HomeMy WebLinkAbout03-0328
PNC BANK, NATIONAL ASSOCIATION,: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL TERM 2003
STANLEYD.ADLER,JR.ANDBETTY : NO. OJ-:1').jJ (3~~L ~~
J. ADLER,
Deceased
and
ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF STANLEY D. ADLER, JR.,
AND ROBERT A. ADLER AND PAUL 1.
KILLION, EXECUTORS OF THE
ESTATE OF BETTY J. ADLER, *
Defendants
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY:
Please issue awrit of revival of judgment entered in this Court at Civil Term 1991, No.
3124 Civil 1991, and revived at No. 1998-543 Civil of same Court, and i!ldex it in the judgment
index against Stanley D. Adler, Jr. and Betty 1. Adler, Deceased, and Robert A. Adler and Paul 1.
Killion, Executors of the Estate of Stanley D. Adler, Jr., and Robert A. Adler and Paul J. Killion,
Executors of the Estate of Betty J. Adler, Defendants, in the amount of One Million Nine
Hundred Forty-Nine Thousand Nine Hundred Seventy-Seven and 34/100 Dollars
($1,949,977.34) with interest from September 12, 1991.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Date: I -- 2 I - 0 J
BY:~~'\
Thomas E. Flower, Esquire
Supreme Court ID #83993
2109 Market Street
Camp Hill, P A 17011
(717) 737-3405
Attorney for Plaintiff
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PNC BANK, NATIONAL ASSCX:IATION
VS.
STANLE'"r D. ADLER, JR., AND 'BETTY J. ADLER,
. DECEASED
AND
ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS
OF THE ESTATE OF STANLEY D. ADLER, JR., AND
ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS
OF THE ESTATE OF BETTY J. ADLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
~m.
W\- l?R r'T\TTT.
TERM
\vRIT OF REVIVAL
STANLEY D. ADLER, JR. AND BETTY J. ADLER, DECEASED AND ·
TO ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS OF THE ESTATE OF STANLEY D.
ADLER, JR., AND ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS OF THE ESTATE
OF BETTY J. ADLER
You are notified that the plaintiff has commenced a ?roceeding to
rev~ve and continue the lien of the judgment entered to
NO. 98-543 Civil
TERM
The Plaintiff claims that the amount due and unpaid is $
with interest from 5E:ntanber 12. 1991
q4q q77 14
You are required within twenty (20) days after service of this Writ
to file an answer or otherwise, plead to this Writ. If you fail to do
so, judgment of revival will be entered.
Costs $
S?R4 07 Pr'I Art-y
$ 2.00 Co.
Curtis R. Long
PROTHONOTARY
Datle
January 22, 2003
"-- do.-o.l {}. 7f.Jl/YV"L..
DEPUTY
Seal
Robert A. Adler
2930 Arcana Road
Mechanicsburg, PA 17055
Thanas E. Flower, Esquire
Attorney for the Plaintiff
2109 Market Street
Paul J. Killion, Esq.
Killion & Metz
214 Pine St.
Harrisburg, PA 17101
r'~mp Hill. PA 17011
717-737-3405
ID # 83993
PNC BANK, NATIONAL ASSOCIATION,: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL TERM 2003
ST ANLEY D. ADLER, JR. AND BETTY : NO. 03-328 CIVIL TERM
J. ADLER,
Deceased
and
ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF STANLEY D. ADLER, JR.,
AND ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF BETTY J. ADLER,
Defendants
TO THE PROTHONOTARY:
PRAECIPE
Please reissue the writ of revival filed in the above-captioned matter.
Date: March 11, 2003
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
B~~~
Thomas E. Flower, Esquire "-
Supreme Court ID #83993
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
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PNC BANK, NATIONAL ASSOCIATION,: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL TERM 2003
STANLEY D. ADLER, JR. AND BETTY : REVIVED NO. 03-328 CIVIL TERM
1. ADLER,
Deceased
and
ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF STANLEY D. ADLER, JR.,
AND ROBERT A. ADLER AND PAUL 1.
