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HomeMy WebLinkAbout00-00541 ~~I ,',;-' - " '~,,~ .,-' , , , -'~ ~- KIVITZ & KIVITZ, P.C. BY: Jay E. Kivitz, Esquire ID# 26769 7901 ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0308 (215) 549-2525 G.E. CAPITAL MORTGAGE SERVICES, INC.: 4680 H~llmark Parkway San Bernardino, CA 92407 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF v. . NO. aco-5t1/ ~ BART OLEWEILER AND MARGARET WAGNER AND John Doe, Jane Doe, tenant/occupiers: 538 N. Pitt Street, Apt 2, 2n fl. : Carlisle, PA 17013 DEFENDANTS 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST ,YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA (717) 240-6200 u " .-j" ,,", .'- , 1. principal 92407. Plaintiff is G.E. offices at 4680 Capi tal Mortgage Services, Inc., with Hallmark Parkway, San Bernardino, CA 2. Defendants are Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, who reside at 538 N. Pitt Street, Apt 2, 2nd floor, Carlisle, PA 17013. 3. Plaintiff is the record owner of 538 N. Pitt Street, Carlisle, PA the premises where defendants reside, having acquired title pursuant to a sheriff's sale duly held in Cumberland County on December 8, 1999. The sheriff sale was authorized under the terms of a foreclosure action and judgment entered thereon in the Court of Common Pleas of Cumberland County. See copy of legal description attached hereto as Exhibit "A". 4. Plaintiff is the owner of said 538 N. Pitt Street, Carlisle, PA and is entitled to possession thereof. The defendants Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, are still in possession of said premises without right, and so far as the plaintiff is informed, without claim of title. 5. Plaintiff has demanded possession of the said premises from the said defendants who have refused to deliver up possession of same. WHEREFORE, Plaintiff demands judgement for possession of the foresaid premises. KIVITZ & KIVITZ, P.C. n ~& ,~ ,~ i . 1"- ,,,,. '-'"""I VERIFICATION Jay E. Kivitz, Esquire, verifies that he is the attorney for the plaintiff in the foregoing matter that he is authorized to take this verification on behalf of the plaintiff, that the facts set forth herein are true and correct to the best of his knowledge, information and belief. Attorney for Plaintiff verifies that the statements herein are made subject to the penalties of 18 Pa C. S. Sec. 4904 relating to unsworn falsification to authorities. KIVITZ & KIVITZ, P.C. JqK~cruire Attorney for Plaintiff u -_.- ,.-." ~ .-- , l ~f, . . All that certain lot or piece of g,round with the buildings and improvements thereon erected, being known as 530 NORTH PITT STREET, CARLISLE, PA ~70~). C~BERLAND county), and being further described on that certain Deed dated 5/).9/98 and recorded on 6/4/98 in the Office of the Recorder of Deeds in CUMBERLAND county in Deed Book No.' 178, Page 678. ' , parcel NO. 095 LEGAL DESCRIPTION Tax Map No. 06-Z0-~798 BEING knOwn as 538 NORTH PITT STREET, CARLISLE, PA 17013. &/j)" j-t~ '.<^; ,- .."~- d '-":'i.'.,'<'":''' , >,.",-:~~,,-, ...... L J ~1IilllIJI1iIlilIIiiiIIii1WlUl~1 .~...~- 1:<Il;w_~'"' ~~, ",,,.- :!fl ~, , .~~ ->> _l.l I ~.,-.. . ~' . ~ ~ ~ ~ ~ ,1 CA ~ , I ~ ~ Cr\ ~ ~I (;\ 0 0 ,C) C 0 -n ~ (j \ t\ ~~~'" (- :-:j ~ """() rJJ }::'''' :~lfg \ mr7"! .:J= " z:n f',} ::Sd , \. ze ~:i~ co g~~ ~C1 --u zQ ~ 7):0 ~ .,..