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HomeMy WebLinkAbout02-3825FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff CUMBERLAND COUNTY TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:7844897 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081 The name(s) and last known address(es) of the Defendant(s) are: TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 2/3/00 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to HOMECOMINGS FINANCIAL NETWORK, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1595, Page 288. PLAINTIFF is now the legal holder of the mortgage and is in the process of formalizing an assignment of same. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $237,018.23 Interest 6,474.72 3/1/02 through 7/1/02 (Per Diem $52.64) Attorney's Fees 1,000.00 Cumulative Late Charges 265.50 2/3/00 to 7/1/02 Cost of Suit and Title Search 550.00 Subtotal $245,308.45 Escrow Credit 868.96 Deficit 0.00 Subtotal ($868.96) TOTAL $244,439.49 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $244,439.49, together with interest from 7/1/02 at the rate of $52.64 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERA?g AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Eric L. Diffenbaugh, R.P.L.S., dated June 16, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 75, Page 49. BEGINNING at an iron pin in centerline of Simmons Road, S.R. 2007 at corner of Lot No. 11, as shown on said plan; thence along centerline of Simmons Road, S.ZL 2007 South 39 degrees 19 minutes 14 seconds West 255.00 feet to a point; thence along land now or formerly of Charlotte G. Gregor, et al, South 89 degrees 18 minutes 42 seconds West 56296 feet to a point at Lot No. 4 on plan; thence along Lot No. 4 North 00 degrees 30 minutes 00 seconds East 195.36 feet to a point at Lot No. 11 thence along Lot Nos. 11, North 89 degrees 18 minutes 42 seconds East 722.85 feet to a point in centerline of Simmons Road, S.R. 2007, the Place of BEGINNING. CONTAINING 2.8827 acres and designated as Lot No. 12 on the Plan of Trindle Estates. BEING part of the same premises which Samuel M. Simmons, Jr. granted and conveyed to KimJon, Inc., Grantor herein, by its deed dated November 24, 1997 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Record Book 168, Page 649. BEING KNOWN AS 16 SD940NS ROAD VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA,C.S. 4904 Relating to unsworn falsifications to authorities, That he/she is Lucy Herrada, Foreclosure Coordinator, of Litton Loan Servicing L.P, plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. Date: 0 cy err &a, Foreclosure Coordinator w ? n cs o 77 ?. -Ti s c? n rn `-.. of -< Dn FEDERMAN AND PHELAN BY: Francis S. Hallinan, Esq. Atty. I.D. # 62695 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY INFACT VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-3825 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Francis S. Hallinan, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 16 SIMMONS ROAD, MECHANICSBURG, PA 17055 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with the Complaint have been unsuccessful, as indicated by the Sheriffs Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". M/Main Forms/motions/county.comp 3. Internal records reviewed by Plaintiff and has not been contacted by defendant as of SEPTEMBER 4, 2002 to bring loan current. 4. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Q Francis S. Hallinan, Esquire R/Main Forms/motions/county-comp ATTORNEY FOR PLAINTIFF FEDERMAN AND PHEL BY: Francis S. Hallinan, Esq. Atty. I.D. # 62695 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (? 15) 561-1000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-3825 Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) if service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendapt(s) and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. rc ales ?, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Ad^^h ^f Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of information Act; 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriffs Return of Service, attached hereto and marked as Exhibit "Al', the Sheriff has been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail. Respectfully submitted: Francis S. Hallinan, Esquire H:/Main Forms/motions/county-comp CASE NO: 2002-03825 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HECK TERRENCE E ET AL Deputy Sheriff, who being duly sworn R. Thomas Kline R according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT. I to wit: HECK ANGELA L unable to locate Her in his bailiwick. COMPLAINT - MORT FORE but was He therefore returns the NOT SERVED , as to HECK ANGELA L the within named DEFENDANT Sheriff's Costs: Docketing Service Affidavit Surcharge So answe 6.00 ' 6.21 R. THOMAS KLINE 00 10.00 SHERIFF OF CUMBERLAND COUNTY .00 22.21 FEDERMAN & PHELAN 08/26/2002 Sworn and subscribed to before me this day of A. D. Prothonotary HISrr A . EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Federman & Phelan Subject: Terrence Heck Angela Heck Property Address : 16 Simmons Road Mechanicsburg, PA 17055 Last Known Address: 16 Simmons Road Mechanicsburg, PA 17055 Current Address: 16 Simmons Road Mechanicsburg, PA 17055 As of July 17, 2002 Last Known Number: 717 691-6962 George H. Lewis, III, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of researcher for EKL DATA, INC. 2. On July 17, 2002, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: Credit Information A. Social Security Number 1. Terrence Heck: 186-60-1558 2. Angela Heck: 178-64-9674 B. Employment Search: Could not locate any employment information for the above named subject at this time. C. Inquiry of Creditors: The creditors indicated that Terrence Heck and Angela Heck both reside at 16 Simmons Road, Mechanicsburg, PA 17055. II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has Terrence Heck listed with an address of 16 Simmons Road, Mechanicsburg, PA 17055. The phone number is 717 691-6962. Called number, spoke to Mrs. Heck and verified that the above named subjects do indeed