HomeMy WebLinkAbout02-4025 LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of
Jeanne German,
Plaintiff
:
VS. :
:
:
Vincent McCue, :
Defendant :
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANNIA
: Civil Division
No.: 96-1244
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY OF SAID COURT:
Please revive the Judgment in the above captioned matter in
favor of the Plaintiff and against the Defendant, Vincent McCue at 460
St. Johns Drive, Camp Hill, Pennsylvania, 17011 for the amount of
$35,000.00 plus costs of $208.78 and interest from October 1992.
Thank you for your attention in this matter.
Date: oC~/2-~-~-
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of :
Jeanne Garman, :
Plaintiff :
:
:
VS. :
:
:
Vincent McCue, :
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
No.: 02-4025
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please enter my appearance on behalf of Plaintiff Vivian
Brannen, Executrix of the Estate of Jeanne Garman in the above
matter.
Date:
tephe'n J. I-~g~,, Esquire
Attorney for Plaintiff
SOS220D Cumberland County Pennsylvania
· Docket Entries
1996 01244
03 12 96
P BRANNEN VIVIAN ETC (VS) MCCUE VINCENT
Page 1 of 1
............. FIRST ENTRY ..............
SHERIFF'S FILE RETURNED FILED.
Case Type: WRIT OP REVIVAL Ret Type.: Regular
Litigant.: MCCUE VINCENT
Address..: 460 ST JOHNS DRIVE
Cty/St/Zp: CAMP HILL, PA 17011
Hnd To: BARB MCGREGOR, ADULT ROOMMATE OF VINCENT MCCUE
Shf/Dpty.: PHILIP BAUGHMAN
Date/Time: 03/11/1996 1350:00
Costs .... : $27.84 Pd By: ANGINO AND ROVNER 03/12/1996
.............. LAST ENTRY ..............
F2=Done Fg=Add F12=Cance1 F13=Reseq F17=Top F18=Bottom
vivian'Brannen, Executrix of
the Estate of Jeanne Garman
va.
Vincent McCue
460 St. John Dr.
Camp Hill PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, pENNSYLVANIA
CIVIL ACTION - LAW
02-4025 Civil TERM 19~
NO.
TO
Vincent McCue:
WRIT OF REVIVAL
You are notified that the plaintiff has commenced a proceeding
revive and continue the lien of the judgment entered to
NO.96-1244
Civil TERM 19
to
The Plaintiff claims that the amount due and unpaid is $ 35,000.00
with interest from October, 1992
You are required within twenty (20) days after service of this Writ
to file an answer or otherwise, plead to this Writ. If you fail to do
so, judgment of revival will be entered.
Costs
$ 135.62 Pd Atty
$2.00 Co. due
Date August 23, 2002
CURTIS R. LONG
PROTHONOTARY
Seal
Stephen J. Hogg, Esq.
Attorney for the Plaintiff
19 S. Hanover St.
Carlisle PA 17u13
(717) 245-2698
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-04025 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRANNEN VIVIAN ET AL
VS
MCCUE VINCENT
HAROLD WEARY Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to
says, the within WRIT OF REVIVAL was served upon
MCCUE VINCENT the
DEFENDANT
, at 1224:00 HOURS,
at 460 ST JOHN DRIVE
CAMP HILL, PA 17011
VINCENT MCCUE
on the 10th day of September, 2002
by handing to
a true and attested copy of WRIT OF REVIVAL
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.97
Affidavit .00
Surcharge 10.00
.00
36.97
Sworn and Subscribed to before
me this j~ day of
~J~ ~-~ A.D.
~rdthonotary
So Answers:
R. Thomas Kline
09/11/2002
STEPHEN HOGG
By:
Sheriff/
SHERIFF ' S RETURN - REGULAR
CASE NO: 2002-04025 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRANNEN VIVIAN ET AL
VS
MCCUE VINCENT
HAROLD WEARY , Sheriff or Deputy She
Cumberland County,Pennsylvania, who being duly sworn
says, the within WRIT OF REVIVAL was served
MCCUE VINCENT
DEFENDANT , at 1224:00 HOURS, on the 10th day o~
at 460 ST JOHN DRIVE
CAMP HILL, PA 17011
~iff of
Lccording to law,
upon
the
SePtember, 200___~2
by handing
VINCENT MCCUE
a true and attested copy of WRIT OF REVIVAL
together with
and at the same time directing His attention to the ontents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.97
Affidavit .00
Surcharge 10.00
.00
36.97
Sworn and SubScribed to before
me this q~ day of
_~ ~3 A.D.
~7 ~rothonot ary /
So Answers
R. Thomas Kline
09/11/2002
By: 7~/z~ 1
'Depu~ Sherit-~/
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix: IN THE COURT OF COMMON PLEAS
of the Estate of · CUMBERLAND COUNTY,
Jeanne Garman, : PENNSYLVANNIA
Plaintiff : Civil Division
:
vs. : No.: 02-4025
:
Vincent C. McCue, :
Defendant :
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
To the Prothonotary:
Kindly enter judgment for Plaintiff and against Defendant
Vincent C. McCue only, and assess damages certified to be calculable
as a sum certain from the Complaint.
Principal due
Interest
Attorney Comm.
Costs
$35,000.00
$22,050.00
$5,250.00
$1,758.78
Total · $64,058.78
I understand that any false statements therein are subject to the
penalties contained in Title 18 of the Pennsylvania Consolidated
Statues Section 4904, relating to unsworn falsification to authorities. I
verify that:
Vincent C. McCue's precise last known address is 460
St. Johns Drive, Camp Hill, PA 17011.
The named Defendant is not in the military service of
the United States or otherwise within the coverage of
the Soldiers and Sailors relief Act and is over 18 years
of age.
It is certified that a written notice of intention to file this
Praecipe was mailed to the Defendant against whom
judgment is to be entered and their attorney(s) of
record, if any, afte~ the default occurred and at least
10 days prior to the date of filing of the Praecipe.
Date:
~ephen J. ~g.~, Esquire
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
VERIFICATION
I verify that the statements made in the foregoing document to
the Court of Common Pleas of Cumberland County, Pennsylvania, are
true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. Section 4904, relating to unsworn
falsifications to authorities.
