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HomeMy WebLinkAbout02-3098WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP. Plaintiff vs. LLOYD H. MORGAN AND JOAN M. MORGAN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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 ajudgment 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 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., Plaintiff vs. LLOYD H. MORGAN AND JOAN M. MORGAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE 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 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., Plaintiff vs. LLOYD H. MORGAN AND JOAN M. MORGAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Oz - 300 g9- COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, WASHINGTON MUTUAL BANK, FA, SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., is a Corporation, with an address of P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53224. 2. Defendant, LLOYD H. MORGAN, is an adult individual, whose last known address is 105 FRYTOWN ROAD, NEWVILLE, PENNSYLVANIA 17013. Defendant, JOAN M. MORGAN, is an adult individual, whose last known address is 105 FRYTOWN ROAD, NEWVILLE, PENNSYLVANIA 17013. 3. On or about, July 30, 1993, the said Defendant, LLOYD H. MORGAN, executed and delivered a Mortgage Note in the sum of $93,000.00 payable to FLEET REAL ESTATE FUNDING 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, LLOYD H. MORGAN, 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 1154, Page 256 conveying to original Mortgagee the subject premises. Fleet Real Estate Funding Corp. is now known as Washington Mutual Bank, FA Successor by Merger to Washington Mutual Home Loans, Inc. Successor in Interest by Merger to Fleet Mortgage Corp. f/k/a Fleet Real Estate Funding Corp. The Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 105 FRYTOWN ROAD, NEWVILLE, PENNSYLVANIA 17240 and is more particularly described in Exhibit "B" attached hereto. 6. By Deed dated June 4, 1994, the said Defendant, Lloyd H. Morgan, conveyed the property subject to the Mortgage to himself and his wife the Co-Defendant, Joan M. Morgan. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Defendants have failed to pay the installment due on November 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $82,698.45 Interest at $16.99 per day From 10/01/2001 To 07/01/2002 ( based on contract rate of 7.500%) Accumulated Late Charges Late Charges $36.06 From 11/01/2001 to 07/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $4,638.27 $0.00 $288.48 $519.74 $4,134.92 $92,279.86 "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 parry 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. 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. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them 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 Defendants have either failed to meet the time limitations as set forth therein or have 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 7.500% ($16.99 per diem), together with other charges and costs including escrow advances incidental thereto to the dat Sheriffs Sale and for foreclosure and sale of the property within described. By: PURCE ,KR & HALLE Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) FmC74722.tit (1696x2800x2 titt) (21 THIS LOAN IN NOT ASSUMABLE WITHOUT THE APPROVAL Oi . THE DEPARTMENT ?F VETERANS VA F" 2"4 RvWd s.c W il, AFFAIRS OR ITS AUTHORIZED PENNSYLVANIA M& Apra 3s, U.S.C. seals. uu h 78 AGENT. •^,U. 370670790 MORTGAGE NOTE LH 457763 $93,000.00 CARLISLE, Permsylvania July 30 .19 FOR VALUE RECEIVED, the undersigned, LLOYD n MOROAN . here- inafter caged the Maker, promises to pay to the order of Fleet Real Estate Funding Corp. as Secretary of Veterans Affairs, an Officer of the United States of America, and his successors in such office, as such. and his or their assigns, hereinafter designated as the Payee, the principal sum of NINETY THREE THOUSAND AND N01100 -------- DOllan($93,000.00 ) with interest from dace at the ir Seven & one-Half percenum( 7.500 %) per annum on the unpaid balance until paid. The rates of 8aar,Ns sTREETand hate?sali be ? 9 ble at the office of the Department of Veterans Affairs in 324 w. or at such place as the holder may designate in writing in monthly hnstallmonts of SIX HUNDRED FIFTY AND 27/100---------------------- Dollars ($650-27 ), commencing on the first day of September 1993, and on the first day of each month thereafter until the principal and bnerest are fully paid, except that the final payment of the entire indebtedness evidenced hereby, If not scatter paid, shall be due and payable on the first day of August , 2023 Privilege is reserved to prepay at any time, without premium or fee the write Indebtedness or arty pan thereof not less then the amount of one Installment or One Hundred Dollars ($100.00), wldcb. ever is less. Prepayment in full shall be credited on the date received. Partial prepayment other thin ou an Insudiment due due, need not be credited until the nerd following installment due date or tatty days after such prepayment, whichever is earlier. Simultaneously with the execution of this Note the Maker has executed and delivered to the Payee a Mortgage secured upon certain premises s mated In the County of CUMBERLAND Commonwealth of Pennsylvania, more particularly described in the Mortgage. All of the terms, cove- neors, provisions, conditions, stipulations and agreements contained in said Mortgage to be kept and performed by the Maker am hereby made a part of this Note to the same extent and with the same force and effect as If they wem fully set forth herein, and the Maker covenants and egress to perform the same, or ease the same to be kept and performed. strictly in accordance with the terms and pro. . visions thereof. The whole of the principal sum or any part [hereof, and of any Otter sums of matey secured by the Mortgage given to secure this Note, shag forthwith, at tie option of the Payee or any subsequent holder thereof, become due and payable immediately, without notice or demand, if default be made In my psymetu under this Note, And If the default is not [Wade good prior to the due date of the next such hutallmertt; or upon the happening