HomeMy WebLinkAbout97-05551
~
I
I
~
.~
~
"
~
"
..,
:>
~
"
~.
o
.'"
...
~
Qt
~
~
!
t.
...
~
-.
.
~
.....
u
-
~
\i)
\n
I
r-
c--
o
~:
CONFESSION OF JUDGMENT
LEON C. MORRISON and
JEANNETfE MORRISON
PlaIntiff.
IN THE COURT OF COMMON LAW
COUNTY OF CUMBERLAND
COMMONWEALTH OF
PENNSYLVANIA
VS.
CIVIL ACTION LAW
EVELYN V. NEIDIGH
Defendant
CIVIL TERM 1997-
Pursuant to the authority contained in the warrant of attorney, the original or a copy of
which is attached to the complaint filed in this action, I appear for the Defendant and confess
judgment in ejectment in favor of the Plaintiffs and against the defendant for possession of the
real property described as follows:
100 Fern Avenue, Carlisle,
North Middleton Township, Cumberland County,
Pennsylvania, as described in Deed Book Volume Page
6{1-l~Zttfl ~a~
r:> i am A, unean, Esquire "
Attorney for the Defendants
I Irvine Row
Carlisle, Pennsylvania 17013
ID # 22080
EVELYN V. NF.IDIGH
Defendant
IN THE COURT OF COMMON LAW
COUNTY OF CUMBERLAND
COMMONWEALTH OF
PENNSYLVANIA
VS.
CIVIL ACTION LAW
LEON C. MORRISON and
JEANNETIE MORRISON
Plaintiffs
CIVIL TERM 1997-
,
f
,
,
,
I
!
I
f
,
COMPLAINT
AND NOW, comes Leon C, Morrison and Jeannette Morrison, through their Attorney,
William A. Duncan, Esquire, and files this Complaint in Ejectment, of which the following is a
statement:
I. Plaintiffs are Leon C. Morrison and Jeannette Morrison, husband and wife, of251
Clemson Drive, Carlisle, Cumberland County, Pennsylvania 17013,
2, Defendant, Evelyn Neidigh, an adult individual, resides at 100 Fern Avenue, Carlisle,
Cumberland County, Pennsylvania.
3, On or about the 31st day of January, 1997, Defendant made, executed and delivered
to Plaintiffs an Agreement For Installment Sale of Real Estate, financing Fifty-two Thousand and
001100 Dollars ($52,000,00), a copy of said agreement being attached hereto as Exhibits "A" and
and is incorporated herein by reference as though fully set forth.
4, Said Agreement For Installment Sale of Real Estate has not been assigned.
5, Leon C. Morrison and Jeannette Morrison, husband and wife, are the sole record
owners in fee simple of said premises subject to said agreement, by virtue of a Deed dated
August 24, 1996, and recorded in the Cumberland County Recorder's Office in Deed Book "36",
Volume M, Page 259, more specifically set forth in Exhibit "B", attached hereto and made a
part hereofby reference.
6, Defendant herein has failed to pay payments that were due and owing for the months
of August 1997, September 1997 and October 1997,
7, The Plaintiffs have given to the Defendant written Notice of Default, for failure to
make required payments under the term of the agreement and failure to have the property insured
as stated in in paragraph 7 of the herein attached agreement, more specifically set forth in Exhibit
"e", attached hereto and made a part hereof by reference,
WHEREFORE, Plaintiff prays the Court to issue possession in favor of Plaintiffs
property together with interest thereon, costs and aI ther amounts advanced by Plaintiff.
ltf!i!I/(~
William A. Duncan, Esquire
Attorney for Plaintiff
1 Irvine Row
Carlisle, PA 17013
(717) 249-7780
VERIFICATION
I veritY that the statements made in the foregoing Complaint are true and correct. I have
been authorized by my clients to prepare and file the aforesaid Complaint and I am familiar with
the facts and have prepared the same with facts pro1lided to me by my client. I understand that
false statements herein are made subject to the penalties of 18 Pa. C,S, Section 4904 relating to
unsworn falsification to authorities,
/MiQ:(/}'/ CCt'f
William A. Duncan --
Attorney for the Plaintiffs
I Irvine Row
Carlisle, PA 17013
;./Ih-
o:lA
COPY FOR y~
IllFORMAnON
AGREEMENT FOR INSTALLMENT
SALE OF REAL ESTATE
MADE THIS 31st day of January, 1997, by and between LEON C.