("') 5>u '-3 (51"1'1 C ~ ~ .:!l '::"D ,'-' '-< . . . . SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00541 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND G E CAPITAL MORTGAGE SERVICES VS OLEWEILER BART ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry fOT the within named defendant, DEFENDANT OLEWEILER BART but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT IN EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , OLEWEILER BART PROPERTY IS VACANT Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 4.00 5.00 10.00 .00 37.00 So ans~~ R.~as Kline Sheriff of Cumberland County KIVITZ & KIVITZ 02/15/2000 Sworn and subscribed to before me this .;l9E: day of :f~ ;Lenrv A. D. ~Q~,~. P ot onotary - -. L~~_ SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00541 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND G E CAPITAL MORTGAGE SERVICES VS OLEWEILER BART ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT WAGNER MARGARET but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , WAGNER MARGARET PROPERTY IS VACANT Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 6.00 .00 5.00 10.00 .00 21.00 SO~~ R. homas Kline Sheriff of Cumberland County KIVITZ & KIVITZ 02/15/2000 Sworn and subscribed to before me this .18' ~ day of :1.d~ ~A.D. ~o. ~,JL!}u.,~ P t onotary ~u~ "- SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00541 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND G E CAPITAL MORTGAGE SERVICES VS OLEWEILER BART ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT DOE JOHN but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , DOE JOHN " PROPERTY IS VACANT Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 6.00 .00 5.00 10.00 .00 21.00 Co an"~~ R. ds Klin ' Sheriff of Cumberland County KIVITZ & KIVITZ 02/15/2000 Sworn and subscribed to before me this ,;) yt!::- day of J~ cMruo A.D. ~-' O~,~, Pr t onotary ~, - "" ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00541 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND G E CAPITAL MORTGAGE SERVICES VS OLEWEILER BART ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT DOE JANE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTI CE , NOT FOUND , as to the within named DEFENDANT , DOE JANE PROPERTY IS VACANT Sheriff's Costs: Docketing NOT FOUND RETURN Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 so~~ R. homas Kli Sheriff of Cumberland County KIVITZ & KIVITZ 02/15/2000 Sworn and subscribed to before me this cw dj>- day of :!~ ;J.u-v-v A.D. ~-' Q ivuPtJ'.,,-, ~ P ot onotary , ~ "-"G,~hiIIIIiiIO~lItlliiliel.!;Wll~6l' ~ ~'" -. ........ ~ ~",-'- -~ 'II . KIVITZ & KIVITZ, P.C. BY: Jay E.Kivitz, Esquire ID# 26769 7901 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0308 (215) 549-2525 G.E. CAPITAL MORTGAGE SERVICES, INC.: 4680 Hallmark Parkway San Bernardino, CA 92407 Attorney for Plaintiff COURT OF COMMON, PLEAS CUMBERLAND COUNTY PLAINTIFF v. NO. dCU5 - c5L/1 e;J BART OLEWEILER AND MARGARET WAGNER AND John Doe, Jane Doe, tenant/occ~~iers: 538 N. Pitt street, Apt 2, 2 fl.: Carlisle, PA 17013 DEFENDANTS NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE }\cTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE, PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA (717) 240-6200 , ~ '.~"...~,..> -~J' ~.. ~ " ~.-,=-,'.. - 'd_' ,"""'"', - ..~~"' II ... 1. principal 92407. Plaintiff is G.E. .offices, at 4680 Capi tal Martgage Services, Inc., with Hallmark Parkway, San Bernardina, CA 2. Defendants are Bart Oleweiler and Margaret Wagner and Jahn Dae, Jane Dae, tenant/accupiers, wha reside at 538 N. Pitt Street, Apt 2, 2nd flaar, Carlisle, PA 17013. 3.' Plaintiff is the recard .owner .of 538 N. Pitt Street, Carlisle, PA the premises where defendants reside, having acquired title pursuant ta a sheriff's sale duly held in Cumberland Caunty an December 8, 1999. The sheriff sale was autharized under the terms .of a fareclasure actian and judgment entered therean in the Caurt .of Carnman Pleas .of Cumberland Caunty. See capy .of legal descriptian attached hereta as Exhibit "A". 