of any default which, by the hems of the Mortgage given to secure rids Note, shall entire the Payee, or any subsequent holder hereof, to declare the same, or any part thered, to be due and payable. The Maker does hereby empower any at nney of any town of record within the United States or elsewhere to appear for M&M with or without a declaration filed, and confess judgment or judg- ments; against said Mercer in favor of to Payee or any subsequent holder hereof, as of any term, for the entire unpaid principal of this Note, and all other sums pail by the holder hereof to or on behalf of the Maker pursuant to the terms of this Nom or said Mortgage, and all Areatages of Interest thereon, together with cross of suit, attorney's obnmkceion Of 5.000% for opllectiea, std a release of all errors, nn which judgement execution or executions may issue forthwith. The Maker hereby waives the right of Inquisition on all property levied upon to colk t the indebtedness evidenced hereby and does volun- . tadly condemn tie same and authorized the Prot hmmiary to enter such condemnation, and waives and releases all laws, now in force or hereafter enacted, relating to exemption, appralse ment or say of ex- ecution. The agreements herein contained shall bind. Ad the benefits and advantages shall inure to, the respective successors and assigns of the parties hereto. Whatever used the singular number shall in- clude the plural, the plural the singular, and the use of any gender shall be applicable to all genders. IN WITNESS WI ERBOF, the Maker has caused these presents to be pxcguW under seal the day and year firs above written. _ SIGNED. SEALED AND DELIVERED • • ••S•) IN TH"RESENCE OF: ... ...................................................._....... (SEAL) .1....•tP....?M,.. .... ... _ ............. _........... .................................. _.................................. (SISAL) ........ ....... .......... .................... .......... ........ --................ ................... ................... _................... .......... (SEAL) TIES IS TO CERTIFY Nat this is the Note described in and secured by Mortgage of eve due here- with secured on reel estate shoats In CUMBERLAND County, Commonwealth of Pennsylvania . ". ............................ nemsewx. Dated July 30 .19 93. RbOc a?en Mtr 1'Age 1 of 1 OarW aoro? A Prom 26 aO - L I- CoaNedonF?p esAa t6. t99a Rnv red Apri119 UCFAV3 EXl-i?b ?I A InaTrnwrAa r.mo- FmC74722.tit (1696x2800x2 titt) L20J ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Upper Frankfimd Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A-5749 known as Bkxetville Road with the omterline of Township Road T-441 known as Frytown Road; thence from said spire at the Place of Beginning along the waterline of said Township Road T-441 known as Frytown Road, North 60 degrees East a distance of 216-86 feet, more or lash to a stone at comer of lands now or formerly of Samuel Ermifs heirs; thence along fine of said land now or formerly of Samuel Erases heir South 34 degrees Est a distance of 34.5 parches or 569.25 feet, more or lass, to a stone; thence still along line of said land now or formerly of Samuel Erst's heirs South 52 degrees 30 minutes West a distance of 111.2 perches or 300.3 feet, more or lass, to a stone; thence still by said land now or formerly of Samuel Enmak heirs North 36 degrees West a distance of 439.10 feet, more or less, to a spice in the centerline of said Pennsylvania Route No. A-5749 known as Blocerville Road in line of land new or formerly of Robert L SheaRer, and wife, which spike in the centerline of said Bkrervgks Road is the southern corner of a .222 acre tract of land conveyed to said Robert L Shealler, and wife, by dead of Benjamin E Clayman dated Dezember 111971, and recorded in the hereinafter named Recorder's Office in Deed Book K, Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known in Bloserville Road approximately due North a distance of 194.95 ken to a spike in the centerline of Township Road T-441 known as Frytown Road at the place of BEGINNIFiC1. THE A13OVE-DESCC2MM tract of land has thereon erected a dwelling house and other improvements with mailing address of 105 Frytown Road, Newville, PA, 17241. THE ABOVE-DFSCRINED tract of land contains an area of 3.99675 acres, more or less. TIM AHWH^DESCRIBID tract of land is the same property which Michael F. Strine and Dorothy L Strine, hit wife, by their deed dated July 1993, and recorded in the Office of the Recorder of Deeds in and for Cumberland County immeidately prior to the recording of this mortgage, granted and conveyed unto Loyd H. Morgan, Mortgagor herein. o; l3rnnsvivanis 1 SS ' in tan office for tM racmding of Daads for artand Coumy, R • my N' nd azygod ei office f:,, tai ?.7 fJ day 1SY93 IC7QOvt?//??19G?1? ? . It COMPANY NAME: WgMrXN H,L, Bam, FA a By rmm m w%,-IjmruQa n LAL. K2& Lavs, IIc.9M:iS iN INI= SitPFIM2'io F= MMUKE 01P. FXA FLMr FnL a i) F? OTP' 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 unsworn falsification to authorities. Dated JU\E 26, 2002, l V Ol cn ?- h ? n c-, i j WASHINGTON MUTUAL BANK, FA SUCCESSOR, BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP, Plaintiff V. LLOYD H. MORGAN and JOAN M. MORGAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3098 CIVIL TERM CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO ENTER APPEARANCE AND NOW, this f I-( T*l day of August 2002, the undersigned attorney enters his appearance on behalf of the Defendant, Joan M. Morgan. Date 811q/0,z Austin F. Grogan, sq ' e 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Attorney for Defendant ID #59020 n C_ r- fTl GO SHERIFF'S RETURN - REGULAR CASE NO: 2002-03098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK ET AL VS MORGAN LLOYD H ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LLOYD the PLAINTIFF at 1901:00 HOURS, on the 9th day of July 2002 at 105 FRYTOWN ROAD CARLISLE, PA 17013 by handing to JOAN M MORGAN, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this day of 14?a.ytc?.Y ?.tSO A. D . r thonotary So Answers: R. Thomas Kline 07/10/2002 PURCELL KRUG HALLER By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-03098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK ET AL VS MORGAN LLOYD H ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORGAN JOAN M the DEFENDANT at 1901:00 HOURS, on the 9th day of July 2002 at 105 FRYTOWN ROAD CARLISLE, PA 17013 by handing to JOAN M MORGAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ,7,,,,,< day of A. D. rothonotary So Answers: R. Thomas Kline 07/10/2002 PURCELL KRUG HALLER By:- L Deputy Sheriff WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 VS. LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS 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 LLOYD H. MORGAN AND JOAN M. MORGAN 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 $82,698.45 Interest $ 4,638.27 (Per diem of $16.99 from 10/1/01 to 7/1/02) Late charges $ 288.48 ($36.06 per month to 7/02) Escrow Balance $ 519.74 5% Attorney's Commission $ 4,134.92 TOTAL $92,279.86** ** 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 & H R By Leon P. Halley PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 K:\MKF\DOCS\CUMBERLA\MORGAN. P WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., VS. LLOYD H. MORGAN AND JOAN M. MORGAN, PLAINTIFF DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW NO. 2002 3098 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on OCTOBER 18, 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 I.D. 415700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 WASHINGTON MUTUAL BANK, FA SUCCESSOR TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP. Plaintiff Vs. LLOYD H. MORGAN and JOAN M MORGAN Defendants To: LLOYD H. MORGAN 105 FRYTOWN ROAD CARLISLE, PA 17013 JOAN M. MORGAN 105 FRYTOWN ROAD CARLISLE, PA 17013 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3098 CIVIL TERM : IN MORTGAGE FORECLOSURE SAIDIS, SNUFF, FLOWER & LINDSAY 26 WEST HIGH STREET CARLISLE, PA 17013 AUSTIN G. GROGAN, ESQUIRE 24 NORTH 3ND STREET CAMP HILL, PA 17011 DATE OF NOTICE: OCTOBER 18, 2002 IMPORTANT NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 TELEPHONE (717)245®3166 OR (800)990-9108 PURCELL, KRUG & jAL R By _ Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF VS. LLOYD H. MORGAN AND JOAN M. MORGAN, DEFENDANTS IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 SS 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 : be re me this?y day : of 20 / P -o ry P is L f<)TARiAL SEAL NIARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Aug. 8, 2006 LEON P. HALLER, ESQUIRE V V ? r`J i. y ? ?7 ( is IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 3098 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF TOTAL AMOUNT OF JUDGMENT $92,279.86 Interest at $16.99 per diem to sale date $ 4,162.55 Late charges at $36.06 per month to sale date $ 252.42 Escrow Deficit $ 2,000.00 TOTAL $98,694.83* VS. LLOYD H. MORGAN AND JOAN M. MORGAN DEFENDANT(S) *SALE DATE: WEDS-,MARCH 5, 2003 (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: December 2, 2002 Attorney for Plaintiff 1719 North Front Street Leo P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND 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 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17240. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY r' fO -P P R I ? ?? C p - 1f tQ? ? `NNNTI, ?.) (I1 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Upper. Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A--5749 known as Bioserville Road with the centerline of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING along the centerline of said Township Road T-441 known as Frytown Road, North 60 degrees East, a distance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Er-nst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence still along line of said land now or formerly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a distance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 degrees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road in line of land now or formerly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Sheaffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K", Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bioserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan., by deed dated 6/4/94 and recorded 6/28/94 in Deed. Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROPERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT ## 43-06-0031-039 K'1MKFVDOCS,CUId BEKLAIMORGAN.DES WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF VS. LLOYD H. MORGAN AND JOAN M. MORGAN, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 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 105 FRYTOWN ROAD, CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Lloyd H. Morgan 105 Frytown Road Carlisle, PA 17013 Joan M. Morgan 105 Frytown Road Carlisle, PA 17013 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 Plaintiff has knowledge who may be affected by the sale. of every other person of whom the has any interest in the property which TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Johnna J. Kopecky, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Austin G. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I 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. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 2, 2002 k:,. CS1 -?: WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING : CORP., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 VS. PLAINTIFF ' LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PENNCVr.vr,., „ PURSUANT TO TAKE NOTICE: helra: That the Sheriff's Sale of Real Property (real estate) ;kill be DATE: WEDNESDAY, March 5, 2003 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Rcom 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated detail in aasu lerel description mainly y consisting of. a stateme in nt - of the me boundaries of the property, together with a brief mention of thed buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 105 Frytown Road Carlisle CUMBERLAND COUNTY PENNSYLVANIA which THE JUDGMENT in the amount Of $92,279.86 under or ,-s ch your property is being sold is docketed in the wi thin and County t,. pu ua to n K,V,KF,000SICUMBERL A1MOR(' AN NOS No. 2002 3098 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property LLOYD H. MORGAN AND JOAN M. MORGAN A SCHEDULE OF DISTRIBUTION governmental , being a list of the persons