MORRISON and JEANNETTE MORRISON, husband and wife, hereinafter
called SELLERS, and
EVELYN NEIDIGH, hereinafter called BUYER.
WITNESSETH:
1. For and in consideration of the terms and conditions
hereof, Sellers agree to convey and to sell and Buyer agr~e to
purchase and accept the real estate as described in Schedule "A"
attached hereto and incorporated herein by reference thereto,
known as 100 Fern Avenue, Carlisle, Pennsylvania.
2. Buyer agrees to pay the sum of Fifty Two Thousand
Dollars and nollOO ($52,000.00) as total consideration, payable
as follows:
A) Six Thousand ($6,000.00) Dollars down, payable
upon the execution of this Agreement;
B) The remaining Forty Six Thousand Dollars
($46,000.00) is to be amortized over thirty (30)
years at ten (10%) percent interest with a monthly
payment of Four Hundred Three Dollars and 69/100
($403.69) Dollars.
C) On or before January 31st, 2002 the remaining
balance shall become due and payable in full.
3. Final settlement shall occur on or before January 31st,
2002. At final settlement Sellers shall tender a duly executed
general warranty deed conveying to the Buyer a !lood and
marketable title in fee simple, free and clear of liens and
encumbrances excepting presently existing easements or
restrictions, visible or of record.
4. Buyer has the right to prepay at any time.
5. Transfer taxes at final settlement shall be divided
equally between Buyer and Sellers, however, if Buyer transfers
his rights under this agreement or requests the deed be conveyed
to a third party, Sellers shall have no liability whatsoever for
transfer taxes, in any case Sellers pay no more than $520.00 if
applicable in realty transfer taxes.
6. Buyer shall be responsible for repairs, maintenance and
upkeep of the premises and agrees, in the t
~:~f~t~~~ ~:~?~~.,~;,:~~t~::~::i~~F~ 1>1["" i."
n'I.'i r,,1 \. .-' ,.
7. Buyer shall pay for and maintain fire and extended
coverage insurance in the amount of at least $52,000.00 on the
dwelling, naming Sellers and Buyers as insured, as their
respective interests may appear.
8. Proration of property taxes and water and sewer charges
shall be as of the date of the execution of this Agreement.
9. Payment of property taxes and water and sewer charges
shall be the responsibility of Buyer after the date of
possession. Buyer agrees to pay all property taxes at face
value and furnish Sellers with receipts of same,
10. Any municipal improvements, liens or assessments shall
be the responsibility of Buyer after the date of possession.
11. Buyer assumes all risk and responsibility for any
accident, injury or damage to persons or property as to
themselves or others on said premises and agrees to hold Sellers
harmless from all liability therefrom,
12. This Agreement is not assignable by Buyers without the
written consent of Sellers.
13. Buyer shall not carry on any unlawful business on the
property or any business whereby the hazard would be increased
or the fire insurance invalidated. The use of the property must
be in accordance with the zoning laws of the Borough of Carlisle
and Buyer will not file an application for a variance without
the approval of Sellers which shall not be unreasonably
withheld.
14. The Buyer shall not make any major structural changes
without the prior written approval of Sellers which shall not be
unreasonably withheld.
15. In the event Buyer shall fail to make a monthly payment
for the space of thirty (30) days after the same shall have
become due by the terms hereof, or if a breach of any of the
other covenants or conditions be made by Buyer, then such
failure or breach shall constitute a default of this Agreement.
Buyer shall be given written notice of a breach of the Agreement
and shall have twenty (20) days from the mailing of the notice
to correct the default. If not corrected, then Sellers shall
have the right to terminate this Agreement and to demand
immediate possession of said premises upon thirty (30) days
written notice and thereupon all rights and obligations under
this Agreement shall cease and terminate, Buyers agree to a
five (5\) percent late charge which shall be added to each
monthly payment more then 5 days late.