4. Plaintiff is the .owner .of said 538 N. Pitt Street, Carlisle, PA and lS entitled ta passessian thereaf. The defendants Bart Oleweiler and Margaret Wagner and Jahn Dae, Jane Dae, tenant/accupiers, are still in passes sian .of said premises withaut right, and sa far as the plaintiff is in farmed, withaut claim .of title. 5. Plaintiff, has demanded passessian .of the said premises fram the said defendants wha have refused ta deliver up passession .of same. WHEREFORE, Plaintiff demands judgement far passessian .of the faresaid premises. KIVITZ & KIVITZ, P.C. T~r.UE (;,D~)''l \/, rU:~0Ri) In Testimony wherEOf, I hc:r3 unto set my hand and the soal of said Ccurt at Ca'lisie, Pa. This..;),<l.."",day d~...m'''', 9?&.lX' ....,.,.".".~~."'..""~~;~"..... <, -,--,..-,," ~- '-'- .- -.' '-,~ ..--,~ .:",<- ~~ - - '~'" - .~ ~~"' """"""'....~.._~~c II ... VERIFICATION Jay E. Kivitz, Esquire, verifies that he is the attorney for the plaintiff in the foregoing matter that he is authorized to take this verification on behalf of the plaintiff, that the facts set forth herein are true and correct to the best of his knowledge, information and belief. Attorney for Plaintiff verifies that the statements herein are made subject to the penalties of 18 Pa C. S. Sec. 4904 relating to unsworn falsification to authorities. KIVITZ & KIVITZ, P.C. ~G~ J 'E. Kivitz, squire Attorney for Plaintiff . .. ,.'~.~. " ~ ~..IIiJij" , I ~,_'i ~ All that certain lot or piece of g,round with the buildings and improvements thereon erected" being known as 530 NORTH PITT STREET, CARLISLE, PA~70~],CUMBERLAND county), and being further described oh that certain Deed dated 5I~9/98 andrecorded on 6(4/96 in the office of the Recorder of Deeds in CUMBERLAND county in Deed Book No.li8, Page 678. " parcel NO. 095 LEGAL DESCRIPTION TaX Map No. 06-20-1796 BEING known as 536NORTll PITT STREET, CARLISLE, PA 17013- ~~h, J-td . , - 3!I!IIIII' \. Of"J:!cr n~ 1)1,1:","'- -, tIE: ~~~,:,: .. " ~'- ef:, ",.:c' 'i)," Jail 31 IJ/" , ,. hit, r ',' ~',I ',_;: , "~~..~"" - C' 3HEt?!,;:r- .~ '( 2 00 PH 'oa ),.',,,_1' ., .' i'-', 1-] !J~ _ !~Ifj~_. ~ """!ll'9!'~!iIilfl>f.",,,+~~~~ ~ ~ '~ ~~~lIl!lf_':_j '.' ~ ..we;: _I ." ~~ , - . ~ , , ~,~~- KIVITZ & KIVITZ, P,C. BY: Jay E. Kivitz, Esquire ID# 26.769 790.1 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0.30.8 (215) 549,-2525 G.E, CAPITAL ,MORTGAGE SERVICES, INC.: 4680., Hallmark Parkway San Bernardino, CA 9240.7 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF v. NO . cXl2:J ~ :5'11 tuJ. BART ,OLEWElLER AND MARGARETW'AGNER AND John Doe, Jane Doe, tenant/occupiers: 538, N. . Pitt street, Apt 2, 2'" fl. : Carlisle, PA 170.13 DEFENDANTS 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED W.ITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY, LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE,PA (717) 240-6200 ~..." ..""~ " - - ~ I"'~ 1. principal 9240.7. Plaintiff is G.E. offices at 4680. Capi tal Mortgage Services, Inc., wi th Hallmark Parkway, San Bernardino, CA 2. Defendants are Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers,who reside at 538 N. Pitt street, Apt 2, 2nd floor, Carlisle, PA 170.13. 3. Plaintiff is the record owner of 538 N. Pitt street, Carlisle, PA the premises where defendants reside, having acquired title pursuant to a sheriff's sale duly held in Cumberland County on December 8, 1999. The sheriff sale' was authorized under the terms of a foreclosure action and judgroententered thereon in the Court of Common Pleas of Cumberland County. See copy of legal description attached hereto as Exhibit "A". 