU
~ GET FREE LEGAL ADVICE:
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland 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 a 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 sherift's sale you may file a petition with the Court of Common Pleas of
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
The petition must be filed before the sherift'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 Cumberland County at one of the
court's regularly scheduled business sessions. The petition must be served on the attorney for the
creditor or on the creditor at least two (2) business days before presentation to the court and a
proposed order or rule must be attached to the petition. ]f a specific return date is desired, such
date must be obtained from the court administrator's office, Cumberland County Courthouse,
Carlisle, Pennsylvania. before presentation the petition to the court.
A copy of the writ of execution is attached hereto.
.,.
, .
....1. ".:;t ct'l'ldn l.,t ..! r,rocr.l' ,'ilh the improver.lents thereon erected situate
. . ~! ~I ~l.ld:rlcn ll'~': chip. C'I!'l"~rhnJ Cou:lly, Pennsylvani3, bounded and
',:: U cd !1:; follows:
.'r.:"'.:.I:: r.l a poirol c" ll.e ~o"lh~rr: sid" oC a twenty (20) Coot wide public
..il..' I ~ the northrr.sLHn COlner or Lot tic. 19 as shown on the herelnaCter
. I.' iv~.'d Plan oC LoIs. "hich rlace oC be!;innin& is three hundred reventy-
:.... ..:..1 Clet)' hundredll.., (311.50) feet cut of the eastern line of & thirty
'J:') ;c ~t ",ic!e I.ubllc r~nl' tnoW:l os T-486; thence southwardly a10n!; lhe
. I': !'"Il 1 in~ (\{ Cti~t1 ~.r" ':0. 1'. nl'_" Or" rormerly of \Jo.yne ','.1.y10[", a distance
.1 l~r LunJl'cd revrr:I,.fivo illS) (peL to a roint on the northern line of
:.....:,;. 'I~cok r~l'l:; 1I".I':e ,:'rtwerdly ~Ionl\ the northern line or Meadow Brocl:
I..:',. _ disL."re uf C"l'lj' C..f.) reel 10 P p~ir.t at the soull;w::st cOt'ner of
~~l ~3. 21 os sho~a on sai~ hereinArlcr ~t'ntloned Plan of Lots: thence In &
:.' ,.t!.cl'ly dlnctlon nll>n:; thl' weste'rn line of raid Lot No. 21, M.I or for-
..er') or E. c. Er~:el'd, a <'hlance of one hundt'ed seventy-five (175) feet to
.. ..,illl 0:1 H.t' soulhern line of said twenty (20). root wide public alley:
I:' :..e westwardly 41u,,& t~e southern line of said twenty (:<0) foot ,,:de
IrLllc elley, a dislan e or rotly (40) feet to a point, the place of BEGIN-
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AFFIDAVIT PURSUANT TO RULE 3129
-
HAROLD S. IRWIN, m, attorney for the plaintiff in the above action, sets forth as of
the date of the praecipe for the writ of execution was filed the following information concerning
the real property located at 620 Conodoguinet Avenue, Carlisle, Cumberland County, PA 17013.
1. Name and adress of OIvner(s) or reputed OIvner(s):
Name:
Address:
A, JeffreyA, Heckman
Sheri S. Heckman
2 Briar Oak Lane
Carlisle PA 17013
B. Tanya M. Keppley
1101 Claremont Road
Carlisle PA 17013
2. Name and address of defendant(s) in the judgment:
Name:
Address:
A. Tanya M. Keppley
1101 Claremont Road
CarlislePA 17013
3. Name and Address of every judgment creditor ",hose judgment is a record lien on the real
property to be sold:
Name:
Address:
A. Jeffrey A. Heckman
Sheri S. Heckman
2 Briar Oak Lane
Carlisle, P A 17013
4. Name and address of the last recorded holder of every mortgage of record:
Name:
Address:
NONE
March 9,1994
IRWIN, IRWIN & McKNIGHT
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5. Name and address of eve". other person who has any Interest In or record lien on the
property and whose Interest may be affected by the sale:
Name:
Address:
NONE
6. Name and address of lWe". other person of whom the plaintiff has knowledge who has any
Interest In the property which may be affected by the sale:
Name:
Address:
NONE
] verity 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 made herein are
made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to
authorities.
By: Harold S. Irwin, ill
Attorney for plaintiff
60 West PomtTet Street
Carlisle, PA 17013
(717) 249-2353
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JEFFREY A. HECKMAN and
SHERI S, HECKMAN, his wife,
Plain tilT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 313 CIVIL 1994
VS,
TANYA M, KEPPLEY,
Defendant
,
.