16, Upon default of Buyers, the entire principal sum
remaining unpaid shall become due and payable at once and may be
collected by suit or otherwise, and if authorized by law, the
Prothonotary or any attorney of any Court of record in
e:JrJK ,')40 i^r.f ,');J')
",
Pennsylvania is hereby authorized and empowered to appear for
and confess judgment against the Buyer and in favor of Sellers
for the whole amount of said principal remaining unpaid,
together with interest, costs of suit, release of errors,
attorney's commission of five (st) percent and waiving
inquisitions and exemptions.
17. Upon default and if authorized by law, the Prothonotary
or any attorney of any court of record is hereby authorized and
empowered to appear for and confess judgment against Buyer in an
amicable action of ejectment and in favor of Sellers for the
said premises and to direct an immediate issuance of a writ of
possession, with clause for costs, waiving all irregularities
without notice and without leave of court.
18. In the event Sellers are unable to give a good and
marketable title such as will be insured by a licensed title
insurance company, Buyers shall have the option of taking such
title as Sellers can give, without abatement of price or of
being repaid all monies paid by Buyers to Sellers on accocnt of
the purchase price, less reasonable rental value for use of said
premises. In the latter event, there shall be no further
liability or obligations as to either party concerning this
Agreement which thereafter shall be null and void.
19. Sellers agree that they will not knowingly or
voluntarily cause any encumbrance to be placed on said premises
without prior written approval of Buyer.
Notice of the entry of any mortgage. judgment, lien or
other encumbrance affecting title to said premises received by
the Sellers after the date of the execution of this Agreement
shall be given by the Sellers to the Buyers within thirty (30)
days of the recording thereof in the CUmberland County
Courthouse, Sellers agree that any encumbrances against
Premises, including default expenses and collection fees, will
never exceed the balance due from Buyer to Sellers during the
term of the Agreement. Sellers or Seller's attorney shall be
responsible for compliance with any disclosure by the "Truth in
Lending Act" or other applicable statutes.
In the event any mortgage, judgment, lien or other
encumbrance affecting title to the said premises existing at the
date of the execution of this Agreement or hereafter entered of
record goes into default and no payment is made by the Sellers,
then Buyer shall have the right to make the delinquent payments
and to receive credit for the full amount thereof from the
required monthly payments under this Agreement. In no event
shall the outstanding balances due and owing to Seller's
lienholder exceed the outstanding principal balance due and
owing from Buyer to Seller. Prior to exercising the rights
stated in this paragraph, Buyer shall give Sellers three (3)
days notice by certified mail of their intent to do so, but this
provision shall not limit Buyers' right to make the delinquent
payments and to claim credit therefor.
"n" '"'i() . r:'l"
"J,I~ .J't ! M,! ,)r:. I
20. This Agreement may be filed of record in any public
office, as appropriate.
21. No modifications of this Agreement shall be binding
unless same shall be in writing and duly approved by Sellers.
22. The failure by Sellers to insist on strict performance
by Buyer, of the terms of' this Agreement shall not be construed
as a waiver, release or relinquishment thereof.
23. This Agreement shall inure to and be binding upon the
heirs, executors, administrators and assigns of the parties
hereto.
"
'.
IN WITNESS WHEREOF the parties hereto have hereunto set
their hands and seals the day and year first above written.
WITNESS:
I~Le:c;:. \,-.
~Jl ~ /
~ t '@ .
4~- ~ - ~..(9'-u~1V
ON C. MORRIS N, SELLER
~~ '
TTE MORRISON, SELLER
v ':L
.t/:UI&;;} ;( Iud, fu ~
EVEr: NEIDIGH, UYER
,
,.
~l.f)7 r--
L.I.; ,Q >- Q
............
..~ ~ ~
:.....JO::J
--. u.. 0
..." '":) 1"-'
;~. : :2
._ '00 --
~~ :~; .~
: ') ~; ~
~
e:
Cl...
.::J
....
="
LO:i
w..
C"-
O)
.
Q~DK 540 '^~l ,')~4
"
COMMONWEALTH OF PENNSYLVANIA:
: ss.
