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Welker, Prothonotar.y Kindly issue a writ ot pOllllession in the abovs matter upon the fOllowing oertain real propertyc ALL that certain tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and desoribed in aooordanoe with a eurvey made by Noel B. smith, Registered Surveyor, on Maroh 26, 1973, all follows I BEGINNING at an existing iron pin at the Northwestern corner of land formerly at Roderick and cynthia May, later of Gsorge Morton, and now or formerly at stephen Keck, thence from said existing iron pin at the place of beginning along the Western line of said land now or formerly of stephen Keck, South 05 degrees 22 minutes East a distance of 120 feet to an eXisting iron pin in a fence along line of land now or tormerly of Cloyd Snyderl thence along said fence and line of land now or formerly of Cloyd snyder, North 82 degrees 09 minutes 04 seconds West, a distance of 316.71 feet to an existing pin in fence along line of land now or formerly of Democratic Clubl thence along said fence and line of land now or formerly of Democratic Club, North 17 degrees 54 minutes West, a distance at 20 teet to a point on the Southern line of road known as Gordon Drive, thence along the Southern line of said Gordon Drive, North 79 degrees 30 minutes East, a distance of 313,83 feet to an existing pin at the place of beginning. CONTAINING .496 acres. HAVING erected thereon a one story aluminum siding covered ranch type dwelling house known ae 60 Gordon Drive, and bearing Tax 1.0. ,I " >'1 '''I I, l,.f 1.(. It; ) . ~, i')" J 1'1 !1! 1! "~I [I), I, , ',t',] 'I I II ( " '.' , 1"1 lj, !!'" I' I' ..'i , I '.' ,~I.:J ' ,,~ ~;(~ ~ ~ ~ ....... 1:? '1Q P \' " I' \';;. ~\ ~ /\') ,...... ,.... ~ ~ ~ ~ ~~~ - . .... - " .1 , , ", .......--..... ...,..,...... ,.. I II ,I Ii IH TKI COURT or COKMOH PLI~B or CUHBIRL~Hn COUHTY, P.HH'YLV~HI~ UNITED COMPANIES LENDING CORPORATION, CIVIL DIVISION '14 'I 2 J'.J. {!.vJ Tl-......- No. Plaintitt v.. LESTER E. SPIDLE, Detendant aOHPL~IHT IH 131CTHIHT AND NOW come. Plaintitt, UNITED COMPANIES LENDING CORPORATION, by and through ite counlel RIMBERLY McDANIEL, ESQUIRE and THOMPSON, CALRINS & SUTTER, and reepecttully reprelentl a. followl I 1. Plaintiff il UNITED COMPANIES LENDING CORPORATION, a corporation whole addrell il 4041 Ellen Lane, Baton Rouge, LouiBiana 70809. 2. Defendant is LESTER SPIDLE, an adult individual who il currently residing at 60 Gcrdon Drive, Carlille, Pennlylvania 17013. 3. Plaintiff cbtained legal title to the real property currently pCllelled by Defendant, at Cumberland County Sheritt'l lale held on June 20, 1996. The Sheriff'l Deed to Plaintitf il currently beinq filed in the Office cf the Reccrder of Deedl ot Cumberland county, Penneylvania. 4. The real prcperty subject to thie ejectment action is more particularly dellcribod as tollowel ALL that certain traot ot land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey made by Noel B. smith, Registered Surveyor, on March 211, 1973, u t'ollower BEGINNING at an exiating iron pin at the Northwe.tern corner at' land tormerly at Roderick and crnthia May, later at' aeorge Morton, and now or tormer y at' stephen Keck, thence tram eaid exiHting iron pin at the place 01' beginning along the Western line at lIaid land now or tormBrly at stephen Keck, south oe degre.e 22 minutes East a distance at 120 teet to an exiating iron pin in a tence along line ot land now or t'ormerly at Cloyd Snyder, thence along said tence and line at land now or tormerly of Cloyd snyder, North 82 degress 09 minutes 04 seconds West, a diatanoe ot 316.71 teet to an exiRting pin in t'ence along line at land now or tormerly at Democratic Club, thence along I!laid tence and line at land now or tormerly at Demooratic Club, North 17 degrees e4 minute. We.t, a dietance at 20 teet to a point on the southern lino at road known eo Gordon Drive, thence along the southern line ot I!leid Gordon Drive, North 79 degrees 30 minutes East, a distance at 313.83 teet to an existing pin at the place ot beginning. CONTAINING .496 acres. HAVING