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Home My WebLink About96-00740 , , '! " \. , , I t'! , 'Ii , , ,. I, J II '! , , " , hi , , , , , ;1 't" , " I) , .' , , Ii It " , iJ \ '1 l! . , , " " " 'I H! " I'. , I" " , ., I! " " 'I, II .i;J , " , , 'II-t , 1,1 !, tI J,I ,il H " 'i_) l' i'! " , ',I " Ii ., ., ., " 'I,' ., !il, !I,I' , il ", Ii ,I i'l " , , , Ii ,'j il u " , " ", , ';\ ,"1 d , 'r8' ;", l"r',!/I,1 1.~);h'U ':;~I/! UI, - r';.(-) -f.',., i~J,(/', :\ ~~ t Ji' , _;."'i,i ,;_::~ :1 q I I " " III h 'I' " " " Ii ;1 I , ),'! " 1', -rl Ii' ;,1'1 \/~ " ~'~r t:!7, j.q 'I."';, , I lL:l M. .. ~.r\ .1;:J '-, . . - , , ;. , '" .', , " 'I'; 'lU "';lJ ~.;. 1;'- "i1 , ,'.,., ! lllU '11) "--,... I) 'J,J ....;1 "!i ~,' "_:'<'(',) ('jlfl ,~J' , ~.~ II , . . , .1 i" I': , ...' .' ALL THAT CER'l'AIN piece or parcel of land, situate in East . pennsboro Township, cumberland county, Pennsylvania being.bounded and described according to a survey made by Gerr i t J. lietz, . Registered surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 2lX and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and'Glenwood Drivel thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle havIng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner. of House No. 618 Erford Road I thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South ~3 degrees 01 minute 42 seconds East the distance of 70.0 feet to a. point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the. distance of 36.30 feet to a hub a.1;. ,the dividing line between Lots Nos. 2lX and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan BOO~ 18, Page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which William L, Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in Cumberland County Recorder of Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMEN'r NO, 1996-C-00740., Tax Map: 09-16-1050-272 ! \ r ! I Ii . THE PRUDENTIAL HOME MORTGAGE COMPANY, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSn..vANIA PLAINTIFF VS. NO. 1996-00740 THOMAS A. JOHNSTON, CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE DEFENDANT AFFIDAVIT PYRSUANT TO P.R.C.P. 3129.1 The plaintiff in the above action, by its attorneys, purcell, KrU9 & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 616 Erford Road, Camp Hill, PA 170111 1. Name and address of the owner(s) or Reputed owner(s): Thomas A. Johnston 616 Erford Road Camp Hill, PA 17011 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be soldl COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX B016 HARRISBURG PA 17105 4. Name and address of last recorded holder of every mortgage of record: PLAI~TIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) I Members First Federal Credit Union 5275 E. Trindle Road Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record I, \, " , , , " \1' , , , , ., I., , , 1'1 i.,! . .I .,' I.' I, " ,\\ " , " , , I , , " 1 " I !\ " I" I"J I' . , " , " ., , , \ " " 'I , ,. , , " , , ,I " " " " " .,t' , , , .. I) ", ., , , , , , " , :' ., '1 ., ., , , " , , . 'I' , " '1 .tl , ", 11" " I'r) tl' ,..,.r:l, ~~h:: ~:~: : ,1..1 ,,:,1 .,1' . l:t i "j ,; I~.: , " I ~" ~,'i ..< I' ., , " '" Ii, "'I " , I'! ., , , , " , , , ,. " ,. il 'I ,0,1 " ,. , I' \,1 i'f , , " .' , ,. ,. , , , " , I , , , , " , , ii, I , 'J" I,' , I ., , I , .. "" , , ,I , , , 1.1:) :or' ':"" , ''1 'C') I 'C) , ~ ~..' ::.'r., i':;:j " "I;J1 '1;:1 , , " , .l ,I , , 'Li I'I O' rql -\ I "n' "I OJ ',GI ",\:1 " ':1 ". '~II ,,] itJ. "r,) ('jllll I ..;~ IJ:l -, , \ i ' ' i ~, ~ , '. I , II. . 'I lei i 'I J j' I / , ,I.j , ,. ,. , " , , t i '\, , , 'II , ,', ',I :11 iJ .'. " ,1," ., , 'I 'j " "J IiI 1'1 'i' ., \I )'1 I Jq' 1 q, , , ii' . , , , I , I " , .'j , P " 'J t" , \J , , ",' ., ., '. i ~ ! " i.ll 1'1 , 'II "d ., I II " \I .. ',j ., , .' Ii! '1,1 " II , , , , i , .., , , " , ,. Ii , 'i' ., , , ]1 , , ., 'I , , " \,i , , , , " I " (, ,jl . "'I , 1''1'" (:.1 ',M "\'.1[\/7 ru. ;J ~~~ri f.n,L !:,., ~i~ _- I ,1.;I'\. . )~:~;i.i/ ~~I ;1 "i' ;' 'i " , 'I , " :;J lij' ' (I', i;~ ! ,',"', ~, ..~-;;~ 1.....1 ';~ .. 'n 'c:;" 1" (:;1 ,'f) ,., " .'il1j jf~..J I I !)~1. , j;"1 ::;-j , ~)I ':" .\ " A SCHIDVLE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to ....,.. pa" of 'h' p.o...da of ,~ aa1' ....i..d a~ '0 b. d,.~..ad by the Sheriff (for ex~ple, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and diatribution of the p.o...da of ,a1' in ...o.d.n.' wi,h ,hi, ,.h.du1. will, in fa.', b. made \~nleas aomeone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of Distribution may be obtained from the Sheriff of the court of Common pleas of the within County at the courthouse address specified herein. THIS PAPER IS A NOTICE of THE TIME ~ PLACE OF THE SALE OF YOUR fROPERTY ~ ~T HAS BEEN ISSUED BECAUSE IT MAY CAUSE YOUR_p~OPERTY 'J.'HE JUDGMEN'I:'. THERE IS A JUDGMENT AGAINST }:Q!,L. TO BE HELD. TO BE SOLD OR TAKEN TO PAX You may have legal rights to prevent your property from being taken ..ay. Ala."....n adv'" yOU mo," ,p.d"..11y of ,h." "gh" , If you wish to exercise your rights, yOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO yOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINO OUT WHERE 'IOU CAN GET FREE LEGAL ADVICEI court Administrator court Administrator's Office cumberland county courthouse carlisle, pennsylvania 17013 phone (717) 249-1133 THJl LEGAL RIGHTS YOU MAY HAVE ARE I 1. You may file a petition with the court of Common pleas of the within County to open the judgment if yOU have a meritorious defense against the person or company that has entered judgment against you. YO" may a1'0 file an p.'i,ion with ,h. .am' Cou,' if you a.. awa.. of a legal defect in the obligation or the procedure us.ed against you. 2. After the Sheriff'S sale you may file a petition with the court of Common pleas of the within County to set aside the sale for a . grosslY inadequate price or for other proper cause. this petition MUST Be FILED BeFORE THill SHERIP'" S DEED IS DELIVERID. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 . (717) 234-4178 " , I' ,I , 'I , , " " " , , , , , ,I , " , I' , , , , . , I, '11.1' ,. , ' I' 1,1 , ., , . ." , , ,. ,. , I ' i', i' II " ,,' ALL THAT CERTAIN piece or parcel ot land, situate in East Pennsboro Township, Cumberland county, Pennsylvania being'bounded and described according to a survey made by Gerrit J. Betz, Registered surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a northerly direction from the Northeast corner of Erford Road and'Glenwood Drive; thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle havIng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South .53 degrees 01 minute 1\2 seconds East the distance of 70.0 feet to a.point; thence along same, South 53 degrees 2e minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a~.~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan BOO~ 18, Page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in Cumberland County Recorder of Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. ! I TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMENT NO. 1996-C-00740. Tax Map: 09-16-1050-272 I ,", , 1 , , I , , ., I 'i , , , , , THE PRUDENTIAL HOME MORTGAGE COMPANY, INC., Plaintiff IN THE C;OURT OF CUMBERLAND CO., COMMON PLEAS PENNSYLVANIA (I( ~(l' ( Jf l /> '- VS. No.1'?. I ~ (~ THOMAS A. JOHNSTON, Defendant CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in. the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR l,AWYER 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 Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la .corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notifica~ion y por cualquier queja 0 alivio que es pedido en la petie ion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 S1 NO TIENE EL DINERO SUFIC1ENTE DE PAGAR TAL SERVIC10, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OF1~1NA CUYA DIRECC10N SE ENCUENTRA ESCR1DA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGU1R ASS1STENC1A LEGAL. CUMBERLAND COUNTX Court Administrator, Cumberland County Courthouse Carlisle. Pa. 17013 -- (717) 240.6200 THE PRUDENTIAL HOME MORTGAGE COMPANY, INC., IN 1 HE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA Plaintiff VS. NO. THOMAs A. JOHNSTON, Cefendant CIVIL ACTION - LAW _ IN MORTGAGE FORECL08URE COMPLAIN;r 1. Plaintiff, THE PRUDENTIAL HOME MORTGAGE COMPANY, INC., is a corporation organized under the laws of the State of New Jersey with an office at 3200 Robbins Road, Springfield, Illinois 62794. 2. Defendant, THOMAS A. JOHNSTON, is an adult individual whose last known address is 616 Erford Road, Camp Hill, PA 17011. 