COUNTY OF CUMBERLAND
On this, the 31st day of January, 1996, before me, the
undersigned officer, personally appeared LEON C. MORRISON and
JEANNETTE MORRISON, husband and wife, known to me or
satisfactorily proven to be, the persons whose names are
subscribed to the within Agreement, and acknowledged that they
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I
seal.
Not3rial Eeal
Cyrll,l" L fl.", !-:(lI:1,-' P'Jb!:e
S.....I . 'I jl....}..J I .""1 "I..' ,:,,:,;,no C.:unty
t~/' c~~I:tlli3;'ln i.,~,rIl5 ~\~q. 1-1.2000
~
rl'~;
,~, ,,-
.~.''''- . -~.":..., ..:.;a
"""_',I(t'l".:~'~;.~,,...~T"I;"
." '....'..;-..>r~:.~~.;,.pJ.. .......
-..$ t) ,of l.....i~.. ... .-:"~-
..... '..,,- . -.,....,....
t~i~. j..~"","""'H"'~""'. ..
. .. .- -~r .-.,," ,
:.' :............1.... ~!I!;:.~.
.:. : ~:..:....~! ...: -v::'" . I~
",,,, " ,.', ':;.:;-- ,,~
~'~!;;-::;;:~'<:.~..,;::. ;'::7-~: ;~;~..'
'j, ""(7 '.,....' ,\.: ..,".:':-fd':".-.
, ,'. . ",.' :'".".... \"\"'~~'..-
.-~I" '........,. f~i ......
..~,,~..,'
...
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ss.
On this, the 31st day of January, 1997, before me, the
undersigned officer, personally appeared EVELYN NEIDIGH, known
to me or satisfactorily proven to be, the person whose name is
subscribed to the within Agreement, and acknowledged that he
executed the same for the purposes therein contained_
IN WITNESS WHEREOF, I
seal.
fficial
NJ!:mHI ~>1nl
Cvnt'~I:J L. CJrr. r'htt-. P'Jb~ic
Scutl':, :.l:dGI1.:,., i.-',;, . ~~U":':':'::'l:i~n CCi,;nrv
t.ty L,:QII1:1i!':;:;tOn t:.,p,re" f..:';, ;.1, ;;:;::CO
. ,--.." --,
!. ~.:;/,:~~,:t. ),.,::~;
'-. ~F:;i,:~.;,,~:,._";:.~,,~/,:JF.;~ ~
,;. ,..,::,;.".
.. .~. "'..:, \ ~. " ."'. ..: .
~. ~ ~;..l':';::.....,,:..'~""':."~'"""'"",
r.'l ....., ~Ti....\'\
.....:a,"'_. '. ,.,'~- ....~
. t; ~~: .. ".,
e:JUK 540 Ihl.l ,')~,'i
SCHEDULE "A"
ALL '!'HAT CERTAIN lot of qround with improv8Jllents thereon
erected, situate in North Middleton Township, cumberland county,
Pennsylvania, bounded and described, .s to!lows:
BEGINNING at a point in the center of the road leading tram
Carlisle to Carlisle springs, at the northwestern corner of lands
now or formerly of Edgar L. Kingsborough; thence by the center at
said road, ~oDCh 06 degrees 47 minutes East, 10~ teet to a ~oint;
thence along the etreet formerly designated all Pern Avenue, South
72 degrees 43 minutes East, 202.S teet to . point; thence by line
of lands now or tormerly of Charles Kingsborough, South 06
degrees 47 minutes West, 63.5 !eet to . point on line at lot now
or tormerly of Edgar L. Kingsborough; thence along said latter
land, North 83 degrees 13 minutes West, 200 feet to a point in
the center at the aforesaid public road, the Place at BEGINNING.
SAID premises being described according to . survey of T.
Elliott Middleton, Registered Surveyor, dated March 31, 1965.
BEING the same premises conveyed by Thelma C. Kingsborough. single person. by
her deed dated August 24. 1993, and recorded in the Office of the Recorder of
Deeds of Cumberland County. Pennsylvania. in Deed Book 36-M, Page 259. unto
Leon C. Morrison and Jeannette Morrison, husband and wife. Se~lers herein.
