The URL can be used to link to this page

Home My WebLink About00-04658 .I GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. ACTION OF EJECTMENT HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF and OCCUPANT (S 1 9 Briarwood Court Camp Hill, PA 17011 Term No.CO -1It...fR (!L('>ll'T~ CIVIL ACTION: EJECTMENT Defendant(sl 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 the Complaint and notice are served, by entering a written appear~nce personally or by 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. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVInO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUE:RlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS) , 215-238-6300. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, CarliSle, PA 17013 (717) 243-9400 !: --,~,';-- .> COMPLAINT IN EJECTMENT 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, Plano, TX 75024-3632. 2 . GILSDORF, Defendants are HERBERT W. and OCCUPANT(S) . GILSDORF JR. and ROBYN L. 3. Plaintiff is the owner of premises 9 Briarwood Court, Camp Hill, PA 17011, a legal description of which is attached hereto. 4. Plaintiff became owner of said property by a Deed from the Sheriff of Cumberland County, which deed was lodged and settlement made with the Sheriff on June 9, 2000 (Abstract of Title) . 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The Defendants, HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF, and OCCUPANT(S), are occupying the same premises without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has repeatedly demanded possession of the said premises from the said Defendants, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the premises. ck, Jr., Esq. !'^ , . .~~~. VERIFICATION I, Joseph A. Goldbeck, Jr. as the Attorney of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ~f91 to , " #4442602 - GILSDORF JR. ,HERBERT W. '., - ~ - . -- -" - I ALL THAT CERT)'>lN tract or parcel of land and premises, situate, , lying and being in the Township of Hampden in the County of Cumber-land and Commonwealth of Pennsylvania. more particularly ~escribed as follows; .- .."",'--'~-'~ .~. BEGINNING at a point on the easterly line ,?f"Br~a~ood Court, a 50 foot wide right-of-way, which said point IS located and referenced 340.00 feet in a southerly direction from the intersection of the easterly line of Briarwood Court and the southerly line of Briarwood Lane, also a 50 foot wide right-of-way, and which said point of beginning is also located at the intersection of the easterly line of Briarwood Court and the dividing line between Lot Nos. 31 and 32 on the Plan of Lots known as Countryside, Section (AI; t~~nce, from said point of beginning along the dividing line between Lot Nos. 31 and 32, .north 74 degrees 37 minutes east, a distance of 118.0o"feet to a .point on the dividing line between'Lot Nos. 32. and 25; thence, from said,point along the dividing line between Lot Nos. 24, 25 and 32, sou~5degrees 23 minutes east, a distance of 85.06 feet to a polUit on the dividing line between Lot Nos. 32 and.J3; thence, from said point along the dividing line between Lot Nos, 32 and 33, south 68 degrees 30 minutes west, a distance of 93.82 feet to a point on a cul-de-sac which is located at the southerly end of Briarwood Court; thence, from said point along a curve to the left with a radius of 50,00 feet, a distance of 47.02 feet to a point on the easterly line of Briarwood Court; thence, from said point along t~~~~Aterly line of Briarwood Court, north 15 degrees 23 minutes west, a distance of 57,08 feet to a point, the point and place of BEGINNING. BEING Lot No. 32 on the Plan of Lots known as Countryside, Section (1\1, prepared by, Charles W. Junkins, Registered Surveyor, dated December 4, I973.and recorded. in the Office of the Recorder of Deeds of Cumberland Courty on !lpril II, 1974, in Plan Book 25, Page 6.. . HAVll;G thereon erected a dwelling hoose being known and numbered .as premises 9 Brfantood Court, Camp lIill, Pennsylvania. ~ '-~ ,~,,' . SUBJECT to covenants recorded on November 30, 1973 in the Office of the Recorder of. Deeds of Cumberland County in Misc. Book 207, Page 59 and to.all other covenants and restrictions of recoI:'d, UtIDBR AND SUBJECT nevertheless to an easement or right-ot-way to Pennsylvania Power and Light Company for the construction or erection of electrical utilities on the aforesaid property. either under or above ground. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 9 Briarwood Court, Camp Hill, PA 17011 SOLD as the property of HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF TAX PARCEL #10-19-1596-121 f - \ \ , - !t.m,,,,,,.,,l"~'" 1If,!~ ~ _"",~.};"Ui - -p [ ~ ~ ~ ~ ~ 8 ..0 ....... 6 D d <:) cc> (:) ~ 0 c:: L-::> -71 ~ I ~ L .