3. On or about September 11, 1992, the said Defendant executed and delivered a Mortgage Note in the sum of $66,300.00 payable to GMAC Mor'g.ge Corpor"ion of PA, which NO'e i. ""ched here,o 'nd m'rked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secUre payment of the same, Defendant made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deed. Offic. of 'he wirhin CO,n,y .nd CO_n~'lrh in Morrg.ge Book 1088, Pg. 302, co.veYing '0 origin.l Mor'g.gee 'h. .,bjec' premi.e.. The mortgage was SUbseqUently assigned to The Prudential Home Mor'g.ge Comp.ny, Inc., .. record.d in 'h. 'i'hin CO'n'y in Vol,", 437, pg. 451 on February a, 1993. The Mortgage and Assignments are incorpOrated herein by reference. 5. The '.nd .'bj.o' '0 'h. Mor'g.g. i., '" Brford Ro.d, C.mp Hill, PennsYlvania 17011 and is more particularly described in I i I j " I '" Exhibit "8" attached her~to. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due ~o the fact that Mortgagor has failed to pay the installment due on August 1, 1995, and all subsequent installments thereon, and the following amounts are due on the Mortgage~ i.l I (a) Unpaid principal balance (b) Interest at $14.17 per day from 7/1/95 to 2/27/96 (based on a contract rate of 8%) $64,637.79 3\429.14 (c) Late Charges at $25.07 per month for 7 months (d) Escrow deficit 175.49 216.B1 (e) 5% Attorney's Commission 3.231..88 TOTAL' $71,691.11 * *Together with interest at the per diem rate noted in (b) above after February 27, 1996, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the ~ortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclosure and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000. ClO. 10. Defendant is not a member of the Armed Forces of the united " LOIn NOI 1-961l60-ll [J'jjf;(;;;-N'--.---.--.'-] 44l~450031-6 703 ..-...--. -.-.----.-.-.-------. lIlulllll.:' NOTE 6EPTtMBER II, 1911 IUtl.' 616 ERrORD ROAD CNlI' IIILL . PA 11011 IPrllptll) AIJIt,ml I, PAJlTIES "Borrow.," ""lnleach pInon ,I.nlnalat the CII~ llflhil NOI~, And the pCrlOn'lllw:ruor. Dlld ...l,nl, "Llnd.r" mlln_ Ind II. IUi:CCllor. and I..I,nl. CMAC HORTGAG~ CORPOllAnON or PA . Z, BOJlJlOWlJl'S PJlOIIIIS[ TO PA~IINn:JllH In ,runn for 0 lo.n received from tender, OtJrrowrr promlul 10 PIlY the l'rlnc;lpallum of BIXTY-SIX THOUSAND 'fI!Rt:V. ItUNUREI) ^Nl> 00/100 ""uuu""""u"'."""."",,",,u DoUa,. (U.S. S 61).300.00 ), plul Inler"I, 10 Ih. order of lcnder. IlIlUtl1 will be chor,cd on unpaId principal. (rom the dill or dllburull1l:m or Ihe 10lln pro~ccdl by l.rndrr, III th, rite of F.IGIIT AND OO/lOO pcr cenl (6.000 '/.) pcr )'Ut ullIlllhe full .moutH o( prlll~lpal h". btrn pllld. J, PJlOIIIIst: TO PA~ NI:CIIJlt:U Borrower'. promise 10 pa)' l'lrcured b)' a mOrll'lf. dud or trull or dmilllr IcclJrh)'lnltrumrnt Ihat II dlled the aim. date u Ihl. Note and ulled Ihr "Sccurltyllllltumenl." That Securll)'lnurumrnt prolects Ihlt Lender (rom laura whh:h ml,ht relull lr BorrowC'r dcrauln under this Note. 4. IIIANNEJI 01. PA~lIIlNT IAI Tim. Dorrower Ihall make II pa)'mrnlor prlncll)aland llIlerest to Lender on the nut do)' or each monlh be,innln, On NOVEMBER 01, 1992 . An)' prlnclpa] and Inlereu remaining on the nut da)' or OCTOBER 2022 .. will be due on IhaL-dale. which Is called the IIIl1turll)' dale. IB) PI." Payment ,h. II be made at 8360 OLD YORK ROA.D ELKINS PA.RK, PA 19111.al ~90 or Illuch olher plll;'c II Lendu m.)' delllnal. In wrflln. b)' notice 10 Borrower. (C) Amount Elli:h lIIomhl)' p.yment or plindplIl and Internl will be in the amounl or S 486.49 . Thlaamount will be part or a lar,er monthly pa)'menl required by lhe SCli:ul'h)' IlIstrumrnt, Ih"llhall be applied to prlndpll. Intercal Dnd olher 111m. In Ihe order demlbed IlIlhe Securfc)' JOttrumenl. (D) Allonle 10 Ihl. nole (or plyment adju.tmlnlS J( An aUonle pro...ldlnl (or plyment adjuslmenls Is executed by Borrower lo,ethcr with thla NOli, the ,ovenanu or the allon,c Ihall be incorporated InlO Rnd Ihall al1lend and supplemenllhe COYenllnU or this NOle a. I( the aUon.c we,e a part or (hi. NOle. (Check applicable hoxl D Grldu'lcd Plyment AII0I11C DOlhcr(spccify) . 5, BOJlJlOWlR'N JlIGIII TO PRI:PA~ Borrower has the rlahl 10 pay lhe debL eyldenced hy Ihls NOle. In whole or In patll wIthout charge or penall)', on the finl day or any month. o Orowln. Equity Allon.. 6. BOJlJlOWlJl'S FAII.Un TO PA~ (A) Lale Ch...., 'or Ourdu. rlymttlll If Lender hILS nol ,tcelyc..J the full monlhl)' payment required b)' the SecurllY Inslrumenl, L\ desc:ribcd In Paraaraph 04(C) of lhil Note by lhe end or Mlten li:nlendilr day, arter Ihe payment Is due. Lender may collf'Ct " laIc li:hMle In Ihe amoullt of FOUR ....ND 00/100 pcr cenl ( t.. 01) '10) or Ihlt overdue amounl or each pa)'l11ent, (8) 1)"1"11 I( Borrower defaults by rallinllto pil)' In (ull RlIY monthly pR)'menl, lhen tender may, e"cepl as IImlfed by re,ulltlon. or the Secretary In the use or pa)'ment dcraults, require Immediate: payment. In rull or the prlnclpal balance remalnln. due and aU accrued lnleresl. Lender may choose 1101 10 c.'terclu this opllon wllhoul wal"'.n.lls rllhts In lhe eyent or an)' .ubsequent de(ault. In many drCllllutancu reMuliulons lUlled by the SeCtelnry wHlllmlt I.endrr's rlShlS 10 requlrc Immtdhllc payment In rullln the cue or paymcnt defaults. This NI)!c doC! nOI l\uthorl1e acceler,llloll when flol pCtltlhtfld by .IUD rea.,laHons. AI uud In this NOle, "Seematy" mcarn lhe Sec.:rel;ory of Hmulng anti Urblln Developmenl or hj~ or her deslanec. (C) ',ymenl .., C081s and .:"'penm I( lender hlu required Immediale payment In (ull, as descrihed abQvC", l.ender ma)' require Rarrower to poy costs IlId upcnsu lnli:ludlnl ru~onBble and cusloll1ary IlllurneY1' fees ror enforclng Ihls Nole, Such fecsalld com shall be-nr InlftUl from Ihe date or dlsbursemenl 41 the unIe rnle as Ihe principal or Ihi5 Note. IIWI, IIlU." lll.C"', 4,t1U p"" 0/1 FHA M..... Pl....... Not.. . 1m 1;!,t) f.~\I\\l\1 !1.. -- LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, cumberland county, pennsylvania being bounded and described according to a survey made by Gerrit J. Betz, Registored Surveyor, dated March 20, 1975, as follows, to witt BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and Glenwood Drive; thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle having a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 61B Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 61B Erford Road, South 53 degrees 01 minute 42 seconds East the distance of 70.0 feet to a point; thence along same, South 53 degrees 2B minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a~ ~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" plan No. 10 of Ridley Park as recorded in plan Book lB, page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which William L. Wolfe and stephanie J. Wolfe, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Thomas A. Johnston. 3'~;Q of PenMylvanla } SS '>"'Jnty of Cumberland ." '~("'!ed in the office for the recClrdlng of DeedI ., f.L~d for 8,~rgberla~d County, ~.,.., :; '::t..cyooW1<]JIVot __ Page ~ . '1i,r'~5~ my hand and Wi of office Df ,-'1)11 9 d, ':.~rli~I~, PA th~ day ~~'1p 'Alf'J7" ~4"t:O~~ ~ Rtl(;order (I . ~,~;~~~.~~2L';, ,., ., :':" , . '1...). ' : r: ' . " .:'., .':'~' . .~ ~'., t, ~.. a .' ...~.':. : t' ... ' . ' ,. ',' :,1'" , . " ",' .0' ., .' .. ii7i~ 108~ PACF 311fi r,(fIitJr! .0 "J'~ '"; ~..... 1"1 ('I ~ - , !,if ~ i ' I" ~ c) , .. ""~-' F"~ ' .., "if : 1..(" .'-. .. ']\ . Io.j. ~ , , fir' ~"J ,""1 - b~ t." n. ',I , ro' l),' ., . I,q L" " In ,. ,I 1,) " o' . l..J ~ o<(H w:z ~ ..lo<( 0<( Il.> ~ :zt;: E-< '" Otll 0 ~~ ,; ~ ow w ~ H UIl. ~ E-< IC. :I: :z 0 H .0: E-<O --' .~ "'u ...: Il. HU ::>0 E-o:z o:z ZH u-< W ...l 0 w'" ::> ;..' :I:W ~:z E-001 Il."': Z ~ Il. H U ~~ E-<U Hill"" .. ONMfO "l""lt.,-,. ~ ..n.'....r'~ ..H..~.". ,"'''''U'u..n, HI ..~ t"'-J ,P,. c.,.' '* \; .~ ,~ r2 ~ ~ ~"""~ ;8 '-Y ~ - IY\ 1'('1 , . , ,,' .... i ~ , . .~ ~~ ~ " l/l &;~ > zw E-< ::t:O :z 0 H ~ ~ ~ .., -< ~ . ~ . ...l ~~ : ...: Il. ,; tIl 0 ~ :" ...: u ]i! 8 < ~ , ~ I! '" " . , ., " ., . . -... " .. THE PRUDENTIAL HOME MORTGAGE I IN THE COURT OF COMMON PLEAS COMPANY, INC. , ~ CUMBERLAND CO., PENNSYLVANIA PLAINTIFF I ~ VS. ~ NO. 1996-00740 ~ THOMAS A. JOHNSTON, ~ CIVIL ACTION - LAW - DEFENDANT , IN MORTGAGE FORECLOSURS NOTICE OF SHERIPF'S SALE OF REAL ESTATZ PURSUANT TO PENNSYLVANIA RULE or CIVIL PROCEDURE 3129 TAXB NOTICBI That the Sheriff's Sale of Real Property (real estate) will, be held, DATE. September 4, 1996 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THB PROPERTY TO BE BOLD 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. 