',' ',' ?ennsylvanla 1 s':.
" ,)1 cumberland d f Oeells
".'.J:n the 'Jiflce lor me r8COr I~g 0
JYJ~'jl :or}:wpberl!!!]!l countY.!-..? /
IJIBI'-".."J:t!::\/Ol, _ PDg.. ~
. :11'; Mnd und )1pl of office 0' .f- 19f2..
, , '\ .hls 1/ ' day of
-~...
.f" ....
J:';"~.I_;:'... . .
. ..' ~",.'.__'-
" ..... .~. .
- - ... . ....' . .~
'r f!"- ";'" ~..
t"~' n~' .:.. .....JT"
w<',.. ",,-,)'.' ,..t..' ,...,...1:
.... w......c-- .ft,ll ....', ~
....f. ,.......t. " .."",'" t! .."
.' ~ ,. ~~~ Il'. .""
...........~,., .,,"';""',.,- '..~ '.\;"";,#
.....' "':' 1." ," '.---- "'A" ZlI-"~I__
~' '1'" '"J' '..,~
oy.:t:..... .:....6.....'
" .... .- .....
I\' t" .. ..~._ r ....' ....~Ir
.~) ,; n ,-- Jr ',I:r ,.Jf!" ..
~\1"'''.u~~'P. _.-::"-11"'"' :~.lf'-.,,'~'.
..~ . ,", ",..' ~.:/(, . 1. ....'
t';"" .. .... .. ~~. .,,~ l) ;"'4~
..... ,~(1,".- .....~.."....--:......~ . ..n#'"
J't' . . .:.... ."J"- '=" .0 '...I.'.
,-.,' ..,.. .1. C .
.., . "'."'_ ...... ... I~.
.r flll.T - -'I . tl,\'
. .a,,~.... ......" ~,""I) .
fItt'":...; ""';.:'1"\:,,,_-..
,..., ;.
Mr . . "
~e
"
P'J'J~ 540 IM,l ,'i?fi
---
THIS DEED
Lord
MADE THE :2 <f ~ay of ~ .. ,:::t
One Thousand Nine Hundred N nety-Three
I,
in the year of our
(1993)
BETWEEN
~ !
"
THELMA C. KINGSBOROUGH, single person, of 100 Fern Avenue,
carlisle, Cumberland county, Pennaylvania 17013/
Grantor,
AND
LEON C. MORRISON and JEANNETTE MORRISON, husband and wife,
of 251 Clemson Drive, Carlisle, Cumberland county, Pennsylvania
17013/
Grant...,
Ii
I
I
I
WITNESSETH/ that in consideration of Twenty-Five Thousand
and NO/100 ($25,000.00) Dollars, in hand paid, the receipt
whereof is hereby acknowledged, the said Grantor does hereby
grant and convey to the said Grantees, their heirs and assigns,
as tenants by the entirety:
ALL THAT CERTAIN lot of ground with improvements thereon
erected, situate in North Middleton Township, Cumberland county,
Pennsylvania, bounded and described, as follows:
BEGINNING at a point in the center of the road leading from
Carlisle to Carlisle springs, at the northwestern corner of lands
now or formerly of Edgar L. Kingsborough; thence by the center of
said road, ~o~h 06 degrees 47 minutes East, 100 feet to a point;
thence along the street formerly designated as Fern Avenue, South
72 degrees 43 minutes East, 202.5 feet to a point; thence by line
of lands now or formerly of Charles Kingsborough, South 06
degrees 47 minutes West/ 63.5 feet to a point on line of lot now
.
or formerly of Edgar L. Kingsborough; thence along said latter
land, North 83 degrees 13 minutes west, 200 feet to a point in
the center of the aforesaid public road, the Place of BEGIN~ING.
SAID premises being described according to a survey of T.
Elliott Middleton, Registered surveyor, dated March 31, 1965.
BEING the same premises which Charles Kingsborough, widower,
by Deed dated September 16, 1965, and recorded in the Office of
the Recorder of Deeds of Cumberland county/ Pennsylvania, in Deed
Book "S", Volume 21, Page 874, granted and conveyed unto Thelma
C. Kingsborough, Grantor herein.
W"Y!II! F, SHi\DE
".....,...u-..