Date:
Attorney for Plaintiff ,/
LAW OFFICES OF
STEPHiq. N j. ttOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix: IN THE COURT OF COMMON PLEAS
of the Estate of ' CUMBERLAND COUNTY,
Jeanne Garman, : PENNSYLVANNIA
Plaintiff : Civil Division
:
vs. : No.: 02-4025
:
Vincent C. McCue, :
Defendant :
TO:
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
DATE: March 22, 2003
IMPORTANT NOTICF
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 help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013//
(717) 246-3166
$tepaen
ARorney for P~ntiff
Vivian Brannen, Executrix: IN THE COURT OF COMMON PLEAS
of the Estate of : CUMBERLAND COUNTY,
Jeanne Garman, ' PENNSYLVANNIA
Plaintiff
VS.
Vincent C. McCue,
Defendant
· Civil Division
:
· No.: 02-4025
..
..
Notice: VINCENT C. MCCUE
Pursuant to Pa. R.C.P. No. 236 Vincent C. McCue is hereby notified
that a Judgment has been entered against you in the above
proceeding as indicated below.
X
Judgment by Default:
Money Judgment:
Amount on Award of Arbitrators:
Judgment on Verdict: $35,000.00
Money Judgment Transferred
From Other Jurisdiction:
Other:
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE
PLEASE CALL ATTORNEY STEPHEN J. HOGG AT THIS
TELEPHONE NUMBER: 717-245-2698
PROTHONOTARY
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of
Jeanne Garman,
Plaintiff
VS.
Vincent C, McCue,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
No.: 02-4025
NOTICE IS HEREBY GIVEN to the Defendants and those parties who
hold one or more mortgages, judgments, or tax liens against the real
estate which is the subject of the NOTICE OF SALE pursuant to
Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common Pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached NOTICE OF SALE.
YOU ARE FURTHER NOTIFIED that the lien you hold against the
said real estate will be divested by the sale and that you have an
opportunity to protect your interest, if any, by being notified of the
Sheriff's Sale.
/~t.e. P hen j. H~e~/Esquire
At-[orney for Plaintiff
Date:
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix: IN THE COURT OF COMMON PLEAS
of the Estate of ' CUMBERLAND COUNTY,
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
· PENNSYLVANNIA
· Civil Division
:
:
· No.: 02-4025
:
:
:
:
.AFFIDAVIT PURSUANT TO RUI ~= 3129.1
TO THE PROTHONOTARY OF SAID COURT:
Vivian Brannen, Plaintiff in the above action, through her
attorney, Stephen J. Hogg, sets forth as of the date the Praecipe for
Writ of Execution was filed the following information concerning the
real property located at 460 St. John Drive, Cumberland County, Camp
Hill, Pennsylvania:
1. Name and address of owner[s] or reputed owner[s]:
.NAME
Vincent C. McCue
Elizabeth A. Wian
NAME
Vincent C. McCue
ADDRESS
460 St. John Drive
Camp Hill, PA 17011
Cumberland County
36 Greenfield Drive
Carlisle, PA 17013
Cumberland County
Name and address of defendant[s] in the judgment:
ADDRESS
460 St. John Drive
Camp Hill, PA 17011
Cumberland County
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
NAME
Kim Tuschak
ADDRESS
4 N. Seasons Drive
Dillsburg, PA 17019
4. Name and address of last recorded holder of every Mortgage of
record:
NAME
None
ADDRESS
5. Name and address of every other person who has any record lien
on the real property:
NAME
Cumberland County Tax Claim Bureau
2000 taxes: $ 5.15
2001 taxes: $457.64
ADDRESS
19 S. Hanover Street
Ste. 102
Carlisle, PA 17013
Name and address of every other person who any has any record
interest in the property and whose interest may be affected by the
sale:
Unknown
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property who may be
affected by the sale:
Unknown
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge, information, and belief.
understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. {}4904 relating to unsworn falsification to
authorities.
Date:
Stephen J, ~l(~g~, Esquire
Attorney for plaintiff
EXHIBIT A
WITNESSETH, th~t i, ca,~ider~tio, o! Twenty-Slx Thousaad ($Z6,000.00) '...
Dollnrs.
in ~ ~, th~ rgv~t ~hgreo[ ~ k~b~ a~nowl~d~vd, th~ said ~rantor a do h~b~
an con,er ~ gh~ said ~,g~e s their heirs and assigns,
ALL t~t certain lot of ~and situate l~ the Township of ;~den,
County o~ C~ber~a~d and State of Pennsylvania, more particularly
bounded and described as fol~ows, to wit:
~ING at an ~ron p~n/~e ~ntersect~on of the northern
of West Circle and the western ~ne of Point ~idge D~lve, as
on the here~ter mentioned Plan of ~ta; thence South e~ghty-
t~ee (83) degrees ~lve (5) m~nutes West n~ong ~he northern l~ne
o~ West C~rc~e one hundred ten (~]O) fee~ to a po~n~; thenc~ North
twenty (20) de,roes seven (7) m~nutes West a~ong~e eastern
o~ ~t No. 8, aa sho~ on the sa~d Plan, one hundred seven,y-four
end ~orty-~ve hundredths (~7~.~5) feet to a stake. ~hence
~ght~-t~ee(83) degrees f~ve (5) mlnut~- ,~ ...... j_ ~- N~th~
· ~n~ o~ ~ No. ]0, as 8horn on said Plan, on8 hundrod
feet to an iron pin at ~he western line of Poin~ Ridge ~ive, now
~own as St. Jo~s Drive; thence South six (6) degrees fifty-five
(55) minutes East, along the western llne of P~t Ridge
hundred seventy (170) feet to the place of BEGINNING. Drive one
~INO ~t No. 9 as shown on Plan of Lots, Section l,'Point ·
Ridge Farm, ~den Township, Cumberland County, Penhsy]~nia, said
Plan being ~ecorded In the Cumberland County Hecorder~s Offlce In
Plan ~ok 8, Page 2.