616 Erford Road Camp Hill Cumberland County Permsyl vania THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to. 1996-00740 THE NAME (B) OP THE OWNER(S) OR RIPUTED OWNERS of this property is, Thoma. A. Johnston .' .. A BCRIDULI: OP DISTRIDUTION, 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 bank. that hold mortgage. .nd munioip.liti.. th.t .re owed taxe.) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it i~ filed. Information about the Schedule of Distribution may be obtained from the Sheriff ot the Court of Common pleas of the within county at the Courthouse address specified herein. THIS PAPER IS A NOTICE OP THE TIME AND PLACE OP THE SALE OP YQYB PROPERTY. IT HAS BI:EN IS~UED BECAUSE THERE IS A ~NT AGAINST YOU. AT MAY CAUSE YQgR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. i \ I I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OPPICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET PREE LEGAL ADVICE I Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 THI LEGAL RIGHTS YOU MAY HAVE ARE I 1. You may file a petition with the Court of Common pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition , ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumberland county, Pennsylvania being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and Glenwood Drive; thence extending from said point of beginning and alang the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle havIng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South 53 degrees 01 minute 42 secondo East the distance of 70.0 feet to a. point; thence along same, S0uth 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a~.~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. DEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan Book 18, Page 47. BEING known as No. 616 Ertord Road. BEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe by their deed dated September 11/ 1992 and recorded on September 15, 1992 in Cumberland County Recorder of Dfleds Office in Book W 35/ Page 722, granted and conveyed unto Thomas A. Johnston. TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMENT NO. 1996-C-00740. Tax Map: 09-16-1050-272 THE PRUDENTIAL HOME MORTGAGE I IN THE COURT OF COMMON PLEAS COMPANY, INC. , I CUMBERLAND CO. , PENNSYLVANIA PLAINTIFF I I VS. I NO. 1996-00740 I THOM.~S A. JOHNSTON, I CIVIL ACTION _ LAW - DEFENDANT : IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.:\, The Plaintiff in thf,! above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 616 Erford Road, Camp Hill, PA 170111 1. Name and address of the Owner(s) or Reputed Owner(s): Thomas A. Johnston 616 Erford Road Camp Hill, PA 17011 2. Name and address of Defendant (s) in the JUdgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment: creditor whose jUdgment is a record lien on the real property to be soldl COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last reco~ded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) I Members First Federal Credit Union 5275 E. Trindle Ro~d Mechanicsburg, PA 17055 5. Name and address of every other perSOn who has any record lien on the property: UNKNOWN 6. Name and address of every other perSOn who has any record " M , , , i " /. , 'j '/ / , 'j ,-I , I , , ,I: I :J' " I' , ,( I , " 1,1 " , I i,\'1 , \ 1/ , I. , " , iii, I I; " ',I " ., :.,)1 , ., il ," " , ., ,I , , , 1"1 , Ii ., I 1'.1 , , , , , ., '," '1 , " 'I I , ., q , ! ,I: ., II' , , ., "J " >I d-I ., , , , , , , , Ii ., , , , , , L I: , , , ,..j '.N , , , ., " , PI ~~ (.:) ti " " 'oW ~ ~ , \1.) .. , , . , ii' , , " ., I V, , d I ~ , I c::.., ,,") , " , ,"II. ~ ,. , ,. , , "" C!: " , I , ,. I' " , , , , " " " , ~ , " I) ]i , ( 'i " , , .~ " ., , Ii '.I I ,'l ., ~' " \, , " i" I ','J ., 'I,; ;"1 1" , , 'i , .'1 , , , , , " ;-1 ., , ;,', " , " " Ii , ., , , , , II , t ~ , , ., . THE ~RUDENTIAL HOME MORTGAGE COMPANY, INC. I PLAINTIFF VS. THOMAS A" JOHNSTON, DEFENDANT I IN THE COURT OF COMMON PLEAS I CUMBERLAND CO., PENNSYLVANIA I I CIVIL,ACTION - LAW I I NO. 1996 - 00740 I IN MORTGAGE FORECLOSURE i~=P;gATII OP SlaVICI PUR PA. R.C.P. 237.1 . I I hereby certify that on March 13, 1996 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the De.fendant(s) in thi.s .matter by ,egular first class mail, postage prepaid, as indicat;.ed on the' attached Notice. -;/ I , ' By .~ 'Leon'p. Haller PA 1.0. #15700 Attorn~y for Plaintiff purcell, Krug & Haller 1719 North Front st. Harrisburg, PA17102' 'I ,'I ., I , , , , I , I , I ,', , , II I, .1 ,'., , , , I ,I III I , " , , I I , , " , . " I, ., , " ., ,,-I , ,I \\ \',.: ' . J . I . I, I' I, " ,',I, I' , 'I' , , " I. , \'1 , ,. , l' 1 1,/ '.. ., ." . , i' I " " , 'I; 1', >I d " " ,,' 'I J:! ., I II If. , " " 11 ;I "I " Iii , I" H! , " " III ,. ,;' "I ;,1 'I Ii .'" ' ~ -X, ~ ~D ft, ,'~ t c:}i ~ (!: , , '~ :j , i , ., ,~ ~ , ~ ii i"! " , , , ", ., ,. "i' ',(/ , \ " , . I, (G;\ ~ ~ ''t',JijV,i ~ " 1 '-" , \)" ,...j '".,J !j '1 ..... I', ::J ~ ......, ..... ., , ., ., , I' .1 , , ., o. , ,., , I) ~ ' U') ., '\1 "ei'l,1 "". ! ",\.)' {I,:.:t'.! :.\J \P ~. i ..... f." (."'.? ;,,1:) " {.-: ) '. "..t.. , ", ,i~l r oj =;i~ t-." , , I',r ;i.-,' (..) ~"l~l I.) .. .~. ! .' I , ~" ~'l ..../', .... , , ", i'l I. " , i , -j!' ',I .11 ., ;.1 " , i \'; t".~.... ......r/ ., , I .. I I I I: I .. Ii -. ....., , ALL THAT CERTAIN piece or parcel of land, situate in East . pennsboro Township, Cumberland county, Pennsylvania being bounded and described according to a survey made by Gerrit J. Betz, . Registered Surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 2lX and 22, Dlock "H" on the herE!inafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a ~ortherly direction from the Northeast corner of Erford Road and Glenwood Drive; thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle having a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South 53 degrees 01 minute 42 seconds East the distance of 70.0 feet to a. point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line betw<len Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a~.~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 2lX and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan BOO~ 18, Page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in Cumberland County Recorder o.f Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND CO~TY JUDGMENT NO. 1996-C-00740. Tax Map: 09-16-1050-272 I II 'I , 1\' J' ',., I , I " I, i,l " I, , I I 11,1 I, 1\1 I, ,'1 ~'r.;;, I~~~ ~ ' I ~.~ ....~~ >oC\~ ~'" . 'I , .' \1.,'........ ~"" \j c,<..>~. N,~ .' . 'TI-- 'fl' .,bo.., oj' r:- (J " ,\,~ r.... , -. .C::- ~ 'It- , " I '~, ~ cl " 'I " ..... ~ e' ,I , ,J II . .".., ,'! 0' I I to, " , I, ,,;1 ~.~ ~ -/ "1 ; ;~I ~~" " . I. I" I J."' en a ~L ...., ,;~~ -.(' ;:l: ~fu ~1 8 . ~I c- ~ -. 0) '1 ,. " , I , i,t I , , I " I ',';/ , IF I I I , " , I 'i" , , \ , 1 I " I I 'I; , ," ,,"~ " ,. ,I., '1 " , , I' " ;1 , ., I " '1 q , , I I d" " ',I, " I I " Ii , ,it I" '1 I, ., ,I " q ,'J " "I, \j 'I " , 1',',,1 I, I, , . .1 ,I I,' .1 ! I "." I , I I I ! , I THE PRUDENTIAL HOME MORTGAGE IN THE COURT OF COMMON PLEAS COMPANY, INC. , CUMBERLAND CO., PENNSYLVANIA PLAINTIFF VS. NO. 1996-00740 THOMAS A. JOHNSTON, CIVIL ACTION - LAW - DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed. the following information concerning the real property located at 616 Erfo~d Road, Camp Hill, PA 170111 1. Name and address of the Owner(s) or Reputed Owner(s): Thomas A. Johnston 616 Erford Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: '.l SAME 3. Name and address of every judgment creditor whose judgment ia a record lien on the re~l property to be sold: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Members First Federal Credit Union 5275 E. Trindle Road Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record 1ne.r..t in the property and whose interest may be affected by the sale; ONltNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any 1neer..e in the property which may be affected by the salel TENANTS IF ANY ... DOMESTIC RELATIONS OFFICE Cumberland County Courthouse High and Hanover Streets Carlisle, PA 1701~ (In the preceding information, where addresses could not be reas?nablyascertained, the same ~s indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 FA C.S. Section 4904 relating to unsworn falsification to authorities. , ~ ' . " II, / ^ hfJ/t, L P. aUer PA I. 'Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 #15700 f.,I_ t;;J , , , , " , , '"" , , , ." , , ,/,1 !I ,. , , ." , ,. , It " J I' I " I i, "I , I , " " , 'I. 'I " .!' t, , I, , " I Ijl' I , I " " ,1,1 , I I" ,. , " " , " " " " " , , 'I, " I, " , " " ,. I" 'i , " , I " H !) ,: , I il , 10 I " .,I' , , I , I) I' t ,I 11'1 if I', ,;, ',' " 'I , I " 'tlh " I " , Iii 'i , , , " , /. J , , , , " "I . , i, il " ,I d , . " , , ~ ~ ,,' , , " " ; ~I ,'\ ,I " " ,I "1 , " 'p " " , C7\ ,'l , b 'il , , ., " ..., , ,',; .