: IN FORECLOSURE
AFFIDA V1T
Harold S. Irwin, III, being duly sworn according to law, deposes and says that he is an
attorney with the law firm of Irwin, Irwin & Irwin, counsel for plaintiff herein, and as agent of
plaintiff, is duly authorized to make this affidavit on its behalf and that affiant has knowledge of
the facts contained in this affidavit. The affiant further states that defendant above named is the
equitable owner of a certain parcel of real estate situate in Cumberland County, PeMSylvania, and
that her last known address is as follows:
Tanya M. Keppley
1101 Claremont Road
Carlisle PA 17013
The affiant further states that the information contained herein is true and correct to the
best of his laiowledge, information and belief.
IRWIN, IRWIN & McKNIGHT
Sworn to and su~~cribed
before me this ~day
of March, 1994,
By: {
HAROLD S. IRWIN, III
No::UiilIS',:.i1
lJct:j A. 1.1omson. NOI<1'Y Puhf<:
Cart<le Iloro, Cu"~>lol,,1 CO<lnlV
My com""""," E ';>n:<; 0<>: 15. 1 'l'JG
Mt.'fltlCr. Pcnr'f.-ylYar~k.soo..lt<.lf1 m ~
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55,
Robert P Ziegler
I, ___ __00___ _nn______ _ ___.nnn_nn_n _u u_.nn 0000 ______n___nn_n _ _. __ Recorder or
I)eed. In and ror said Counl)' and Slale do hereb)' certir)' Ih.t Ihe SherUr. Deed in whleh _____0000_00____
Jeffrey A Heckman and Sheri S Heckman .
___.______nn_n____n_____u_____n__nn__n_ n_nn_____n_n_u____nn_n_nn IS the gran Ie<.'
lhe .ame hl\Vin!: hcell .old to said !:ralllee on Ihe -u--_~.!'_I~_____n__n________nn_n__nu___n day or
June 94
_____nn______nn__nn__________n_n A. D.. 19_____00_' under and by virtue or a wriln__uu_nn_
execution . 10th
______n___nnnnnnn___ __00 n_____n_____n ...ued on the. __ ___0000_ n__n___nn_U_____n ___
March 94
da)' or nu_h____n_nnn___n_ A. D., 19___00_' oul or the Court or Conllnan Plea.. or .aid COUIII)' a.. or
Civil 94
_u________nnu____nnu___nnn_________n_ u______n___nn_nnn__nn_n Tern.. 19_000.__
313 . Jeffrey A Heckman and Sheri S Heckman
Number nnu__nn__, at the,ull or -nn-__nnn___n_n_nn_____n_____nn_n_nnu______n__
. Tanya M Keppley
-- - _nn n _ 00 00_ __ - __ 00 n _ _ _. _ _ __ _ _ agaln"_ _ _ _ _ _ _ _.. _ _ _ _ _ n _ _ _ _ 00 __ _. n 00 __ _ _00 ___ _ nn __ 00 __ _ i.
dul)' recorded in Sherirr. need Book No. _~_~qn__._.. I'age _._~~_1.._____.
IN TESTIMONY WHEREOF, I have hereunto
.ellll)' hand and .eal or .aid ornee th;" ___gJ..~ day
or mnn~~n~-~T~' n.,19_?_~___
______________~--5t"~:-~-~-------
. f .<r.-.f<-?Recorder or Deed.
NOTIRIAl SEAL
RECORDER Of DEEDS. IIOTARY PUBLIC
CARLISLE. CUMBERlAIlD COUNTY COURT HOUSE
MY COW.'ISSION rxPIRES JANUARY I. 1998
Writ No, 313 Civil Term, 1994
Robert L, Fink, Deputy Sheriff, who being duly sworn according
to law, says on April 5, 1994 at 12:15 o'clock P.M" E.D,S,T., he
posted the property of Tanya M. Keppley at 620 Condoguinet Avenue, Carlisle,
Cumberland County, Pennsylvania with a copy of Real Estate Writ, Notice,
Poster and Description according to law,
Barry J. Horn, Deputy Sheriff, who being duly sworn according to
law, says on April 19, 1994 at 4:05 o'clock P,M., E,D.S,T" he served
true copies of Real estate WRit, Notice, Poster and Description in the
above entitled action upon the within named defendant, to wit: Tanya M,
Keppley by making known unto Tanya M. Keppley at Cumberland County
Sheriff's Office, Courthouse, Carlisle, Cumberland County, Pennsylvania,
its contents and at the same time handing to her personally the said true
and attested copies of the same.