ereoted thereon a one story aluminum siding covered ranoh type dwelling houl!lo known as 60 GCJrdon Drive, and bearing Tax 1.0. No. 29-0e-042e-088. TOGETHER with the right at ingreal!l, egre.. and regress over the road known as Gordon Drive whioh extends from North middleton Drive to and along the above-described premisee. BEING the same property whioh LeeteI.' E. Spidle granted and oonveyed unto LeeteI.' E. spidle and Lillian J. spidle, by Deed dated October 27, 1994 and recorded in the Recorder of Deeds Office of Cumberland County in Deed Book Volume 114, page 874. e. Plaintitt ie the owner in fee at said property and is entitled to immediate posselleion thereof. 6. Defendant is presently oocupying the subject real property without any olaim of right. 7. Detendant has unlawtully withheld, and oontinues to unlawfully withhold, posllellllion ot the real property trom Plaintitt. 8. Furthermore, Defendant has been in possession of the subject real property sinco prior to July 20, 1996. ~" J(I 11?~ (J ",I ~ . t~ I I,dn 1,.,1 . (l~~v 1(';t~//l(i'-,:"I (f" fJ I', . ~{f I' ! , " " " 'I a ~ , G-, ~\6 ~ ~~ \;, 0.,. -. ~ ~ r,: II. ~ . ,. I , ,.': '> ~ ~~( 1 ) , ,~ p \.., I' :1- _~ '-oS .m ~ ' I.... ,"." "- ' '- -..:::r I '1,) ... ell' '1' , "~ r..: L t,l} ~ ~ (,' I t, , , ~'... .~ '. , i . j ~ ~~~ ) .' " c.) 1..'1 l.." , ' , 'I " " II , , ", "'\'1" " I! I " , , , " , , IN THI OOURT 0' OOKMON >>~IA8 0' OUMB.lLAND OOUNTY, >>IHN8YLVANIA UNITED COMPANIES LENDING CORPORATION, CIVIL DIVISIO~ Plaintiff No, v.. LESTER E. SPIDLE, D.fendant QOMPL~INT IN IJIOTMINT AND NOW com.. Plaintiff, UNITED COMPANIES LENDING CORPORATION, by and through it. oounl!lel KIMBERLY MoDANIEL, ESQUIRE and THOMPSON, CALKINS & SUTTER, and rRllpeotfullY represent. a. follow.l 1. Plaintiff is UNITED COMPANIES LENDING CORPORATION, a oorporation whose address ill 4041 Essen Lane, Baton ROUge, Louisiana 70809. 2. Defendant is LESTER SPIDLE, an adult individual who i. ourrently residing at 60 Gordon Drive, Carlisle, Pennsylvania 17013. 3. Plaintiff obtained legal title to the real property ourrently possessed by Defendant, at cumber.land County Sheriff's sale held on June 20, 1996. The Sheriff'lI Deed to Plaintiff is ourrently being filed in the Offioe of the Reo order of Deeds of cumberland County, Pennsylvania. 4. The real property sUbjeot to thill ejeotment action is more partioularly ~esoribed as follows I ALL that oertain traot of land situate in North Middleton Township, cumberland County, Pennsylvania, bounded and desoribed in aooordanoe with a survey made by Hoel B. smith, Req istered surveyor, on Maroh 26, 1973, al follower BEGINNING at an existing iron pin at the Northwestern ccrner of land formerly of Roderick and cynthia May, later of Guorge Morton, and now or formerly of Stephen Keok, thence from said exillting iron ~in at the place of beginning along the Western line of said land now or formerly of stephen Keck, South 05 deqrees 22 minutes ~ast a distance of 120 feet to an exioting iron pin in a fence along line of land now cr formerly of Cloyd snyder, thence along said fence and line of land now or formerly of Cloyd Snyder, North 02 degrees 09 minutos 04 seconds West, a distance of 316.71 feet to an existing pin in fence along line of land now or formerly at Democratic Olub, thence along said fence and line of land now or formerly of Democratic Club, North 17 degrees 54 minutes Wel!lt, a distanoe of 20 feet to a point on the Southern line of road known as Gordon Drive, thonce along the Scuthern line of said Gordon Drive, North 79 deqreos 30 minutes East, a distance of 313.83 feot to an existing pin at the place of beginning. CONTAINING .496 acrea. HAVING ereoted thereon a one story aluminum sidinq covered ranch type dwelling house known all 60 Gordon Drive, and bearing Tax I.D. No. 29-05-0425-088. TOGETHER with the right of ingrells, egress and reqrells over the road known as Gordon D~ive which extendll from North middleton Drive to and along the above-described premises. BEING the same property whioh Lester E. spidle qranted and conveyed unto Lester E. Spidle and Lillian J. spidle, by Deed dated Octoher 27, 1994 and recorded in the Recorder of Deeds Office of CUmberland County in Deed Book Volume 114, page 874. 