~ I it " :~:' ::lI: , , '~.r ,P " Cd ~ " C, ,\1, ,.~ t,; ~ , " " , , " '" ',I , , '1,1 , , /, I " , I , , " II, , :' " , , I , " , , , I , " , , 'I 1\ " " ,t , ,f1, , ,I d' " 1" ,II', , , !'I'I . I " .' , i' , ,I , " " " " , i-' c, , ,,, , , . ~ I I I 'I I' " ,I , " I " I " '" ;; , '" I, iJ 1,1 I " p; , ,-I I , , I " II I " I' " I , 'l,' " , , , , ',I " .' , I f. , , , I ,I I THE PRUDENT~AL HOME MORTGAGE COMPANY, ~NC., IN THE COURT OF COMMON PLEAS CUMBIj:RLAND CO., PENNSYLVANIA PMINT~FF VS. THOMAS A. JOHNSTON, DEFENDANT NO. 1996-00740 CIVIL ACT!ON - LAW _ IN MOR'I'GAGE FORI3CLOSURE NON.~ILITARY AFFIDAVIt , COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for 8ai~ Commonwealth and County, LION P. HALLER, ISQUIR. who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any w~y which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this 5' day of YF~ 19 q,- , ) ~ ~ ~\ CL\.c,,^ " . h^-.I'-..... Notary Public L ON P. ){ALLER, ESQUIRE 1"-_.",, "I~"'" '...: ";:..,'.'- ...- ~"'I ' I" I . "..-" , '''.' ',' ' J. ", ",' '. . .. " "".)", : '" I _~......:~I"''''_'''_'':_'''';'''L .,.l,..,"...~._, .,..,1",.. ...._.,..~ , " .."J. 'I " ,I I , , , " ,I ,'J ;/ ,,' I I! 1 , , ,I " , " " , , , 'I , , , , I,! , , , , " ',' " ,I "~Of,' ," 1 "I i-I I I 'I '.1 , " , " , 'I " " II 'J " " II I 1:1 ,'I LI , n " ~ ! I' , I '11\ ,','I ',I H! Ii ! I' I, " 1,:1 !I d " '" " " :, Ji " ,I '1.1 1,1 . L 'I , d I' "I Ii" (,' , \.' , I,il! \'1 ,I H , " I; ,-)i' " , I ti, ,-) '),1 1 " J' i,l' , " ' q , ,I "i' " I " ii; 1,\1 11_ ]1 'i I,' ," I I ., " " I' ,)-,-, ~ I 'I Ir H Ii; I , , I I , I , .. " i! " " i-I t I I' '. ~ ~ ~".' '. ~ ~J' en j 1~1' '~' ~ ~ f; ~' " , , I '" ';i " Ii! , ,"! " " 'in '1'1' '); , \, I I ~HE PRUDENTIAL HOME MORTGAGE COMPANY, INC., IN THE COURT OF CoMMON PLBAS CUMBERLAND COUNTY, PA CIVIL ACTION - tAW NO. 1996 - 00740 IN MORTGAGE FORECLOSURE plaintiff VS. THOMAS A. JOHNSON, Defendant IMPORTANT NOTICE TO: THOMAS A. JOHNSTON 616 ERFORD ROAD CAMP HILL, PA 17011 I I \ DATE OF NOTICE: MARCH 13/ 1996 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 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 FIN' OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 PURCELL, KRUG & HALLER , , ti ,I , " BY Leon P. Haller 1719 North Front Street Harrisburg, PA, 17102 (717) 234-4178 ~ttorney ID # 15700 . , , , I, " " , I ~I ' If /, i i " , ., , , ! Ii 1'1 " 1;1 " 1 . Iii II , \ " , " ,I " , , , " "I, t iJ , I , ., I , , , 'I , , , , , , , 11 \ '1'1 , " , ;", .' J,. ., I' , , , " , I ! i' , , ,\ ~, , ' I, " 'I' , , ~ 'I , , \ , I i' ," , , li-' " ;/' ;, 1-,' I' , , " , , 'I,! " , , il I' , I~j , it 'J 1,1 I , , , I " , , , , I , I ii I!I " , "II II rJ H 'J iJ'j; " II " ,'., I, , , , , , ' , I' j', " , , " , , I I' , " , i! " , ;' , III I , " " , , , , , " , , ., . , j J '-J'I I, I ~ , , , , "j-I ., ;', ~ \JI , , , I; 'I , , , . . . . ,i 'I " ;1 " " ')1 " , " ~ ~ ~ ~'I ~' ~ ~ ~i W 9 ~ ~ ~ ~ !i " , THE PRUDENTIAL HOME MORTGAGE COMPANY, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA PLAINTIFF VS. NO. 1996 - 00740 CIVIL ACTION - LAW . IN MORTGAGE FORECLOSURE THOMAS A. JOHNSTON, DEFENDANT NOTICB OP SHERIPF'S SALB OP REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OP CIVIL PROCEDURE 3129 TAItB NOTICBI That the Sheriff's Sale of Real Property (real estate) will be held: DATE: September 4, 1996 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nc Floor cumberland county Courthouse Carlisle, Pennsylvania 17013 THI PROPBRTY 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 ary other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 616 Erford Road Camp Hill Cumberland County Penn.ylvan1a I , THI JUDGMENT under or pursuant to which your prop~rty io being sold is <;locketed in the within Commonwealth and CO'lnty to: 1996-00740 THB NAMB(S) OF THB OWNER(S) OR RmpUTBD OWNBRS of this property is: Thoma. A. John.ton . A BCHIDULE OP DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (tor eX~ple, to bank, that hold mortgage. and municipalities that are owed taxe.) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OP THE TIME AND PLACE OF THE SALE OP YOUR PROPERTY. . IT HAS BEEN ISSUED BECAU~E THE~~MENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO RE HELD. TO BE SOLD OR 'rAKEN TO PAY THE JUDGMENT. You may have leg'al r'ights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FRSE LEGAL ADVICE. Court Administrator Court Administr.ator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 . THI LBGAL RIGHTS YOU MAY HAVB ARB I 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also fUe an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition ALL THAT CERTAIN piece or parcel of land, situate in 2ast Pennsboro Township, Cumberland County, Pennsylvania being bounded and dsscribed according to a survey made by Gerri t J. Betz, , Registered Surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and Glenwood Drive; thence extending from said point of beginning and along the said side of Er.ford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle hav1ng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South S3 degrees 01 minute 42 seconds East the distance of 70.0 feet to a.point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a1,~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan Book 18, Page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in cumberland County Recorder of Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnaton, TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMENT NO. 1996-C-00740. Tax Map: 09-16-1050~272 LAW OFPICZS PURCZLL I JtRUG & HALLER :1.7:1.9 NORTH FRONT STRUT HARRISBURG, PZNNSYLVANIA 17102 (717) 234-4178 Thomas A. Johnston 616 Erfotd Road Camp Hill, PA 17011 COMMONWEAL'l'H OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE PoBOX 8016 HARRISBURG PA 17105 Members First Feder~l credit Union 5275 E. Trindle Road Mechanicsburg, PA 17055 DOMESTIC RELATIONS OFFICE cumberland County Courthouse High and Hanover Streets carlisle, PA 17013 NOTICZ IS HERZBY GIVEN to the Defendants in the within action and those pnrties 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 proce~ure 3129.1 attached hereto. YOU ARE HEREBY NOTIPIED 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 PURTHER NOTIPIED that the lien real estate will be divested by the sale opportunity to protect your interest, , said Sheriff's Sale. By: hold against the said that you have an by being notified of n . Haller PA 1.0.15700 torney for plaintiff " I " t-". A SCHEDULB OP 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 wxample, to bank. that hold mortgage. and municipalities that are owed tax..) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptionA to it within ten (10) days of the date It is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OP THE TIME AND PLACE Ol-IHE SALE OP YOUR i.BQP.ERTY. IT HAS BEEN ISSUED aECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO P~Y THS JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OpFICE SET PORTH BELOW TO FIND OUT WHERE YOU CAN GET PRSE LEGAL ADVICE: Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 THE LIGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if, you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for othp.r proper cause. This petition ....", I ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, cumberland county, Pennsylvania being bounded and described according to a survey made by Gerrit J. Betz, . Registered Surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and Glenwood Drive; thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle having a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South 53 degrees 01 minute 42 seconds East the distanco of 70.0 feet to a, point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 teet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub as. ~he dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan Book 18, Page 47. BEING known as No. 616 Erford Road. BEING THE SAME PREMISES which william L. Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in Cumberland County Recorder of Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMENT NO. 1996-C-00740. Tax Map: 09-16-1050-272 . u. S. POSTAL SlaVICI ;.1:-r;:I;Ail 0: MAILING aO~l)li. a t OBt 1 Service Perm 387'7) (In Rice i ved f rom ~ purcell, Krug 1719 North Harrisburg, & Haller Front Street PA 17102 postage~ One piece of ordinary mail addressed to~ DOMESTIC RELATIONS OFFICE Cllmberland County Courthouse High and Hanover Streets Carlisle, PA 17013 p08tma~k~ I hi " . . " " , ; ~ . ,,: , , !'l I, " , /i ,. " "'-, 1,11, " , ," r I , , " , 'i I I,' ''1 , I' 'I , I , " , , , , " , , 'I 1 " " _. I" I' II , " , " ,,' , THE PRUDENTIAL HOME MORTGAGE COMPj\N'l, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA PLAINTIFF NO. 1996-00740 CIVIL ACTIO~ - LAW - IN MORTGAGE FORECLOSURE VS. THOMAS A. JOHNSTON, OEFENDANT BIlTURN 01' SIRVICI I hereby certify that I have deposited in the u.s. Mails at Harrisburg, pennsylvania on I.