~VINO thereon erected ~ one story brick ranch dwelling with
a'ttached ~wo car garage.
~INO the same premises whloh George DeBoard anti Ruby D.
~avd) his Wife, by their deed da~od April Iii, 1958 and recorded
in the Recorder of ~eds Office in and f~r Cumberland County,
Pe~eyl~nia, In ~ed ~ok ]8-J, Pago ]6~ granted and conveyed
~to the Orantora herein.
T~ above described premises nrc conveyed under and. subject
to.a mortgage b~ record from tho Grantors herein ~o Peoples Bond
and Mortgage Co,any assigned to Mutual Lifo Insurance Company of
New Yo~k which the Orantees assume and agree to pay according to ."
the te~s and conditions of the said mort age and accomp n I ,
The above deso~ibed ppemi~e, a~e also ~onve~ed n~er and sub~ : '~
Ject to eaae~nts and restrictions of record, i '~'.' ·
Vivian Brannen, Executrix:
of the Estate of
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY,
· PENNSYLVANNIA
· Civil Division
:
· No.: 02-4025
..
:
:
:
AFFIDAVIT OF MAILIN~
I, Stephen J. Hogg, Esquire, attorney for Plaintiff, do hereby verify that
I have sent the attached notice and affidavit (copies of which are
attached hereto), to the mortgages, judgment creditors, the
defendants, terre-tenant(s), and others listed below notifying them of
the Sheriff's Sale of Real Estate in the above captioned action. Said
notice~_as be~n sent certified mail, return receipt requested, on
/"~/~1,4K_~ j/~--'/',~ ~ to the address listed on the copy
attached hereto. '~'
(1) Vincent C. McCue
(2) Elizabeth A. Wian
(3) Klm Tuschak
(4) Cumberland County Tax Claim Bureau
The foregoing information is true and correct to the best of my
knowledge, information, and belief, and is made subject to the
s of 18 Pa.C.S. {}4904, to
authorities, relating~rn falsification
Date: .~/~--"/~'~' tephen J. :~g~squire
Attorney fo,,V'Pla,~tiff
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of :
Jeanne Garman, :
Plaintiff ·
VS. ·
Vincent C. McCue, ·
Defendant ·
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
No.: 02-4025
on
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT
TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held
in the Cumberland County Courthouse, at
, prevailing time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED.)
THE LOCATION of your property to be sold is:
460 St. John Drive
Camp Hill, PA 17011
THE JUDGMENT under or pursuant to which your property is
being sold is docketed to:
Cumberland County Court of Common Pleas
EXECUTION NUMBER: 2003-
LAW OFFICES OF
STEPHEN j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of :
Jeanne Garman, ·
Plaintiff ·
VS. ·
Vincent C. McCue, ·
Defendant ·
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
No.: 02-4025
AFFIDAVIT OF MAILINC,
I, Stephen J. Hogg, Esquire, attorney for Plaintiff, do hereby verify that
I have sent the attached notice and affidavit (copies of which are
attached hereto), to the mortgages, judgment creditors, the
defendants, terra-tenant(s), and others listed below notifying them of
the Sheriff's Sale of Real Estate in the above captioned action. Said
notic/e.~.s_be..e,~Fsent certified mail, return receipt requested, on
· ///'('~ /'?/~C~0 ~. to the address listed on the copy
attached hereto. ' /
(1) Vincent C. McCue
(2) Elizabeth A. Wian
(3) Klm Tuschak
(4) Cumberland County Tax Claim Bureau
The foregoing information is true and correct to the best of my
knowledge, information, and belief, and is ma, ~e subject to the
penalties of 18 Pa.C.S. {}4904, relating to,,~/ v(~,n falsification to
authorities. ~
Date: ~/~'~C_~ _~//~
' ' ~tephen J. Hoj~, ~squire
Attorney for Plaintiff
IN THE COURT OF COMMON PLFAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
BRANNEN VIVIAN ~
: ( ) Confessed Judgment
: ( ) Other
vs.
MCCUE, VINCENT ~.
: File No. 2002-04025
: Amount Due $35t000.00
: Interest $22,050.00
: Atty's Corem $5,250.00
: Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installrr~nt sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
an~nded; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described p-roperTy of the
defendant(s) Vincent McCue: Real Estate at 460 St. Johns Drive , Cumberland
Count Cam i 11 n · 1 '
PRAECIPE FOR AT~~ EX~CUT/_ON
Issue writ of attachment to the Sheriff of
County, for debt,
interest and costs, as above, directing attachment aga/nst the above-nan~d _garnishee(s) for
the following proper~y (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee ( s ).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against
real ~state-of the defendant(s) described in the attached ex~i~,~.
DATE:_. ~,~/(~/0 '-~ Signature: .~~
Print Name: Stephen/~.~ogg, Esquire
Address: 19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
A~ ~o .rney for: Plaintiff .
Telephone: (717) 245-2698
.i;ti!','.'c'.~.t, C~L:: : ID Nc~.: 36812
Notes: If real property, supply six copies of description including improvements and an - original and copy of affidavit of ownership (PaR. C.P. No- 3129).
If lengthy personaltY list, supply four copies of list.
To index writ, file separate praecipe with writ.
Vivian Brannen, Executrix of the Estate
Of Jeanne Garman
VS
Vincent C. McCue
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-4025 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Stephen J. Hogg.
Sheriff's Costs:
Docketing 30.00
Poundage 13.27
Posting Bills 15.00
Advertising 15.00
Mileage 31.05
Levy 15.00
Surcharge 20.00
Law Library .50
Prothonotary 3.00
Law Journal 270.05
Patriot News 235.18
Share of Bills 28.90
$ 676.95 paid by attorney
9/4/03
Sworn and subscribed to before me
This .lO ~ day of ~zT~
Prothonotary
R. Thomas Kline, Sheriff
Real Es(~qte Deputy
Real Estate Sale # 33
On May 23, 2003 the sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA
known and numbered as 460 St. Johns Dr.,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: May 23, 2003
Real Estate Deputy
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ac~ 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/ Metre 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
COPY
S A L E #33
Tern/L Russell, NO~ p ·
J My(~F'~June6'2O~6 I NO'I~,RY PUBLIC
IV, em~r.l~A~x:iaa~OfNolat~y commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA, 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$ 233.43
$ 1.75
$ 235.18
Publisher's Receipt for Advertising Cost
publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
receipt of the aforesaid notice and publication costs and certifies that the same have
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.