4. Plaintiff is the owner of said 538 N. Pitt Street, Carlisle, FA and is entitled to possession thereof. The defendants Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, are still in possession of said premises without right, and so far as the plaintiff is informed, without claim of title. 5. Plaintiff has demanded possession of the said premises from the said defendants who have refused to deliver up possession of same. WHEREFORE, Plainti,ff demands judgement for possession of the foresaid premises. KIVITZ & KIVITZ, P.C. J At TiRiJE con fllOM RECORD In TEstimony 'P:t";':J:' : here unto set my hand and 1hc seed or SJ:'~ ...1-.-, j '- f C: <:2,l:, ;JJ, This Q?;;? .., da'! c~........, ~ ....,',::,.:',~.,"..~~;r~~ , ~~ ...... ~..~- ~, 'l1I ' . 1 , VERIFICATION .:Jay E. Kivitz, Esquire, verifies that he is the attorney for the plaintiff in the foregoing matter that he is authorized to take this verification on behalf of the plaintiff, that the facts set forth herein are true and correct to the best of his knowledge, information and belief. Attorney for Plaintiff verifies that the statements herein are made subject to the penalties of 18 Pa C. S. Sec. 490.4 relating to unsworn falsification to authorities. KIVITZ & KIVITZ, P.C. ~.G~ J "E. Kivitz, ' squire Attorney for Plaintiff - o LEGAL DESCRIPTION 'All that certain l'ot. or piece .of g,round with the buildings' and ,improvements thereon erected; being known' as 530 .NORTH PITT STREET, CARLISLE,!?A17Q13, CUMBERLAND County), and being further described on that certain Deed dated "5/.19/98 and 'recorded on 6/4/9B in the Office of the Record..r of Deeds ,in CUMBERLAND County in Deed Book No. 17B, 'Page 678.' Parcel No. 095 ,Tax Map No. 06-20-1.798 BEING known as 538,NORTH PITT STREET, CARLISLE, PA 17013, C~~. J-j-d , , .: '. . '\ ~ ~, ~" ,/-,:0'9 ,,( c, " r pi!l!IIIII', t",_~ - €NflFT~:'-E ::~'F r",i '~~ r~ J:." - '- :~,]4E~!,!F'lF , -:(' J~1l31 327 FN 'IJQ PEiL ,',; l i i\ - .. ~~ w,_~_~~ "' -~. ~~ .~-~. ~ -.. .,- '. ~~', ", '~~,--', \ 'o;.,:;(;!.) , ':: '_ 'l~ ,'i',' , ,. ,,' ,," !IlQIIl!l1lllfl!~mw~llW~,,., ~ ~ ""~,~",~-~~"-,~__1JI!Ift{IIl m~~ KlVITZ & KIVITZ, P.C. BY: Jay E. Kivitz, Esquire 10# 26769 7901 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0308 (215) 549-2525 G.E. CAPITAL MORTGAGE SERV~CES, INC.: 4680. Hallmark Parkway San Bernardino, CA 92407 Attorney for P,laintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF v. NO . <:Xa> ~ .541 &J BART OLEWEILER AND MARGARET WAGNER AND John Doe, Jane Doe, tenant/occupiers: 538 N. Pitt Street, Apt 2, 2"'0 fl. Carlisle, PA 17013 DEFENDANTS 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL' TO DO SO THE ,CASE MAY. PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED' AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEFnREQUESTED BY THE PLAINTIFF. YOU MAY, LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. I YOU SHOULD TAKE THIS PAPER TO YOUK LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAl'lYER REFERRAL SERVICE COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA (717) 240-6200 '- , _1:_ ~ ~ '" ~- ~-""' ,,~ '. 1. principal 9240.7. Plaintiff is G.E. offices at' 4680. Capi tal Mortgage Services, Inc., with Hallmark Parkway, San Bernardino, CA 2. Defendants are Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, who reside at 538 N. Pitt Street, Apt 2, 2nd floor, Carlisle, PA 170.13. 