~I\~~' a true and correct copy of the Notice of sale of Rea~e pursuant to PA R.C.P. 33.29.1 as followsl To the Defendants herein and all lienholders of record by regular first class mail (certificate of Mailing form in compliance with U.S. postal Form 3817 is attached hereto as evidence), and also to the ' Defendants by certified Mail, which mailing receipts are attached. service addresses are as follows I Thomas A. Johnston 616 Brford Road Camp Hill, FA 17011 COMMONWEALTH OF PENNS'lLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG FA 17105 union.... Member~ First Federal credit 5275 E. Trindle Road Mechanicsburg, FA 17055 Karen K. J'ohnston ' 616 Erford Road Camp Hill, PA 17011 ,,' Keith B. DeArmond, Esquire 2800 MarKet street 'Camp Hill, PA 17011 DOMES'rIC RELATIONS OF'FICE cumberland county courthouse High and Hanover Streets Carlislel PA 17013 " ' .. /J. / /-'. ..//?' ~/ ,. .' ,,'-"'", \ t BY $2, HAL. Ap1torneys for Plau\tif f ,,/~1719 North Front Street Harrisburg, FA 17102 (717) 234-4178 ,t .~.,., l ~ LAW OP"ICES PURCIlLL, KRUG & HALLER 1719 NORTH PRONT STREET HARRISBURG, PENNSYLVANIA 17102 (717) 234-4178 Thomas A. Johnston 616 Erford Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBI,IC WELFARE POBOX 8016 HARRISBURG PA 17105 , , Members First Federal Credit Union 5275 E. Trindle Road Mechanicaburg, PA 17055 Karen K. Johnston 616 El'for~1 Road Camp Hill, PA 17011 Keith B. DeArmond, Esquire 2800 Market Street Camp Hill, PA 17011 DOMESTIC RELATIONS OFFICE CUmberland County Courthouse High and Hanover Streets Carlisle, PA 17013 NOTICE IS IfEREBY OIVEN to the Defendants in the within action and those parties who hold one or more mortgages, jUdgments or tax liens against the real estate which is t'he 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 wi thin 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, ifar,J.y, by beina) notified of ' said Sheriff's Sale. "t:" ,~ '( J " --~ L / .,- " \. /)/) By: \ ,J--- , c-?' . lL.-f::"'~u.~._ i, Leon P. Ha ler PA I.D.15700 /1 Atto nay for Plaintiff I' , i' I,' THE PRUDENTIAL HOME MORTGAGE COMPAN l, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA \ PLAINTIFF VS. THOMAS A. JOHNSTON, DEFENDANT NO. 1996-00740 CIVIL AC~ION - LAW - IN MORTGAGE FORECLOSURE NOTICE or SHERIFF'S SA~l-OP REAL mSTATZ PURS~_N- ~mNN~'~VANIA RUME 0 CIVIL p~OCEDURm 3129 TAJtI NOTICII That the Sheriff's Sale of Real Property (real estate) w~ll b~ heldl , DATE I March 4, 1.998 TIMEI 10100 O'clock A.M. LOCATION 1 commissioner's Hearing Room 2nd Floor cumberland County Courthouse Carlisle, pennsylvani~ 17013 THI PROPERTY TO Bm SOLD is delineated in detail in a legal descript ion 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 lart~. (SEE DESCRIPTION ATTACHED) , , , THE LOCATI0N of your property to be sold iSl 616 mrford Road ClI1IIp Hill Cumberland County pennsylvania THE JUDGMENT under or pursuant. to which your property is Ioeing sold is docketed in the within commonwealth and County tOI 1996-00740 THE N~E(S) OF THm OWNER(S) OR aEPU'1'ID OWNmRS of this propert.y iSI Thomas A. Johnston Ii c.;' " MUST BE PILED BEFORE THE SHERIPF'S DEED IS DELIVERID. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs mllst be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule mllst be attached to the petition. If a specific return date is deSired, sllch date mUst be obtained from the Court Administrator's Office. CiVil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUQ & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 1710:/ (717) 234-4178 " " , i' , " I' " i' i , I " , , , -, , l,j I , , " I, " ;j .J\' I I .f I, , i'l '\ 1,.1 , , " " , ' ;' I 'Ill ,J_j , I' . .',1 " , ! I ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumberland county, Pennsylvania being"bounded and described according to a Survey made by Gerri t J. Betz, . Registered Surveyor, dated March 20, 1975, as follows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 21X and 22, Block "H" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a ~ortherly direction from the Northeast corner of Erford Road and 'Glenwood Drive; thence extending from said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle havIng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South 53 degrees 01 minute 42 seconds East the distance of 70.0 feet to a. point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereinafter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub aj;. ,the dividing line between Lots Nos. 21X and 22; thence along said dividin~-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the pI ace of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan Boo~ 18, Page 47. BEING known as No. 616 Brford Road. BEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe by their deed dated September 11, 1992 and recorded on September 15, 1992 in Cumberland County Recorder'of Deeds Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. TO BE SOLD AS THE PROPERTY OF THOMAS A JOHNSTON UNDER CUMBERLAND COUNTY JUDGMENT NO. ~996-C-00740. Tax Map: 09-16-1050-272 I , . 'i !, " I, il " , , , Ii! I , \:,/1 , :1, , , " Iii , , , d , , , , , , , I, , , ; , I I 'I i " , " 1 I, r 'II " II! Ii " I' " ,\ \1 Jj, II' Ii " , , , r; " " , " , , " , ,I" , I , ,rl , ~ I , , 1;"1 " ,',1 I , 'I " .' I , n , ;1 I 'I " , " , ,'; , I , , " , , , , , "-'I " " I, , I", " ,,) 1,'1 , , " 1'.. " , I " 1'1 h "i, Ii r 'I " " , , , , " "I 'I' I, ,;1 , I d , " I " " , , ,I " J)" " ;1., q , " 1:1 ,I I " , I. " , " ij , 1\ 'ill 1I';i8" IfJ ';U1'Jfn I {tiff, " ,,'~ ~I 1 :-"1," ~;~~ :;. . f,r",' :', ~,!;;: :~ -'j "',"" " , , '. r)i " " I , , , , I' ", (11 '.':'tJt .," ~\, I N , 1'.~ ...J ....' .- ,. ',,) ,to , , . I " q .j r: i ~'l I, ,'-- !~~ ~lJ "'h ,1.:1 J (">' ,-..(jnl ,:-~-:~ ~' , '!i The Prudential Home Mortgage Company Inc. -vs. Thomas Johnston In the Coun o!'Common Pleas of Cumherlnnd County. Pennsylvania No. 96- 740 Civil Term , I I I \ ! ! " I I II. .Ichnel E. Barrick. Deputy Sheriff. who hdng duly sworn according to law, suys on Jnnuw'y 6. 1998 ut 5: 18 P.M.E.S:r.. he posted the property of Thomus Johnston nt 616 Erford Road. Cump llill. Cumherlnnd County. Pennsylvania. with a copy Real Estate Writ Notice Poster and Description nccording \0 Inw, MicJllIeI E, Barrick. Dcputy Shcriffwho heing duly sworn according to law. says on Jnnuary 6. 1998 at 5: I !lP,M.E.S.T.. he scrved a truc copy of Real Estatc Writ Notice Postcr tmd Description in the uhove cntitlcd action upon the within named ,Icfendant to wit: Thomns A. Johnston hy handing to Thomas Johnston at (li6 Erlill'd Road. Camp lIill. Cumberland County. I'ennsylvunia its cnntents and at the samc time handing to him personally the said true and ntlested copies of the same. R. Thomas Kline. Sheriff who being duly sworn according to law says he served the within Real Estute Writ NOlice pnster and Description in the fnllnwing manner: The sheriff muiled the within named defendant Thomas Johnston a notice of the pendency of the aC'lion by regular muil to his last known address 62(1 l'rliml Road. Camp lIill Cumherland County, Pennsylvania. The letler was mailed under the date nf January 7. 1998 and never relurned to the Sheriff Oflke. R. Thomas Klinc. Sheriff who bcing duly sworn according 10 law. says that after due and legalnol\ce had hecn given according to law. exposed the within described premiscs al public venue or outcry at the Court House Carlisle. Cumberland County. Pennsylvania. on March 4, 1998 at 10:00 o'cJoe\ A.M,E.S:r.. and sold the same for the slim of $ 40.000,00 to Nicole Straley till' The Secretary of 1 lousing and Urban Development of Washington D.C.. his successors and assigns. It being the highest bid reccived till' the samc The Secretary of Housing and Urban Development of Washington D,C.. his succcssors and assigns paid to R. Thomas Kline, Sheriff the slim 01'$ 1755.77 it being sheriffs costs. Sheriffs Costs listed below. Shcriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging decd Auctioncer Law Library County Certilicd Mail Milcagc Levy Surcharge Legal Search Law Journal 30.00 800.00 \5.00 15.00 30.00 10.00 ,SO 1.00 1.31 9.30 15.00 4.00 150.00 335.00 Patriot News Share of Bills Distribution of Proceeds Sherltrs Deed 263.85 25.31 25.00 25.50 $1755.77 pdby Atty. ,I ,t' 'I "I So Qnsw~!J;.." . ,."I..~ ~5.r"~................< ~,' ...