reside at 16 Simmons Road. III. Inquiry of Neighbors Made every attempt to contact the neighbors of 16 Simmons Road, but none could verify that Terrence Heck and Angela Heck do indeed reside at 16 Simmons Road. IV. Inquiry of Post Office A. National Address Update: As of July`17, 2002 the National Change of Address has no forwarding record for Terrence Heck and Angela Heck listed at 16 Simmons Road, Mechanicsburg, PA 17055. • EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION V. Inquiry of DMV The Pennsylvania Department of Motor Vehicles has Terrence Heck and Angela Heck listed at 16 Simmons Road, Mechanicsburg, PA 17055. VI. Other Inquiries A. Death Records: As of July 17, 2002 the Social Security Death Index has no death record on file for Terrence Heck under his social security number nor is there a record for Angela Heck under her social security number. B. Public Licenses None Found C. County Voter Registration: The county does not have Terrence Heck listed as a registered voter and does not have Angela Heck listed as a registered voter with an address of 16 Simmons Road, Mechanicsburg, PA 17055. D. D.O.B.: Terrence Heck: 01/04/1967 Angela Heck: 10/04/1970 E. Miscellaneous Information None H Lewis III and sworn before me on July 17, 2002. Notarial Seal dotarynblic Ellen K. Lewis, Notary Public Lower Merion Twp., Montgomery County My Commission Expkres Feb. 24, 2003 'p EXHIBIT FJ Francis S. Hallinan, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. Date: seplernhera 202 Francis S. Hallinan, Esquire H:/Main Forms/motions/county-comp ? r, ? ? , ?' 'n r ?? G, - ,__ ?r ;: r? ' .: 3,. :J '??n i _'? -? =i-* ?? FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215)563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Defendants Attorney for Plaintiff . COURT OF COMMON PLEAS . CIVIL DIVISION . Cumberland County . No.02-3825 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: SEPTEMBER 4, 2002 r? C_. t?? '? F_-? rn _ "'a ?; r ._... '_- C - ?: ' ?"t_'? -'? 7 CAS '? - J .r FF/kmk FEDERMAN AND PHELAN BY: Francis S. Hallinan, Esq. Atty. I.D. # 62695 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 r5) 563.7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CHASE MANHATTAN, AS TRUSTEE RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY INFACT Vs. CIVIL DIVISION TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK CUMBERLAND COUNTY NO. 02-3825 I, Francis S. Hallinan, Esquire, herby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individual(s) as indicated below by first class mall, postage prepaid, on the date listed below. ANGELA L. HECK, A/K/A ANGELA HECK at: 16 SIMMONS ROAD MECHANICSBURG, PA 17055 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Date: September 4 00 O Q - Francis S. Hallinan, Esquire Attorney for Plaintiff R/Main Forms/motions/county.comp c a a cr -n T t9 -C JP MORGAN CHASE BANK, FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, Plaintiff V. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3825 CIVIL TERM ORDER OF COURT AND NOW, this 17'' day of September, 2002, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, the motion is granted to the extent that service of the complaint may be made upon Angela L. Heck a/k/a Angela Heck, by (1) First Class and Certified Mail to Angela L. Heck at 16 Simmons Road, Mechanicsburg, PA 17055, said service to be complete upon mailing, (2) Posting of the said property and (3) Publication once in a newspaper of general circulation in Cumberland County and in the Cumberland Law Journal. BY THE COURT, Francis S. Hallinan, Esq. FEDERMAN AND PHELAN Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 Attorney for Plaintiff G? Jsley Oler ., J. I IT7 ,,, -1;-- , v. ?,qr",.,;,.. ,.?.,;? ? ,.? ,,,? :l1Fl?? ?1 cj]S?? ?• ?''? ?. n.- ?.. SHERIFF'S RETURN - REGULAR CASE NO: 2002-03825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HECK TERRENCE E ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HECK TERRENCE E the DEFENDANT , at 2121:00 HOURS, on the 19th day of August , 2002 at 16 SIMMONS ROAD MECHANICSBURG, PA 17055 by handing to TERRANCE HECK a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.83 Affidavit .00 Surcharge 10.00 .00 32.83 Sworn and Subscribed to before me this day of 100 A. D. ?roP thonotar So Answers: R. Thomas Kline 08/26/20 FEDERMAN By: SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-03825 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HECK TERRENCE E ET AL R. Thomas Kline , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: HECK ANGELA L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT HECK ANGELA L PER POST OFFICE, MOVED AND LEFT NO FORWARDING ADDRESS. Sheriff's Costs: So answe j Docketing 6.00 Service ! 6.21 Affidavit .00 R. THOMAS KLINE Surcharge 10.00 SHERIFF OF CUMBERLAND COUNTY .00 22.21 FEDERMAN & PHELAN 08/26/2002 Sworn and subscribed to before me this -StL day of 2M A. D. C]". h iO J Pr t onotary FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-3825 AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to ANGELA L. HECK, A/K/A ANGELA HECK at 16 SIMMONS ROAD, MECHANICSBURG, PA 17055, on SEPTEMBER 23, 2002, in accordance with the Order of Court dated SEPTEMBER 17, 2002. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Date: September 23, 2002 ??C?Q.+?' Z•Cl/?? FkANK FEDERMAN, ESQUIRE Attorney for Plaintiff ra n C sv 7?n l: te ij Tt p ? T s FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215)563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Defendants Attorney for Plaintiff . COURT OF COMMON PLEAS CIVIL DIVISION . Cumberland County . No. 02-3825 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. RANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: SEPTEMBER 23, 2002 C-) CD rJ cn t -v Ez m UJ r c ID Ca .. ?:k a ?V SHERIFF'S RETURN - REGULAR CASE NO: 2002-03825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HECK TERRENCE E ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HECK ANGELA L the DEFENDANT at 1710:00 HOURS, on the 1st day of October 2002 at 16 SIMMONS ROAD MECHANICSBURG, PA 17055 by handing to POSTED PROPERTY AT 16 SIMMONS ROAD MECHANICSBURG 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 6.90 Posting 6.00 Surcharge 10.00 .00 40.90 Sworn and Subscribed to before me this 7' day of CO l •- a)-m L. A. D. .n (2, 112/ 0 Prothonotary So Answers: R. Thomas Kline 10/02/2002 FEDERMAN & PHELAN By: / 4p -? ll,La Deputy Sheriff f FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Attorney I.D. No. 12248 Suite 1400 - Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT VS. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION . CUMBERLAND COUNTY . No. 02-3825 AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the Court Order dated SEPTEMBER 17, 2002 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)in in THE SENTINEL on SEPTEMBER 28, 2002 and CUMBERLAND LAW JOURNAL on OCTOBER 4, 2002. Proofs of the said publications are attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J J W1 FRAN FE ;RMAN, IR PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication You, have been su' September 28, 2002 - The Carlisle Sentinel Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. September 30, 2002 Sworn to and subscribed before me this 30th day of September 2002. Notary Public (21 5) 5W10(W My commission expires: NOTARIAL SEAL --? FSHIRsW LEY 0. DURNIN, Notary Public f Boro., Cumberland County mmission Expires Aug. 9, 200? PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3825 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, PLAINTIFF Vs. TERRENCE E. HECK, A/K/A TERRENCE HECK and ANGELA L. HECK, A/K/A ANGELA HECK, DEFENDANTS tember 28, 2002 - The Carlisle Sentinel her deposes that he is not interested in : matter of the aforesaid notice or lent, and that all allegations in the >tatement as to time, place and character NOTICE TO ANGELA L. HECK, A/K/A ANGELA HECK: Ion are true. You are hereby notified that on AUGUST 9, 2002, Plaintiff, JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDEW TIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUMBERLAND County, Pennsylvania, docketed to No. 02-3825. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 16 SIMMONS ROAD, MECHANICSBURG, PA 17055, whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. September 30, 2002 NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the court. You are warned that if you fail to do so, the case may proceed without you and Judgment may be entered against you wilhout further notice for the relief requested by the Plaintiff. You may lose money, the property or other rights i t t t 30th nd subscribed before me this mpor an o you. You should take this notice to your lawyer at once. Ifyou do not have a lawyer or cannot afford one, go to or telephone the office setfortli below to find out where you September , 2002. can apt Ipnel halo. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISE, PA 17013 (717) 249-3166 FRANKFEDERMAN Attorney for the Plaintiff FEDERMAN & PHELAN, L.L.P. One Penn. Center, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Notary Public ?sion expires: NOT'r. ? 1' SHIRLE>' O. Dlji N!N Iw;,, y %ut Carlisle Boro., .',urnioeriand Cot,- r M Ccmmission PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of 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 OCTOBER 4, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are Roge M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 4 day of OCTOBER 2002 LOS E. SWMR, Notary P&k C901 1810 CuMbedand e4mly My Casa "M E*= Meath 6, 2W5 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE of this publication or a Judgment will be entered against you. In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 02-3825 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, PLAINTIFF vs. TERRENCE E. HECK, A/K/A TERRENCE HECK and ANGELA L. HECK, A/K/A ANGELA HECK, DEFENDANTS NOTICE TO ANGELA L. HECK, A/K/A ANGELA HECK: You are hereby notified that on AUGUST 9, 2002, Plaintiff, JP MOR- GAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUND- ING CORPORATION, AS ATTORNEY IN FACT, filed a Mortgage Foreclo- sure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUMBER- LAND County, Pennsylvania, docket- ed to No. 02-3825. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 16 SIMMONS ROAD, MECHAN- ICSBURG, PA 17055, whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the court. You are warned that if you fail to do so, the case may proceed with- out you and Judgment may be en- tered against you without further notice for the relief requested by the Plaintiff. You may lose money, the property or other rights important to you. You should take this notice 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE FEDERMAN & PHELAN, L.L.P. Attorneys for Plaintiff One Penn Center Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Oct. 4 ? ? C - m n --? •:. ?_ cn : , r C: FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081 Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3825 V. TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against TERRENCE E. HECK A/K/A TERRENCE HECK and ANGELA L HECK A/K/A ANGELA HECK Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 7/2/02 to 11/5/02 TOTAL $244,439.49 $ 6,685.28 $251,124.77 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. ERMAN, ESQUIRE Attorney fir Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. 2 ; DATE: , ?k,fN Zpp?_ /-' PRO PROTHY FEDERNIANI AND PHELAN BY: FRANK FEDERNLALN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff vs. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Defendant(s) Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION CUMBERLAND PJ y NO. 02-3825 COpr TO: TERRENCE E. HECK, A/K/A TERRENCE HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 DATE OF NOTICE: OCTOBER 25. 2002 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1 Prank ederman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 5613-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff vs. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK Defendant Attomey for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-3825 TO: ANGELA L. HECK, A/K/A ANGELA HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 DATE OF NOTICE: OCTOBER 25. 