3. Plaintiff is the record owner of 538 N. Pitt Street, Carlisle, PA the premises where ,defendants reside, having acquired title pursuant to a sheriff's sale duly held in Cumberland County on December 8, 1999. The sheriff sale was authorized under the terms of a foreclosure action and judgment entered thereon in the Court of Common Pleas of Cumberland County. See copy of legal description attached hereto as Exhibit nAn. 4. Plaintiff is the owner of said 538 N. Pitt Street, Carlisle, PA and is entitled to possession thereof. The defendants Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, are still in possession of said premises without right, and so far as the plaintiff is informed, without claim of title. 5. Plaintiff has demanded possession of the said premises from the said defendants who have refused to deliver up possession of same. WHEREFORE, Plaintiff demands judgement for possession of the foresaid premises. KIVITZ & KIVITZ, P.C. ~~' J "E K~ITZ,- Esquire At orney for Plalntlff :"',,',_-,;,0_ ~ ~~ "~~'~'Ili~ ..~~ - - ""-~"" ~ ." " VERIFICATION Jay E. Kivitz, Esquire, verifies that he is the attorney for the plaintiff in the foregoing matter that he is authorized to take this verification on behalf of the plaintiff, that the facts set forth herein are true and correct to the best of his knowledge, information and belief. Attorney for Plaintiff verifies that the statements herein are made subject to the penalties of 18 Pa C. S. Sec. 490.4 relating to unsworn falsification to authorities. ,KIVITZ & KIVITZ, P.C. ~v~ J E Kivitz, squire Attorney for Plaintiff I I II Ii II I I I II II '".-': -,"'/-'''?\/ Fr~<-"-/: .. "', In .\" I h.:.(:~; urr:o ::;i.:;i ;~;':Y hand and the seai or CCJ:'T at Carlisle, Pa. This..a'S':'.... day oy~..........., ~ ..............,~""'~~~yW ,,-,'<"'..-':;,1',;,-.,,' , ,,' -~" -. :;, :-: ,~, " - ~~,....._..~...... u ~ ~~.,,,,--,"",,, ,." - - ,,~-, ~~ _.~ .l. ..~~ I . A~~, that certain ~ot ,or piece of g.round with the bui~dings and improvements thereon erected, being knOWn as 530 NORTH pITT STREET, CARLISLE, PAnOU, CtMBERLAND county), and being further described on that, certain Deed dated 5/1.9/98 and recorded on 6/4/98 in the office of the Recorder of Deeds in CUMBERLAND county in Deed Book No. 178, Page 678. LEGAL DESCRIPTION parce~ NO; 095 Tax Map No. 06-20-1798 BEING known as 538 NORTH PITT STREET, CARLISLE, PA 17013. '~?rj"j-t ~ . " .- ~,~, "' "'_';'.;r__' . . ~' ~ ~ , . .. '~. 0:r17'\';,~ t: 1-' r T ,t:r ',' . '-' ,~ jal\ 'j\ 3 21 11'\ 'uG. C'E ::",:] '1) \ 'I,ll''''' ~-~ ,...~ ~ ~ ""~" ~',O"', =~~ '~~ffli' - ~ ~ ~ ~ ...~II;M~':'''''1~~7''~_~J""",., ".' 'j' ~""'-"''''''~''''~'1'~''~~''"~ -" ~"-'- - ~~ ~-~." liWa~'~~ ~ , ~" .' . KIVITZ& KIVITZ, P.C. BY: Jay E. Kivitz, E",quire ID# 26769 790.1 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0.30.8 (215), 549-2525 G. E. CAPITAL, MORTGAGE SERVICES, INC.: 4680. Hallmark Parkway San Bernardino, CA 9240.7 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF v. NO. d~ - 5tj/ ~ fVill.T OLEWElLERAND MARGARET WAGNER AND Johri Doe, Jane Doe, tenant/occupiers: 538 N. Pitt Street, Apt 2, 2"- fl. : Carlisle, PA 170.13 DEFENDANTS 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED, THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED W.ITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA (717) 240-6200 ~~I"""-~ .. "- ,." ~"~""""lIil ~ . .....1,,,.,, 1. principal 9240.7. Plaintiff is G.E. offices at 4680. Capi tal Mortgage Services, Inc., wi th Hallmark Parkway, San Bernardino, CA 2. Defendants are Bart Oleweiler and Margaret Wagner and John Doe, Jane Doe, tenant/occupiers, who reside at 538 N. Pitt Street, Apt 2, 2nd floor, Carlisle, PA 170.13. 