<<":c.t '1": ,1'" " R. Thomas Kline. Sheriff " Sworn and Subscribed To Before Me By 11~<ML..h4. Real Estate Deputy This(~ ""day of atCi.. L" , 1998, A.DC} . .. (l ~i!e<v, ~ . ~onolary It I " " " " " I, , I , I " , !! , .. , , ;)' il , I ;I ., i" 111,1, 1 " i J ,j " ,. , " " " , I! I I" .~~ ..... oY ,'v L\)' ~ \1) 1.!1e...:; ~"f ., \. 12...... 7.:J. I iO . - . . . . . TITLE REPORT THE PREMISES ENDORSED HEREON ARE SlIBJECT TO TilE FOLLOWING ITEMS. WHICH WILL BE EXCEPTED IN THE POLlCY UNLESS SATISFACTORY EVIDENCE PERMI'lTING THEIR REMOVAL IS PRODUCED. SH..:R......' SALE NO. 21 Held Wednesday, March 4, 19911 I>lIle: March 6, 1998 TAXES: Receipts 1'01' ulltuxes fur Ihe years 1995 to 1997 inclusive. Tuxes for the current year 19911, MORTGA(;ES: Listed lindeI' Other Exceptions Beluw. JUDGMENTS: Listed lindeI' Other Exceplions Beluw. INSTRUMENTS TO HE PROI>UCEI>: Deed from CUlllbcrlund Counly Sheriff to duted . 19911, und recurded , 19911, in Cumberland Cuunty Deed Buok , Puge . , RECITAL: Being the sallie premises which Willium L. Wolfe und Stephunie J. Wolfe hy their deed duted September 11. 1992, and recorded Septemhcr 15. 1992. in the Oft1ce of the Recorder of Deeds in und for Cumberland Cuunty at Carlisle, Pcnnsylvunia, in Deed Bnok "W", Vulume 35. Puge 722, grunled and cunveyed tu Thomas A. JohnSIUrl. OTH":R EXCEPTIONS: I. The identity and legal competency of palties m the c1nsing uf this tille shuuld be established 10 Ihe smisfaction uf the c1using anumey ucting for this Company. 2. Rights or claims uf purties in possession. if any. other than the owner. 3. Unrecorded easemcnls, discrep~ll1cies or conllkls in boundary lines. shortage in urea and encroachmellls which an accurate und \:umplcte survey would disclose, 4. Payment of StalC und local Real Eslale Transfer Taxes, if required. 5, Conditions and reSlrktions as shown on Plan No. 10 of Ridley Park recorded in Plan Book 18, Page 47. 6. Conditions and restrictions as set furth in Deed recorded in Deed Book "U". Volume 22, Page 883. 7. Restrictions recorded in Miscelluneuus Record Book 1711, Page 1147. 8. Rights granted IU Pennsylvania Power and Light COlTlpany and Bell Telephone Company of Pcnnsylvania by inslrumcnt rccorded in Miscellaneous Record Book 176. Page 1134. 9. Rights granted to Pennsylvanias Power and Light Company and Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneuus Record Book 1711. Page 392, 10, Public and privme rights in the roadbed of Erford Road, 11, Satisfactory evidence to be produced thutlhe proper nolificution was given to the holders of ullliens ullll encumbrances intended 10 he divested hy subject Sheriff Sale. 12 Righls in party wall scpuraling dwelling house 616 Erford Road from adjoining dwelling house bill Erford Roud, 13. Mortgage given hy James P. LeonLO and Priscilla A. LeonLO. hushand und wife. to Bogley, Harting, Mahoney and Lehling. Inc,. dated March 31. 1975. and recorded August I, 1975, in Mortgage Book 5117. Page 531. which was assigned to Bogley, Harting and Reads in Miscell.\I1eous Record Book , Page . and thereafter assigned to VNB Mortgage Corporation. Box 26388, Richmond. Virginia. on June 21, 1979. by instrument recorded in Miscellaneous Record Book 244. Page 365. which mortgage is in Ihe amount of $25,400.00. ,- . . , , THIS MORTGAGE IS NOT DIVESTED BY SUBJECT SHERIFF SALE AS EXECUTION HAS BEEN ISSUED ON A JUNIOR MORTGAGE WHICH IS A SECOND LIEN. . 14, Mortgllge given by Thonllls A. Johnstoll to GMAC Mortgllge Corporation 'If Pennsyl- vllnllldllted Septembcr 11,19')2. und rccordcd Scptcmbcr 15. 1'I1i2. in Mortgllgc Buok 10118. Pagc 302. in thc amount of $66.300.00. whidlmortgagc was [Isslgncd by instrumcnt duted February 8. 1993 to Prudcntialllome Mortgage Co.. Inc.. by Instrumcnt rccorded in Miscellancous Rcc,ml Book 437.. pagc 451. This prudcntial Mortgagc was lhc subject of a Complaint in Mortgage Forcclusure flIcd Fcbruury 12. 19'16 to No. 1996-00740 by Prudcntial Homc Mol'lgagc Co. agalnsl Thomlls A. Johnston. wilh judgmcnt entcrcd on April 10. 19'16. inthc amount of S71,691.11 with Wril of Exccution issucd on Junc 6. 1996. which Writ was stayed by 11 procccdlng In bankruplcy which was suhscl\ucntly dismisscd. IS. Mortgagc glvcn by Thomas A. Johnston ami Karcn K. Johnston to Mcmbers First Federlll CrcdltUnlon datcd Octohcr 13. 1995. and rccordcd Octobcr 19. 1995. In Mortgllgc Book 1287. Page 194. in thc amounl of $11.249.4'1. 16. Municlpllllicn filcdon August 14. 199610 No. 1996-04568 inlhc llmount of $469.85 In favor of East pcnnshoro Township. NO NOTICE FOUND OF A NOTIFICATION TO THE HOLDER OF THIS MUNICIPAL LIEN. : \' I \ , \ 17. Municlpallicn filcd May 19, 1997 in favor of East Pennsboro Township in thc amount of SI.OII.39. FOUND NO NOTICE TO EAST PENNSBORO TOWNSHIP OF THIS PROCEEDING. 18. Delinquent relll estatc taxes. 19. Relll estate taxes accruing on and aftcr July I. 1998. not yet due and payablc. 20. Advertised descriplion Ilppears to have Iltypogmphical error designating thc pLlftition willi between subJecl premises lit 616 Erford Road and Ildjoining premises at618 Erford ,ROlld. VC'~-in, '--;'fVl. ' Robert M. Frey, Agent 7 NOI~: This 'Titl~ R~port shall nul bc valid ur hlndintl unlll cuunlcrsltln~d hy an aUlhurizcd signlllury. ',' , ' . I, " " " , " I J, \ " , , ' " Ii " " , , .. I I i I',' '. i d' .1 I, I ,., 'I ,I " i' " '.1' i" , " , "l" I I :J , , " , , ' , , " . ~,~ ," . I' '.. " . ',' , .. ,"-'H'.'I"~ , , IIIAI. .....Aft IAUI NO. II " d 1'1, WrlI No. 1111-140 CIVIl TIlt PrudtnUaI Home MOI1C..e Company In~. .Ii , YO, HI II. , TIIomu II. Johnotan Atly.: Leon P. Haller I , , , ALL ntAT CERTAIN piece or par. " etl or land. lltuall tn Eul PeMlboro il I I ~p. Cwnbertond Counly, Penn. I)'IYarIla bctnC bounded and deocrIbed occorclIn& 10 0 5ww)' made by Oerrll 1'1 J. Bela. Rellll.ml Surveyor. daled March 20. 19711. .. followl. to w1l: BEOlNNlNO at a hub on the South. , ...terly old. of Erford Rood lWull , 1110 feel wid.1 al the dlYldlne IIn. ! ~ between Loll No. 2aX and 22. Block .H. on the h.relnln.. menUon.d plan 0( loll. wd polnl being m.... .. I uml alone the Nld old. of Erford ,I RDad (Weill. 388,02 feel In 0 North. erly dlre~Uon lrom the North...t ~or- " ner of Erford Rood and OI.nwoOO Drive: th.n~e ut.ndlng lrom ..Id polnl of beg1Mlng and along the ..Id lid. 01 Erford Road lWell). North 26 d.greeo 30 mlnut.. Ealllh. dlllance 0120.77 1..110 a hub: thence along " lhe lame on an arc or a circle ham" " , o radlul of 191.21 led In a North. ,I, ...Ierly dJrecUon 10 th. rtght, a dl.- ), ' lane. of 36.04 le'l 10 a hub II the com.r of Hou.. No. 618 Erlord Road: 'II thence throuKh the centerline or a , , "L partJUon waU betWffn Houael Noe. l. HI 606 and 618 Erford Rood. SoU~I!l3 . d.gree. 01 mlnul' 42 ..condl Ea.1 ! " the dJ.tan.. of 70.0 1..1 10 a potnl: thence along l&I1Ie. South 53 d.gree. 28 mlnules II ..condl Eatl. the dJ.- lance 01 43,!l4 1..1 10 an Iron pin: th.nce along the dMdlng line be. IWftn Loll NOlI. 6 and 21: !IX and ~ IX on the hereinafter menUoned ,'I , i! plan. South 26 degreel 30 mlnuteo t, I WUI the dl.tance of 36.30 I..! 10 a ,I hub al the dJvldln& Une belWftn Lola 'I Nos. 21X and 22: thence along wd " dividing line North 63 degreu 30 I, mlnule. Wulthe dl.tance of 1111.0 1..110 a polnl. Ihe place 01 BEOIN. " ,I ,I NING. :1, BEING LoINo. 21XandparlolLoI " "1 No. 21. Block .W Plan No. 10 01 , Ridley Park.. recorded tn Plan Book , , 18. Pille 47. 1'1 " BEING known .. No. 616 Erlord "1 " " Road. I'" " Ii BEING TIlE SAME PREMISES " which William L. Wolle and Stepha. nle J. WolI. by their deed daled Sep- , ' tember II. 1992 and recorded on Seplember 15. 