I SauIb ",-u-'
c.rtiIIo,--,Iv....
170ll
800YJ136 PACE 259
1i-Blf""
. " .-......-,--_..._.._,..
--. .- -"-'
I .
AND the said Grantor hereby covenants and agrees that she
will warrant generally the property hereby conveyed.
IN WITNESS WHEREOF, the said Grantor has hereunto set her
hand and seal the day and year tirst above written.
Siqned, Sealed and Celivered
1n the Pre.enee ot
t(~ E'~
~ (! ~~SEAL)
Thelma C. K ngs rough
I do hereby certity that the precise residence and complete
post otfice address ot the within named Grantees is 251 Clemson
Drive, Carlisle, Pennsylvania 17013.
Date:
.+r- VI-.
, 1993
..J:,(,ty,:> ;rlb......, . 1< 'MI,) 4-
\-, I~ '), 0&-
Attorney r Grantees
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF CUMBERLAND )
On this, the .;71".:tb..aay ot ()uJ~ , 1993, before
me, the undersigned. officer, perso~~try ~ppeared THELMA C.
KINGSBOROUGH, single person, known to me (or satistactorily
proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that she executed the same tor the, ,
purposes therein contained.. ...','
IN WITNESS WHEREOF, I hereunto set my
seal.
i
.-
WAYIII! F, SHADE
AIor'DCy II La.
,---
CoriIII, -,.....
1701)
-2-
BOOi/J7ao PAGE 260
l
t~
)
) 55:
COUNTY OF CUMBERLAND )
Recorded on this ~ day of ~ ' 1993, in
~Recorder~~ice of the said County, i~_Deed Book -~ Vol.
Page . Given under my hand and seal of t~d
off ce, the oate above written.
~~~~n~l-
, Reco~':",;',,,\...,
, ..".. ,~,~\""", ",r
.~if''''''': ""l"'~'':':
,~.,..tf. -">' I .....:...i...' ';,,,
" .. .' j'...l ''Q' .." 1 ..J....
".~.'l.. '. ;;., ...~ -:." . ..,....
"1~"11. -,.. ' .... ........r~..~ '. .
. '. t:).,s" ...........( . . .~..
.: ......'. '".~'''j't1'.1'.';''''' :s,,'
. '"", c.: ~ . ~~.,' "...~~-;f l
", .." Co: ... --< " ,~,.),~..,o fI,.,,,
I .,1 . ..... .1 '. , ,.. r~.,'
J u'.. p""" .M..;.;.......,..,...~i\".
'..\" '" ........... . .-..... ;111
" V"'" " "';;--..,f'\ ,,' ...~~~4 p' -;' "I ""'1,"
, 0.,. '.-C":'" ........Ie ~"...l;.
_,-: "'~~.~V .':_1..' .;,g....VI.
, I ....- ". ..... ,,' .....,-V ."..' .....,.
,..~. .'j-...... ...... ~':-..'..'.,..
lor'" "" I' 'e.::;l.I"'~"
.' ~~,. "U"I\I,~.. I ';"~:,,,-"
; - , "...:.>fu,t::;j , . .
. . ""'....:.~T
.,... *1.....
, .. ',..f.l.\r<Cl'1'~
~!
h
"
COMMONWEALTH OF PENNSYLVANIA
llI~,~.J JitA lfltddMPJ
Cumb. eo.. ...
-!" ~ EIlIM.......,.
o.:-~"W'-9.3 NrI..~ tW-.
IIobIrt Po ZIegler
Cumb. Co. D'aL Co/. AaI
l?~
School 0111 Cumbo Co,. PI.
~ RNI Eul8 Tranafw flllal.
~ r~.JI/-f3 1vnL/;;J.. S.
Robert Po Z1eQl"
CUmb. Co. Din Col, Ag~
,
.
