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HomeMy WebLinkAbout00-06390 , SAlOIS SHUFF, FLOWER, & LINDSAY ATIORNBYS-AT-LAW 26 W, High Street Carlisle. PA SANDY POINT PROPERTIES, LTD., Plaintiff vi. STANLEY E. RICKRODE, JR., ADMINISTRATOR OF THE ESTATE OF PEGGY RICKRODE, Defendant AND NOW this IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No.: 00-6390 ORDER OF COURT 'ltl day of \\ IV) (' 2001, upon consideration of the with Motion for Rule Absolute, the Rule of this Honorable Court issued on May 2, 2001 is made absolute and the title to the mobile home known as Serial Number 08-L-19996 and Model Number SG147038FKSDV, be issued to the Plaintiff, Sandy Point Properties Ltd. I I .i'i ,1,1 ,', ':i' :,j' I:; I I : By the Court, j1 . fYI~ L :01 1* :) :?: J1:' "'C r' ~'" ..,";-.~ .'.., CPL:-~ =-.- ~_.J.. , ",j-n zr;:;. co ~~j~: (.1) ~:~. -<,"- J:<C' ,,--.. .--.--,-1,\ .~'---T1 ~O -:>'" 0--- ..'- --;....0 "'=0 '-P. om )>c: -,I ~ N ~ \0 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA SAND)' POINT PROPERTIES, LTD., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. Civil Action - Law STANLEY E. RIC~ODE, JR., ADMINISTRATOR OF THE ESTATE ,OF PEGGY RICKRODE, Defendant No.: 00-6390 MOTION FOR RULE ABSOLUTE NOW COMES Sandy Point Properties, Ltd" by and through its counsel, Saidis, Shuff, Flower & Lindsay, and moves this Honorable Court as follows: 1. On May 2, 2001, this Honorable Court entered a Rule up~n the Respondent to show cause why Terry Leiby should not receive the certificate of title to the mobile home which was at one time owned by the Estate and now purchased by Terry Leiby. The Court issued the Rule returnable 10 days from date of service. A copy of the Court's Order is attached hereto as Exhibit "AU. 2. On May 9, 2001, the Court's Order was served on the Respondent. A copy of the Certified Mail card is attached hereto as Exhibit "BU. 3. More than ten days have passed since the service of the Court's Order of May 2, 2001, and no response has been received II SAIDIS SHUFF, FLOWER & LINDSAY AITORNEYS.AT.LAW 26 W, High Street Carlisle. P A WHEREFORE, Movant prays this Honorable Court to enter a Rule Absolute ordering the title to be issued to the Plaintiff SAIDIS, SHUFF, FLOWER & LINDSAY By: John ID# 147 26 West High Street Carlisle, PA 17013 (717) 243-6222 II '" SAlOIS SHUFF, FLOWER & LINDSAY AtTORNEYS-AT-LAW 26 W. High Street Carlisle, PA VERIFICATION The undersigned, Johnna J. Kopecky, Esquire, avers that the facts set forth in the foregoing instrument, based upon information and belief, were developed from conversations with Terry Leiby and information gained in the investigation of this file, and this Verification is made subject to the penalties of 18 Pa, C.S. 34904, relating to unsworn falsification to authorities. SAIDIS, SHUFF, FLOWER & LINDSAY By II SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle. P A , , CERTIFICATE OF SERVICE AND now, this~day of ~~.A.~ 2001, I hereby certify that I served the w~in Motion for Rule Absolute this day by depositing same in the United States Mail, First Class, Prepaid, Postage in Carlisle, Pennsylvania, addressed to: Stanley E. Rickrode, Administrator of the Peggy Rickrode R.D.3, Box 34R New Bloomfield, PA Jr. Estate of 17068 I ,I :1 i'i! SAIDIS, SHUFF, FLOWER & LIND,SAY II II ~~~~ -, IYI~~,;,;lIIilll2iU:il~~~~I"",i\l-1(1mi;illli;'~'~1<I~lii<'0aii~~1&"fi4"~b:\'M':>W""",/U;j~Jjjall&~"lllijj.!ldliillll!~----' p, ',~O ," ~ ~~ ~~=,~~~ v~" L~,_ _ .,~ ~~ ,~." " ~~,"~" ". ~, "'"c. ~.,_o,' ~ ~",'~_ .j;J. 0- _ ". --~lllIiil~~*,,' ."~, '<<iliI.iM' n c:> C) C .,.., ~ '- .,-t "'003 c:: ~~~~ ~rTI % ':::f) , ZS;; ,',,0 .<:' cS, 1- ~~ _..