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LAW OFFICES OF GREGORY JA V ARDIAN
BY: GREGORY JA V ARDIAN, ESQUIRE
ATTORNEY LD, #55669
44 Second Street Pike, Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
LA SALLE NATIONAL BANK, AS
TRUSTEE, ET AL
135 SOUTH LA SALLE STREET
CHICAGO, IL 60603
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No, tro . 3oH' ~ I~
vs.
RAYMOND C, MARDIS
AND OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, P A 17070
Defendant( s)
COMPLAINT - CIVIL ACTION
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 attorney and filing in
writing with the court your defense 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 TillS NOTICE TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
717-249-3166
,
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************************************************************************
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
************************************************************************
1. This is an attempt to collect a debt and any information obtained will be used for
the purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices,
3, If you notify our offices in writing within thirty (30) days ofreceipt ofthis notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification ofthe debt or copy of the judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4, If you notify our offices in writing within thirty (30) days of receipt ofthis notice,
our offices will provide you with the name and address of the original creditor, if
different from the current creditor.
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JURY TRIAL WAIVED
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
Identification No. 55669
44 SECOND STREET PIKE
SUITE 203
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
LASALLE NATIONAL BANK, AS
TRUSTEE ET AL
135 South LaSalle Street
Chicago, IL 60603
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
COMPLAINT IN EJECTMENT
RAYMOND C. MARDIS
and OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, PA
No.
o-v. 3Nf Cw:J ..,-~
17070
COMPLAINT
1. Plaintiff, LaSalle National Bank, As Trustee et al
referred to as 'Plaintiff") is a Corporation conducting business
under the laws of the Commonwealth of Pennsylvania and brings this
action against Raymond C. Mardis and Occupants (hereinafter
referred to as nDefendants").
2. Defendant(s) is/are individual(s), presently
residing and occupying the premises at (504 9th Street,
New Cumberland, PA 17070) more fully described in the legal
description as Exhibit nA".
- I ~
3. plaintiff is the owner of the aforesaid premises,
which real estate is fully described in Exhibit "A".
4. Plaintiff is the record owner of the premises where
defendants reside, having completed a Sheriff sale on said
premises on March 1, 2000.
5. Defendants have no valid legal right to possession
and title to the premises.
6. Plaintiff claims the right to possession of the
premises to the exclusion of the Defendants,
WHEREFORE, plaintiff, requests that this Court enter
judgment for Possession against Defendants, Raymond C. Mardis and
Occupants, with respect to the aforesaid
premises at 504 9th Street, New Cumberland, PA 17070.
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THE LAW
Offices of
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44 Second Street Pike
Suite 203
Southampton, PA 18966
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GREGORY JA VARDIAN
April 6, 2000
Raymond C. Mardis
and Occupants
504 9th Street
New Cumberland, P A 17070
RE: 504 9th Street
New Cumberland, P A 17070
TO WHOM IT MAY CONCERN:
Phone: (215) 942-9690
Fax: (215) 942-9695
Philadelphia Office
2021 Locust Street
2"' Floor Suite
Philadelphia, P A 19103
Please reply to
Southampton Office
Please be advised that this office represents LaSalle National Bank, who was the
purchaser of the above referenced premises at the mortgage foreclosure sheriff sale on
March 1,2000.
Kindly vacate the premises within thirty (30) days ofthe date of this letter. If you
fail to vacate the premises, my client has instructed me to take all legal action necessary
to recover possession,
GJ/lms
Cc: Kate De Zago (Superior Bank)
Loan No. 660996604
Very Truly Yours,
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ALL THA T CERTAIN tract or parcel of land and premises, situate, lying and being in the
Borough of New Cumberland in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the southerly line of Ninth Street (50 feet wide), said point being the
dividing line between Lots Nos.12 and 13, Block "F", of the hereinafter mentioned Plan of Lots,
said point also being one hundred ninety-two and ninety-five hundredths (192.95) feet measured
along the south side of Ninth Street from the west line of Sharon Street; thence southeastwardly,
along the aforementioned dividing line, a distance of one hundred eighteen (118) feet to land
formerly of C,C, Davis; thence Southwestwardly, along said Davis Land, a distance of eighty-
two (82) feet to Lot No, II, Block "F", on said Plan; thence northwestwardly, along said Lot No.