R, Thomas Kline, Sheriff, who being duly sworn according to law.
says that he served the above Real Estate Writ, Notice, Poster and
Description in the following manner: The Sehriff mailed one of the
within named defendants, to wit: Tanya M. Keppley a notice of the
pendency of the action by regular mail to her last known address at 134
N. Hanover Street, Casmetech Studios, Carlisle, Pennsylvania, 17013.
This letter was mailed under the date of April 20, 1994 and was never
returned to the Sheriff's Office.
R, Thomas Kline, Sheriff, who being duly sworn according to law,
says 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, Calrisle, Cumberland County, Pennsylvania on June 8, 1994
at 10:00 o'clock A.M., E.D.S.T., and sold the same for the sum of $1,00
to Attorney Harold S, Irwin III for Jeffrey A. Heckman and Sheri S, Heckman
Their heirs and assigns, It being the highest bid and the best price
received for the same Jeffrey A, Heckman and Sheri S. Heckman at 2 Briar
Oak Lane, Carlisle, Pennsylvania 17013, being the buyer in this
Execution paid Sheriff R. Thomas Kline the sum of $1,039.45 it being bid
price poundage, stamps etc. Sheriff's Costs listed below. See attached
distribution sheet for additional costs.
Sheriff's Costs:
Docketing
Poundage
Pos ting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Cert Mail
Levy
Surcharge
So answers:
18.00
371. 65
9.00
9.00
10.00
7.00
.50
1.00
5.60
3,34
7.00
4.00
446.09
. ..'~
.,,:-i'Y .... i.;r:.....:,.......J,:.... ." . -v..
R, Thomas Klin€,'sheriff
by
atLot.O~ )1, Oih/YJfA.-/
Real state Deputy
Pd, by Atty.
8-19-94
Sworn and subscrjbed to before me
this ;).,!!- day of U~1".,r
19')1 A.. D. 7.,...... c. ~ . A,[M
lua;;;~
U' 100 - }.fl
. ;. ,'D ..iJ. ,.. /'/ '/';7
./u"'" ~
-
JEFFREY A, HECKMAN and
SHERI S, HECKMAN, his wife,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 313 CIVIL 1994
: IN FORECLOSURE
VS,
TANYA M, KEPPLEY,
Derendant
NOTICE OF SHERIFF SAI.E OF REAl. PROPERTY
PURSUANT TO PENNSYLVANIA !WI.E OF CIVIL PROCEDfl.RE 3129
TAKE NOTICE:
That the sherift's sale of real property (real estate) will be held on June 8, 1994, in the
COMMISSIONERS' HEARING ROOM, CUMBERLAND COUNTY COURTHOUSE,
CARLISLE, PENNSYLVANIA, at 10:00 A.M., prevailing local time,
THE PROPERTY TO BE SOLD IS described 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:
620 Conodoguinet Road
Carlisle PA 17013
THE JUDGMENT under or pursuant to which the property is being sold is docketed to:
313 C]VIL 1994
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS PROPERTY IS:
Jeffi'ey A. Heckman and Sheri S. Heckman (Legal Owners)
Tanya M. Keppley (Equitable Owner)
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 (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 days of the date it is filed. Information about the schedule of
distribution may be obtained from the sheriff of the Court of Common Pleas of Cumberland
County, Courthouse, Carlisle, PA.
~ PAPER IS A JIIOTICE QE THE TIME AND PLACE QE THE SALE QE
YOUR PROPERTY. It has been issued because there is a judgment against you, It may cause
your property 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 specifieally of these rights, If you wish
to exercise your rights, you must act promptly.
X21! ~HOULD TAKE THI$ PAPER IQ YOUR LAWYER !!I ONCE. !ill m
OR TELEPHONE THE 9FFICt( SET FORTH BELOW IQ FIND W!I WHERE XQ!!
CAN GET FREE LEGAL ADVlCE~
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
:rm; LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland 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 a 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 sherift's sale you may file a petition with the Court of Common Pleas of
Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause.
The petition must be filed before the sherift'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 Cumberland County at one of the
court's regularly scheduled business sessions, The petition must be served on the attorney for the
creditor or on the creditor at least two (2) business days 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, Cumberland County Courthouse,
Carlisle, Pennsylvania, before presentation the petition to the court.