~ E~TATE 8ALE NO, 33
Writ No. 2002 4025 Civil
Vlvian Brannen, Executrix of the
Estate of Jeanne Garrnan
VS.
Vincent C. McCue
Atty.: Stephen J. Hogg
LEGAL DESCRIPTION
ALI. that certain lot of land situ-
ate in the Township of Hampden.
County of Emnberland and State of
Pennsylvania, more particularly
bomxded and described as follows,
to wit:
BEGINNING at an iron pin in the
intersection of the northern line of
West Circle and the western line of
Point Ridge Drive. as shown on the
hereinafter mentioned Plan of lots;
thence South eighty-three i831
grees five {51 minutes West along
the northern line of West Circle one
hundred ten tlr0) feet to a paint;
thence North twenty 1201 degrees
seven {7) minutes West along the
eastern line of Lot No. 8. as shown
on the said Plan, one hundred
seventyffour and forty five hun-
dredths (174.45) feet to a stake;
thence North eighty-three (83)
grees live i51 wanutes East along the
southerly line of Lot No. 10, as shown
on said Plan, one hundred fifty (1501
feet to an iron pin at the western
line af Point Rid_ge_ Driv~ now
Atty.: S~ephen ,J. ~",e~
LEGAL DESCRIPTION
ALL that cei~ain lot of laxxd sltu
ate in the Township of Hampden,
County of Cumberland and State of
Pennsylvania. more particularly
bounded and described as follows,
to wit:
BEGINNING at an iron pin in the
intersection of the northern line of
West Circle and the western line of
Point Ridge Drive, as shown on the
hereinafter mentioned pla~ of lots;
thence South eighty4hree (831 de-
grees five (5} minutes West along
the northern line of West Circle one
hundred ten (1101 feet to a point:
thence North twenly (20) degrees
seven (71 minutes West along the
seventy four and forty-five hun-
thence North eighty three {83) de-
grees five {5) minutes East along the
on said Plan, one hundred fifty [150)
line of Point Ridge Drive, haw known
six 16) degrees fifty-five [55) Ir/tn-
Point Ridge Drive one hundred sev-
enty [170) feet to the place of BE-
Farm, Hampden Township, Cumber-
land Count-/, Pennsylvania. said Plan
Book 8, page 2.
inched two car garage.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Br~nnen Vivian ~
McCue Vincent/
( ) Confessed Judgment
( ) Other
File No. 2002- 04025
Anount Due $35,000.00
Interest $23,800.00
Arty' s Corm $6,000.00
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
Th~ undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgn~nt, but if it does,
it is based on the appropriate orJ.ginal proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s) Vincent McCue: Real Estate at 460 St. Johns Drive,
Cumberland County, Camp Hill, Pennsylvania
PP, A~CIPE ~DR A~TA(ZP~M~%~ EXECUTION
Issue writ of attachment to the Sheriff of County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply slx copies of the description; supply four
copies of lengthy person~tlty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee( s ).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against
DATE:real estate of the defendant (s)'~//?/~ ? described inSignature the at tached ex~ t~~: ~. //Y/~/' _
Print Name: Stephen ~'. ~'{ogg, Esquire
Address: 19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
At tor~ey for: Plain~i_~ f
Ieie~hone: 245-2698
;/:ytc!!'-' <'~:: '~ ID NC~.: 36812
Notes: If re~l property, supply six copies of description including LmProvements and an
original and copy of affidavit of ownership (PaR. C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
BETWEEN
BONALD ?. (]U$CHEL and MARY E. (]USCHEL, his wife,
of l~"mpdgn Township, Cumberland County, Pennsylvania,
~art!cs of the first, pert ..............
VINCENT C, McCrJE and ELIZABETH A. McCUE, Ills wife,
of the b~rougD of Camp ]till, Cumberlaqd County,
Pennsylvania, parties of the second pq~rt
SVITNE$SETH, thu~ b; ¢o.,id~rat. ion of TwenLy-S tx Thousand ($26,000,00) '- - -
............................... Dolt,Ira,
ALL t~t certain lob of land situate ih the Township of I~den,
bounded and described as follows, to wit:
~I~ING a~ an iron ptn/~e Intersection of the northern line
on the hereinafter mentioned Plan of Lots; ~honce South eighty-
three (83) de,roes five (5) minutes Wes~ along the northern llne
of West Circle one hundred ten (110) fee~ ~o a point; thence North
twenty (~O) degrees seven (7) minutes West along ~e eastern line
of. ~t No. 8, as shown on the said Plan, one hundred seventy-four
and forty-five hundredths (17~.I~5) feet to.a stake; thence North
eight~-t~ee(83) degrees flys (5) minutes East alon~ the southerly
line of ~t No. 10, as shown on said Plan, one hund~e,l
~own as St. Johns Drive; thence South slx (~) degrees f[f~y-five
(55) minutes Esst~ ,lon~ the western line of P~t Ridge Drive one
hundred seventy (170) feet to the place of BEGINNING.
BEING ~t No. 9 as shown on Plan of Lots, Section l, Point '
'Plan ~ok 8, Page 2.
~ING 6he same premises whlcb George DeBoard and Ruby
~Boa~d~ his wife, hy their deed dated April 1~, 1958 and I. ecorded
In the Recorder of Deeds Office In end f~r Cumberland Coungy,
Pe~syl~nia, In ~od ~ok 18-J, Page .16~ granted and conveyed
¸%.
to.a mortgage b£ ~ecord from ~he Grantors herein to Poop]es Bond P.i '~'.'
end Mortgage Company assigned to Mutual Life Insurance Company of ~ ..
mortgage bond. Tho present balance o~ the mortgage is :[;2~,8q9.O~. "'~
Tile above"deecrihed premises are also conveyed ~er end ~ubi i '
Ject to'eaae~nts and restrtctioni of record, [ I.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-4025 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VIVIAN BRENNAN, EXECUTRIX OF TE ESTATE OF
JEANNE GARMAN Plaintiff (s)
From VINCENT MCCUE, 460 ST. JOHNS DR,, CAMP HILL PA 17011.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 460 ST. JOHNS DRIVE, CAMP HILL PA 17011 (SEE LEGAL
DESCRIPTON).