II, Block "F", a distance of one hundred (118) feet to the southerly line of Ninth Street; thence
northeastwardly along the southern line of Ninth Street, a distance of eighty-two (82) feet to Lot
No, 13, Block "F", the place of beginning.
Being Lot No. 12, Block "F", in the Plan of Simpson Terrace, part of Addition No, 1 to Forrest
Hills,
Having thereon erected a single brick dwelling house known as No. 504 Ninth Street, New
Cumberland, Pennsylvania,
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'1999 11:08
2159424841
PAGE l'lG
VERIFICA nON
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best ofhislher knowledge, information and belief,
The undersigned understands that the statements therein are made subject to the penalties
of 18 Pa. C. S. Section 4904, relating to unSWorn falsification to authorities,
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-03088 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
LASALLE NATIONAL BANK
VS
MARDIS RAYMOND C
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
MARDIS RAYMOND C
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - EJECTMENT
NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, MARDIS RAYMOND C
DEFT. NO LONGER RESIDES AT ADDRESS STATED,
PROPERTY IS VACANT.
Sheriff's Costs:
Docketing
Service
NOT FOUND RETURN
Surcharge
18.00
11.16
5.00
10,00
.00
44,16
~~
R. 'Thomas Kline .'
Sheriff of Cumberland County
GREGORY JAVARDIAN
06/09/2000
Sworn and subscribed to before me
this alo i:- day of y.,o..<---
2rnro A.P.
Grt<- f2 'n,jo, 'J II ~:r-
Pro onotary
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LAW OFFICES OF GREGORY JA V ARDIAN
BY: GREGORY JAVARDIAN, ESQUIRE
ATTORNEY LD, #55669
44 Second Street Pike, Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
LA SALLE NATIONAL BANK, AS
TRUSTEE, ET AL
135 SOUTH LA SALLE STREET
CHICAGO, IL 60603
Plaintiff
COURT OF COMMON PLEAS
TRlAL DIVISION
CUMBERLAND COUNTY
No. (HJ - 30 r f ~ .- b--....
vs,
RAYMOND C. MARDIS
AND OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, P A 17070
Defendant( s)
COMPLAINT - CIVIL ACTION
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 attorney and filing in
writing with the court your defense 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 TillS NOTICE TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
717-249-3166
TRVE COPY FROM REOORO
III T astlmony whelllOf, I here unto set my MIlO
a'1d the seal of said Court at Cirlisle. 1Pa.
r.hiS ~..~ c1 bp" ~ . DA;;V
. ProthonOtary
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************************************************************************
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
************************************************************************
I, This is an attempt to collect a debt and any information obtained will be used for
the purpose,
2, Unless you dispute the validity of this debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices,
3, If you notify our offices in writing within thirty (30) days of receipt of this notice
. that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy ofthe judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4, If you notify our offices in writing within thirty (30) days of receipt of this notice,
our offices will provide you with the name and address ofthe original creditor, if
different from the current creditor.
,
,
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.~
.
JURY TRIAL WAIVED
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
Identification No. 55669
44 SECOND STREET PIKE
SUITE 203
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
LASALLE NATIONAL BANK, AS
TRUSTEE ET AL
135 South LaSalle Street
Chicago, IL 60603
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
COMPLAINT IN EJECTMENT
RAYMOND C. MARDIS
and OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, PA 17070
No. o-v - .JOn CW-J. I ~
COMPLAINT
1. Plaintiff, LaSalle National Bank, As Trustee et al
referred to as 'Plaintiff") is a Corporation conducting business
under the laws of the Commonwealth of Pennsylvania and brings this
action against Raymond C. Mardis and Occupants (hereinafter
referred to as "Defendants").
2. Defendant(s) is/are individual(s), presently
residing and occupying the premises at (504 9th Street,
New Cumberland, PA 17070) more fully described in the legal
description as Exhibit "A".
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3. Plaintiff is the owner of the aforesaid premises,
which real estate is fully described in Exhibit "A".
4. Plaintiff is the record owner of the premises where
defendants reside, having completed a Sheriff sale on said
premises on March 1, 2000.
5. Defendants have no valid legal right to possession
and title to the premises.
6. Plaintiff claims the right to possession of the
premises to the exclusion of the Defendants.
WHEREFORE, plaintiff, requests that this Court enter
judgment for Possession against Defendants, Raymond C. Mardis and
Occupants, with respect to the aforesaid
premises at 504 9th Street, New Cumberland, PA 17070.