A copy of the writ of execution is attached hereto.
. .
'.,1. ".:;: crrtcin l,t I.f r,rOUr.l' ,'ith the improver.lents thel'eon el'ected situate
, . ~!!l ~i.ld:clcll ll,.':.chir. C'ln"~rls::J Cou:lly. pennsylvar.i3, bounded and
".:; i: ('d :l~ rollcws:
,'r,:".:.:.I:: nl a polr.l CI; U.e ~o"th"r" cidn of a twenty (20) foot wide public
. .;l... . ~ the northrr.slHn COlner of Lot Ne. 19 as shoW:! on the hereinartel'
. I,' iur...:1 Plan of LOls, ",!lith place oC be&lnnin, is three hundl."ed seventy-
:.;0 ..:..1 fitly hundredll.., 1371.50) Ceet ust oC the eastern line oC a thil."ty
:,:>) ;",t ...Ic!" I.uhll c r~n~ tnoWlS llS T-~86; thence southwardly alon& the
. I': ru 1 in..:- n{ ru:cl :.,.,t 1;0. 1'1, n"~' or formerly of \Jeyne 'i..:J.ylor, a distance
.f .n~ Lu::Jl'cd sev~r.IJ,(ivo (175) fret to a roint on the northel."n line oC
:,...':... .t:-CQk r~I.");: lI,',I':e ','rtward)y ~lon!: the northern lir.e oC Mcadow Brocl:
I."". . distance uf C,'rlj' (';(\) fee.t 10 ~ p:>ir.t al the sOulh..."st corner oC
~aL ~~. 21 os sho~a on cal~ hereinr.!lnr At'ntioned Plan of Lots; thence in a
:.. n!.cl'ly dinction "]on:; the western line of said Lot No. 21, ne.1 01' fol."-
..cr') oC E, C. Er~:(!rd. a r'lslance of one hundred seventy-five (175) Ceet to
" (.dlll on H.C' southerll line oC said twenty (20) foot wide public alley;
,:,~.e wcslwQl."dly alu,,& t~e soulhern line of said lwonty (~O) foot ",:de
I "!.llc alley, a llislall e of Corly I~O) Ceet to a point, the place of BEGIN-
I;:t:.;.
~~'~"
,
~
AFFIDAVIT PURSUANT IQRULE 3129
HAROLD S, mWIN, ill, attorney for the plaintiff in the above action, sets forth as of
the date of the praecipe for the writ of execution was filed the following information concerning
the real property located at 620 COllodoguinet Avenue, Carlisle, Cumberland County, PA 17013.
1. Name and adress of owner(s) or reputed owner(s):
Name:
Address:
A. JeffreyA. Heckman
Sheri S. Heckman
2 Briar Oak Lane
Carlisle PA 17013
B. Tanya M. Keppley
11 0 I Claremont Road
CarlislePA 17013
2. Name and address of defendant(s) in the judgment:
Name:
Address:
A. Tanya M. Keppley
1101 Claremont Road
CarlislePA 17013
3. Name and Address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name:
Address:
A. Jeffi'ey A. Heckman
Sheri S. Heckman
2 Briar Oak Lane
Carlisle. PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
Name:
Address:
NONE
..
5. Name and address of t!l'ery other person who has any Interest In or record lien on the
property and whose Interest may be affected by the sale:
Name:
Address:
NONE
6. Nallle ancl address of every other person of whom the plaintiff has knowledge who has any
Interest In ti,e pro perl)' which may be affected by ti,e sale:
Name:
Address:
NONE
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 made herein are
made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
March 9, 1994
IRWIN, IRWIN & McKNIGHT
~
tJ.
By: Harold S. Irwin, m
Attomey for plaintiff
60 West PomtTet Street
Carlisle, PA 17013
(717) 249-2353
-
JEFFREY A, HECKMAN and
SHERI S. HECKMAN, his wIre,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
,
,
VS.
TANYA M, KEPPLEY,
Defendant
: NO. 313 CIVIL 1994
,
,
: IN FORECLOSURE
AFFIDA VlT
Harold S. Irwin, m, being duly sworn according to law, deposes and says that he is an
attorney with the law firm of Irwin, Irwin & Irwin. counsel for plaintiff herein, and as agent of
plaintitr, is duly authorized to make this affidavit on its behalf and that affiant has knowledge of
the facts contained in this affidavit. The affiant further states that defendant above named is the
equitable owner of a certain parcel of real estate situate in Cumberland County, Pennsylvania, and
that her last known address is as follows:
Tanya M. Keppley
11 0 I Claremont Road
Carlisle PA 17013
The affiant further states that the information conlained herein is true and correct to the
best of his knowledge, information and belief.