3. Plaintiff is the record owner of 538 N. Pitt street, Carlisle, PA the premises where defendants reside, having acquired title pursuant to a sheriff's sale duly held in Cumberland County on December 8, 1999. The sheriff sale was authorized under the terms of a foreclosure action and judgment entered thereon in the Court of Common Pleas, of Cumberland County. See copy of legal description attached hereto as Exhibit nAn. 4. Plaintiff is the owner of said 538N. Pitt Street, Carlisle, PA and is entitled to possession thereof. The defendants Bart Oleweiler and Ma'rgaret Wagner and John Doe, Jane Doe, tenant/occupiers, are still in possession of said premises without right, and so far as the plaintiff is informed, without claim of title. 5. Plaintiff has demanded possession of the said premises from the said defendants who have refused to deliver up possession of same. WHEREFORE, Plaintiff demands judgement for possession of the iforesaid premises. KIVITZ & KIVITZ, P.C. T"nr.: C' ;,."t~.\A rl'i7rnl(>1') N\~'t;:. '~_, f,'.,,_' .n ,"''i",'~,_'"''')~_~''' In Testimonv vjh~-:r~;cf, r h_ {,"> untr) set'my hand and the ssal of sa:d CCj:'''i 5t C::;::-510" Pa. This 'u~u, , CaY ......u...~w o~uuuu, ~ ..khMa;u~ Prc'h-IVi;utary -"...;;.",.;."-:-,,,,, ~ "~"=_"""i~j~~ ~ -...'..--,....... ~- ~- .~11llli'i-,. VERIFICATION Jay E. Kivitz, Esquire, verifies that he is the attorney for the plaintiff in the foregoing matter that he is authorized to take this verification on behalf of the plaintiff, that the facts set forth herein are true and correct to the best of his knowledge, information and belief. Attorney for Plaintiff verifies that the statements herein are made subject to the penalties of 18 Pa C. S. Sec. 490.4 relating to unsworn falsification to authorities. KIVITZ & KIVITZ, P.C. ~rG~ J E. Kivitz, squire Attorney for Plaintiff [_; '''J~~ "d,,:_.--,~ ' . ~.~~ WiltII/lOl5i.~~ ~~ . . , LEGAL DESCRIPTION All that certain lot or piece of g-round with the buildings and improvements thereon erected, being known as 530 NORTIt PITT STREET, 'CARLISLE, PA 17013, CtJto1BERLAND county) , and being further described' on that certain Deed dated 5/19/98 andrecorded on 6/4198 in the Office of ,the" Recorder of Deeds in CUMBERLAND county' in Deed Bool< No. ~78, page' 678. ' parcel NO. 095 TaX l'lap No. 06-20-~798 BEING known as 538 NORTa PITT STREET, CARLISLE, PA ~7013- &~h,jj- 4 - L~."_, ,.j !"i I", " " :;' ~ ~, ~~:" " . !~~ > , ~ ~- , - ^'fO"'llC'f OFFF'i:' i)r:- THi: :Jf ::1id G!':'>:" l - '-,'cf JAW 31 3 27 PrI 'on D t"- i-!" ;~' '-0" ! C. d I ~ ..; 1 , , 1.,1 ',' .1 ., ;' r\ ,. ". ~ ,"""""'" , ~ ~ 1Il\IIM~~~~,. ~, . ~-^"'~'~~~~'"~r'T"'" ."'~ ~i ..'''," ~ ,~'...""""", KIVITZ & KIVITZ, P.C. BY: JAY E. KIVITZ, ESQUIRE LD.# 26769 790.1 Ogontz Avenue P.O. Box 27368 Philadelphia, PA 19118-0.30.8 (215) 549-2525 ATTORNEY FOR PLAINTIFF G.E. Capital Mortgage Services, Inc.:COURT OF COMMON PLEAS CUMBERLAND COUNTY V. Bart Oleweiler and Margaret Wagner John Doe, Jane Doe, tenant/occupier No.: 2000-541 PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the Complaint in the above captioned matter. KIVITZ & KIVITZ, P. C. ~,G(~ ' E KIVITZ, SQUIRE Attorney for Plaintiff , . ~;j ! II :! il ,I I' \1 " ii I ':1 m !j ,1 ;,1 :~ 'I I'] I; II :j 'I 1 , 1 j i 1 1 ""IV~~'r'I-'t. ij~.fII" ..;....~~"........_~_i'I ~~. ,:"'";E~ T~''::: _- .-~S ;.:~." , ~,' ," - ,-" '""_,..,, o,o~, '-" ~ .., ~<~iiJlJi1 ,'",."'"'" "'''j -"~- - , _ 0' .-" '&~ .,;:. ;:1"2 lUll ;\", ,." ~.~ N ~' :.> ,:_":,,,. '!JL'"C ,:" ~~ :'i.i'8i ';:"s.b.s-.:.. ~,- ,--' '"" -" .......:~ ~.... 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