(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) ~fpr~perty~fthedefendant(s)n~t~eviedup~nansubjectt~attachmentisf~undinthep~ssessi~n
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 $35,000.00
Interest $23,800,00
Atty's Corem % $6,000.00
Atty Paid $945.50
Plaintiff Paid
Date: FEBRUARY 19, 2004
(Seal)
REQUESTING PARTY:
Name STEPHEN J. HOGG, ESQ.
Address: 19 S. HANOVER ST., STE. 101
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: (717) 245-2698
Supreme Court ID No. 36812
Due Prothy 1.00
Other Costs
CURTIS R. LONG
STEPI-I~N J. I-IOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
VivJan Brannen, Executrix:
of the Estate of :
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNiA
CivilDivision
No.: 02-4025
AFFIDAVIT PURSUANT TO RULE 3129.1
TO THEPROTHONOTARY OFSAIDCOURT:
Vivian Brannen, Plaintiff in the above action, through her
attorney, Stephen J. Hogg, sets forth as of the date the Praecipe for
Writ of Execution was filed the following information concerning the
real property located at 460 St. Johns Drive, Cumberland County,
Camp Hill, Pennsylvania:
1. Name and address of owner[s] or reputed owner[s]:
NAME ADDRESS
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
Cumberland County
Elizabeth A. Wian
36 Greenfield Drive
Carlisle, PA 17013
Cumberland County
2. Name and address of defendant[s] in the judgment:
NAME ADDRESS
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
Cumberland County
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
NAME
Kim Tuschak
ADDRESS
4 N. Seasons Drive
Dillsburg, PA 17019
4. Name and address of last recorded holder of every Mortgage of
record:
NAME
None
ADDRESS
5. Name and address of every other person who has any record lien
on the real property:
NAME
Cumberland County Tax Claim Bureau
2000 taxes: $ 5.15
2001 taxes: $457.64
ADDRESS
19 S. Hanover Street
Ste. 102
Carlisle, PA 17013
6. Name and address of every other person who any has any record
interest in the property and whose interest may be affected by the
sale:
;TEPHEN J. ItOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Unknown
Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property who may be
affected by the sale:
Unknown
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge, information, and belief. I
understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Date:
~tephen J. H~g, Esquire
Attorney for Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
Supreme Court ID#: 36812
~TEPHEN.,I. HOC~
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
EXHIBIT A
MADLY, TH~ ' ' I/ T ~
o/ Ot~r Lord OhO thos~and nin$ hnndred ~x~y (
o~ I~mpd~n To~n~hlp~
par~os ct the tirst
VINCENT ~:. McCrIE and ELIZ~H A, McCUE, His wife,
of the ~,rough of Ca~ N~ll, Cumberlaqd County,
Ps.sylvania, par~ee of the ~econd pq'r~ .... . -
WI~WIZ$$gTIL tAat in contidtratlon o[ Twent¥-51n Thousand ($26~000.00} '- - -
hertb~ ~ant
nn conve~ to th~ raid ~rant~ s their heirs and assigns,
ALL t~t certain lot of land situate i~ the Township of
County o~ C~berland and S~a~e of Pon..ylvanla, moro particularly
bounded and described as follows, to
~ING a~ an ~ro. pin/~e ln~ersec~fon of the norther~ l~ne
of West Circle and the western linc of Point HidEs D~tve, as ahow~x
on the hereinafter mentioned Plan of Lots; thence South
~hree (83) degrees f~ve (5) minutes Wes~ a~ong the northern line
of West Oircle one hundred ten (1~0) feet to a point; thence North
twenty (20) de~rees seven (7) m~nu~es West along O,e eastern line
o~ ~t No. 8, as shown on tho sa~d Plan, one hundred seven,y-four
and fo~ty-five hundredths (17~.;~5) feet to a sta]{e; thence North
eighty t~ee(83) degrees five (5) m~nutes EsS~ alon~ the southerly
l~ne of ~t No. ]0, as shown on said Plan. o~e hundred f~f~y'(150]
fee~ to an iron pin at ~be western l~ne of Pofnt Midge Drive, no~
~own as St. Johns Dr~ve; thence Sou~h slx (~) de,tees fifty-five
(55) m~nutos Ess~, elong the wester~ line of.P~ Ridge Drive one
hundred seventy (170) fee~ to the p~ace of
BEING ~t Ho. 9 as shown on P~sn of Lots, Section l,'Point ·
Ridge Farm, I~m~en To~{nshlp, Cumber]and County, Pen~sy]~nia. sa~d
~Boa~di his wife, by ~heir deed dated Apr~l IIi, 1958 anJ re~orded
Pe~syl~nia, In ~od ~ok 18-J, Pa~e ~6~ granted and conveyed
end Mortgage Company assigned to Mukua~ Life Insurances Company of .'
mortgage bond. Tho present balance of tBe mortgage ls :1;20.t~9.o0. .. .'
Ject ~o'ease~n~s end, res~ric~iooi of record, [ {..
· ,.. ,.
Vivian Brannen, Executrix:
of the Estate of
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
INTHECOURTOFCOMMONPLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
CivilDivision
No.: 02-4025
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT
TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held
on in the Cumberland County Courthouse, at
, prevailing time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED.)