IRWIN, IRWIN & McKNIGHT
Sworn to and sul?~cribed
before me this ~ day
of March, 1994.
L
By:
HAROLD S.IRWIN,])]
Nct.~~ll~,.:.,1
OctiA M"""",,. tlol"'Y PI.b\::
c.,t,.~, Doro. Cumo,:rt,,,ld Co.l1llV
MyCorr:ntr.:onb;....Lf.,[)c.:.15. HfJG
f&:ntJCt, "'t,;llfll)'h'tlfIJA:.soat&t()ll~ Nct..J.'lOS
, .
W1U'l' OF EXfXl1I'ION and/or A'l'l'l\CIfolENr
CGM>/'oMEAL'll1 OF PENNSYLVANIA)
COlJNl"{ OF CLMBERLAND )
No. 313 CIVIL 19 94
CIVIL ACTION - LAW-
TO 'lllE SHERIFF OF CUrrberland
COllm"{ I
To satisfy the debt, interest and costs due
Jeffrey A. Heckman and Sheri S. Heckman. his wife
from Tanva M. Kecolev
620 Conodoauinet Avenue. Carlisle. PA 17013
PLAINI'IFF( S)
DEFENDANI'(S)
( 1) You are directed to levy upon the property of the defendant ( s) and to sell
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
garnishee ( s) is/are enjoined from paying any debt to or for the aCCXlunt of the defendant ( s)
and from delivering any property of the defenclant(s) or otherwise disposing thereof;
(3) If property of the defendant( s) not levied upon and subject to attachment is found
in the possession of anyone other than a named garnishee, you are directed to not~fy
him/her that he/she has been added as a garnishee and is enjoined as above stated.
lvrount lXIe 18131.49
Interest at 10% per annum until date of
payrrent
Atty's Comn %
Atty Paid $72,00 (includes Sat Fee)
Plaintiff Paid
L.L. $.50
lXIe Prothy $1. 00
Other Costs
DATE: March 10, 1994 Lawrence E. Welker
Prothonotary, Civil Division
by: D JlI,',m. tfJ/lIIJA, r..1iJ
Deputy
REQUESTIl'li PARTY:
Name Harold S. Irwin, III, Esq.
Address: 60 W. Pomfret St.
Carlisle, PA 17013
Attorney for: Plaintiff
Telephone: 717-249-2353
Supreme Court 10 No.
HEAL ES'iAn~ S}\LE No..,
. .
@~~n@m
On 11'1o.......Q.. /I, /11'( the shariff levied u~on the defendants
Interast In the real property situatild In _ .k'f'
Cu"'~~land Counlv p" I'ne..,. ',.' j.,.. ,": '''' I ?/\ "tJ~.r. _..: ,.J-t---
UnJ01 ], 101'1 "h,t~t: ...i\..t 1.....lt.,:...'. ....,... '(;::LW'..J..c.~ '~K-.I'r
Ca.J~[L and more fully .jll~:":i';JlJ'; vol i:."i;iUI"A" WiX! with
thIs writ and by tais refllrencr. Incorp"';jlcO hC'lt<in.
tate: .~ - II . q 'f
By: (JLJ...J-I-:l ~E OtJa4?4-
~~ a..t::tJ4:u-"~
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r Ill'U
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. .
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Proof of Publication of Notlte In The Patriot and The Evening News
and The Sunday Patriot-News
11ader Aet Ko. 1181, "rpro~ed ala, Ie. 1_.
Commonwealth 01 penMlJlvania,} .
Cormtll 01 Dal/pllin ...
........................~!S!}.~~*...~g.r.E~~...............................belnlf duly swom according to law. deposes and aaya:
Asst. Controller
That he Is the ............................of THE PATRIOT. NEWS CO.. a corporation organized and existing
under the laws of the Commonwealth of Penns)'lvanla. with Its principal office and place of buslnesa at
812 to 818 Market Street. In the City of Harrl.burg, County of Dauphin, State of Pennsylvania, owner
and publisher of THE PATRIOT and THE EVENING NEWS and the SUNDAY PATRIOT.NEWS
newspapers of general circulation. printed and published at 812 to 818 Market Street, In the City.