ARDIAN
r Plaintiff
,
THE LAW
Offices of
44 Second Street Pike
Suite 203
Southampton, PA 18966
GREGORY JA VARDIAN
Phone: (215) 942-9690
Fax: (215) 942-9695
April 6, 2000
Philadelphia Office
2021 Locust Street
2"' Floor Suite
Philadelphia, P A 19103
Raymond C, Mardis
and Occupants
504 9th Street
New Cumberland, P A 17070
Please reply to
Southampton Office
RE: 504 9th Street
New Cumberland, P A 17070
TO WHOM IT MAY CONCERN:
Please be advised that this office represents LaSalle National Bank, who was the
purchaser of the above referenced premises at the mortgage foreclosure sheriff sale on
March I, 2000.
Kindly vacate the premises within thirty (30) days of the date of this letter. If you
fail to vacate the premises, my client has instructed me to take aU legal action necessary
to recover possession.
Very Truly Yours,
~
GJ/hns
Cc: Kate De Zago (Superior Bank)
Loan No. 660996604
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ALL THAT CERTAIN tract or parcel of/and and premises, situate, lying and being in the
Borough of New Cumberland in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the southerly line of Ninth Street (50 feet wide), said point being the
dividing line between Lots Nos.l2 and 13, Block "F", of the hereinafter mentioned Plan of Lots,
said point also being one hundred ninety-two and ninety-five hundredths (192.95) feet measured
along the south side of Ninth Street from the west line of Sharon Street; thence southeastwardly,
along the aforementioned dividing line, a distance of one hundred eighteen (l18) feet to land
formerly ofC,C. Davis; thence Southwestwardly, along said Davis Land, a distance of eighty-
two (82) feet to Lot No. II, Block "F", on said Plan; thence northwestwardly, along said Lot No.
II, Block "F", a distance of one hundred (l18) feet to the southerly line of Ninth Street; thence
northeastwardly along the southern line of Ninth Street, a distance of eighty-two (82) feet to Lot
No, 13, Block "F", the place of beginning,
Being Lot No, 12, Block "F", in the Plan of Simpson Terrace, part of Addition No, I to Forrest
Hills,
Having thereon erected a single brick dwelling house known as No, 504 Ninth Street, New
Cumberland, Pennsylvania,
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'1'3'3'3 11:08
215'3424841
PAGE 06
"
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are We and correct to the best ofhislher knowledge, information and belief.
The undersigned understands that the statements therein are made subject to the penalties
of 18 Pa. C.. S. Section 4904, relating to unsworn falsification to authorities.
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LAW OFFICES OF GREGORY JA V ARDIAN
BY: GREGORY JA V ARDIAN, ESQUIRE
ATTORNEY I.D, #55669
44 Second Street Pike, Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
LA SALLE NATIONAL BANK, AS
TRUSTEE, ET AL
135 SOUTH LA SALLE STREET
CHICAGO, IL 60603
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No, uo- 3tJff ~ 7.u--.
vs,
RAYMOND C, MARDIS
AND OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, P A 17070
Defendant( s)
COMPLAINT - CTVTL ACTION
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 attorney and filing in
writing with the court your defense 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 TillS NOTICE TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
lRue.COPYFROM RECORD
In TestlrJlony whereof, Iherellnto ii6rmy MIlO
and tf1eseal of saki Court at Carllsle, PI.
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This IE; day oI~.~." -:;--
~' --r~ /J__--.!... -I, A-f~
Prothonotary
=~"~lW; -
,
~o
~~ """'"'
,
************************************************************************
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
************************************************************************
I, This is an attempt to collect a debt and any information obtained will be used for
the purpose,
2. Unless you dispute the validity ofthis debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices,
3, If you notify our offices in writing within thirty (30) days of receipt of this notice
. that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4, If you notify our offices in writing within thirty (30) days ofreceipt of this notice,
our offices will provide you with the name and address ofthe original creditor, if
different from the current creditor,
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,
JURY TRIAL WAIVED
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
Identification No. 55669
44 SECOND STREET PIKE
SUITE 203
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
LASALLE NATIONAL BANK, AS
TRUSTEE ET AL
135 South LaSalle Street
Chicago, IL 60603
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
COMPLAINT IN EJECTMENT
RAYMOND C. MARDIS
and OCCUPANTS
504 9TH STREET
NEW CUMBERLAND, PA 17070
No. IHJ- 3Dif'? ~ 1J.k--
COMPLAINT
1. plaintiff, LaSalle National Bank, As Trustee et al
referred to as 'Plaintiff") is a Corporation conducting business
under the laws of the Commonwealth of Pennsylvania and brings this
action against Raymond C. Mardis and Occupants (hereinafter
referred to as "Defendants").