KILLION, EXECUTORS OF THE
ESTA TE OF BETTY J. ADLER,
Defendants
PRAECIPE TO ENTER JUDGMENT OF REVIVAL UPON DEFAULT
TO THE PROTHONOTARY:
Please enter judgment of revival In favor of the Plaintiff, PNC Bank, National
Association, and against the Defendants, Stanley D. Adler, Jr. and Betty J. Adler, Deceased, and
Robert A. Adler and Paul 1. Killion, Executors of the Estate of Stanley D. Adler, Jr., and Robert
A. Adler and Paul J. Killion, Executors of the Estate of Betty J. Adler, for failure to file an
answer or otherwise plead to the Writ of Revival within twenty (20) days of service thereof, and
enter judgment in the amount of One Million Nine Hundred Forty-Nine Thousand Nine Hundred
Seventy-Seven and 34/100 Dollars ($1,949,977.34) with interest from September 12, 1991.
I hereby certify that in accordance with Pa. R.C.P. 237.1 a written notice of intention to
file a praecipe for entry of defuult judgment was mailed to the Defendants. Attached as Exhibit
"A" hereto is a copy of Plaintiff's written notice of intention to file a praecipe for entry of default
judgment which was sent via United States First Class Mail, which is at least ten (10) days prior
to the filing of this Praecipe. Postal Forms 3817 evidencing the mailing of said notice are
attached hereto as Exhibit "B".
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LIND SA Y
Date: May 13, 2003
By:
~~
Thomas E. Flower, Esquire "
Supreme Court ID #83993
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
PNC BANI<, NATIONAL ;SOCIATION,: IN THE COURT OF ^.')MMON PLEAs
Plaintiff : CUMBERLAND C(,~I'ITY, PENNSYLVANIA
v. : CIVIL TERM 2003
STANLEY D. ADLER, JR. AND BEITY : REVlVIED NO. 03-328 CIVIL TERM
1. ADLER,
Deceased
and
ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF STANLEY D. ADLER, JR.,
AND ROBERT A. ADLER AND PAUL J.
KILLION, EXECUTORS OF THE
ESTATE OF BETTY 1. ADLER,
Defendants
TO: Robert A. Adler
2930 Arcana Road
Mechanicsburg, PA 17055
NOTICE OF INTENTION TO FILE A PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT OF REVIVAL
Paul 1. Killion, Esquire
200 North Third Street
Suite 1400
Harrisburg, P A 1710 1
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM
THE DATE OF THIS NOTICE, A lUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING, AND YOU MAy LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAwYER AT ONCE.
IF YOU DO NOT HA VE 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 or 1-800-990-9108
Respectfully submitted,
Date: April 28, 2003
SAIDIS, SHUFF, FLOWER & LINDSAY
BY:~~~~
Thomas E. Flower, Esquire
Supreme CoUrt ID #83993
2109 Market Street
Camp Hill, PA 17011
(717) 737-3405
Attorney for Plaintiff
E~ h. brl- H,A II
U.S. POSTAL SERVICE CERTIFICATE OF MAILING t{i'>
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll. DOES NO'~ u.,
PROVIDE FOR INSURANCE-POSTMASTER V "
PS Form 3817, Mar. 1989
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
successor by merger to CCNB, National
Association,
NO. 3124-N-1991
Plaintiff
v.
REVIVAL NO. 98-543
REVIVAL NO. 03-328 ~
STANLEYD. ADLER, JR. AND
BETTY 1. ADLER,
Defendants
CIVIL ACTION - LA W
PARTIAL RELEASE OF JUDGMENT LIEN
WHEREAS, on September 12, 1991, Judgment was entered in favor of Plaintiff
and against Defendant in the Court of Common Pleas of Cumberland County at No. 3124-N-
1991, and such Judgment was revived on January 30, 1998, at No. 98-543; and on May 23,2003
at No, 03-328; and
WHEREAS, Defendant owns an interest in that certain real property known as
1249 Market Street, Borough of Lemoyne, Cumberland County, Pennsylvania, as more
particularly described on Exhibit "A" attached hereto and made a par hereof (the "Property");
and
WHEREAS, Defendant has requested Plaintiff to release the Property from the
lien ofthe Judgment, which property constitutes a portion, but not all, of the property that is
subject to the lien of the Judgment.
NOW THEREFORE for good and valuable consideration, the receipt of which
is hereby acknowledged, and intending to be legally bound, Plaintiff, PNC Bank, National
Association, for itself and its successors and assigns, agrees that it will not attach or levy upon,
sell or dispose of, or claim or demand the property as a result ofthe Judgment, and further
releases the lien of the Judgment only on the property; provided, however, that neither this
Partial Release nor anything herein contained invalidates, diminishes, alters, or otherwise affects
the Judgment or the lien or security ofthe Judgment upon or against any other property of
Defendant in Dauphin County, Pennsylvania, or Cumberland County, Pennsylvania, or
elsewhere; and provided further that neither this partial Release nor anything contained herein is
or should be construed to be or to evidence satisfaction or discharge of the debt to Defendant to
Plaintiff, PNC Bank, National Association.