ROBERT !" ZIEGLER
RECORDER OF DEEDS
CUMBE.RLMlD COUHTY-PA Q
... COM/I,ONWEAlTH OF PH~I'15i'LV;"1 JIA :::
N rJ~~Ap. rMEI~1 OF REVENUE .:::
"" .~ I "1~~-'
~ Ir'~~'N:~'r(" l,~~?i,i\ 2 t' 0 0 !l j :::
'.J tAX' J r AUU~l'93 ~~~J, ~ . ~ :"-:
Po6. ii:'Cl9 Ii::;
'93 BUG 2'\
Pl'l 1 ~
'"
WAYNI! F, SHADe
A_" \.ow
5__"_
Cotlillo, r-qlv....
17011
-3-
'r;ooilfl 36 PACE 261
I '. . ,
" ,
...~ . . /. k '.. .....-..!-,-.. _._,-.~ .
, ,
0)
FH ED"{HlCE
C" 7>": ,"""'''''')7.ny
. j I.' ,,' 11,;,,'.,\ I/ln
070"-, _" c', I, 10
, .\" 'J I Ii .j. \J
r'lj',r. <, "',,, I .,
\,- IH"..__'..., 'j I i \'; "if,
f' .-~. :', ,\", i I'; ;;'",....'
....1 d .,.1 r.~,.,. ',I \. I
"
f-27J
q.ft
J~
.!'
~
I qS6
C!t SF I?
l f7t;d!
';:1'
~.
/: ',.
'r
" ~" ;,
,. .'.
,L
,\',
(
!
:r ,'~
.. ~ ..~," "
, ",
"
Duncan & Otto, P.C.
Attorneys at Law
One Irvine Row
Carlisle, Pennsylvania 17013
...;'
"
. '.'
"
, ,
~i
i
I ,
"i ..<'.:, ~ IJ.:. '~l i-,h i.n ::nr'1lJ..:.!lJJLL--11.LU..:.._iE~I.I'.-.r:
..' w;:~ _, '.: ...
,l
~1 i. U L t_ i ';;\:i :. :\ :
:~ f' :~ L ~" ,\ :i !'
1.- ,
t "i'U._S
",
, "
:1
.,
;:'HI,C..__fT
'I
:.1.,".______
. ."
,
! "
[' . "C,\'.,,:::2ff,I_ _, . ,_ _ _ ____..__'u__
:" t..:-..;," l. f t
')1
[i~..;.I_' u 1.,'
.... t~,..' l l i i 'J 1.
I '1'! nI:J-, (. ,"dlL"' I:' ':"J n t. it, FL" n rkiY 1 'j LI tl1 '.1, ~~l(l b ('.i og d \; l '/
W(,Jl11 ;;.J"':COi.--d.II~J
u;'
r, [:J~~:} ;,-1:~.YJ~LIlL._ I{_^~.~____
!. i . ~.~
j, "
~ '.. j .
j! __J~l~~~:_t):;'_ H~)UE'~, ,;fl t;lll:' J:~t_rl i.!dl' "t ~l2_'~.:--~~..;:_L__________.._
1'-' J .__JS'~~_I~r.f\rI...t~VF ______.____.___.______.
, .. t', :.: !. ~'
L-1_!...J _-...:'.:'J_ '_
_..._.__......_________._..__.____., ~ U!1 D EhJ-;.D r: t, _.__~_._._'
.L<:I. r ':'lIJI_;i'lv;jnl~). by h:1ndlll\] t," k..Y..~J~,(H nEIL-ILit!
1.1" ,"fl.1 ;It.tl.'::;t-.I~d '='UPl' ('1 t:h~.:' -.i.:tJrl.Ll~Uti..~l1'l[:._rl.!~-'T.I~1.___._.,______.._.,
t, :'1'-_" t,,-, r '-,/.1" tl tlClT~:"s_Jlll~~P. _lLll!-_.~_.8"~j.: J.:" OF TUU:J~I;rJT..--A!Lf~___.
S::F'~~t Ii I illj
.____,__._ .'0..,,-- __.
.._,,----~_.......~_..__._". -,.-----.--.---.--...---...---.--..