2. Defendant{s) is/are individual{s), presently
residing and occupying the premises at (504 9th Street,
New Cumberland, PA 17070) more fully described in the legal
description as Exhibit "A".
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3. Plaintiff is the owner of the aforesaid premises,
which real estate is fully described in Exhibit "A".
4. Plaintiff is the record owner of the premises where
defendants reside, having completed a Sheriff sale on said
premises on March 1, 2000,
5. Defendants have no valid legal right to possession
and title to the premises.
6, plaintiff claims the right to possession of the
premises to the exclusion of the Defendants.
WHEREFORE, plaintiff, requests that this Court enter
judgment for Possession against Defendants, Raymond C. Mardis and
Occupants, with respect to the aforesaid
premises at 504 9th Street, New Cumberland, PA 17070.
,
THE LAW
Offices of
44 Second Street Pike
Suite 203
Southampton, PA 18966
GREGORY JA VARDIAN
Phone: (215) 942-9690
Fax: (215) 942-9695
April 6, 2000
Philadelphia Office
2021 Locust Street
2nd Floor Suite
Philadelphia, PA 19103
Raymond C. Mardis
and Occupants
504 9th Street
New Cumberland, P A 17070
Please reply to
Southampton Office
'RE: 504 9th Street
New Cumberland, P A 17070
TO WHOM IT MAY CONCERN:
Please be advised that this office represents LaSalle National Bank, who was the
purchaser of the above referenced premises at the mortgage foreclosure sheriff sale on
March I, 2000.
Kindly vacate the premises within thirty (30) days of the date of this letter. If you
fail to vacate the premises, my client has instructed me to take all legal action necessary
to recover possession.
Very Truly Yours,
!p_m
-;L
GJ/lms
Cc: Kate De Zago (Superior Bank)
Loan No. 660996604
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ALL THAT CERTAIN tract or parcel of/and and premises, situate, lying and being in 1he
Borough of New Cumberland in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the southerly line of Ninth Street (50 feet wide), said point being the
dividing line between Lots Nos.12 and 13, Block "F", of the hereinafter mentioned Plan of Lots,
said point also being one hundred ninety-two and ninety-five hundredths (192.95) feet measured
along the south side of Ninth Street from the west line of Sharon Street; thence southeastwardly,
along the aforementioned dividing line, a distance of one hundred eighteen (118) feet to land
formerly ofC,C, Davis; thence Southwestwardly, along said Davis Land, a distance of eighty-
two (82) feet to Lot No. II, Block "F", on said Plan; thence northwestwardly, along said Lot No,
II, Block "F", a distance of one hundred (118) feet to the southerly line of Ninth Street; thence
northeastwardly along the southern line of Ninth Street, a distance of eighty-two (82) feet to Lot
No. 13, Block "F", the place of beginning,
Being Lot No. 12, Block "F", in the Plan of Simpson Terrace, part of Addition No, I to Forrest
Hills.
Having thereon erected a single brick dwelling house known as No, 504 Ninth Street, New
Cumberland, Pennsylvania,
,
,.
~w_ _' ~ ,I",
,".
'lNf'
'1999 11:e8
2159424841
PAGE eG
VERIFICA nON
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of hislher knowledge, information and belief,
The undersigned understands that the statements therein are made subject to the penalties
of 18 Pa. C.. S. Section 4904, relating to unSWOrn falsification to authorities.
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LAW OFFICES OF GREGORY JA V ARDIAN
BY: GREGORY JA V ARDIAN, ESQUIRE
Identification No, 55669
44 Second Street Pike
Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
LASALLE NATIONAL BANK, AS
TRUSTEE ET AL
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
vs,
No, 00-3088 Civil Term
RAYMOND C, MARDIS
AND OCCUPANTS
Defendants
PRAECIPE TO DISMISS COMPLAINT WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly DISMISS the Complaint entered against defendants without Prejudice in the
above captioned case,
Date: January 12,2001
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