Pennsylvania, or elsewhere; and provided further that neither this Partial Release nor anything
contained herein is or should be construed to be or to evidence satisfaction or discharge of the
debt of the Defendants to the Plaintiff, PNC Bank, National Association.
IN WITNESS WHEREOF, the Undersigned executed this Partial Release this
-tL..
~ day of December, 2006.
PNC BANK, NATIONAL ASSOCIATION
By: fA O~ L - Q
Eric D. Krimmel
Vice President
COMMONWEALTH OF PENNSYLVANIA
ss.:
COUNTY OF CUMBERLAND
On this, the {ljA'1- day of December, 2006, before me, the undersigned officer,
personally appeared Eric D. Krimmel, who acknowledged himself to be the Vice President of
PNC Bank, National Association, who being authorized to do so, executed the foregoing
instrument for the purposes therein contained as such officer.
IN WITNESS WHEREOF, I hereunto set my hand and notarial seal the day and year
aforesaid.
~~
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherry M. Baney, Notary Public
~., Ct.mberIand County
,." ExpIres JLne 25, 2009
Member, Pennsylvania Association of Notaries
'.
EXHIBIT "A"
PARCEL NO. 12-21-0269-030, 12-21-0269-030A, 12-21-0269-030B, and 12-21-0269-030C
ALL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County of
Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the northern line of Market Street [sixty (60) feet wide] at the
southeastern comer of Lot No. 31 on the Plan of Lots hereinafter mentioned; thence by the
eastern line of said Lot No. 31 and through an iron pin two and one-half (2 1/2) feet north of
Market Street, North nineteen (19) degrees forty (40) minutes West, two hundred feet (200.00) to
a point; thence by the southern line of Lot No. 29, North seventy (70) degrees twenty (20)
minutes East, twenty and thirty-three hundredths (20.33) feet to a point; thence by the eastern
line of said Lot No. 29, North twenty-four (24) degrees eight (08) minutes thirty (30) seconds
West, one hundred eighty-five and sixty-five hundredths (185.65) feet to a point on the south
side of Walnut Street as laid on said plan but not yet opened; thence by the southern line of
Walnut Street, North sixty-five (65) degrees fifty-one (51) minutes thirty (30) seconds East, one
hundred sixty (160.00) feet to a concrete monument upon the southern line of Walnut Street and
thence continuing along the southern line of Walnut Street and on the same course seventy-nine
and ninety hundredths (79.90) feet to a concrete hub at the northwestern comer of Lot NO. 25;
thence by the western line of said Lot No. 25, South twenty-four (24) degrees eight (08) minutes
thirty (30) seconds East, two hundred four and forty-three hundredths (204.43) feet to an iron
pipe; thence by the northern line of Lot No. 35, South seventy (70) degrees twenty (20) minutes
West, fifty-nine and ninety-six hundredths (59.96) feet to an iron pin; thence by the western line
of said Lot No. 35, South nineteen (19) degrees forty (40) minutes East through an iron pin two
hundred (200.00) feet to the northern line of Market Street aforesaid; and thence by the northern
line of Market Street, South seventy (70) degrees twenty (20) minutes West, two hundred one
(201.00) feet to a point, the place of BEGINNING.
HAVING THEREON ERECTED a building known as 1249 Market Street, Lemoyne,
Pennsylvania.
BEING Lot Nos. 26,27,28,32,33 and 34 on the Plan of Rosene Farms as laid out by G. Frank
Wetzel, Master in Partition in the case of Caroline H. B. Brandt, et al. vs. Jacob H. Longnecker,
et al. in the Court of Common Pleas of Cumberland County, Pennsylvania at No.4 October
Term, 1935.
Lot Nos. 28 and 33 BEING two of the lots which were awarded to Caroline R. H. Daub in the
said petition proceedings by a Decree of the Court dated September 15, 1936.
Lot Nos. 27 and 34 BEING the same lots which Wernersville National Bank and Trust
Company, guardian of the Estate of Maude H. Longnecker, a weak minded person, by its Deed
dated September 7, 1955 and recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania in Deed Book 16, Volume R, Page 557, conveyed to said Caroline R. H.