County and State aforeaald; that THE PATRIOT and THE EVENING NEWS and the SUNDAY
PATRIOT. NEWS were established March 4th, 1854, and February 15th, 1917 and September 18th,
1949, respectively, and al1 have been continuously published ever alnce;
That the printed notice or publication which is securely attached hereto la exactly as printed and
26th day of April and
published In their re8'l11ar editions and laaues which appeared on the ..........................................................
the 3rd and lOth days of May 1994.
........................................................................................................................................................................................
That neither he nor said Company Is Interested In the subject matter of aald printed notice or adver.
tlslng, and that all of the allegationa of this statement aa 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 reao1u-
tlon unanimOus1~.'ed &IlCl adopted severally by the stockholders and board of directors of the said
C<>"'lP"lIf'.ud"au UllltIy dulv re.:orded In the office fOll t~e . eco. rdlng of De.eds In and for aald County
of1"iio'...."IOi.\nATlSAllNo.7 "M". Volumrl-l,P'Kr3171 -'\ flAt
WriI No. m I J Ai, I 'riA
c::.-=. ~n" In ..........................6........~~::c.... I :U...~.~.............I..............
ChlI T-..I9M ]..gl:ll
IoIhor A.'-'" Sworn to and subscribed before me.th "''7..T. ......dayof
-""":'""...... ...~~.y..... 1994. /'. ,/ (" /t~ "ff~'
~"'Io.M;w~"~ 'Ii ..~OJllI\3l. .=...f.%J..... ;~.,.........f.t:~::1 .........
... ~~ ..- 'd ._.~ ~ .... lot. oH'ry .1, U~~O"'I, .0 "'X Pu Nota.... Pu ie
_~ - ~- _ allisburo 3"0:,,"\: ~ .,
.....,..... - -... -- 10 M Uu "."""'=; '. '"", 'UM 6 1998
.......... T........ ~ CounIy. hftno Y OlHmJI!ISIDn. t:Z!r ...................... .......................
................w... ~.. -- Mambor.Pc.orcyt'~~"fG'icl~
-:...a:r;:i::i!5:..:::;:':;" Statement OT Aavertl51ng Cosls
_ .......... .... .. lAoh. _ pIoco 01 .
......... b 371.50 loot Iart ...... -T l~ c!:\mg.l?,!i".t.~.!}.g...!;g!.1.!}.1;y....~P..~.t;J,.t.tR...Qj;.u..I1.~...
...:10,...-........--.. ,-: .
....ne. toUfhwonlty .~.~ty-:i'Wr;,;i: Ca t;.*.;.~.!~.!.......~~.:......!.7..9.!.~.................................
~~~.::7~f......poInt...... To THE PATRIOT-NEWS CO., Dr.
...;,.....A..~_-O
~ _..... 01 -poIoIoI For publishing the notice or publication attached hereto on the
........... . ".0 Ioot~,. 24
.. _ ~ ':.2~ i..:'"""": above stated datea . ,.............2.:.:?~....
:w~"*-........_..... P b tl . 1.00
...: lot No. 21. _ Of -"" tt.._ 1'0 a ng same ...........2.48....5...0.....
._...7SIool...poIoI......- T tal · .
............ 701o?i_............,,- 0 ..............................
wetfwDrd" ale", .... MUthtm PM of lOW 20
,..._............._...01o?i...
_............GI_. I R "t f Ad rt"" C Is
TAll7,U~~"::~/:::I~ ::f.~~':~ 5 ecelp or ve ISing 05
mVANlA _WTY TIANIIII TAll ACT AHO
nOU=NS,TIANmIJITWUN miNT publisher of THE PATRIOT and THE EVENING NEWS and the
S\.J'~A' '. AUUV1-'''''''''. 1I"n'spapers of generat circulation. hereby acknowledge receIpt of the
aforesaid notice and publication costs and certifies that the same have been duly paid.
THE PATRIOT-NEWS CO.
Ry..,.......,.........................,................................................
,,",,--- -.. .
Proof of Publication of Notlte In The Patriot and The Evening News
and The Sunday Patriot-News
UDder Act 110. Ar, Arpro...s ),., Ill. 111:IO.