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
THE LOCATION of your property to be sold is:
460 St. Johns Drive
Camp Hill, PA 17011
THE JUDGMENT under or pursuant to which your property is
being sold is docketed to:
Cumberland County Court of Common Pleas
EXECUTION NUMBER: 2004 ~
THE NAME OF THE OWNER OR REPUTED OWNER OF THIS
PROPERTY IS:
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
Cumberland County
and
Elizabeth A. Wian
36 Greenfield Drive
Carlisle, PA 17013
Cumberland County
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 hod mortgages and
municipalities that are owed taxes) will be filed by the sheriff twenty
(20) 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 Cumberland County,
1 Courthouse Square, Carlisle, 17013, (717) 240-6100
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
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. 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. IF' YOU CANNOT AFFORD A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET FREE LEGAL ADVICE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
You may file a petition with the Court of Common Pleas
of Cumberland County to open the judgment if you have
meritorious defense against you. You may also file a
petition with the same court if you are aware of a legal
defect in the obligation or the procedure used against
you.
After the sheriff's sale you may file a petition with the
Court of Common Pleas of Cumberland County to set
aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the
sheriff's deed is delivered.
A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be
presented to the Court of Common Pleas of Cumberland
County at one of the court's regularly scheduled business
court sessions. The petition must be served on the
attorney for the creditor or on the creditor at least two
business days before presentation to the court, and a
proposed order or rule must be attached to the petition.
If a specific return date is desired, that date must be
obtained from the Court Administrators' Office, 1
Courthouse Square, Carlisle, before presentation of the
petition to the court.
S,ephe. J.
Attorney for Plaintiff'
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
Supreme Court ID#: 36812
LAW OFFICES OF
STEPI~E~ J. I-IOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
LAW OFFICES OF
STEPHEN j. HOGG
10 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of :
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
No.: 02-4025
AFFIDAVIT OF MAILING
I, Stephen J. Hogg, Esquire, attorney for Plaintiff, do hereby verify that
I have sent the attached notice and affidavit (copies of which are
attached hereto), to the mortgages, judgment creditors, the
defendants, terre-tenant(s), and others listed below notifying them of
the Sheriff's Sale of Real Estate in the above captioned action. Said
notice has been sent certified mail, return receipt requested, on
~-~E~'o.o,~u ~: ~OO~r to the address listed on the copy
attached hereto.
(1) Vincent C. McCue
(2) Elizabeth A. Wian
(3) Kim Tuschak
(4) Cumberland County Tax Claim Bureau
The foregoing information is true and correct to the best of my
knowledge, information, and belief, and is made subject to the
penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Stephen J~, Esquire
Attorney fbr Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
Supreme Court ID#: 36812
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
~ Print Clearly)
I-I Agent
address different from item 17 f-lyes
If YES, enter delivery address below: ~,~1o
[-] Registared ~;[,Return Receipt for Merchandise
FI Insured Mail [] C,O.D.
Restricted Delivery? (Extra Fee)
2, Article Number
¢_ransfer from service label) "T O0 ~ DqlO
PS Form 3811, March 2001 Domestic Return Receipt
J Postage & Fees Paid
I usPs
L Permit No. G-10 J
· Sender: Please print your name, address, and ZIP+4 in this box ·
· Complete items 1, 2, and 3. Also complete
item 4 ~f Restricted Delivery is desired.
· r name and address on the reverse
· pnnt y.ou .... return the card to you.
or on the front if space permits.
1. Nticte Addressed to:
(Tran~
A. Received by (p~ease print clear~v) h
iD Agent
:3yes
~r delive~ address below:
'D Registered
Dyes
02595'01 .M-1424
Sender Please ~rint'YeUr~rame' ad~~
.- - 1 2, snd 3 Also complete
· /~r on the front ff space P
· Comptete items 1, 2, and 3. Also comptete
item 4 if Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
PS Fm
A. Received by (Please pdnt C!eady)
C. Signature r-I Agent
3Yes
if YES, enter delivery address below: r-I No
3 Se~,ice Type
~ ~. Certified Mail ["[ Express Mail
[ i-3 Registered ~ Return Receipt for Merchandise
~_ r"l Insured Mail [] C.O.D. __
UNITED STATES POSTAL SE~
· Sender: Please P~wni~r~e, address-; and-'ZIP¥~'lll-tf~is-box
I"Jlh'JIh,,,,,ll,,th,,IJ,,,ll,,,hhll,,l,h,hl,,,ll,,i
Vivian Brannen, Executrix of the
Estate of Jeanne Garman
VS
Vincem C. McCue
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-4025 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Stephen Hogg.
Sheriff's Costs:
Docketing 30.00
Poundage 19.68
Posting Handbills 15.00
Advertising 15.00
Law Library
Prothonotary 1.00
Levy 15.00
Mileage 20.70
Postpone Sale 20.00
Surcharge 20.00
Law Journal 470.00
Patriot News 347.89
Share of Bills 29.26
$1003.53
Sworn and subscribed to before me
This tq ~ day
2004, A.D.~
Prothonotary
So Answers:
R. Thomas Kline, Sheriff
Real Esffite Deputy
i~EPI-IEN J. HOGG
i S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Vivian Brannen, Executrix:
of the Estate of :
Jeanne Garman,
Plaintiff
VS.
Vincent C. McCue,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANNIA
: Civil Division
:
:
: No.: 024025
:
:
:
:
AFFIDAVIT PURSUANT TO RULE 3129.1
TO THE PROTHONOTARY OF SAID COURT:
Vivian Brannen, Plaintiff in the above action, through her
attorney, Stephen J. Hogg, sets forth as of the date the Praecipe for
Writ of Execution was filed the following information concerning the
real property located at 460 St. Johns Drive, Cumberland County,
Camp Hill, Pennsylvania:
1. Name and address of owner[s] or reputed owner[s]:
NAME ADDRESS
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
Cumberland County
Elizabeth A. Wian
'36 Greenfield Drive
Carlisle, PA 17013
Cumberland County
2. Name and address of defendant[s] in the judgment:
NAME ADDRESS
Vincent C. McCue
460 St. Johns Drive
Camp Hill, PA 17011
Cumberland County
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
NAME
Klm Tuschak
ADDRESS
4 N. Seasons Drive
Dillsburg, PA 17019
4. Name and address of last recorded holder of every Mortgage of
record:
NAME
None
ADDRESS
5. Name and address of every other person who has any record lien
on the real property:
NAME
Cumberland County Tax Claim Bureau
2000taxes: $ 5.15
2001 taxes: $457.64
ADDRESS
19 S. Hanover Street
Ste. 102
Carlisle, PA 17013
6. Name and address of every other person who any has any record
interest in the property and whose interest may be affected by the
sale:
LAW OFFICES OF
_'EPHEN J. HOGG
~ S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
Unknown
Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property who may be
affected by the sale:
Unknown
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge, information, and belief.
understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Date:
Stephen J. H~,g, Esquire
Attorney for Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
Supreme Court ID#: 36812
LAW OFFICES OF
STEPI-~N J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
MADE THE ' ' I! I' t, dali o! ~.9~
o[ OItr Lord one ghoutand nin~ hundred sixty (1960)
BETWEEN
RONALD P. GUSCHEL and MARY E. GUSG11EL, bis wife,
of llampd~n Township, Cumberland County, PennaylvaGla,
part,es cf the £~rat. part
and
VINCENT C. McCIJE and ELIZ^BETN A. McCUE, His wife,
of the ~,rough of Cam~ ]Jill, Cumberlsqd County,
Pennsylvania, par~ies of the second p~rt .......
WITNESSETH, tha~ in conaidtratlon o/ Twenty-Six Thousand ($26,000.00) '- - -
- _ . ............._ .......
ALL t~ certain lot of land situate ~ the Township of I~den,
County of C~berland and S~ate of Ponnaylvania~ mmm particularly
bounded and described as follo~s, ~o ~:
~I~ING a~ an iron pin/[He intersection of the northern line
of West Circle and the western line of Point H[dge DriVe, as shoun
three (83) degrees five (5) m~nutes Wes~ along the northem~ line
of West Circle one hundred ten (lie) fee~ to a point; thence North
. twenty (20) degrees seven (7) minutes Wes~ along ~e eastern 1~ne
and forty-five hundredths (17~.~15) feet to a stake; ~hencc North
elghty-t~ee(83) degrees f~ve (5) minutes East along t~e southerly
line of ~t No. 10, as shown on said Plan, o~e hundred
~own as St. Jo~s Drive; thence South six (~) degrees f~fty-five
(55) minutos Ess~, elong the western line of 'P~ Ridge Dr~ve one '.
hundred seventy (170) feet to ~he place of BEGINNING.
BEING ~t No. 9 as shown on P]en of Lots, Section 1, Point ·
Plan ~ok 8, Page 2.
~ING tho same promises which George DoBoard and Ruby O.
~Board} his wtro, hy their deed dated April ]Il, 1958 anJ recorded
Pe~syl~nia, In ~od ~ok 18-J, Page .16~[ granted and conveyed
mortgage bond. Tho present balance of the mortgag,~ la :];20,~tU9.O~. "
The above"descrthed premises are a~so conveyed ~er and sub~
Ject to~ease~nts end. restrlct~o~ of record (
Vivian Brannen, Executrix:
of the Estate of :
Jeanne German, :
Plaintiff :
:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANNIA
Civil Division
vs. : No.: 02-4025
:
:
Vincent C. McCue, :
Defendant :
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT
TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
.That the S;,heriff's Sale of Real Property (real estate) will be held
on ~'./C~/~ .~L in the Cumberland County Courthouse, at
/Z)~ (")(_.) ~ , prevailing time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED.)
LAWo
. ~ANO
SUiT
~RLISLE
~'EPI'-I~N J. HOGG
~ S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
THE LOCATION of your property to be sold is:
460 St. Johns Drive
Camp Hill, PA 17011
THE JUDGMENT under or pursuant to which your property is
being sold is docketed to:
Cumberland County Court of Common Pleas
EXECUTION NUMBER: 2004-
o/Onr Lo~d one tAmtsa~d ninm hundred · lx ty (I9~0)
BET;VEiN
o£ thmpdqn ?ownehip~ Oumberland County, Ponneylva~t~.a,
.~arb~os o£ bbs £Xreb pert ..............
VINCENT (?. llcO~lE and ELIZABETN A. McCUE, ills wife,
of the I~rou~h of Carap Nill, CumberlaQd County,
Fera~sylvania, parb.~.os o£ the ascend p~'rt
I~ITNE$$ETH, that in ~onaidtration o! Twenty-Six Thousand ($26,000.00) '- - -
an convey to l~e said orantss 8 bhe1~ he,ps and
ALL ~ oer~aln lo~ of land s~ua~o ~h ~hs Township of
Ooun~ of O~bepla~d and S~a~a o~ Ponnsylvsn/a, mope pav~ula~]y
' bounded and desup~bed as follows~ ~o
~I~INO ab an iron pin/{~e lnbepamo~lon o~ the no~theen line
of West O~cle and bbs western line o~ Point )lldge Drive, a~ shown
on the hereinafter mentioned Plan of ~ba; thence 8oubh e~&hby-
three (83) de&room ~lve (5) m~nutes West a~ong the northern line
of West O~rcle one hundred ben (~20) feet bo a pein:; thence North
twenty {20) degrees seven (7) minutes West along ~e eastern
o~ ~t ~o. 8, as s))o~ on the sa~ P~an, one hundred seventy-four
and forty-five hundredths {17~.~5) feet bo a sbalce, thence North
eI&hby-b~ee(83) de&re~a five {5) mtnubes East a2on~ the southerly
l~ne of ~t No. 10, as shown on said Plan, one hundred ftfby'(150)
feet to an ~ron p~n ab the ~asbern line oK Point ~ldgo D).[vo, now
~own as St. Jo~a Drive; thence 8ot~bR six (6~) de~reee f~fby-f~ve
(55) m~nubes East, R~on8 the western linc of P~b Ridge Drive one
hundred seventy ~170) feet to [he p~ace of
gEING ~b No. 9 aa aho~n cn ~lan of F~oba, Secbton l.'Point
Ridge ~arm, I~m)~)en Town~h~p~ Cumberland Counby, Pen~sy]~nta,
Pla~ bain& ~ecorded in the Cumberland ~ounby )(ecorderma Office
Plan ~ok 8, ~ago 2.
~ING ~he same prem[se~ ~hlch Oeorge DeBoard and ~)by D.