and/or 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) 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. YOUR PROPERTY. PAY THE JUDGMENT. You may have legal rights to prevent your property front be- taken away. A lawyer can advise you more specifically of these . If g rights you wish to exercise PROMPTLY. Your rights, YOU MUST ACT YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND FREE LEGAL ADVICE: OUT WHERE YOU CAN GET 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 o used against you, bligation or the procedure 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 County. The petition must be servedoonctheoattorneyoforhthelcreditoror on the creditor bfre presentation to the court and a proposed order or rule mustobe 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 171,02 (717) 234-4178 ALL THAT CERTAIN tract of land erected ed situate with the improvements thereon Pennsylvania i.n Upper FTankford Township, Cumberland County, , bounded and described as follows; BEGINNING at a spike at, the intersection of the centerline of Pennsylvania Route No. A-5749 !mown as Bloserville Road with the centerline of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING along the centerline of said Township Road T-441 known as Frytown Road, North 60 degrees East, a distance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence still along line of said land now or formerly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a distance of 18.2 perches or 300.3 feet more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 degrees 'Test, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road in line of land now or formerly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Sheaffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K", Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as rrytown Road at the Place of BEGINNING HAVING THEREON ERECTED - RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94 and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H M TO BE SOLD AS THE PROPERTY OF LLOYD H. MORGAN AND JOAN M JUDGMENT NO. 2002 3098. ASSESSMENT # 43-06-0031-039 . ulgan and Joan M. Morgan. MORGAN ON K,WKFDOCS?CumBE RLAWORGAN. DES r "? C? , = ? ? c - `, ? o „' ?? r:i>' _J _ ' ` i _- ? i; ?;- „y .' ? - .. __ j c J"? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3098 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff (s) From LLOYD H. MORGAN AND JOAN M. MORGAN,105 FRYTOWN ROAD, CARLISLE, PA 17240 n the property of the defendant (s)and to sell SEEE LEG (1) You are directed to levy upo DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $92,279.86 L.L. $.50 Interest AT $16.99 PER DIEM TO SALE DATE $4,162.55 Due Prothy $1.00 Atty's Comm % Other Costs LATE CHARGES AT $36.06 PER Atty Paid $122.21 MONTH TO SALE DATE $252.42 --- ESCROW DEFICIT $2,000.00 Plaintiff Paid Date: DECEMBER 4, 2002 CURTIS R. LONG P(Seal) Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Washington Mutual Bank, FA Successor BY Merger to Washington Mutual Home Loans, Inc., Successor in Interest by Merger to Fleet Mortgage Corp. f/k/a Fleet Real Estate Funding Corp. VS Lloyd H. Morgan and Joan M. Morgan In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002_3098 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, is returned STAYED pursuant to instructions from Attorney Leon Haller. states this writ Sheriffs t- osts. Docketing Surcharge 30.00 Advertising 30.00 Posting Bills 15.00 Law Library 15.00 Prothonotary .50 Mileage 1.00 Certified Mail 23.46 Levy 3.10 Patriot News 15.00 Law Journal 194.73 Poundage 133.65 Share of Bills 9.73 25.21 $ 496.38 paid by attorney 02/21/03 Sworn and subscribed to before me This aZ 7 day of 2003, A.D. _ Prothonotary So Ir ?145ew R. Thomas Kline, Sheriff BY Real E to Deputy j&; 13 50 Y3 Real Estate Sale # 39 On December 6, 2002 the sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA known and numbered as 105 Frytown Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 6, 2002 By?b c Real Estate Deputy 4-?? 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. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law.fournal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 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. 39 Writ No. 2002-3098 Civil Washington Mutual Bank, FA Successor by merger to Washington Mutual Home Loans, Inc., Successor in interest by merger to Fleet Mortgage Corp., f/k/a Fleet Real Estate Funding Corp. VS. Lloyd H. Morgan and Joan M. Morgan Atty.: Leon Haller ALL THAT CERTAIN tract of land with the improvements thereon erect- ed situate in Upper Frankford Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEGINNING at a spike at the in- tersection of the centerline of Penn- sylvania Route No. A-5749 known as Bloserville Road with the center- line of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING t- Lisa Marie TO AND SUBSCRIBED before me this 14 day of FEBRUARY, 2003 LOPS E. SIWDEK Notwy F" Cwhb SM, C=bXia colft Wy Ca m**n Expires M80 5,2W5 along the centerline of said Town- ship Road T-441 known as Frytown Road, North 60 degrees East, a dis- tance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now ,or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence still along line of said land now or for- merly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a dis- tance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 de- grees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloser- ville Road in line of land now or for- merly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern cor- ner of a .222 acre tract of land con- veyed to said Robert L. Sheaffer, and wife, by deed of Benjamin E. Gay- man dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K", Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Blos- erville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94 and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROP- ERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT #43-06-0031-039. t? THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the (laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of January and the 4th day(s) of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. .? PUBLICATION ............. ....f........? .............. . ......... COPY