Commonwealth of PenMlIlvaniCl, }
Corlnlll of Dallphin .. :
........................ri~~~.?~!...~~.;:E.g~...............................beln1t duly sworn according to law, deposel and lay.:
Asst. Controller
That he Is the ............................of THE PATRIOT - NEWS CO., a corporation orll'anlzed and exlatlnll'
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of businesa at
812 to 818 Market Street. In the City of Harri.burll', County of Dauphin, State of Pennay1vanla, owner
and publisher of THE PATRIOT and THE EVENING NEWS and the SUNDAY PATRIOT-NEWS
newspapera of Il'eneral circulation, printed and published at 812 to 818 Market Street, In the City.
County and State aforesaid; that THE PATRIOT and THE EVENING NEWS and the SUNDAY
PATRIOT-NEWS were eatabllshed March 4th, 1864, and February 15th, 1917 and September 18th,
1949, respectively, and all have been continuously published ever aince:
That the printed notice or publication which is securely attached hereto Ie exactly as printed and
26th day of April and
published In their rell'\llar editions and Isauea whleh appeared on the ..........................................................
the 3rd and lOth days of May 1994.
........................................................................................................................................................................................
That neither he nor said Company Is Interested In the subject matter of said printed notice or adver.
tlslnll', and that aU of the allell'ations of this statement sa to the time, place and character of publication
are true: and
That he haa personal knowledll'e of the facta aforesaid and Is duly authorized alld empowered to
verify this statement on behalf of The Patriot-News Co. afpresald by virtue and pursuant to a resolu-
tion unanlmoua1y passed and adopted severally by the stqckholders and board of directors of the said
Company and aubsequently duly re.:orded In the office fOil t~e;aecordlnll' of Deeds In and for said County
of Dauphin In MiKell.neoul Book "M". Volume 14. P.~e 317/ (;GL 1, f:~
Cop>, of Notice or Publication ..........................l.......~~:::'-..Ul\J.~............................
Sworn to and subscribed before m~.th ... .. .b......day of
May, 1994. ~ ./ / .
........ ..... . j .e~i?ff~.
...NQJilt\ll~. "=....f.~.... .; ..............;;;...~::1 .........
Torry I, AUSMII, ,.0 hI.'( Pu . Nolaf"/l Pu lie
HaUlsburn. O:t'm:1ln (.; ..,
M Uu."'."""k~; . ."", JUI1Il 6. 199B
.&: Y ommJ8S1Dn. ~ ................... .......................
Stii8miilion~y8rtlsing Costs
C.\\!!\l;?!?F:.!~.!}.c;l...!;.9.!,1,n.j;'i.,..~r...~.t.;i..t.f.li...Qj;.t;i..Q.~...
Ca t;.!!.~.~!:.!.......~~.~......!.7..9.*.~.................................
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached hereto on the
above stated dates - $.........~~.7.:..~.~....
Probatlnll' same $..............~.:.~.~....
Sale No, 7 248.50
Total $............................
Publisher's Receipt for Advertising Costs"
THE PATRIOT-NEWS CO.. publisher of THE PATRIOT and THE EVENING NEWS and the
SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the
aforesaid notice and publication costa and certifies that the same have been duty paid.
THE PATRIOT-NEWS CO.
Ry "...................................................................................
193./u
Proof of Publication of Notice in Cumberland Law
Journal
(Under Act No. 587. Approved May 16, 1929), P.L. 1784
5tate of Pennsylvania)
County of Cumberland )
55.
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 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,
vlz:
APR]L 15.22. 29. 1994
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. .~r.
~Iar// )') / l_
IWIL UTATS IIAL& KO. 7 -::2.1.---..
Roger M. orgenthal
Sworn and subscribed before me
Writ No. 313 Civil t994
Judg, No. 3t3 CIYI11994
Je~ A. Heckman and
Sheri 5. Heckm.n hi. wife
this
APRIL 94
day of 19
~4 ~\.: c;- ~e{~~J
- I
NDIAAII.l SEAl.
JAHlce E HEIlTZlEll, NCTA.- HJ8UC
CUMsElllAND COUNTY. CAA~IM e, PA
MY COMMISSION EXPIRES FEIlliUAH\' 4. 1m
29
va.
Tanya M. Kcpplcy
Atty.: Harold 5. Irwln
ALL th.t certain tot or ground wl\h
\he bnprovmlenta Ihcn:on crcclcd all.
u.te In North Middleton Townahlp.
Cumberland COUnty. P<:nnaylvan\a.
bounded and dcacrIbcd as rollo_,
BEOINNlNO..t . point on the
aou\hcrn alde or. 20 Coot wide rubUc
aDcy.t\he northcaatern c:omcrorloot
No. 19 as .h...... on \he hcrclnallcr
mentioned Plan or loot.. which place
orbcglnnlng I. 371.110 reet East orthe
caatern Une or . 30 root wlde pubUc
road known as T-488: \hence lOuth.
ward1y along \he ...tern Une or said
, ... ..t~ t"" _......... f'.._....,.. ..r'l'..._..