2002 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 rank Federman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-03825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK VS HECK TERRENCE E ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HECK TERRENCE E the DEFENDANT , at 2121:00 HOURS, on the 19th day of August 2002 at 16 SIMMONS ROAD MECHANICSBURG, PA 17055 by handing to TERRANCE HECK a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.83 Affidavit .00 Surcharge 10.00 .00 32.83 So Answers: R. Thomas Kline 08/26/20 FEDERMAN Sworn and Subscribed to before By: me this day of A. D. Prothonotary 10 JP MORGAN CHASE BANK, FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, Plaintiff V. TERRENCE E. HECK, A/K/A TERRENCE HECK ANGELA L. HECK, A/K/A ANGELA HECK, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3825 CIVIL TERM ORDER OF COURT AND NOW, this 17a' day of September, 2002, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, the motion is granted to the extent that service of the complaint may be made upon Angela L. Heck a/k/a Angela Heck, by (1) First Class and Certified Mail to Angela L. Heck at 16 Simmons Road, Mechanicsburg, PA 17055, said service to be complete upon mailing, (2) Posting of the said property and (3) Publication once in a newspaper of general circulation in Cumberland County and in the Cumberland Law Journal. BY THE COURT, Francis S. Hallinan, Esq. FEI?ERMAN AND PHELAN ite 14001400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 Attorney for Plaintiff 7 esley Oler ., J, rfquE COPY FRCkl RECORD In Tastlmiy whereof, I here Lnto set my hand 'ind the seal of said Court at Carlisle, Pa. I ni9_l 7 a- claw M V s [. _ ", 7. Prothonotary V Rr 4 !) a FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT 4828 LOOP CENTRAL DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK Defendant(s). NO. 02-3825 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant TERRENCE E. HECK A/1K/A TERRENCE HECK is over 18 years of age and resides at, 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. (c) that defendant ANGELA L. HECK A/K/A ANGELA HECK is over 18 years of age, and resides at, 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. (PRESENT WHEREABOUTS UNKNOWN) This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. i FRANK F 3DERMAN, ESQUIRE Attorney for Plaintiff C7 ?? C. e.a i 7 _ 7 1 C?l !r ?": rt . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT No. 02-3825 Plaintiff, V. TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $251,124.77 Interest from 11/6/02 to 3/5/03 (per diem -$41.28) $ 4,953.60 and Costs TOTAL $256,078.37 AN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff RANK FE ERM Note: Please attach description of property.No. kn 0 a a A U W ?d ??C7d Ww ? U ?? ? zk„ Ux F W O F" W C4 U` W a p / w 5O a W x ? F? w V ^: O Q d O d P cd d F F F o o G q Uz www? ??¢ d >, ? FCA UUC4p xx w o ~ O? (40 W F, w4.4 aW U0. ?FCr Ur?7 V ani ,w? wA 000 ? 45 0 z w U F / F- -}- CA i u ^ ?• rd 14 0 QO Q "Dr Dr ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Eric L. Difrenbaugh, R.P.L.S., dated June 16, 1997 and recorded in the Ofrica of the Rceorder of Deeds of Cumberland County in Plan Book 75, Page 49. BEGINNING at an iron pin in centerline of Simmons Road, S.R. 2007 at corner of Lot No. 11, as shown on said plan; thence along centerline of Simmons Road, S.It- 2007 South 39 degrees 19 minutes 14 seconds West 255.00 feet to a point; thence along land now or formerly of Charlotte G. Gregor, at al, South 89 degrees 18 minutes 42 seconds West 562.96 feet to a point at Lot No. 4 on plan; thence along Lot No. 4 North 00 degrees 30 minutes 00 seconds East 195.36 feet to a point at Lot No. 11 thence along Lot Nos. 11, North 89 degrees 18 minutes 42 seconds East 722.85 feet to a point in centerline of Simmons Road, S.R. 2007, the Place of BEGINNING. Estates. 2.8827 acres and designated as Lot No. 1:2 on the Plan of Trindle TITLE TO SAID PREMISES IS VESTED IN TERRANCE E. HECK AND ANGELA L. HECK, HIS WIFE BY DEED FROM KIMJON, INC., A PENNSYLVANIA CORPORATION DATED 812611998 AND RECORDED 9/17/1998 IN RECORD BOOK 185 PAGE 560. TAX PARCEL #2209-0539-045 BEING 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT v. Plaintiff, TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3825 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. ?FRF.NK F DERMAN, ESQUIItE Attorney for Plaintiff C? o c_: +v ,, z'?% - ?:_i ? ..,. n 6r _2_ L? `, ? i t? ' ( ?_.. .. ? - c . JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff, V. TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK AIWA ANGELA HECK Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3825 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,16 SIMMONS ROAD, MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 16 SIMMONS ROAD MECHANICSBURG, PA 17055 (PRESENT WHEREABOUTS UNKNOWN) 2. Name and address of Defendant(s) in the judgment: Same as above Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO, OF PENNSYLANIA 4910 CARLISLE PIKE, SUITE 104 MECHANICSBURG, PA 17050 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 16 SIMMONS ROAD MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. November 1, 2002 InLa ivy DATE FRANK EDERMAN, ESQUIRE Attorney for Plaintiff n ? - C_ hi _-, ,,r;, t'ii i'I' U? ` 1 - v , r=? L _ -ro ?- G '.+ ;'. ?'? 