me this 14th day f Feb ry 2003 A.D. Notarial Seal SALE #39 Terry L. Russell, Notary Public hin County Dau b i REAL ESTATE SALE No. 39 Writ. No. 2002-3098 p urg, s City Of Harr My Commission Expires June 6, 2006 N A RY PUBLIC Civil Terra Washington Mutual Bank, FA Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 Successor by merger.to Washington Mutual Home Loane, Inc., CUMBERLAND COUNTY SHERIFFS OFFICE Successor In Interest CUMBERLAND COUNTY COURTHOUSE By merger to Fleet Mortgage Corp. f/k/a Fleet Real Estate CARLISLE, PA. 17013 Funding Corp. Statement of Advertising Costs VS Lloyd H. Morgan And Joan M. Morgan To THE PATRIOT-NEWS CO., Dr. A • Leon Haller IPTION For publishing the notice or publication attached 98 DESCR ALL THAT CERTAIN tract of land with the hereto on the above stated dates $ 192. improvements thereon erected situate in Upper Probating same Notary Fee(s) $ 1.75 Frankford Township, Cumberland County, bounded and described as follows: lvania Penns $ 194.73 Total , y BEGINNING at a spike at the intersection of the f n_ Ivania Route No. A-5749 centerline o nnsy known as Bloserville Road with the centerline of publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .............................. South forty-five (45) degrees nine (09) minutes thirty-seven (37) seconds Fast three hundred eighty-seven and Forty-sever] hundredths (387.47) feet to an existing iron ,pin; thence along the northern berm of Township Route #331 along a curve to the right having a chord hearing South seventynine (79) ddgrees twenty-one (21) minutes forty-six (46)tseconds West, a radius of seven hundred ninety-nine and two hundredths (799.02) feet, a tangent of thirty-eight and fifty- seven hundredths (38.57) feet, an arc distance of seventy-seven and eight hundredths (77.08) feet and a chord distance of seventy- seven and five hundredths (77.05) feet to an existing iron pin; thence by the same" South eighty-two (82) degrees fifteen (15) n*utes seven (07) seconds West two hundred thirty-four and eighty-two hundredths (234.82) feet to an existing iron pin, the place of BEGM NG. Containing 1.6994 total acres and known as Lot #3 pursuant to subdivision draft prepared by John R. Kissinger, R.S., dated November 13, 1992, and recorded in Cumberland County Plan Book 67, at page 100. TRACT N0.2: BEGiNMG at anexisting iron On located on the northern berm of Township Ro MOrtPgOrs known as Lot ute #331 at comer of other lands of the described subdivision si n plan; 3 thon the hereinafter ence along the northern berm of said Township Route #331, South eighty-two (82) degrees ten (10) minutes forty-nine (49) seconds West two hundred sixty- seven and forty-one hundredths (267.41) feet to an existing parker kalou nail located in the center of Township Route #330; thence along the centerline of said Township Route #330 North forty-four (44) degrees one (01) minute twenty- seven (27) seconds West two hundred fourteen and seventy-five hundrddths (214.75) feet to a set railroad spike; thencq by other lands of the Mortgagor known as Lot #2 on the hereinafter described subdivision plan, North forty-four (44) degrees forty-eight (48) minutes five (05) seconds East three hurtdted thirty-two and eleven hundredths (332.11) feet to a point; thence by other lands of the Mortgagor known as Lot #2A on the above described subdivision plan, North IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 3098 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. TOTAL AMOUNT OF JUDGMENT $ 92,279.86 Interest at $16.99 per diem to sale date $ 7,288.71 Late charges at $36.06 per month to sale date $ 432.72 Escrow Deficit $ 3,138.74 TOTAL $103,140.03* LLOYD H. MORGAN AND JOAN M. MORGAN DEFENDANT(S) *SALE DATE: WEDS.,SEPT. 3, 2003 (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: June 9, 2003 Attorney for Plaintiff 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND 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 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17240. Date: PROTHONOTARY/CLERK CIVIL DIVI BY DEPUTY F? j O ? e *Iq o C C b C p ?, v ? ? w ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Upper Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A-5749 ]mown as Bloserville Road with the centerline of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING alone the centerline of said Township Road T-441 known as Frytown Road, North 60 degrees East, a distance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence still along line of said land now or formerly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a distance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 degrees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road in line of land now or formerly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Shaeffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K", Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS, 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94,and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROPERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT # 43-06-0031-039 K WKPDOCS\CUMBERL WORGANDES WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 vs. LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS 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 105 FRYTOWN ROAD, CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Lloyd H. Morgan 105 Frytown Road Carlisle, PA 17013 Lloyd H. Morgan 10 Mountain Road Newville, PA 17241 Joan M. Morgan 105 Frytown Road Carlisle, PA 17013 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 Johnna J. Kopecky, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Austin G. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17050 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I 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. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 9, 2003 c? < - ? ?-. z?? .;,; - ?' c'? ?-; ?:` , 'n ?? . _? WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 VS. LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS RELIEF FROM STAY Docket for Case: " + GetCaseNoo + " (" - DktT-ypeExpand(m.gsDktType) + ") Page I of 2 Bankruptcy Docket Report 102-06909 (Harrisburg) MORGAN, LLOYD H Docket items entered between 01/01/1931 and 04/25/2003 Filing No. Docket Entry View Date document 12/20/02 1 VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Doc # I PDF Plan and Summary [EOD 12/23/02] [BR] $ pages) ?