Daub.
'.
of' ...,
Lot No. 26 BEING the same lot which Carol Bigler Brandt and Margaret A. Brandt, his wife by
their Deed dated May 10, 1950 and recorded in the Office of the Recorder of Deeds aforesaid in
Deed Book 14, Volume I, Page 532, conveyed to Caroline H. Daub and Walter H. Daub, her
husband. The said Walter H. Daub having died on October 9, 1961, title to the said lot vested in
Caroline R. H. Daub absolutely.
Lot No. 32 being the same lot which Tradesmens National Bank and Trust Company, sole
Trustee under the Will of Jacob H. Longnecker, by its Deed dated April 11, 1950 and recorded in
the Office of the Recorder of Deed as aforesaid in Deed Book 14, Volume H., Page 377,
conveyed unto Caroline R. H. Daub.
461535vl
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SHERIFF'S RETURN - REGULAR
,CASE N0: 2003-00328 P
`~ COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D JR ET AL
DAWN KELL
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF REVIVAL
was served upon
ADLER ROBERT A EXECUTOR OF ESTATE OF STANLEY D ADLER JR the
DEFENDANT at 2015:00 HOURS, on the 6th day of February 2003
at 2930 ARCUNA RD
MECHANICSBURG, PA 17101
ROBERT ADLER
by handing to
a true and attested copy of WRIT OF REVIVAL
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this day of
(, Jim .: ~ ~~lty-3 A . D .
.~~
othonotary
So Answers:
i~ ~-~
R. Thomas Kline
03/28/2003
SAIDIS SHUFF FLOWER LINDSAY
By C1Ls-~'1''l t~ 1~~-u-X~--
Deputy Sheriff
SHERIFF'S RETURN - REGULAR
.CASE NO: 2003-00328 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D JR ET AL
DAWN KELL
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF REVIVAL
Sheriff or Deputy Sheriff of
was served upon
ADLER ROBERT A EXECUTOR OF ESTATE OF BETTY J ADLER
the
DEFENDANT at 2015:00 HOURS, on the 6th day of February 2003
at 2930 ARCONA ROAD
together with
and at the same time directing His attention to the contents thereof.
MECHANICSBURG, PA 17055
ROBERT ADLER
by handing to
a true and attested copy of WRIT OF REVIVAL
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
~~
1 V . V V
Sworn and Subscribed to before
w
me this ~'~ day of
o2b~.3 A.D.
~u.e~ ~~ ,
So Answers:
~ .~,. ,.
R. Thomas Kline
03/28/2003
SAIDIS SHUFF FLOWER LINDSAY
By . _ ~Q
O~-1.x.7'1'1
Deputy Sheriff
othonotary
SHERIFF'S RETURN - OUT OF COUNTY
:CASE N0: 2003-00328 P
COMMONWEALTH OF PENNSYLVANIA:
` COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D 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:
KILLION PAUL J EXECUTOR OF ESTATE OF BETTY J ADLER
but was unable to locate Him
deputized the sheriff of DAUPHIN
in his bailiwick. He therefore
serve the within WRIT OF REVIVAL
County, Pennsylvania, to
On March 28th 2003 this office was in receipt of the
attached return from DAUPHIN
_--
_--
Sheriff's Costs: So ansc~t~ ;--'""/~./=-"
Docketing 6.00 -'` - d%'~
i
Out of County .00 ~-
Surcharge 10.00 R: Thomas K1 ne
.00 Sheriff of Cumberland County
.00
16.00
03/28/2003
SAIDIS SHUFF FLOWER LINDSAY
Sworn and subscribed to before me
this ~-?~^~- day of `
a-v'b3 A . D .
n~.~~-
Prothonotary
(~~'EtLE IT~ ~E ~~P.~Tff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717)255-2660 fax: (717)255-2889
Jack Lotwick
Sheriff
PNC BANK NA
• KILLION PAUL J
Sheriff's Return
vs
No. 0592-T - - -2003
OTHER COUNTY NO. 03 328
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
NOW: March 25, 2003 at 11:35AM served the within
WRIT OF REVIVAL upon
KILLION PAUL J by personally handing
EXEC OF ESTATE OF BETTY J ADLER
to JANET EVENS (OPERATION COORDINATOR) 2 true attested copy(ies)
of the original
WRIT OF REVIVAL
to him/her the contents thereof at 200 N THIRD STREET
Sworn and subscribed to
before me this 16TH day of APRIL, 2003
~~ ~ i
PROTHONOTARY
and making known
SUITE 1400
HARRISBURG, PA 17101-0000
So Answers,
Sheriff of D Co~~ Pa.