5. Plaintiff is the owner in fee of said property and is entitled to immediate possession thereof, 6. Defendant is prellently occupying the subject real property without any claim of right. 7, Defendant has unlaWfully withheld, and continues to unlawfully withhOld, possession of the real property from Plaintiff. 8. Furthermore, Defendant has been in possession of the subject real property since prior to July 20, 1996. IN TN. OOURT or OOKMaN >>L.~8 or OU"B.RLAN~ OOUNTY, >>.""8YLVANX~ UNITED COMPANIES LENDING CORPO~ATION, CIVIL DIVISION Plaintiff No. VI. LESTE~ E. SPIDLB, Defendant OOKPL~INT IN BJeCT~ AND NOW oomes Plaintiff, UNITED COMPANIES LENDING CORPORATION, by and through its oounsel KIMSERI,Y MoOANIE~, ESQUIRE and ~HOMPSON, CALKINS & SUTTER, and respeotfully representll as followsl 1. Plaintiff is UNITED COMPANIES LENDING CORPORATION, a corporation whose address is 4041 ESl!len Lane, Baton Rouge, Louisiana 70809. 2. Defendant is LESTER SPIDLE, an adult individual who is ourrently residing at 60 Gordon Drive, Carlisle, Pennsylvania 17013. ~. Plaintiff obtained legal title to the real property ourrently possessed Py Defendant, at Cumberland County Sheriff's sale held on June 20, 1996. The Sheriff's Deed to Plaintiff is currently being filed in the Office of the Recorder of Deedll of Cumberland County, Pennsylvania. 4. The real property subject to this ejectment action is more particularly described as followSl ALL that certain tract of land situate in North Middloton Township, Cumberland County, Pennsylvania, bounded And described in accordance with a survey made by Noel B. smith, R.qistered surveyor, on Maroh 26, 1973, all tollowSI BZGINNING at an eKistinq iron pin at the Northwelltern oorner ot land tormerly ot Roderiok and cynthia May, later ot George Morton, and now or formerly at Stephen Keok, thenoe tram lIaid eKistinq iron pin at the plaoe ot boqinning along the Western line at said land nuw or formerly at stephen Kook, south O~ deyrees 22 minutes East a distance of 120 teet to an eK sting iron pin in a fenoe alonq line at land now or formerly of Cloyd Snyder, thence along l5aid fonce and line of land now or formerly of Cloyd snyder, North 82 degrees 09 minutes 04 seconds West, a distanoe of J16.71 feet to an existing pin in fenoe alonq line of land now or formerly of Democratio Club, thence along said tenoe and lino of land now or formerly of Democratic Club, North 17 degrees ~4 minutes West, a distance of 20 feet to a point on the Southern line of road known as Gordon Drivel thence alonq the Southern line of said Gordon Orive, North 79 degrees JO minutes East, a distanco of 313.83 feet to an existing pin at the place of beginninq. CONTAINING .496 acres. HAVING erected thereon a one atory aluminum sidinq oovered ranch type dwelling house known as 60 Gordon Drive, and bearinq Tax I.O. No. 29-05-042~-088. TOGETHER with the right of inqress, egress and reqrella over the road known as Gordon Drive which eKtends from North middleton Drive to and alonq th~ above-described premises. BEING the same property which Lester E. SpJ.dle qranted and convoyed unto Lester E. Spidle and Lillian J. spidle, by Deed dated October 27, 1994 and reoorded in the Recorder of Deeds Office of Cumberland County in Deed Book VolUme 114, paqe 874. 5. Plaintiff is the owner in fee of said property and is entitled to immediate possession thereof. 6. Defendant is presently occupying the SUbject real proporty without any olaim of right. 7. Defendant has unlawfully withheld, and continues to unlawfully withhOld, possession of the real property from Plaintiff. 8. Furthermore, Defendant has been in PossQssion of the SUbject r.eal property since prior to July 20, 1996. v . . % . J 0 A_'-1-DI_ ., I, _ a.llrae KiU.. _., ..~~~1!.~!