(- - 12/20/02 2 Ch. 13 Plan Re: Item # 1. [EOD 12/23/02] [BR] Doc #2 PDF (2 pages) 12/20/02 3 MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR Doc #3 PDF_(_ [Disposed] [EOD 12/23/02] [DR] ?age) 12/23/02 4 ORDER to pay trustee. Re: Item # 3. [EOD 12/23/02] [DR] Doc #4 PDF (2 pages) 12/30/02 5 NOTICE to parties of filing of claim by Debtor on behalf of Internal Revenue Service Doc #5 PDF in the amount of $3,349.00 [EOD 12/30/02] [DR] Vie) 01109103 6 1 CERTIFICATE of Mailing of Notice lof 341 Meeting. Objections to the plan are due Doc #6 PDF (5 15 days after meeting held. [EOD 01/09/03] [AUT] pages) Art: PLAN PDF pages 01/23/03 7 Amendment to Schedule(s): F. Re: Item # 1. [EOD 01/24/03] [BR] None FEE PAID rec. 591119. Re: Item # 8. [EOD 01/27/03] [BR] 01/24/03 8 NOTICE TO DEBTOR(S) OF DEFECTIVE AMENDMENT $20.00 Fee due. due by None 02/13/03 Re: Item # 7. [Complied] [E'OD 01/24/03] [BR] 01/24/03 9 ENTRY OF APPEARANCE of DANIELLE BOYLE-EBERSOLE, ESQUIRE and Doc_#9 PDF (2 JOSEPH REJENT, ESQUIRE of SHAPIRO & KREISMAN on behalf of pages) WASHINGTON MUTUAL BANK, FA successor by merger to WASHINGTON MUTUAL HOME LOANS, INC. [EOD 01/27/03] [DR] 02/13/03 10 341 meeting held. [EOD 02/14/03] [CA] None 02/19/03 11 OBJECTION to plan by WASHINGTON MUTUAL BANK, FA successor by Doc #11 PDF merger to WASHINGTON MUFUAI, HOME LOANS, INC. Re: Item # 2. (3 pages) [Disposed] [EOD 02/19/03] [DR] 02/20/03 12 CORRESPONDENCE SETTING HEARING with Judge John J. Thomas on Doc #12 PDF 05105103 at 10:00 A.M. at FED.BLD BKRPTCY CTRM.(3RD FLR.), THIRD & (I page) WALNUT STS., HARRISBURG,PA'. 17108 Re: Item # 11. [Rescheduled] [EOD 02/20/03] [DR] 02/21/03 13 ENTRY OF APPEARANCE of LEON P. HALLER, ESQUIRE of PURCELL, Doc #13 PDF KRUG & HALLER on behalf of WASHINGTON MUTUAL BANK FA [EOD (2 a es) , 02/21/031 [DR] p g 03/03/03 14 Praecipe/Withdraw by WASI IINGTON MUTUAL BANK, FA, successor by merger Doc #14 PDF to WASHINGTON MUTUAL 1 TOME LOANS, INC. Re: Item # 11. [EOD 03/04/03] 1 a e http://pacer.pamb.uscourts.gov/cgi-bin/foxweb.exe/npacer/nPacer?ExecThis=docket&puid=010 4/25/03 Docket for Case: " + GetCaseNoo + + DktTypeExpand(m.gsDktType) + Page 2 of 2 [DR] 03104103 15 APPROVED by the court. Re: item # 14. [EOD 03/04/031 [DR] Doc #15_PDF This entry disposes of motion. Re: Item # 11. [EOD 03/04/03] [DR] (1 page This entry cancels the previous due date. Re: Item # 12. [EOD 03/04/031 [DR] 03106/03 16 MOTION for relief from stay by WASHINGTON MUTUAL BANK, FA, successor Doc _# 16 PDF by merger to WASHINGTON MUTUAL HOME LOANS, INC. [Disposed] [EOD (5 pages) 03/07/031 [DR] CERTIFICATE OF CONCURRENCE [EOD 03/07/031 [DR] 03/10/03 17 ORDER granting relief from stay Re: Item # 16. [EOD 03/10/03] [DR] Doc #17 PDF (2 pages) 03/10/03 18 ORDER Confirming Plan Re: Item # 2. [EOD 03/10/03] [DR] Doc #18_PDF . (2_pages) Printed: 04/25/03 14:06:21 PACER Service Center Transaction Receipt 04/25/2003 14:06:21 PACER Login: pk0015 Client Code: Description: Docket Case Number: 1 2002-06909 Billable Pages: 0 Cost: 0.21 Need help? Try the PACER User's Guide EJPace>, Service Center http://pacer.pamb.tLscourts. gov/cgi-binlfoxweb. exe/npacerInPacer?ExecThis=docket&puid=01... 4/25/03 WASHINGTON MUTUAL BANK, FA IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY CIVIL ACTION - LAW MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING NO. 2002 3098 CORP., PLAINTIFF VS. LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 3, 2003 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: 105 Frytown Road Carlisle CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $92,279.86 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2002 3098 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property LLOYD H. MORGAN AND JOAN M. MORGAN 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) 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 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 TEAT CERTAIN tract of land with the improvements thereon erected situate in Upper Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A-5749 known as Bloserville Road with the centerline of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING along the centerline of said Township Road T-441 known as Frytown Road, North 60 degrees East, a distance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence'still along line of said land now or formerly of Samuel Ernst's heirs, south 52 degrees 30 minutes West, a distance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 degrees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road in line of land now or formerly of Robert L. Shaeffer, and wife which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Shaeffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's office in Deed Book "K" Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94 and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROPERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT # 43-06-0031-039 K WKRDOCSSCUMBERLAWORGANDES c-:, - =',' ?, ?_; r; v 'n •?J -4 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., PLAINTIFF vs. LLOYD H. MORGAN AND JOAN M. MORGAN, DEFENDANTS . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on June 17, 20031 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 lienholders 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: Lloyd H. Morgan 105 Frytown Road Carlisle, PA 17013 Joan M. Morgan 105 Frytown Road Carlisle, PA 17013 Lloyd H. Morgan 10 Mountain Road Newville, PA 17241 Joan M. Morgan 10 Mountain Road Newville, PA 17241 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Johnna J. Kopecky, Esquire Saidis, Snuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Austin G. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17050 Bye/ PURCELL, KRUG 6, HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 JOHN W.PURCELL HOWARD B. KRUG LEON P.HALLER .IOHN W. PURCELL.IR. BRIAN.I. TYLER JILL. M. WINEKA NOTICE TO: Lloyd H. Morgan 105 Frytown Road Carlisle, PA 17013 Joan M. Morgan 105 Frytown Road Carlisle, PA 17013 Lloyd H. Morgan 10 Mountain Road Newville, PA 17241 Joan M. Morgan 10 Mountain Road Newville, PA 17241 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Johnna J. Kopecky, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Austin G. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17050 (717) 533-3836 JOSEPH NISSLEY 0910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD 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. LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will he divested by the sale and that opportunity to protect your interest, if any b have an said sheriff's Sale. g notified of By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. F/K/A FLEET REAL ESTATE FUNDING CORP., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3098 PLAINTIFF VS. LLOYD H. MORGAN AND JOAN M. MORGAN, IN MORTGAGE FORECLOSURE DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, SEPTEMBER 3, 2003 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: 105 Frytown Road Carlisle CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $92,279,86 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2002 3098 is: THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property LLOYD H. MORGAN AND JOAN M. MORGAN 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) 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 I- 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 tract of land with the improvements thereon erected situate in Upper Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A-5749 known as Bloserville Road with the centerline of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING alona the centerline of said Township Road T-441 known as Prytown Road, North 60 degrees East, a distance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence 'still along line of said land now or formerly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a distance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 degrees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road in line of land now or formerly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Shaeffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K", Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94 and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROPERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT # 43-06-0031-039 KAWFOOCS\CUMBERLAWORGAN.DES Re: WAMU v. Morgan Cumberland 9/3/03 U. S. POSTAL SERVICE Received from Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Lloyd H. Morgan 105 Frytown Road Carlisle, PA 17013 U. S. POSTAL SERVICE Received from Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Joan M. Morgan 105 Frytown Road Carlisle, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail address Lloyd H. Morgan 10 Mountain Road Newville, PA 17241 a r? ?'PYkS FUpT 4b 1 $ 00.900 R 'L ?dA1 F fF, Ptq IF S,. ?0E ., ?,3 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Joan M. Morgan 10 Mountain Road Newville, PA 17241 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addresse Johnna J. Kopecky, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Postage: Postmark: Postage: Postmark: Postage: s osr .10 ... k° ," K Sd $ 00.90E to AILFil 'P JM II 'AUP --'2 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Austin G. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 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: James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17050 0?P??S PpgT4 ? .w GF, "' $ 01.80°" M LED i00 IF C 0E U::. L.. _ t n 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 Secretary of Veterans Affairs of Washington D C is the grantee the same having been sold to said grantee on the 3rd day of Sent A.D., 2003, under and by virtue of a writ Execution issued on the 10th day of June, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3098, at the suit of Washington Mutual Bank F S sbm to Fleet Mtg Corp fka Fleet Real Estate Funding Corp against Lloyd H Morgan & Joan M is duly recorded in Sheriff's Deed Book No. 260, Page 190. IN TESTIMONY WHEREOF, I have hereunto set my hand 1 and seal of said office this l A.D.2003 '? D? J ? day of Recorder of Deeds Washington Mutual Bank, FA successor In The Court of Common Pleas of By merger to Washington Mutual Home Cumberland County, Pennsylvania Loans, Inc., successor in interest by Writ No. 2002-3098 Civil Term Merger to Fleet Mortgage Corp. Wa Fleet Real Estate Funding Corp. VS Lloyd H. Morgan and Joan M. Morgan Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2003 at 6:48 o'clock PM, he 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: Lloyd H. Morgan, by making known unto Lloyd Morgan personally, at 10 Mountain Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Kenneth Gossett, Deputy Sheriff, who being duly sworn according to law, states that on July 18, 2003 at 9:05 o'clock PM, he 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: Joan M. Morgan, by making known unto Joan Morgan personally, at 1156 Redwood Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2003 at 7:23 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lloyd H. Morgan and Joan M. Morgan located at 105 Frytown Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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: Lloyd H. Morgan, by regular mail to his last known address of 10 Mountain Road, Newville, PA 17241. This letter was mailed under the date of July 22, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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: Joan M. Morgan, by regular mail to her last known address of 1156 Redwood Dr., Carlisle, PA 17013. This letter was mailed under the date of July 22, 2003 and never returned to the Sheriffs 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, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon Haller for The Secretary of Veterans Affairs of Washington, D.C., His Successors and/or Assigns. It being the highest bid and best price received for the same, The Secretary of Veterans Affairs of Washington, D.C., His Successors and/or Assigns of 5000 Wissahickon Ave., Philadelphia, PA 19144, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $986.97. Sheriffs Costs Docketing $30.00 Poundage 19.35 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 22.77 Levy 15.00 Surcharge 30.00 Law Journal 404.90 Patriot News 300.55 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 986.97 Sworn and subscribed to before me So An we : This 27..da of R. Thomas Kline, Sheriff 2003, A.D. ' !nLcu 0 onotary BY ?JC (iL \G1.'i.A?'1 Real Estate beputy -XI 6b WY?PA411? 