By
De Sheriff
;..
Sheriff's Costs: $31.50 PD'.03/2r0~~2003
RCPT NO 176669
E TORO
PNC Bank NA
VS.
Stanley D. Adler Jr et al
SERVE: paul J. Killion exector of 03 328 civil
No.
estate of Betty J. Adler
~ `, ~~ag~
Now, ~ , I, SHERIFF t~F CUIV,~ERZ,A~1~ CO~TN 1 Y, PA_; do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintifr':
Sheriff of CumUerland County, PA
~~~d~vli~ ®f ~~>l-v~~e
Now,
within
upon
at
by handing to
20 , at o'clock M. served fife
a
and made known to
Swop and subscribed before
nle This d.ay of , ?p
copy of the original _
So answers,
Sheriff of
CGST'S
SER~~CE
T~III,EA GE _
AFFIL~AVZT
County, PA
the contents thereof.
g
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SHERIFF'S RETURN - OUT OF COUNTY
•CASE NO: 2003-00328 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D 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:
KILLION PAUL J EXECUTOR OF ESTATE OF STANLEY D ADLER JR
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within WRIT OF REVIVAL
On March 28th 2003 this office was in receipt of the
attached return from DAUPHIN .
..
Sheriff's Costs: So answer ;
Docketin 6.00 ~ '~- "~
Out of County 9.00 ~ ' /~
Surcharge 31.50 R. Thomas Kline
Dep Dauphin County 10.00 Sheriff of Cumberland County
.00
56.50
03/28/2003
SAIDIS SHUFF FLOWER LINDSAY
Sworn and subscribed to before me
this ,2 ~,~,,~( day of /~,~,~
~U s~ A . D . `"~-
~.~rt LC / YLi Dpi ~ ~5~
U Prothonotary'
PNC Bank NA
VS.
Stanley D. Adler Jr et al
SERVE: Paul J. Killion executor of 03 328 civil
estate of Staneey D. Adler Jr. No.
~ 3 ~~~.~ 7007
Now, _ , I; SHERIFF OF CU1v~ER.LArTD COUN 1 Y, PA, do
hereby deputize the Sheriff of Dauphin County. to execute this Writ, this
deputation being made at the request and risk of the Plaintifr`:
Sheriff of Cumberland County, PA
~f~id~v~$ ~f Se~vpee
Now,
within
20 , at o'clock M. served the
upon
at
by handing to
a
and made known to
copy of the original
So answers,
the contents thereof.
Sheriff of
.:~OS1'S
Sworn and subscribed before SERVICE
nee this day of , 20 I~~III,EAGE _
AFFIDAVIT
County, PA
D
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
PNC BANK NA
• KILLION PAUL J
Sheriff's Return
vs
No. 0592-T - - -2003
OTHER COUNTY NO. 03 328
AND NOW: March 25, 2003 at 11:35AM served the within
WRIT OF REVIVAL upon
KILLION PAUL J by personally handing
EXEC OF ESTATE OF STANLEY ADLER JR
to JANET EVENS (OPERATIONS COORDINATOR) 2 true attested copy(ies)
of the original
WRIT OF REVIVAL
to him/her the contents thereof at 200 N THIRD STREET
SUITE 1400
and making known
HARRISBURG, PA 17101-0000
Sworn and subscribed to
before me this 16TH day ~if `APRIL, 2003
r3 ~d
~~
PROTHONOTARY
So Answers,
Sheriff o w~ypk~in ounty, a.
By
uty Sheriff
Sheriff's Costs: $31.50 PD 03/20/2003
RCPT NO 176669
E TORO
SHERIFF'S RETURN - OUT OF COUNTY
•CASE N0: 2003-00328 P
COMMONWEALTH OF PENNSYLVANIA:.