1992 In Cumberland County Recorder 01 o.ed. orn~e In i.: Book W 311, Page 722. lVanled and , conveyed unlo Thomao A. John.lon. , "I TO BE SOlD AS THE PROP!R1Y ".j 'I> 0' mOMAS A. JOHNSTON UNDER CUMBERLAND COUNTY JUDG. MENt' NO. 1896-C-G0740. , ' , Tax Map: 09.18-10150-272. ,'1 ,,' \' I , i; \1 ,. , ,i- " 11'11 I " Ij " , Tl-lE PRUDENTI~L l-lOME MORTG~GE C9MPI\N'l, INC., IN Tl-lE COURT OF COMMON PLEAS CUMBERLAND CO., PENNS'lLV/I.NI~ plJAINTIFF NO. 1996-00740 VS. CIVIl. ~CTION - lJAW - IN MORTGAGE FORECLOSURE . Tl-lOMAS ~. JOl-lNS'!ON," . DEFEND/l.NT tiOTIC.Il,P:' ....l~~.:r:." ..... ...... pEllli-!l.X!!V_:t~ RJe: ~~:tV:tL PROCEDURE 31U TAKII NOT:tCEI That the Sheriff's Sale of Real property (real estate) will be held: ' D~TE: March 4, 1998 TIME: 10:00 O'cloCK ~.M. LOC~TION: commissioner'S l-learing Room 2nd Floor cumberland county courthouse carlisle, pennsylvania 17013 THE PROPERT'l 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 improvement~ erected on the land. (SEE DESCRIPTION ~TTACl-lED) THE LOCATION of your property to be sold is: 616 Erford Road Ca1lIP Hill Cumberland County pennsylvania ... Jut",..'" undor 0' pu,"uan' " which YOu' p,ope,'Y ie ,.ing .old is docketed in the within commonwealth and County tOl, 1996-00740 THE NAME(S) OF THE OWNER(S) OR REPUTED oWNERS of this property iSI Thomas A. Johnston A SCHBDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days aftp.r the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed, Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPBRTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGM~NT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY ~HE JUDGMENT.:. You may have legal rights to prevent your prope~ty from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE I Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 THE LEGAL RIGHTS YOU MAY HAVE ARE I 1. You may file a pet i t ion with the Court of Cort)mon Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition . ALL TIlA'l' CER'l'AIN piece or parcel ot land, situate in East . pennsboro Township, Cumberland County, Pennsylvania being'bounded and described according to a Survey made by Gerrit J. Betz, . Registered Surveyor, dated March 20, 1975, as fOllows, to wit: BEGINNING at a hub on the Southeasterly side of Erford Road (West) (50 feet wide) at the dividing line between Lots No. 2lX and 22, Block "fI" on the hereinafter mentioned plan of lots, said point being measured along the said side of Erford Road (West), 388.02 feet in a Northerly direction from the Northeast corner of Erford Road and'Glenwood Drive; thence extending f.rom said point of beginning and along the said side of Erford Road (West), North 26 degrees 30 minutes East the distance of 20.77 feet to a hub; thence along the same on an arc of a circle havIng a radius of 197.21 feet in a Northeasterly direction to the right, a distance of 36.04 feet to a hub at the corner of House No. 618 Erford Road; thence through the centerline of a partition wall between Houses Nos. 606 and 618 Erford Road, South ~3 degrees 01 minute 42 seconds East the distance of 70.0 feet to a. point; thence along same, South 53 degrees 28 minutes 11 seconds East, the distance of 43.54 feet to an iron pin; thence along the dividing line between Lots Nos. 6 and 21; 5X and 21X on the hereina fter mentioned plan, South 26 degrees 30 minutes West the distance of 36.30 feet to a hub a.t. .the dividing line between Lots Nos. 21X and 22; thence along said dividing-line North 63 degrees 30 minutes West the distance of 115.0 feet to a point, the place of BEGINNING. BEING Lot No. 21X and part of Lot No. 21, Block "H" Plan No. 10 of Ridley Park as recorded in Plan Boo1< 18, Page 47. BEING known as No. 616 Erford Road. SEING THE SAME PREMISES which William L. Wolfe and Stephanie J. Wolfe bi' their deed dated September 11, 1992 and recorded on September 15, 1992 in CUmberland County Recorder of Deeqs Office in Book W 35, Page 722, granted and conveyed unto Thomas A. Johnston. 70 BE SOLD AS THE PROPERTY OF THOMAS ~ JOHNSTON UNDER CUMBERLAND COUNTY JtJDGMENT NO. 1996-C-00740. 7ax Map: 09-16-1050-272 II , I f i II 'I I " . THE PRUDENTIAL HOME MORTGA.GE IN THE COURT OF COMMON PLEAS COMPANY, INc. , CUMBERLAND CO., PENNSYLVANIA PLAINTIFF VS. NO. 1996-00740 THOMAS A.. JOHNSTON, CIVIL A.C'rION - LAW . DEFENDANT IN MORTGAGE FORECLOSURE ,J\.PFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The plaintiff in the above action, by ,its attorneys, purcell, Krug & Haller, sets forth as of the date the praecipe for the writ , ,of execution was filed, the following information concerning the real property located at 616 Erfo~d Road, Camp Hill, PA 170111 1. Name and address of the Owner (s) or Reputed Owner (s) I, Thomas A. Johnston 616 Erford Road Camp Hill, PA 17011 2. Name and address of Defendant (s) in the Judgment, ~f different from that liated in (1) abovet SAME 3. Name and address of every judgment creditor whose juqgment is a record lien on the real property to be sold'l, COMMONWSALTH OF PENNSYLVANIA DEPARTMENT OF FU3LIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last recorded holdex: of every mortgage of record: PLAINTIFF HEREIN (AND ANY ,OTHERS A8 NOTED BELOW) : Members First Federal Credit Union 5275 E. Trindle Road Mechanicsburg, FA 17055 5. Name and address of other person who has 'I eye,ry any record lien on the property: UNKNOWN 6. Name and address of every other persol'/ who has any record REAL ESTATE SALHO 21 51.000,00 AdvlUlce Costs Paid, An.... Leon Heller Assessed Valuation S 6,220.00 . WRIT 1'0. 96 -740 Civ i 1 Term The prudentiel Home MortgDge VS Thomes A. Johnston 616 Erford Roed Cemp Hill, PA I" " , ' RE/l,L DEBT nsTEREST 2-27-96 to 3-4-98 ATT'S FEES WRlTCOSTS AnY ESCROW LATE CH.-1,RGE SHERlFF'S COSTS D,)~keting Poundage Posting Bills Advertising AckMwledging Deed Auctioneer Law Library County Mileage Cert Mail Le',,)' postpone Sale " Surcharge, , ' , I , ' Legal Search ADVERTISr>:G: Law Journal Patriot Share of Bills Distribution of Proceeds Sher![t" s Deeds STA~(PS Pa. Transfer Tax Twp or Boro Tro.nsfe~T:.\x TAXES 1997 School Tax Claim Bureau Sewer & Refuse ", 992.09 1,622.!)4 . 1,472.94 PROOF OF PllULlCA TION OF NOTIC..: IN ClJMDERLAND LAW JOURNAL (Under Act No. ~1l7. upproved May 16. IlJ2lJ), P. L.17H4 STATE OF PENNSYLVANIA : COUNTY OF CUMDERLAND : ss. Roger M. Morgenthul, Esquire. Editor of the Cumb~r1and Luw Joul'llul. of the County IlI1d State aforesaid. being duly SWOITI. according to law. deposes and says that the Cumberland Law Jou1'l1al. a legal periodical published in lhe Borough of Carhsle in the County and State aforesuid. was established January 2. 1952, and designated by the local courts us the ofl1cial legal periodical for the publication of all legal notices. and has. since JanuUl'y 2. IlJ~2. been regulUl'ly issued weekly in the suid County. and that the printed notice or publication uttuched hereto is exactly the same as was printed in lhe regular editions and issues of the said Cumberland Law Jou1'l1al on the following dales. viz: JANUARY 30. FEBRUARY 6. 13. I~~ll Affiant further deposes that he is uuthOl;zeu to verify this statement by the Cumberland Law Journal. a legal periodical of generul circulution, and that he is not interested in the subject matter of the aforesaid notice or Ildveltisement. and that all ullegations in the foregoing statements as to time, place and character of publication are true. UAL UTATE IIALI: NO. n Wrtt No, 96,740 Civil The Prudrnltal BOnJr- Mortli(nge Company Inc. va, Thomas A. .Johnston Atty., Leon p, Hall.. ALL THAT CE:RTAlN piece or par- c~l orlnnel, situate In Ensl PrnnsboYl) Township. Curnbtrlnnd County. }lImn- sylvania being hounded And dl"til'rtbt"d llccorolng to n Survey mnde by GrrrH J. Hetz, Rr!Vsltred Surveyor, dated Marth 20. 1975, ll!! follows, to wtt; BEGINNING ilt a huh on the South- l"a~ltrly sIde of Erfnrrl Rallet (Wl.'litl 150 feet wld{"l at the dlVltlln,ll, Hnt" ht"lwu'n l.ot~ No '.HX I\nd 22. Blcu'k "U" on the ht"r~tr\olft~r mrntlorjt'" plan of lOlli, liald pnlnt hrlflt.t m~nli- 1\1'1',1 .dlln~ Ih,' .,,1\11 .,Id,' Ill' t:rfnrd HI 10111 (WI'''') :\HH l)'lll'l'\ 11l.1 ~111,ll t"dvlllrc'I'II11n IHJl1l Ill(' :\0111\1',1..1 I Ill" nrr of Erford ROild nnd Glenwooo Drtve: thencr el(ttndln~ from stlld point ofbtf(lnnlntl( I\nd nlonjl( th(" satd side of Erford ROlld (W("~tl. North 2t> d("J(rrtlt :10 n\lnlltl"~ ~:i'!\t thtctl.ill\nn' or 20.77 fl"l"t to a huh; thl"rH't" ;\1011,1( the !\i\nlt on .lfl ,m' of a I'Irrh- hilvln,l( a r.uliu!'l of 19721 frol't In i\ North. ("usttrly (IIrtctloll 10 tht' rl)(ht. a dlMi tance of :\tUH frr"l to it huh ul tht' corner ofHo\lse No, (i IH Erfnnt Road: thtnct throu,II,h the!' n't1trrline of i\ partlllon wall hetwern HOlllil"1i NOli, 606 and 6tH Erford Road, SmIth 5:' dl"r.(rr~l"s 01 mlnutr 42 litl'ond.'\ t:alit tlH' dhl,H\(I' tlf 70 \} 1l'r'1 III .l 111111\\ lhroll'!" i1lutl~ "HIIH'. Stlllll! :-1:\ (\I'I.I.n't'., '/.H rullllllt'S 11 SI.t'Ollll"l 1-:,,'~I, 1111' 1\1,., t,mo' of 4:l:l" 1f'I'\ 10 .m trOll pill: tht'lll'l' .lInll'" Ill!' dlvtllltl~ hili' Ill' IW"I'1I Lot.. ~o.'"i t; ,lilt! "2\, :)X dill! '11 X 1)11 ,111' 1\I'Il'Ill,dtt'l 1lI"llllillW!\ pI ' \ I; '. , "' i I t I ') I, ill ' I' II - I ", I I) II \ ! I.)l ~ 1 I ", ? d, /---. - /.' , / '., ') /l {./---,-~ Ro~)rgenthal, Editor SWORN TO AND SUBSCRIBED before me this 13 day of FERUARY. 1\198 r-,>/~.,;'.J C, NOTARIAL $I L l0l5 e lINyon _ry Publk (.oritll. kim, ('IMb.,iorad County, PA I'll'( (fl",mluJon fAptr.~ Mmdl ), 20tH - --....-.--...-.....--.-- THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication PUBLICATION COpy SA L E .21 "A~ ~:tr . ~_ . CUMBERLN-lD COUNTY SHERIFFSOFFlCE r..: ~S~,. "'" ~~'6 stiltement of A_vertlllng Cost$ I 0I0wft: To THE PATRIOT.NEWS CO., Dr. l''''o ..... .l,gt~~i.,. ~"'~on~ For publishing the notice or publication attached hereto ols..u 2' ^ _~ 22. 