~ -err) I nli"f\ c:: ,~F: -,""' "1:.l :Z:~j .",- f .... t/) zi"':- N 'Ti ~ r 0.2;: \D ,'!'~':,? ~ ~e '.:'<:) v T-'-' 1- ~C:' -,. (--',~:,! zc' -~ ,~C) >c.: N :-',-rn '..) Z -.; """ );..... =< :D ,'-' -< .,:1 J~,WU'll! ~~J,_~~,llf:i_.~l.)",I!Wl'tl~:~-'-\!'ffl_~~I~;mi~~1!I","",h",,,,"" - ~":'!l~~~,..,."",."... 'I', SHERIFF'S RETURN - NOT FOUND " CASE NO: 2000-04658 P COMMONWEALTH OF PENNSYLVANIA COuNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS GILSDORF HERBERT W JR 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 GILSDORF HERBERT W JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTI CE , NOT FOUND , as to the within named DEFENDANT , GILSDORF HERBERT W JR . PROPERTY AT: 9 BRIARWOOD COURT IS VACANT. Sheriff's Costs: Docketing Not Found Service Surcharge 6.00 5.00 9.30 10.00 .00 30.30 ~~ R. Thomas Kline Sheriff of Cumberland County GOLDBECK, MCCAFFERTY, MCKEEVER 07/27/2000 Sworn and subscribed to before me this /.4k day of ~ .u>-t.rD A.D. ~a~ P 0 honotary , ~ ~..".., 0 ,~ ,..- - ~"~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-04658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS GILSDORF HERBERT W JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: GILSDORF HERBERT W JR but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of GREEN serve the within COMPLAINT - EJECTMENT County, Pennsylvania, to On July 27th , 2000 , this office was in receipt of the attached return from GREEN Sheriff's Costs: Docketing Out of County Surcharge Dep. Green Co .00 9.00 .00 29.30 .00 38.30 07/27/2000 GOLDBECK, MCCAFFERTY, ~~~~- R. Thomas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this /4 day of (2,/,-,1-' c2b7U A. D . ~ (2 ~,/~" Prothonota y "~ - .~, ,,^ SHERIFF'S RETURN - REGULAR CASE NO: 2000-04658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS GILSDORF HERBERT W JR ET AL JACOB BAKER , Sheriff or Deputy Sheriff of Cumberland county, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon GILSDORF ROBYN L the DEFENDANT , at 0014:30 HOURS, on the 26th day of July , 2000 at CUMBERLAND CO. SHERIFFS' DEPT 1 COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to ROBYN GILSDORF a true and attested copy of COMPLAINT - EJECTMENT together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 .00 .00 10.00 .00 28.00 So Answers: ~~t~~~< R. Thomas Kline 07/27/2000 GOLDBECK, MCCAFFERTY, MCKEEVER Sworn and Subscribed to before By: ~;I~ Deputy Sheriff me this IAJ;- day of (2"ru..-l- JMDA.D. ~o~t~'~ (;'!/i.",_ ., IN THE COURT OF COMMON PLEAS OF CUMaERLAND COUNTY, PENNSYL V ANlA COMMONWEALTH OF PENNSYLV ANlA COUNTY OF GREENE ) ) ) NO. 00-4658 NOTICE TO DEFEND AND COMPLAINT IN CIVIL ACTION TO THE HONORABLE JUDGE WITHIN NAMED:. Personally appeared before me, David E. PatterSon, Chief Deputy Sheriff for RICHARD C. KETCHEM, S~eriff of Greene County, Pemisylvania, who being duly sworn according to law, deposes and SIlYS that on the 6th day of July, 2000 at 2:30 p.m., he served the within named Defendant Herl1ert W. Gilsdorf Jr. at SCI Waynesb].lrg, 373 Prison Road, Waynesburg, PA 15370, Greene County by handing to and leaving with him, a true and correct copy of the within Notice to Defend and Complaint in civil action, NO. 00-4658 Civil and by reading to him the notification endorsed thereqn and by making known to him the cpntents thereof. /)heriffs Fees $24.30 Frothy $ 5.00 Total $29.30 '~--i"--'""!,, ~_.- ,~;,-. rAID BY CUMBERLAND COUNTY Sworn to and subscribed Before me this 7th day of July, 2000 k;~l~~ PROTHONOTARY My Commission expires on the l'tMon. ofJan. 2004. So Answers, pavid E. Patterson 9hiefDeputy Sheriff I, . Served as set Forth, .~/' /J fr' ~ a/J i,.f' ~-P L.. \ ':J'.r.....- RlCHARD C. KETCHEM .i ,.q~ENE COUNTY, PENNSYL V ANlA i ~', : j, :: :,'" ">>i "_ "illIIr ~ ~ In The Court of Common Pleas of Cumberland County, Pennsylvania countrywide Home Loans, Inc. YS. Herbert W. Gilsdorf, JR No. 00 4658 Civil . Now, June 30 ,20 00, I, SHERlFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Greene County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.~ ~ _ A . ~ .('t:.,.~ Sheriff of Cumberland County, P A Affidavit of Service Now,:\b~ \0 1. ,2000, at ,,): dOo'clock--12-M. served the within_(l(:)t<\~\~\(\~ \~._~~\J~\~0r\()y\. ~1<-t-~t~ uponller:he.d lAY (;;\'3dflr-C Jr EE - 4b96 at6a \~o.~,)'oll~(11~il;~n ~l0\JL\f'5 -:V~.\537b byhandingto H('~0\ \~. ~i \~OCl\'~ ~('. E.l=.%CfS a C' Cl r Ie (;\- copy ofthe original t bW\~ \4.\ 0-t and made known to ~ '- IfVI the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before methis~~ayof JlA.f~ ; 20 DO i~!!f~~D . $ AFFIDAVIT s. [)?J .f/rXg.30 $ , !'-01' "~, ,_ <" , j '" """"',, lif @ =tfiI ~iR1 ,= (~''';i! ffl 'i:!il! ",....~,'"~,,~ , "'.dtA'l "''1!i:i~t~,.tilmllilil<';;;l<ll'~ '" -,' - I :ti:} :,')J ,i:j ,-' , " ''I ,;., r~ ":1:/ '1') '.......,. ,>', .,. .,. '-' "'1 ~ ~ c::<{. ' ~:.~ ~"2> Ifm1