~Boa~d~ his wife, by bhelr deed de,ed Apr[2 ~1, 2958 an~ re~orded
PermaTl~n~a, in ~od ~ok ~8-J, Page 16)~ granted and conveyed
New ~o~k which tBe Orantees assume and a&ree bo pay eccord~n~ ~o
morb&a&e bond. The present balance of the mo~ga~ :s $20,8UQ,Oq. '.
.
ject bo eese~ta end, resbr~ct~o~ of record. / '!..
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-4025 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VIVIAN BRENNAN, EXECUTRIX OF TE ESTATE OF
JEANNE GARMAN Plaintiff (s)
From VINCENT MCCU-E, 460 ST. JOHNS DR., CAMP HILL PA 17011.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 460 ST. JOHNS DRIVE, CAMP HILL PA 17011 (SEE LEGAL
DESCR/PTON).
(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) ~f pr~perty ~f the defendant(s) n~t ~evied upun an subject t~ attachment is f~tmd in the p~ssessinn
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 $35,000.00
Interest $23,800.00
Atty's Cotton % $6,000.00
At~y Paid $945.50
Plaintiff Paid
Date: FEBRUARY 19, 2004
(Seal)
REQUEST/NG PARTY:
Name STEPHEN J. HOGG, ESQ.
Address: 19 S. HANOVER ST., STE. 101
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: (717) 245-2698
Supreme Court ID No. 36812
Due Prothy 1.00
Other Costs
CURTIS R. LONG
Proth~tary
Deputy
Real Estate Sale//17
On February 27, 2004 the sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA
Known and numbered as 460 St. Johns Drive,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Real Estath Deputy
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the
City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general cimulation, 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 27th day(s) of April and the 4th and 11th
day(s) of May 2004. 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 behaJf 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 subscribed befor ~ 28th day o~Vlay/~4 A.D.
My commission Expires June 6, 2000 NOTARY PUBLIC
Member, Penn~),lvanlaA~loel&tl~nefNet~riet My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Total
$ 347.89
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.
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,
v/z:
APRIL 16, 23, 30, 2004
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 E~TATE SALE NO. 17
Writ NO. 2002-4025 Civil
Vivian Brannen, ExecutrLx of the
Estate of Jeanne Gan-nan
VS.
Vincent McCue
Atty.: Stephen Hogg
This Deed, MADE THE 11th day
of May in the year of our Lord one
thousand nine hundred sixty {1960)
BETWEEN RONALD P. GUSCHEL
and MARY E. GU$CHEL, his wife.
of Hampden Tova~hip, Cumberland
County, Pennsylvania, parties of the
first par~, Grantors, and VINCENT
C. McCUE and ELIZABETH A~ Mc-
CUE, His w/fa, of the Borough of
Camp Hill, Cumberland County,
Pennsylvania, parties of the second
part, Grantees:
WITNESSEWH, that in consider-
ation of Twenty-Six Thousand
{$26,000,00) Dollars, in hand paid,
the receipt whereof is hereby ac-
'
SWOP, Jq TO AND SUBSCRIBED before me this
30 day of APRIL 2004
N~.~L SEAL ~'
LOIS E. SNYDER, Notary Publio
Carlisle Boro, Curcberland County
My Comrcissio~ Expires March 5, 2005
of Hampden Township, Cumberland
County. pennsylvania, par~es of the
firs% par[, Grantors, and VINCENT
C. McCUE and ELIZABETH A. Mc-
CUE, His wife, of the Borough of
Camp Hill. Cumberland County.
PermsylvanJa, parties of the second
part, Grantees:
WITNESSETH, thai in consider-
ation of Twenty-Six Thousand
{$26.000.00) Dollars, in hand paid,
the receipt whereof is hereby ac-
knowledged, the said grantors do
hereby grant an convey to the said
grantees their heirs and assigns,
ALL that cer[a/n lo% of land situ-
ate in the Township of Hampden,
County of Cumberland and State of
Pennsylvania, more particularly
bounded and described as follows,
to wit:
BEGINNING at an iron pin in the
intersection of the northern line of
West Circle and the western line of
Point Ridge Drive, as shown on the
hereinafter mentJoned Plan of Lot~;
thence South eighty~three (83) de-
grees five (5) minutes West along
the northern line of West Circle one
hundred ten (110) feet to a point;
thence North twenty (20) degrees
seven (?) minutes West along the
eastern line of Lot No. 8, as shown
on the said Plan. one hundred sew
enty-four and forty-five hundredths
[174~45) feet to a stake; thence North
eighty-three (83) degrees five (5)
minutes East /dong the southerly
line of Lot No. 10. as shown on said
Plan, one hundred fifty [150) feet to
an iron pin at the western line of
Point Ridge Drive, now known as
St, Johns Drive; thence South six
(6) degrees fifty-five (55) minutes
East, along the western line of Point
PJdgs Drive one hundred seventy
(170) feet to the place of BEGIN-
NING.
BEING Lot No. 9 as shown on
Plan of Lots, Section 1, Point Ridge
Farrn, Hampden Township, Cumber-
land County, pennsylvania, said Plan
being recorded in the Cumberland
County Recorder's Office in Plan
Book 8. Page 2.
HAVING thereon erected a one
story brick ranch d~elhng with at-
tached two car garage.
BEING the same premises which
George DeBoard and Ruby D. De-
Board, his wife, by their deed dated
April 14, 1958 and recorded in [he
Recorder of Deeds Office In and for
Cumberland County, pennsylvania,
In Deed Book 18-J, Page 164 grant-
ed and conveyed unto the Grantors
herein.
The above described premises
are conveyed under and subject to
a mortgage of record from the Grant-
ors herein to Peoples Bond and
Mortgage Company assigned to
Mutual Life Insurance Company of
New York whlch the Grantees as-
sume and agree to pay according to
the terms and conditions of the said
mortgage and accompanythg mort-
gage bond. The present balance of
the mortgage is $20,899.00, set 5/
3/78.
The above described premises
are also conveyed under and sub-
ject to easements and restrictions
of record.
LOIS E, SNYDER
Carlisle Bom, Cum
My Commission E;~'pi