1IioC."'H..... on the above ststed de tea $ ~~P~ic;>I)o'lol1. ~ Probating same (1) Notery Fae(s) $ ~ R' (lfdid II9cid <W",,\ the SOld Total $ a ~ cheilIOn ~ ^ ,02 feet 8ClIt !=Q!neI 0/ E~Ord Ro:i:l' Norlt1- WQod pn.;.e. thwiC8 ~ Glen. r:U:t:"o~~r:;{mdtik'J from i.her'. Receipt for Adverti.ing C08t: M,~~~Y~HOI'~Ja~ ~ sher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS, newspapars of general - on: g,.,"-t ~' recalpt of the aforaaald notice and publication costs and certltles that the same hava G;! ~7 ~~, l:. ~ 0 THE PATRIOT.NEWS CO. M~~~ ~.......................................................m....... \Ills 18C0Ildi EClfi ~.... 01 mln, /ll.O , to o="~once of ..... South ~ . ~ m,e :w ~~_'!*>i:e eo,~~, ~~x on'i:'~~~~ IlIao\. Sault! 26 <leo, ~ ~ men I::~; Mmee'~''I,' est !Jt'Q: line between lots ~~I)t NoItt 0I<m SOld ~ ~ ~.if}l~/~n~~~,. ~' tI<>-'~k .~ f,'X ona IlOtf ~OI ,~ CII rOCOfd,,(j in IQn ~.:.1P or .~ ~~Iap 8f,NG !mown ell " Id ..0, 616 fJfooll BflNQ IHf. SAMP,... /In l,WoIr.) '(JPI, I. ....MISfS Which WII, ,".. dIO(j rl<J'8d PIlonla J, WOi'e b\I <Jndllcor(JOdon~t91'TtbfJ' '." 'm /SJ:J""'lnd COU~t"mrel r 15, '99'2", GMt., In BooIt'" eCordaf 0' Grcnt! '.1 ond r on" W,.)6: 1-1\100 /'}2 ..JOtl'l~ton . t.I\I"r IJnt, , III'lnlll', 1\ TO Ilf '01.0 AS !HOM,o,s A "JOt.IWro~" ""UPI illY ()f l~D ,aUN,V' IJD"NGDM!~C:UMH!1I 1.......C()lI40 ' d~T Nn Tn_Mop: OQ.'1j lu!"JO.?n UndllI Act No, ~87, ADoto.od IAs. 16 1929 Commonw,,'th 01 Pennlylvanle, County 01 Dauphin) .. FflnkJ. Epl., being duly sworn according to low, deposes and says: ThaI he II the Controller of THE PATRIOT.NEWS CO., a corporlllon organized and existing under tha 'awl 01 tha Commonw..,th 01 Pennsylvania. with Itl principal oHlce and pleoa 01 bUllna.. It 812 to 818 Markel Straet. In the City of Herrllburg, County of Dauphin, State 01 Pannsylvlnla. owner and publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS newlpape,. 01 general clrculltlon. printed end published at 812 to 818 Market Street, In the City, County and State eforesald; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS wers astabllshad March 4th, lS54, and September 18th. 1940. raspectlvely. and III hsve been continuously published evsr since; Thlt the prlnteQ notice or publication which Is slcurely attechld hereto Is exactly as printed and published In their regular dalty andlor Sunday end Metro adlllons/lasues which eppeared on the 3rd, 10th and 17th dsy(s) 01 February 1998. That neither ho nor said Compeny Is Intarested In tha subject metter a. sBld printed nollca or adverllllng, and that all of the allegallonl of this Itelement as to the time, piece and character of publication are true; and That he has personal knowladga o. the lacts aforesaid and Is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforasald by virtue and pursuant to a rasolullon unanimously passed and adopted severally by the stClckholders Bnd board of dlractors of the seld Compsny and aubsequently duly recorded In the olllce lor the Recording of Dellds In and for said County of Dauphin In Mlecellaneous Book "M". Volume 14, Page 317, . ___,,---7----- '--= --." ~ c;~~;,-~;;;~i;;~;;"~;;~;D. NOlI/'ll 'lei, . ( . ~'.j. ~~'e'./ Terrv l fj,,",.I, 10,,11'/ P~,..: NOT ARy-'PUBLlC H.,rll.l'Mg DiilJf,)hln County My CtXnrrnslOn .E 19tfet Junw 6, 1 9M 1oUrClor, f'ery..')IotTlill Aww.1Ion Iss/on explrf/s Junf/ 6. 1998 282,35 1.50 283.85 I I 1 ! v. I XN THE COURT OF coMMON PLEAS I CUMBERLAND COllN'I''l, PENNS'lL~ANIJA : No. 1 it - "741 (I, ..L.. L L-L'rl'-' I I CIVIL ACTION - LAW I I CUSTOD'l I I I, f! CUOL J. CUOY, Plaintiff/petitioner KICHAIL A. CANOY and CHRISTINA R. HOYYIR, Defendants/Respondents QRDER It ,1996, upon consideration of the is hereby ORDERED and DECREED, as AND NOW, r::"~"'J"7 foregoing stipulation, it folloWS I 1. Full legal and physical custody of Kaitlyn Christine Canoy, born october 23, 1992 shall be with the Plaintiff/petitioner, carol J. Canoy. 2. Michael A. Canoy shall retain partial custodY for the purposes of visitation with the child. Said visitation periodS shall be mutually agreed upon by the parties. B't THE COURT: . / .A~ J. " ' \, "~I, " I' " I, 1-, i' I' I' "b""u. , , , I Fil fll.(mGlt 'I--j !i,; 'I'}"" t', !,{-.~ ,r- -11'1 l"'\( 1-" "'.'.,'-_"\1"\ ell 'i "J'I;'I':n \ j" oJI) r,- ,I . t;iI 1"11'" .1,.) II) Ii 'i' " f'lJl"" I "," 11\"" 1I,'iIi- -.i,!,.?'1 ,1_il.'ll'-_.-_.-'. ',1.1 1"'1'1' '1"'\'" I; ,~f - ". '1,),1)111, -.,-\ ,'; .J' ,. , , ,.1 ,I ',I I " "I i! , , ': I:" I' , 1'1 ;,1 " q 'I ) i' " , " 1'1 " 'I )i 'I , I, 1,", " .) j, " '! " I , , 1 jl I"~ ., 'I ,I 'I , , i.', I " 'i Ii , , 'j'1 I, , I i 1,1 ,; lIt ,I I, 11 'Ii " ,-II "I , 'ii, ,.' I ';1' I'.II' II 'i"']" II' i, , I'; II . . ;.... v. I IN THE COURT OF COMMON PLEAS I I CUMBERLAND COUNTY, PENNSYLVANIA I I No. I I CIVIL ACTION - LAW I I CUSTODY I. , I i C~ROL J. OAlfOY, Pla.tntitf KIOHAIL A. CANOY an4 CHRI8TIN~ R. HOrrIR/ Defendants CUSTODY COMPLAI~T '1'0 THE HONORABLE, THE JUDGES OF SAID COURTI 1. The plaintiff is carol J. canoy, paternal grandmother of the subject minor child who currently resides at 142 Bosler Avenue, Lemoyne, CumbeI'land county, Pennsylvania 17043. 2. The Defendants are ~ichael A. Canoy who currently resides at 142 Bosler Avenue, Lemoyne, Cumberland County, pennsylvania and Christina R. Hoffer who$e last known address is 51 Wyoming Avenue, Lot 14, Middletown, Dauphin county, pennsylvania 17057. 3. Plaintiff seeks primary legal and physical custody of the following child: Kaitlyn Christine Canoy, born October 23, 1992, who currently resides at 142 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. 4. The child was born out of wedlock. ~. " 5. The child is presently in the custody of Carol J. Canoy, the paternal grandmother, who resides at 142 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. 6. During the past five years, the child has resided with the following persons and at the following add~sssSSI t: I I: I I , I' ii I't I i i~ " or. -..IIIL I Persons Ad4resses Dat,s Michael A. Canoy 4920 Eastman Dr. 10-23-92 Christina R. Hotter Harrisburg, PA 17109 to 3-92 Carol J. Canoy Michael A. Canoy 4920 Eastman Dr. 3-92 to Carol J. canoy Harrisburg, PA 17109 7-1-95 Carol J. Canoy 142 Bosler Avenue 7-1-95 to Michael A. Canoy Lemoyne, PA 17043 Present 7. The mother of the child is Christina R. Hoffer, who currently resides at 51 Wyoming Avenue, Lot 14, Middletown, Dauphin County, Pennsylvania 17057. She is singls. 8. The father of the child is Michael A. canoy who currently resides at 142 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. He is single. 9. The relationship of Plaintiff to the child is that of paternal grandmother. The Plaintiff currently residss with the following persons: ~ Relationshin Son Michael A. Canoy 10. The relationship of the Defendants to the child 1M that' of mother and father. The Defendant, christina R. Hoffer currently resides with the following persons I ~ Relationshin Cheryl & John (Last Names Unknown) Friends 11. The Dsfendant, Michasl A. canoy currently reBides with the following psrsonst ~ Relationshig Mother Carol J. canoy 12. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of ths child in this or another court. There was a previous custody action entered in Dauphin county, No. 1315 S, 1993 in which a stipulation was entered between Michael A. canoy, plaintiff and Christina R. Hoffer, Defendant, regarding the child. A copy of the most recent Order is attached hereto. 13. plaintiff has no information of a custody proceeding concerning the child pending in a court of this commonwealth , i I \ . I i except as referred to above. 14. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child except the parties named herein. 15. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is in a better position to provide for the physical, emotional and spiritual wellbeing of the child. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have besn named as parties to this action. WHEREFORE, plaintiff requests the Court to grant primary . ; I I , \ , ' ! legal and physical custody of the child to carol J. canoy, " paternal grandmother of the child. Respectfully submitted, ) i,' Lor BIlRRA ELLI, BROWN , CALHOON 2040 Linglestown Rd., suite 106 Harrisburg, PA 17110-9483 (717) 540-9170 Attornsy for plaintiff I, " ',i I I I , , , , I I, " "I q , , , , , " ,I I " I " I .. 'iI' I I" 'I , , , " " , I , ,I 'J.1 , , i I , 'I " I \1 'oj " " I " 11 , I I, 'I, , , " " II ,,, , , I " . ' , ,j " 1'1 II, Ii, I I 1-' , il " ! ' , " 111,/1" ..11 " " I;, " " ','i , 1''' " , ;ji " I , I , ' , I , YERIFICr..TIOt!. 1 verify that the statsments made in the Foregoing petition are true and correct. 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