1 cry vz?YC? P, /w3pcP Real Estate Sale # 63 On June 17, 2003 the sheriff levied upon the defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA known and numbered as 105 Frytown Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. CVD Cy c=? Date: June 17, 2003 By:,,,, CC(c f v ik Real EstA6 Deputy a THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ................. .... ......1... . ? ................. COPY Sworn to d bscribed before m s 13th day o Au ust-?003 A.D. S A L E #63 Notarial Seal ? REAL ESTATE SALE No. 63 Terry L. Russell, Notary Pubhc Writ No. 2002-3098 City Of Harrisburg, DaupNnCuxtty NO RY PUBLIC Civil Term Washington Mutual Bank, FA My Commission Expires June 6, 2006 Ly commission expires June 6, 2006 Successor by merger to Washin t n Mutual H Member. Pennsylvania Association Of Notaries o g ome Loans, Inc. CUMBERLAND COUNTY SHERIFFS OFFICE Successor In Interest by merger to CUMBERLAND COUNTY COURTHOUSE Fleet Mortgage Corp., f/k/a Fleet Real Estate CARLISLE, PA. 17013 Funding Corp. vs Statement of Advertising Costs Lloyd H. Morgan and Joan M. Morgan At L P H l To THE PATRIOT-NEWS CO., Dr. ty eon . al er DESCRIPTION For publishing the notice or publication attached ALL THAT CERTAI(4 tract of land with the hereto on the above stated dates $ 298.80 improvements thereon erected situate in Upper Frankford Township, Cumberland County, Probating same Notary Fee(s) $ 1 .75 Pennsylvania, bounded and described as follows: Total $ 300.55 BEGINNING at a spike at the intersection of the centerline of Pennsylvania Route No. A-5749 known as Bloserville Road with the centerline of Township Road T-441 known as Frytown Road; publisher's Receipt for Advertising Cost g The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By ..................................................... thence from said spike at the Place of BEGINNING along the centerline of said Township Road T-441 known as Frytown Road, North 60 degrees East,a distance of 216.86 feet, more or less, to a stone Pt corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34,5 perches or 569.25 feet, more or less, to a stone; thence still along line of said landnow or formerly of Samuel Emst's heirs, South 52 degrees 30 mii;utes West, a distance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said 'and now or formerly of Samuel Ernst's heirs, North 36 degrees West, a distance of 439.10 feet, moreor less, to a spike in the centerline of said,Pennsylvania Route No. A- 5749 known as Bloserville Road in line of land now or formerly of Robert L. Sheaffer, and wife, which spike in the centerline of said Bloserville Road is the southern corner of a .222 acre tract of land conveyed to said Robert L. Sheaffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book' ', Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approximately due North a distance of 194.95 feet to a spike in the centerline of Township Road T-441 known as Frytown Road at the Place of BEGINNING. HAVING THEREQN erected a residential dwelling house known as 105 Frytown Road, Carlisle, Pennsylvania !7013. BEING THE SAME. premises which Lloyd H. Morgan and loan M. 6-gan, by deed dated 614/ 94 and recorded 6/28/94 in Deed Book 107 Page 576 granted ankonveytd unto Lloyd H. Morgan and Joan M. Morgm. TO BE SOLD as the oroperty of Lloyd H. Morgan and Joan M. Mcqan on Judgment No. 2002 3098. ASSESSMENT NO.: 43-00031-039. 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. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 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. 63 Writ No. 2002-3098 Civil Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp., f/k/a Fleet Real Estate Funding Corp. vs. Lloyd H. Morgan and Joan M. Morgan Atty.: Leon P. Haller ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Upper Frankford Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a spike at the in- tersection of the centerline of Penn- sylvania Route No. A-5749 known as Bloserville Road with the center- line of Township Road T-441 known as Frytown Road; thence from said spike at the Place of BEGINNING SWORN TO AND SUBSCRIBED before me this 1 day of AUGUST, 2003 NOTARIAL t L ? LOTS E. SNYDER, kzftwy F-'ubk CJe ill, Ovr9 C' My Ca *sfon Ex?s m Maki 5, 2006 along the centerline of said Town- ship Road T-441 known as Frytown Road, North 60 degrees East, a dis- tance of 216.86 feet, more or less, to a stone at corner of land now or formerly of Samuel Ernst's heirs; thence along line of said land now or formerly of Samuel Ernst's heirs, South 34 degrees East, a distance of 34.5 perches or 569.25 feet, more or less, to a stone; thence still along line of said land now or for- merly of Samuel Ernst's heirs, South 52 degrees 30 minutes West, a dis- tance of 18.2 perches or 300.3 feet, more or less, to a stone; thence still by said land now or formerly of Samuel Ernst's heirs, North 36 de- grees West, a distance of 439.10 feet, more or less, to a spike in the centerline of said Pennsylvania Route No. A-5749 known as Bloser- ville Road in line of land now or for- merly of Robert L. Sheaffer, and wife which spike in the centerline of said Bloserville Road is the southern cor- ner of a .222 acre tract of land con- veyed to said Robert L. Sheaffer, and wife, by deed of Benjamin E. Gayman dated December 13, 1971 and recorded in the hereinafter named Recorder's Office in Deed Book "K". Volume 24, Page 578; thence along the centerline of said Pennsylvania Route No. A-5749 known as Bloserville Road approxi- mately due North a distance of 194.95 feet to a spike in the cen- terline of Township Road T-441 known as Frytown Road at the Place of BEGINNING. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 105 FRYTOWN ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Lloyd H. Morgan and Joan M. Morgan, by deed dated 6/4/94 and recorded 6/28/94 in Deed Book 107 Page 576 granted and conveyed unto Lloyd H. Morgan and Joan M. Morgan. TO BE SOLD AS THE PROP- ERTY OF LLOYD H. MORGAN AND JOAN M. MORGAN ON JUDGMENT NO. 2002 3098. ASSESSMENT # 43-06-0031-039.