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D 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:
KILLION PAUL J EXECUTOR OF ESTATE OF STANLEY D ADLER JR
but was unable to locate Him
deputized the sheriff of DAUPHIN
in his bailiwick. He therefore
serve the within WRIT OF REVIVAL
County, Pennsylvania, to
On March 28th 2003 this office was in receipt of t
attached return from DAUPHIN
_------
Sheriff ' s Costs : So answer • _ ~''- ,..~.~-~
Docketing 6.00 .~ ~ ~'"
Out of County 9.00
Surcharge 10.00 R. `Thomas Kline
31.50 Sheriff of Cumberland County
.00
56.50
03/28/2003
SAIDIS SHUFF FLOWER LINDSAY
Sworn and subscribed to before me
this ~ day of
~.~3 A . D .
~ Prothonotary
(~£ftcE ~f ~e ~l~ertff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717)255-2660 fax: (717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK NATIONAL ASSOCATION
vs
County of Dauphin KILLION PAL J EXECUTOR OF ESTATE OF
Sheriff's Return
No. 0222-T - - -2003
OTHER COUNTY NO. 03 328CIVIL
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for KILLION PAL J EXECUTOR OF ESTATE OF
STANLEY ADLER JR
the DEFENDANT named in the within WRIT OF REVIVAL
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, February 21, 2003
NEED BETTER ADDRESS. NOTE THAT WAS LEFT IS STILL THERE. IT SEEMS THAT
BUSINESS HAS MOVED.
Sworn and subscrib to
before th' ~2~1S~T day of E RUARY, 2003
~~~~~~~
PROTHONOTARY
So Answers,
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Sheriff's Costs: $31.50 PD 01/27/2003
RCPT NO 174623
SERVE:
PNC Bank NA
VS.
Stanley D. Adler Jr et al
Paul J. Killion executor of 03 328 civil
No.
estate of Stanely D. Adler Jr.
Now, January 23, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of ~uph'-r' County to execute this V~rit, this
deputation being made at the request and rislc of the Plaintiff.
g e~ ..
Sheriff of Cumberland County, PA
~f~d~vBt ®f S~rv~ce
Now, , 20 , at o'clock M. served the
within
upon
at
by handing to
a
aizd made known to
Sworn and subscribed before
me this day of , 20
copy of the original
So answers,
Sheriff of
~~'OsTS
SERVICE _
h~IIL.EAvE
AFFIDAVIT
the contents thereof.
County, PA
n
SHERIFF'S RETURN - OUT OF COUNTY"
'CASE NO: 2003-00328 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ADLER STANLEY D JR ET AL
R. Thomas Kline
.00
16.00
03/28/2003
SAIDIS SNUFF FLOWER LINDSAY
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
KILLION PAUL J EXECUTOR OF
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within WRIT OF REVIVAL
On March 28th 2003 this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Sworn and subscribed to before me
this ,Z~.,,~,,( day of
a~~ A.D.
~- ~h.~..e.~,, _
Prothonotary
Sheriff or Deputy Sheriff who being
to wit:
ESTATE OF BETTY J ADLER
_.__ -,
.._
..->
So answer ` ~ -~/_ ~~"~,"~~
~,.. .,
. 00
10.00 R Thomas ine
.00 Sheriff of Cumberland County
(!~y£~tCE LY# ~P ~~Prif~
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
J. Damel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717)255-2660 fax: (717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK NATIONAL ASSOCATION
vs
County of Dauphin KILLION PAL J EXECUTOR OF ESTATE OF
Sheriff's Return
No. 0222-T - - -2003
OTHER COUNTY NO. 03 328CIVIL
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for KILLION PAUL J EXECUTOR OF ESTATE OF
BETTY J ADLER
the DEFENDANT named in the within WRIT OF REVIVAL
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, February 21, 2003
NEED BETTER ADDRESS. NOTE IS STILL THERE. IT SEEMS THAT THE BUSINESS HAS
MOVED.
Sworn and subscribed to
before me this 9TH day of APRIL, 2003
PROTHONOTARY
So Answers,
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Sheriff's Costs: $31.50 PD 01/27/2003
RCPT NO 174623
PNC Bank NA
VS.
Stanley D. Adler Jr et al
SERVE: paul J. Killion exector of 03 328 civil
No.
estate of Betty J. Adler
Now, __ January 23, 2003 , I, SHERIFF OF CIJM~ER.LAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
~f~i~avit ®f S~>1-vpe~
Now,
within
upon
at
by handing to
a
and made known to
Sworn and subscribed before
ane This day of , 20
the contents thereof.
COSTS
SERVICE _ _ ~
MILEAGE
AFFIDAVIT
County, PA
20 , at o'clock
M. served the
copy of the original
5o answers,
Sheriff of
m
.p
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