~
,
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 )
55.
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 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,
vlz:
APRIL 15. 22. 29. 1994
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. ~ / ...(}J I
UAL UTA1U"I,UO. 7 - I:{) /1 \..._- ---.,
Roger M. ~~rgenthal
Sworn and subscribed before me
Wrll No. 313 C1vl11994
Judll. No. 313 CIvl11994
Jctrrey A. H.ckman and
Sh.rI S. Hcekman hla wIf.
va.
Tanya M. Keppley
Ally.: Harold S. irwin
ALL that certain tol or lP"'und with
th. Imprcwcm.nla thereon ....e1ed all.
uate In North Mlddl.lon Township.
Cumberland County. Pennsylvania.
bounded and dcacrIb<d as rollo_:
BEOINNlNO, al a polnl on th.
southern alde or.a 20 ....1 wide public
aDeyalthenortheaatcrn carnerorLot
No. 19 as ohown on th. hcrelnaller
m.ntloned Plan or Lola. which place
orbcpmlnllla 371.50 reel Easlorth.
eastern Une or a 30 rool wid. pubU.
road known as T-4ll8: th.nce south.
ward1y along th. eastern Un. or saki
Lot No. 18. now or fonnerly or Wayne
Taylor. a d1atance or 175 rcello a polnl
on the northern Un. or Meadow Brook
Park: th.nce eaalward1y along Ih.
northern Une or Meadow Brook Park.
a d1atance or 40 r.e11o a polnl allh.
southweal corner or LoI No. 21 as
ohown on aaJd h.reInaIler menUoned
Plan or Lola: th.nce In a north.r1y
dlJCIC:Uon along the wealcm Une oraakl
LoI No. 21. now or rormerly or E. C.
Eckcrd. a d1atance or 175 r.ct 10 a
polnl on th. southern Un. or aaJd 20
rool wid. pubU. aDey: then.e weal.
ward1y along th. south.rn Un. or aakI
20 rool wide pubUc aDey. a dIalance or
40 r..llo a polnl. th. Place orBEotN.
NINO.
FULLY EXEMPT FROM PA RE.
ALTYTRANSFERTAXESPURSUANT
TO REO. SEC. 92,52 PENNSYLVANIA
REALTY TRANSFER TAX ACT AND
REOULATIONS-TRANSFER BE.
TWEEN PARENT AND CHILD,
29 APRIL 94
this day of 19
\_~~~\'~ ~ ~-ec}~~J
NOTAAlI.l SEAl. ·
JANice E HEllT2l.EIl. NOTA~V AlBUC
CUUBEIlLAHO COUNTY. CAA:'Ibl E, PA
MY COMMISSION EXI'lRES FCOlIUAHY 4. 1~
i
I
.
, -,--' .
.
.
, .
SALE NO, 7
$750,00 Advance Costs Pd.3-11-9~ttY'1 Harold S, Irwin
Assessed Valuation $2.280,00
WRIT NO. 313 Civil
Term, 1994
Jeffrey A. Heckman and Sheri S. Heckman his wife
vs
Tanya M, Keppley
620 Condoguinet Avenue
Carlisle. Pa,
18,131.49
451,31
72.00
REAL DEBT
INTEREST @10% per annum
ATTY'S COMM.
WRIT COSTS. ATTY.
WRIT COSTS, PLIFF
ESCROW
LATE CHARGES
SHERIFF'S COSTS:
DOCKETING
POUNDAGE
POSTING BILLS
ADVERTISING
ACKNOWLEDGING DEED
AUCTIONEER
LAW LIBRARY
COUNTY
MILEAGE
MONEY MADE WRIT
CERT MAIL
POSTPONE SALE
LEVY
SURCHARGE
18.00
371. 65
9.00
9.00
10.00
7,00
.50
1.00
5.60
3,34
7.00
4.00
Legal Search
ADVERTISING
LAW JOURNAL
PATRIOT
SHARE OF BILLS
DEEDS
193.10
21~'. ~~
10,00
Sheriff I S Deed
14.00
Fede ral Stamps
Pat Realty Transfer
Twp Realty Transfer
TAXES 1994 Cty Lib & Twp
84.01