.-.-,,-.,
;1[I,j
, ,
~ h":l ,,;,1111>' t.iml~ dlr.?ct~ln'J !i:l:..r.. -:.It.:r.';-'l":tl,(,rl tu t.h';..' i::';lj~',',flf_~" !.tl'.:.'i-.,',-"f.
r::,i_)
"'~'?~~
r:--'TE-;:::-;:i'-j"__" T:: c-;~j'_:-=---T;":"; "~-'::""---"" --._..-~
'-: 1'_; 1 ft' ~:;
['1'_'1"'\'; .',' t. ,1 !,"I.J
'I"!' ii"'"
1\ f t \ <fa\" 1 t.
:-,.1 1 :: h 'J C'J.'
1 ~1. '~'C-I
J. 10
00
'1i==:.
r;;r-L'Ut:(" t, n
10 1 (.
I''',
f n...
~..I
, ,
I ,
..,
!i!.
I'
I.
, ,~
II. ~
1'1
,"
,
-, f
(P~
.- ,...-.,.--.. ',._--.-
C), U- c:.
?JkO',',.~'
",. '. ".,
SIIEf:IFF'S RETURtl - REGULAR
CASE tlO: 1997-05551 P
COMMOtlWEALTII OF FENtlSYLVAtlIAI
COUtlTY OF CUMBERLAN~
tlEIDIGH EVELYtl V
vs.
MORRISON LEON C ET AL
KEIWETI! E. GOSSERT , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, "~yo;, t.hE' within COMPLAINT Atl[1 NOTICE wa:; 5erved
upon tlEIrIIGH EVELYN V
def"nd~nt., at 1020:00 HOURS, on tl,<: 15t.h day of O,;t,Ob<!l'
th",
lC'''7 'Jt
1(1':" FERII AVE
CARLISLE. PA 1712113
County, Pennsylvania, by handing to EVELYN N~IDIGH
a t.rue and at.teat."d copy of the COMPLAINT AtlD NOTICE
together with NOTICE UNDER RULE 2973,2 OF JU~GMENT AND
EXECUTION
, CUMBERLAN['
and at the same time directirlg ~ attention to the content:s thereof.
Sheriff's Costs:
[Iocketing
Service
Affidavit
Surcharge
18.0121
3. 10
.012:
2.00
So answers:~/?/ . //
r~~/-t:.~
rr.-Thomas 1\13.ne, 5her3.J.J.
$23. l~ DUNCAN AND OTTO
10/1E./19S17
bi'
VI-ff{
/ L1epu ,}' "e 3.
Swt.rr, an,j subscribed to beior~ me
t.hi::
19
day of
A. D.
r r(.ttlorl'7ltar}'
LEON C. MORRISON and
JEANNE17E MORRISON
PlalntifTs
IN THE COURT OF COMMON LAW
COUNTY OF CUMBERLAND
COMMONWEALTH OF
PENNSYLVANIA
VS.
EVELYN V. NEIDIGH
Defendant
CIVIL ACTION LAW
CIVIL TERM 1997- oj-55/
/uu1..,,,, Q......
PRAEClfE FOR WRIT OF POSSESSION
UPON A CONFESSED JUDGMENT
Issue writ of possession upon the judgment in ejectment entered by confession in the
above maller,
fe/l> F.u- ~
--n.....u.. ~I..t,t;:... -r "i'
C, e,.(.- I fL 17"')
la A. Dunca, squire
Attorney for the Defendants
I Irvine Row
Carlisle, Pennsylvania 17013
ID # 22080
.-, .
,.,',.
f~ : ,
:: ; ~.
:,'~ r
~.- .
.:r~;
-or'
.
n
c
~~
,.;; '.
ft! 1.'1
~;I,';
':'..)
10
\D
....,
;..
5:?
'.
if1
~-:J
_ .'il?l
,);,) ".71
.!CJ
if)
r:':!
>..,.71
';:-1
~:J
-..;
~~!
......
':.)
..
~
f: jf
t
, t f
t l
\, -\.. r
~
'\
:-.' t"
:"1\ '- ~
<! ~ .\
~~ ! ~C(,
...
\
.,
V,
~
\
~
..,=-- -.
.~_.~
'.----"
-.....-,,--.
~ .__t. .-