~~~."1I11_~ , ot Unihd Oompanhl Lendin\1 corporation, henby c.rUty that I am authori.ed to make thie Veritioation all behalf at United Oompani'l Lending corporation and that tho I.'lIotlll rJolltainod in the tangoing Complaint whioh are within my parNon"l kllowled~1I are true and oorreot, and ae to taota baaed Upoll lnl.'ormation 01.' othera, I believa them to b. truo. Thia Veritioation ia made aubjaot to the penaltie. at 18 pa.. C.S.A. 14904, relatinl1 to unlworn I.'alaitioation to authorities. Dlltel~)' H, 1996 ~ -- - IhlllrllU KIII/IIII, Vlell I'rll/ltdunt UCLC/SPIDLlB " , IN TnB aOURT or OOHMON P~B~8 or aUM8.n~~ND OOUNTY, >>BNN8YLV~NI~ unI~ED COMPAnIES LEnDInu CORPORATIon, OIVIL DIVISIon Plaintitt no. Ve. LESTBR E, SPIDLE, Detendant COKP~lrNT IN eJECTMBNT AnD now oomee Plaintitt, UNI~BD COMPAnIES LEnDInG CORPORATIon, by and through ite counsel KIMBERL'i MoDAnIEL, ESQUIRE and ~HOMPSON, CALKINS & SUTTER, and respeotfully represents as tolloWSI 1. Plaintitt is UNITED COMPANIES LENDING CORPORATION, a corporation whose address is 4041 Essen Lane, Baton Rouge, LouJ.siana 70809. 2. Defendant is LESTER SPIDLE, an adult individual who is ourrently residing at 60 Gordon Drive, Carlisle, Pennsylvania 17013. 3. Plaintift obtained legal title to the real property ourrently possessed by Defendant, at cumberland County Sheriff's sale held on June 20, 1996. The Bheritf's Deed to Plaintiff ia ourrently being filed in the Offioe of the Recorder ot Deeds ot oumberland County, Pennsylvania. 4. ~he real property subject to this ejectment action is more particularly desoribed as followSI ALL that certain tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey made by Noel B. smith, Registered survoyor, on Maroh :lll, 1973, as follows I BEUlnnlnG at an existing iron pin at the Northwestern corner or land tormerly at Roderick and cynthia May, later of George Morton, and now or formerly of stephen Keok, thenoe from said existing iron pin at the plaoe of beginning along tho Western linG of said land now or formerly of Stephen Reck, South 05 degrees 22 minutes East a distance of 120 feet to an existing iron pin in a fence along line of land now or formerly of Cloyd Snyder, thence along said fence and line of land now or formerly oF. Cloyd snyder, North 02 degrees 09 minutes 04 seconda West, a distanoe of 316.71 feet to an existing pin in fence along line of land now or formerly of Democratic ClUb, thenoe along said fence and lin$ of land now or formerly of Democratic ClUb, North 17 degrees 54 minutes west, a distance of 20 feet to a point on the Southern line of road known as Gordon Drive, thence along the Southern line of said Gordon Drive, North 79 degrees 30 minutes East, a distance of 313.03 feet to an existing pin at the place of beginning. CONTAINING .496 acree. HAVING erected thereon a one story aluminum siding oovered ranch type dwelling house known as 60 Gordon Drive, and bearing Tax I.D. No. 29-05-0425-088. TOGETHER with the right or ingress, eqress and regress over the road known as Gordon Drive which oxtends from North middleton Drive to and along the above-described premises. BEING the same property which Lester E. spidle granted and oonveyed unto Lester E. spidle and Lillian J. Spidle, by Deed dated October 27, 1994 and recorded in the Recorder of Deeds Office of Cumberland county in Deed Book Volume 114, page 874. 5. Plaintiff is the owner in fee of said property and is entitled to immediate posseesion thereof. 6. Defendant is presently OcclJpying the subj ect real property without any claim of right. 7. Oefendant has unlawfully withheld, and continues to unlawfully WithhOld, possession of the real property from Plaintiff. 8. Fur.thermore, Dofendant: has boon in possossion of the subject real proporty sinco prior to July 20, 1996. ~5(l'(r:JlCl j(). lfil(f . h ((',.( (I ((J..L ~~:'j' fh1l':) (l at v-- , ) f fJ.! ,II- ~..c~..J.. ''''',t) ':11-' / V ~ --jj 'J OFr ..' I~ I I' 'f'll/ ': 1't:'lftFIf ,I; I Y Ocr ~ I U 011 ~11'36 . , I 1'1.1. i, '. , I. \1111;11\ I' , I I " I"~ I ;'1 , \' I I I . 'I ,\ \, , , ., ~I~ '@~ ;"'" ~~.-; ~. ~ " " I, I 'I 1'1 i ~ i I I " \ I , , I' " ;c ,- ~ ... . J ~ In ,. .. ,.: ~ ~. tr: :'}"s fi ;J ~ , f ')! \J'- ............ 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