-{<...) C "'0 6"'-' :.:: . ':D ~8 3 2M 5>c Y? 9; ~ - ?is eJ'l -< ._- = ~ "J '\ ~ R. Thomas Kline, Sheriff, who being dilly sworn according to law, states that a Sheriffs Sale of personal property was held on January 8, 2001, at which time one 12 x 70 Mobile Home, License No. 1292,64, and its contents were sold to Sandy Point Properties, Inc., for the sum of $1.00, it being the highest bid and best price quoted for the same. Date and Time of sale, Monday January 8, 2001 at 2:00 P.M.E.D.S.T. at the vacant field located at the comer of Wilbert Drive and Lucinda drive, Carlisle, Pennsylvania, this writ is returned stayed, per instructions from attorney. Sheriffs Costs: Advance Costs: Sheriffs Costs: $150.00 76.19 .$ 73,81 Docketing Poundage Advertising Law Library Prothonotary ~Milage ~Misc, ~ Surcharge ji:;;:::, Levy ~ Post Pone Sale ~ . Garnishee $ 18.00 1.49 10.00 .50 1.00 6.20 Refunded to Atty on 8/21/01 10.00 20.00 .:s \ " (J.> "(l Q 9 .00 $ 76.19 Sworn and Subscribed to before me this ~ day of lF~..l.. , 2001 A.D, g, &' 0. 11<,1,,- ,,~ r thonotary' ~./~ . R. Thomas Kline, ,,-:r;; By t1 <". ",+. L, l d:1'" L't - 1,0> Ci/... :J31'f7 Ru.-. Ilt;Z 7 f' jjtfi;"'-,.,;", ., ',UIilIt~~f.Hiii;","'"bl......-",~~~J!\\'I,a,;,!"'W"I.gl~~WL4di",.j)!1ii~W"'~"'~'"'~~-";1lii.:M' . l' ....~ 'Ii' ~'" ,~" ~~, :, - iL'~~ I;; F' ;'1 ;1 WRIT OF EXECUTION and/or ATTACHMENT PLAINTIFF(S) " :;1 1'1 "I :Li " 'I u'j Ij j 1 ; j 1 I ,I I:j p i " i COMMONWEAltTH OF PENNSYLVANIA) COUNTY pF CUMBERLAND) NO, 00-6390 CIVIL Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Sandy Point Properties LTD from Estate of Peggy RIckrode, RD3 Box 34R, New Bloomfield, PA 17068 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell All that certain Mobile ~ and contents of same located at the corner of wilbert Drive and Lucinda DrivE!, in a vacant field, Carlisle, Cumberland County, PA 17013 (2) You are also directed to attach the property of lhe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereolf; (3) If prqperty of thedefendant(s) notl~yied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notnyhimlherthat he/she has been added as a garnishee and is enjoined as above stated, Amount Due $2,045.72 L.L. % Due Prothy Other Costs $.50 $1. 00 Interest Atty's Comm Atty Paid PlaintiU Paid $31.75 Date: , September 19, 2000 Curtis R. Long Prothonotary, Civil Division a~ c P. 71)rJ]AA~L c.. Deputy ~: REQUESTING PARTY: Name Johanna J. Kopecky, Esq. Address: 26 West High Street Carlisle, PA 17013 AttornllY for: Plaintiff Telephone: 717-243-6222 Supreme Court 10 No, 53147 ""'c\":,?,-""",,,Yo"~\,r~'"""~ ~ -',,~".." .' ',', k'Ov.'", Wr,,~, '0,','" <""~"",,'<',.,,,, '. .~ "Ji',__,,_~\,", _",,,,~,,_,, '':' ,"',~_> ""_,, - """~""" ,,"" " -,""""",.,,',1 '^"". e" " ,.c' ,~,'" , ". -."", ,<, ~~ , ~~. ,,~ ~, -- <,~" ,",","'."~' ~ "0' , ," I' ,~ -~ - ~ ,',--"--, ""- c ... SHERIFF'S SALE BY VIRTUE OF WRIT OF EXECUTION NO. 2000-6390 CIVIL TERM ISSUED OUT OF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, AND TO ME DIRECTED, I WILL EXPOSE TO PUBLIC SALE ON MONDAY, THE 8TH DAY OF JANUARY 2000 AT 2:00 PM, THE PROPERTY OF THE ESTATE OF PEGGY RICKRODE, AT A VACANT FIELD AT THE CORNER OF WILBERT DRIVE AND LUCINDA DRIVE, CARLISLE, CUMBERLAND COUNTY, PENNSYL VANIA THE FOLLOWING PROPERTY TO WIT: 12 X 70 MOBILE HOME, LICENSE NO 129264 TWO CHAIRS COFFEEIEND TABLES MISC, FURNITURE PICTURES STEREO SEWING MACHINE FAN FOOTSTOOL DINETTE TABLE CHAIRS POTS/PANS GAS STOVE GEWASHER WHIRLPOOL DRYER COFFEE POT COFFE TABLE BED TWO DRESSERS TWO CHAIRS TWO LAMPS NIGHT STAND TELEVISION DESK HEADBOARD R. Thares Kline. Sheriff. who being duly sworn accordin9 to law. saystbat due and legal,notice bav:j.ng been given accc"rihna to Ipw. he sold. one 12 x 70 JliJobJ.le Home, LJ.Cense No. 129264, and contents.to Sandy Point PropertJ.es, LTD. 283 Echo Road, Carlisle~ PA 17013, for the sum at-? l.Oa it being the highest bid and price quotea for the same. Date and bme of sale, Monday, January 8. 