1J ^? JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT Plaintiff, V. TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK Defendant(s). CUMBERLAND COUNTY No. 02-3825 November 1, 2002 TO: TERRENCE E. HECK A/K/A TERRENCE HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 ANGELA L. HECK A/K/A ANGELA HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COL LECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. is scheduled to be sold at the Sheriffs Sale on MARCH 5, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $251,124.77 obtained by JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE; CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL that certain tract of land situate in Monroe Township. Cumberland County, Pennsylvania, bounded and described in accordance with a Pllan prepared by Eric L. Difrenbaugh, R.P.L.S., dated June 16, 1997 and recorded in the Oflice of the Recorder of Deeds of Cumberland County in Plan Book 75, Page 49. BEGINNING at an iron pin in centerline of Simmons Road, S.R. 2007 at corner of Lot No. 11, as shown on said plan; thence along centerline of Simmons Road, S.R 2007 South 39 degrees 19 minutes 14 seconds West 255.00 feet to a point; thence along land now or formerly of Charlotte G. Gregor, et al, South 89 degrees 18 minutes 42 seconds West 562.96 feet to a point at Lot No. 4 on plan; thence along Lot No. 4 North 00 degrees 30 minutes 00 seconds East 195.36 feet to a point at Lot No. 11 thence along Lot Nos. 11, North 89 degrees 18 minutes 42 seconds East 722.85 feet to a point in centerline of Simmons Road, S.R. 2007, the Place of BEGINNING. CONTAINING 2.8827 acres and designated as Lot No. 1:2 on the Plan of Trindle Estates. TITLE TO SAID PREMISES IS VESTED IN TERRANCE; E. HECK AND ANGELA L. HECK, HIS WIFE BY DEED FROM KIMJON, INC., A PENNSYLVANIA CORPORATION DATED 8/26/1998 AND RECORDED 9/17/1998 IN RECORD BOOK 185 PAGE 560. TAX PARCEL #2209-0539-045 BEING 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. c o - c r.5 - r, 2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3825 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, Plaintiff (s) From TERRENCE E. HECK A/K/A TERRENCE HECK ANGELA L. HECK A/K/A ANGELA HECK, 16 SIMMONS ROAD, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRITPION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $251,124.77 L.L. $.50 Interest FROM 11/6/02 TO 3/5/03 (PER DIEM - $41.28) - $4,953.60 AND COSTS Any's Comm % Due Prothy $1.00 Atty Paid $172.94 Other Costs Plaintiff Paid Date: NOVEMBER 5, 2002 CURTIS R. LONG Prothonot (Seal) ? Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 PNC BANK, N.A. Executor of the Estate of WILLIAM G. MAGARO, Deceased Plaintiff V. RICHARD E. PHELAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - EQUITY NO.: 95-3825 DEFENDANT'S ANSWER TO PETITION TO FIX FAIR MARKET VALUE AND NOW COMES defendant, Richard E. Phelan, by and through his counsel, and responds to plaintiff's Petition for Deficiency Judgment Hearing stating in support thereof as follows: Admitted. 2. Admitted. 3. Denied. The averments of Paragraph 3. constitute legal conclusions requiring no responsive pleading. 4. Admitted. By way of further answer, defendant is entitled to certain credits against the judgment as a result of cash received by Plaintiff prior to the sale of the Shippensburg real estate. 5. Denied. The amounts set forth by plaintiff in Paragraph 5 considerably exceed the unpaid balance of the judgment as of June 6, 2002, inasmuch as no credit against the initial amount of the judgment for cash received by plaintiff prior to June 6, 2002 (nor concomitant reduction in interest calculation) are reflected therein. 6. Admitted. 7. Admitted in part and denied in part as stated. It is admitted that the real estate was bought at the sheriffs sale on September 4, 2002 by plaintiff for $250,000 and that $250,000 is less than the unpaid balance of the judgement as of that date. It is, however, denied that the fair market value of the property on September 4, 2002 was $250,000. To the contrary, the fair market value is much higher, as will be established at the scheduled October 15, 2002 hearing. 1 SLI 298517vl/67129.001 S. Denied. The averments of Paragraph 8 constitute legal conclusions requiring no responsive pleading. 9. Denied. The averments of Paragraph 8 constitute legal conclusions requiring no responsive pleading. WHEREFORE, Defendant joins in Petitioner's request to fix the fair market value of the real estate, and thereby determine the credit to which defendant is entitled on Plaintiffs judgement. STEVENS & LEE By. (a 7 aL Mark D. Bradshaw, Esquire Supreme Ct. I.D. #61975 P.O. Box 11670 Harrisburg, PA 17108-1670 (717) 561-5258 SLl 298517vl/67129.001 CERTIFICATE OF SERVICE I, MARK D. BRADSHAW, ESQUIRE, certify that on this date, I served a certified true and correct copy of the foregoing Defendant's Answer to Petition to Fix Fair Market Value upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: John M. Eakin, Esquire Main & Market Streets Mechanicsburg, PA 17055 Date: October 7, 2002 Mark D. Bradshaw, Esquire SLl 298517vl/67129.001 3 C'3 ?? ??> ?- ??.: ?, ?'" o mr: ?. :_., - -- z. ? t `. , ' U?_..: e:0 . S ? -? fV ?? =-{ -'? JJ -G -< 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 JANUARY 3, 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 Marie SWORN TO AND SUBSCRIBED before me this 3 day of JANUARY 2003 LOBS E. SNYDER, f k Lary R6k Garda 3:, ?... ,R si My r t ' r March CUMBERLAND LAW JOURNP.,L NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 02-3825 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, PLAINTIFF vs. TERRENCE E. HECK, A/K/A TERRENCE HECK & ANGELA L. HECK, A/K/A ANGELA HECK, DEFENDANTS NOTICE TO: ANGELA L. HECK, A/K/A AN- GELA HECK NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TAKE NOTICE that the real es- tate located at 16 SIMMONS ROAD, MECHANICSBURG, PA 17055 is scheduled to be sold at Sheriffs Sale on WEDNESDAY, MARCH 5, 2003 AT 10:00 A.M. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $251,124.77, obtained by JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPO- RATION, AS ATTORNEY IN FACT (the mortgagee). Prop. sit. in the Township of MON- ROE, County of CUMBERLAND, and State of Pennsylvania. Being Premises: 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. Improvements consist of residen- tial property. Sold as the property of TERRENCE E. HECK, A/K/A TERRENCE HECK & ANGELA L. HECK, A/K/A ANGE- LA HECK. Terms of Sale: As the auctioneer knocks down a property to a suc- cessful bidder, ten (10%) per cent of the purchase price or all costs, which- ever is higher, shall be delivered to the Sheriff and, upon default of such payment, the Sheriff shall direct the auctioneer to resell the property. In all cases, the balance of the success- ful bid shall be paid to the Sheriff no later then Friday, March 21, 2003 at 12:00 P.M., prevailing time. Other- wise, all monies paid will be forfeited and the property will be re-sold on March 28, 2003 at 10:00 A.M., pre- vailing time in the Office of the Sher- iff. TAKE NOTICE that a Schedule of Distribution will be filed by the Sheriff on February 3, 2003 and distribution will be made in accor- dance with the schedule unless ex- ceptions are filed thereto within ten (10) days thereafter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Suite 1400 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Jan. 3 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-=5 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, PLAINTIFF Va. TERRENCE E. HECK A/K/A TERRENCE HECK & ANGELA L. HECK A/K/A ANGELA HECK, DEFENDANTS NOME TO: ANGELA L. HECK A/K/A ANGELA HECK "NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" TAKE NOTICE that the real estate locatedat 16 SIMMONS ROAD, MECHANICS- BURG, PA 17055 is scheduled to be so4 at Sheriff's Sale on WEDNESDAY, MARCH 5, 2003 AT 10:00 A.M. M the Clmberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to odorce the court judgment of $251,124.77, obtained by JP MORGAN CHASE BAN14FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDEKhAL FUNDING CORPORATION, AS AT- TORNEY IN FACT (the mortgagee). Prop. sit. in the Township of M N OE, Canty of CUMBERLAND, and State of Pennsylvania Being Premises: 16 SIMMONS ROAD, ME'HANICSSURG, PA 17055 Improvements consistof resklerMal property. Sold as the property of TERRENCE E. HECK A/K/A TERRENCE HECK & ANGELA L. HECK A/K/A ANGELA HECK Terms of Sale: A"& auctioneer knocks dywn a property to successful bidder, ten (1061.) perceMof the purchase prim or al costs, whichever Is higher, shall be deliv- ered to the Sheriff and, upon default of sY,h payment, the Sheriff shall direct the auctioneer to resell the property. In all coos, the balance of the successful bid shall be paid to the Sheri" not later than FridayyNarch 21, 2003 at 12:00 P.M., prevailing time. otherwise, all monies paid will be bdefted and the property will be re-sold on March 28, 2003 at 10:00 P.M., prevailin{ time in the Office of the Sheriff. TAKE NOTICE that a Schedule of Dlstribdon will be filed by the Sheriff, on February 3, 2003 and distribution w*be made in accordance with the schedule unless expec- tions are filed thereto within ten (10) daylthereafter. Frank Federman, Esquire Suite 1400, One Penn Center 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-184 4 (215) 563-7000 AtlOmej pr Plaintiff December 26, 2002 deposes that he is not interested in 3tter of the aforesaid notice or t, and that all allegations in the ement as to time, place and character are true. December 31, 2002 subscribed before me this 31 st December .2002. 4)- u Notary Public on expires: NOTARIAL SEAL SHIRLEY 0.OURNIN, Notary PuNic j Ctirttale Bao., Cumberland County ! My Commission Expires Aug g, 2003 " 10 State of Pennsylvania, County of Cumberland. PROOF OF PUBLICATION Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication Em loxn?t 11MrIM?d • HI ? 1 UVUtlyu lut Pam at 25 more Womu resur r -W& 4 SportMe *** sportl December 26, 2002 Aff!ant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. December 31, 2002 Sworn to and subscribed before me this 31 st day of December 2002. My commission expires: TARIAL SEAL aSHREY:O. DURNIN, Notary Puts;,? o., Cumberland Count, on Expires Aug 9, 2Gd3 t 14 Notary Public C7 C-- O C E 3 -TI rri 1. VvY J ? -r3 rn tJl -?G FEDERNL4,N AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 - ONE PENN CENTER PHILADELPHIA, PA 19103 215) 563-7000 JP MORGAN CHASE BANK vs. TERRENCE HECK ANGELA L. HECK ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3825 I hereby certify that a true and correct copy of the Notice of Sheriffs Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s) ANGELA L. HECK on 11/5/02 as evidenced by the attached receipts, in accordance with the Order of Court dated, 9/1/02, in addition a copy of the Notice of Sale was published in a local newspaper in the surrounding area of the mortgaged premises on 12/26/02 & 1/3/03, also a copy of the Notice of Sale was posted at the mortgaged premises by the Cumberland County Sheriffs office. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unworn falsificaton to authorities. RANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF DATE: February 3, 2003 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 192:9), 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 JANUARY 3, 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 Marie SWORN TO AND SUBSCRIBED before me this 3 day of JANUARY 2003 LOIS E. SN` DER, ND y PubHc Camels Sw=, ."rhv? d Cm Fr Cots ,z? 3 l.;t 52005 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 02-3825 JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT, PLAINTIFF VS. TERRENCE E. HECK, A/K/A TERRENCE HECK & ANGELA L. HECK, A/K/A ANGELA HECK, DEFENDANTS NOTICE TO: ANGELA L. HECK, A/K/A AN- GELA HECK NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TAKE NOTICE that the real es- tate located at 16 SIMMONS ROAD, MECHANICSBURG, PA 17055 is scheduled to be sold at Sheriffs Sale on WEDNESDAY, MARCH 5, 2003 AT 10:00 A.M. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $251,124.77, obtained by JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPO- RATION, AS ATTORNEY IN FACT (the mortgagee). Prop. sit. in the Township of MON- ROE, County of CUMBERLAND, and State of Pennsylvania. Being Premises: 16 SIMMONS ROAD, MECHANICSBURG, PA 17055. Improvements, consist of residen- tial property. Sold as the property of TERRENCE E. HECK. A/K/A TERRENCE HECK & ANGELA L. HECK, A/K/A ANGE- LA HECK. Terms of Sale: As the auctioneer knocks down a property to a suc- cessful bidder, ten (10%) per cent of the purchase price or all costs, which- ever is higher, shall be delivered to the Sheriff and, upon default of such payment, the Sheriff shall direct the auctioneer to resell the property. In all cases, the balance of the success- ful bid shall be paid to the Sheriff no later then Friday, March 21, 2003 at 12:00 P.M., prevailing time. Other- wise, all monies paid will be forfeited and the property will be re-sold on March 28, 2003 at 10:00 A.M., pre- vailing time in the Office of the Sher- iff. TAKE NOTICE; that a Schedule of Distribution will be filed by the Sheriff on February 3, 2003 and distribution will be made in accor- dance with the schedule unless ex- ceptions are filed thereto within ten (10) days thereafter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Suite 1400 One Penn Center 1617 John F. Kennedy Boulevard Philadelphia., PA 19103-1814 (215) 563-7000 Jan. 3 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication December 26, 2002 7",, ' deposes that he is not interested in fitter of the aforesaid notice or and that all allegations in the ement as to time, place and character are true. December 31, 2002 subscribed before me this 31 st December , 2002. _4 z>i n expires: t. UAO& 1 Notary Public 7106 4575 1294 1441 2526 TO: ANGELA L. HECK A/K/A ANGELA HECK { 16 SIMMONS ROAD MECHANICSBURG, PA 17055 SENDER: KMD 7 REFERENCE: 7844897 i PS Form 3800 June 2000 RETURN Postage 7 i RECEIPT Certified Fee i SERVICE Return Receipt Fee j Restricted Delivery Total Postage & F \?. -) US Postal Service CSTMARt TE Receipt for i,= s Certified Maij? o j ? ? No Insurance Coverage Provided ?jIt17" j -- Do Not Use for International Mail ------------ ------------------ --------------- ------------------------ ------- -- n CD 0 79 s AFFIDAVIT OF SERVICE PLAINTIFF JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT DEFENDANT(S) TERRENCE E. HECK A/K/A TERRENCE HECK SERVE TERRENCE E. HECK A/K/A TERRENCE HECK AT 180 STONE HEDGE LANE MECHANICSBURG, PA 17055 SERVED Served and made known to7 t C V_n ?' P C at `l4 , o'clocl?_I.m., at o Penn ylvama, in the manner described below: fendant personally served. Defendant, on the day of 1k *023 JAalno, ?ommon lth Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. -?Other: Descrip?rion Ag r-- r/I ?.., Height _D_/0 Weigh, Race Sex M Other -Y V 1 , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth erein, issued in the captioned case on the date and at the address indicated above Rbtariaa Seal UndaJ. Jurrper• Nctary Punic Sworn to and subscribed Carrde Boro, Cumbedand Cou Expires July 20W ' r before me this /?? day my ?ornmission ??. ? • ,/J of E-t& , 2003. / p asnnlw. Perxissylvar>ia Notary- ,. 3. ! _M ? By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of , 200_, at o'clock _.m., Defendant NOT FOUND because: Moved _ Unknown No Answer Vacant 1St Attempt: Time: 2nd Attempt: Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this day of 1200-. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 CUMBERLAND COUNTY KMD No. 02-3825 ACCT. #7844897 / J Type of Action V - Notice of Sheriff's Sale Sale Date: MARCH 5, 2003 RUSH co ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT ) CIVIL ACTION vs. TERRENCE E. HECK A/K/A TERRENCE HECK ) CIVIL DIVISION ANGELA L. HECK A/K/A ANGELA HECK ) NO. 02-3825 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, FRANK FEDERMAN, ESQUIRE attorney for JP MORGAN CHASE BANK FORMERLY KNOWN AS CHASE MANHATTAN, AS TRUSTEE, RESIDENTIAL FUNDING CORPORATION, AS ATTORNEY IN FACT hereby verify that on 11/5/02 & 1216/02 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 11/5/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: March 3. 2003 F1:?ANK FEDERMA , SQUIR 300 , dt? vgo6:i 0311dW Vt zo v. ooz, ?o $ S?M(iil) INlki a• Z .,r`??blsod 5?dy? H f? O O U W 0 O a a? Q? ' U CA W ? W rV•, zz? ax eW 0 in Rn In x r- t- ? oQ, a ? ? oQ. W H vav?a v JQc? Q o o Q W Q? W U W CDs a x .rA a aze ? xcW°a°? ?°a x x wrAx?aQ ?cn zw zoQO? a c W W z a Awd rAu7zz z? wzx w,?zQ,,oww w,? r? 0 a z H -r, oq a F -• QZ • iF L N M v1 R vii •t7 c b y :a A 'O w Z Q o a? 0 y T W V o y' `-•`? 1? ? p -` V ap .Z? > ' r W d ? O T p ?D l? 00 01 .r N. ?- H O. rl W F Q ? N ' a° ?Wa ?'ze zqWq ?aa ?Oa ii .0 L C £ 'fl V] zQ° 91102 P' w , £0 l6 L 3400 dIZ W021A 4311+W ;? i ZOOZ 9030 LL£OO£7000 = c? Vt ZO 008' W $ .r G3M09 A3N1{d I? ? ?? ,s i ' ? ,? Oaf r d1` 0 U sop `0'°V a C e V V1 Q T ' 1 O ?i, 0. W o a ? 'd > U = A w a ;? u H ti ? + am V N O W y , e Y:2 p0 w0 0 O k°q ?a a V ?$ z> ? ?WO ;b e?.,. ? FC?4 z UAo: A..U u V ? i * i C Ir ?z • * p T .?O Y N •? N M d' h ?O c- 00 ON "" N M C v1 ? z q 7106 4575 1294 1441 2514 TO: TERRENCE E. HECK A/K/A TERRENCE HECK 16 SIMMONS ROAD MECHANICSBURG, PA 17055 SENDER: KMD REFERENCE: 7844897 PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee .37 SERVICE 30 ` Return Receipt Fee 175 Restricted Delivery. 3 56 Total Postage & Fees IL '7 01) US Postal Service . RK Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail 7106 4575 1294 1441 2526 E TO: ANGELA L. HECK A/K/A ANGELA HECK i 16 SIMMONS ROAD MECHANICSBURG, PA 17055 SENDER: KMD REFERENCE: 7844897 i PS Form 3800 June 2000 RETURN Postage 37 RECEIPT Certified Fee 7,10 SERVICE Return Receipt Fee 1-75 Restricted Delivery Total Postage & t,'?PAN, 3-50 r US Postal Service j„ OSTMAR TE Receipt for N Certified Mail' No Insurance Coverage Provided y31' Do Not Use for International Mail -------------- ------------------------------- --------------- -- - -T7 t--_. t I L y <. ? ?_ - l; 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 JP Morgan Chase Bank fka Chase Manhattan tr is the grantee the same having been sold to said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the 5th day of November, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3825, at the suit of JP Morgan Chase Bank fka Chase Manhattan tr against Terrence E Heck aka Terrence & Angela L aka Angel a is duly recorded in Sheriff's Deed Book No. 256, Page 3613. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a S day of A.D.2003 Recorder of Deeds cM°°rd??a?m?wion°9ft-. y? ,'? A JP Morgan Chase Bank f/k/a Chase In the Court of Common Pleas of Manhattan, as Trustee, Residential Cumberland County, Pennsylvania Funding Corporation, as Attorney- Writ No. 2002-3825 Civil Term In-Fact VS Terrence E. Heck a/k/a Terrence Heck And Angela L. Heck a/k/a Angela Heck R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made diligent search and inquiry for the within named defendants, to wit: Terrence E. Heck a/k/a Terrence Heck and Angela L. Heck a/k/a Angela Heck, but was unable to locate them in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendants, Terrence E. Heck a/k/a Terrence Heck and Angela L. Heck a/k/a Angela Heck. House at mortgaged address is vacant. Defendants did not leave a forwarding address with the post office. Service upon defendants was completed by attorney for executing creditor. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 6, 2003 at 3:51 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 Terrence E. Heck a/k/a Terrence Heck and Angela L. Heck a/k/a Angela Heck, located at 16 Simmons Road, Mechanicsburg, Pennsylvania, according to law. 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 March 5, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for JP Morgan Chase Bank formerly known as Chase Manhattan, as Trustee, Residential Funding Corporation, as Attorney-In-Fact. It being the highest bid and best price received for the same, JP Morgan Chase Bank, formerly known as Chase Manhattan, as Trustee, Residential Funding Corporation, as Attorney-In-Fact of 4828 Loop Central Drive, Houston, TX 77081, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $810.00, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 15.88 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 9.66 Certified Mail 4.42 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 288.65 Patriot News 235.18 Share of Bills 25.21 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 810.00 Sworn and subscribed to before me This 36 t?- day of J R. Thomas Kline, Sheriff 2003, A.D. a't': Q_ lYYl? i4 r honotary BY J Real Estat eputy (Y' 3b??v Lk ypL3Z' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND 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: 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. 24 Writ No. 2002-3825 Civil JP Morgan Chase Bank, f/k/a Chase Manhattan, as Trustee, Residential Funding Corporation, as Attorney In Fact vs. Terrence E. Heck, a/k/a Terrence Heck and Angela L. Heck, a/k/a Angela Heck Atty.: Frank Federman ALL that certain tract of land situ- ate in Monroe Township, Cumber- land County, Pennsylvania, bound- ed and described in accordance with a Plan prepared by Eric L. Diffen- baugh, R.P.L.S., dated June 16, 1997 and recorded in the Office of the Recorder of Deeds of Cumber- land County in Plan Book 75, Page 49. f isa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this ::dm"cr' 14 day of FEBRUARY. 2003 BEGINNING at an iron pin in centerline of Simmons Road, S.R. 2007 at corner of Lot No. 11, as shown on said plan: thence along centerline of Simmons Road, S.R. 2007 South 39 degrees 19 minutes 14 seconds West 255.00 feet to a point; thence along land now or for- merly of Charlotte G. Gregor, et al, South 89 degrees 18 minutes 42 seconds West 562.96 feet to a point at Lot No. 4 on plan; thence along Lot No. 4 North 00 degrees 30 min- utes 00 seconds East 195.36 feet to a point at Lot No. 11 thence along Lot Nos. 11, North 89 degrees 18 minutes 42 seconds East 722.85 feet to a point in centerline of Sim mons Road, S.R. 2007, the Place of BEGINNING. CONTAINING 2.8827 acres and designated as Lot No. 12 on the Plan of Trindle Estates. TITLE TO SAID PREMISES IS VESTED IN TERRANCE E. HECK AND ANGELA L. HECK. HIS WIFE BY DEED FROM PENNSYLVANIA (CORPORATION DATED 8/26/ 1998 AND RE- CORDED 9/17/1998 IN RE=CORD BOOK 185 PAGE 560. TAX PARCEL #2209-0539-045. BEING 16 MECHANICSBURG, PA17 ROAD. N 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 and 11th 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 ............................. COPY Sworn to and rt 1e?his 14th d of Febr?ar 2003 A.D. SALE #24 ?- Notarial Seal J ' ,. 1L Russell, Notary is G Of Harrisburg, Dahin County REAL ESTATE SALE No. 24 ommission Expires June 6, 2066 N TARY PUBLIC Writ No. 2002825 CIVIITerm Member, Pennsylvania Association of Notaries My commission expires June 6, 2006 JP Morgan Chime Bank flk/a Chase Manhattan, as Trustee, Residential CUMBERLAND COUNTY SHERIFFS OFFICE Funding Corporation, CUMBERLAND COUNTY COURTHOUSE As Attorney In Fact PA. 17013 CARLISLE va vs Terrence E. Heck Wide , Terrence Heck and Angela L. Heck Statement of Advertising Costs y: Angola Heck Wide Atty: Frank ?C Federman To THE PATRIOT-NEWS CO., Dr. DESCRIPTION For publishing the notice or publication attached ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania, hereto on the above stated dates $ 233.43 bounded and described in accordance with aPlan Probating same Notary Fee(s) $ 1.75 prepared by Eric L. Diffenbaugh, RP.L.S., dated Total $ 235.18 June 16, 1997 and recorded in the office of the Recorder of Deeds of Cumberland County in Plan Book 75, Page 49. 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 acknowledg e receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. BEGINNING at an iron pin in the centerline of Simmons Road, S.R. 2007 at comer of Lot No. 11, as shown on said plan; thence along centerline of Simmons Road, S.R. 2007 South 39 degrees 19 minutes 14 seconds West 255.00 feet to a point; thence along land now or formerly of Charlotte G. Gregor, et al, South 89 degrees 18 minutes 42 seconds West 562.% feet to a point at Lot No. 4 on plan; thence along Lot No. 4 North 00 degrees 30 minutes 00 seconds Past 195.36 feet to a point at Lot No. I l thence along Lot Nos. 11, North 89 degrees 18 minutes 42 seconds East 722.85 feet to a point in centerline of Simmons Road, S.R. 2007, the Place of BEGINNING. By..... CONTAINING 2.88Z-1 acres and designated as Lot No. 12 on the Plan of Trindle Estates. TITLE TO SAID PREMISES IS VESTED IN Terrance E. Heck and Angela L. Heck, his wife, by Deed from Kimjon, Inc., a Pennsylvania corporation, dated 8WI998 and recorded 9/17/ 199, in Record Book 185 Page 560. TAX PARCEL #2209-0539.045. BEING 16 Simmons Road, Mechanicsburg, PA 17055.