2001 at 2:00 P.M.E.D.S.T., at vacant lot located at, the comer of Wilbert Drive and Lucinda Drive. Carlisle, Pennsylvania. this s~~~ r~ t"~Sheriff Sworn and Subscribed to before me 2001 I . # - - --. .. (A) ALL CLAIMS TO PROPERTY MUST BE CERTIFIED AND FILED WITH THE ~HERIFF BEFORE THE SALE, ALONG WITH THE PRESCRIBED FEE OF FIFTY-FNE DOLLARS ($55.00) (B) ALL CLAIMS TO THE PROCEEDS MUST BE FILED WITH THE SHERIFF BEFORE DISTRIBUTION. (C) THE SHERIFF'S SCHEDULE OF DISTRIBUTION WILL BE FILED IN HIS OFFICE ON THE 13TH DAY OF JANUARY2000 NOT LATER THAN FIVE (5) DAYS AFTER THE SALE, AND DISTRIBUTION WILL BE MADE IN ACCORDANCE WITH THE SCHEDULE UNLESS EXCEPTIONS ARE FILED WITHIN THE TEN (10) DAYS THEREAFTER. TOGETHER WITH ALL THE BALANCE OF THE DEFENDANT'S PERSONAL PROPERTY SEIZED AND TAKEN IN EXECUTION AS PROPERTY OF THE ESTATE OF PEGGY RICKRODE, AT A VACANT FIELD AT THE CORNER OF WILBERT DR. AND LUCINDA DR., CARLISLE, CUMBERLAND COUNTY, PENNSYL VANIA. AND TO BE SOLD BY: R. THOMAS KLINE, SHERIFF CUMBERLAND COUNTY SHERIFF'S OFFICE CARLISLE,PA 17013 POSTED {J-;JG'(JO l~ rsfirsr 12J;\ CUMBERLAND COUNTY SHERIFF'S OFFICE CARLISLE,PA 17013 ~ ' ,j - '~..I "";". . , SANDY POINT PROPERTIES, LID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW STANLEY E. RlCKRODE, JR" ADMINISTRATOR OF TI-IEESTATE OF PEGGY: RICKRODE, Defendant NO. 00-6390 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of May, 2001, upon consideration of Plaintiffs Petition To Award Title, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY TIlE COURT, J. Johnna J. Kopecky, Esq. 26 West High Street Carlisle, P A 17013 Attorney for Plaintiff :rc ^" - - lll!ll!ll ~,=. ~-~ -."~ '^'; ~ -," ~', '. ' ',~-,""~,, ~._, ".--. . HtEO -OFFICE OF' T' :~:'''''H]f'''(!T!->P,Y 01 ~IAY -3 PN I: 27 cu"'", , 1(' """I"TY ivld,':r1I.Af\,.J C(JU ''J PENNSYLVANIA , " ,~" , l"II!'III~~r~Jl!lIlml!!'Wl'J illl.. ~\ ,11:' .'"'~~ .. -"'---'r" ~i~ffi'I~ ,".,~liq~I1l~, ' -8)l:~_.,,_ SAIDIS SHUFF, FLOWER & LINDSAY ATrORNBVS.AT-LAW 26 W. High Street Carlisle, PA ," ."~ <<,',,' -"", '., SANDY POINT PROPERTIES, LTD., :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. :Civil Action - Law STANLEY E. RICKRODE, JR. ADMINISTRATOR OF THE ESTATE OF PEGGY RICKRODE, :No.: 00 CCOG "'3'10 Defendant ORDER OF COURT AND NOW, this day of , 2001, in consideration of the attached Petition, the mobile home previously located at 7 Wilbert Drive, Serial Number 08-L- 19996 and Model Number SG147038FKSDV, is hereby ordered to Terry R. Leiby so he is free to receive a certificate of title to said vehicle. This Order also extinguishes the right, title and interest of any other person in said vehicle, BY THE COURT: J. II SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEys.AT.LAW 26 w. High Street Carlisle. PA SANDY POINT PROPERTIES, LTD., :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. :civil Action - Law STANLEY E, RICKRODE, JR. ADMINISTRATOR OF THE ESTATE OF PEGGY RICKRODE, :No.: 00-6930 Defendant PETITION TO AWARD TITLE AND NOW comes the Petitioner, Sandy Point Properties, Ltd. by Terry Leiby, through its attorneys Saidis, Shuff, Flower & Lindsay to aver the following: 1. Your Petitioner is Sandy Point Properties, Ltd., run by Terry Leiby, an adult individual residing at 283 Echo Road, Carlisle, Cumberland County, Pennsylvania. 2. The Respondent is the Estate of Peggy Rickrode, by Stanley E. Rickrode, Jr., as the Administrator of the Estate, residing at R.D. 3, Box 34R, New Bloomfield, Perry County, pennsylvania. 3. The Sheriff of Cumberland County sold, pursuant to the Writ of Execution and an attachment, a mobile home and its contents at one time owned by the Estate and now purchased by Terry L. Leiby. 4. The title to the mobile home apparently has been lost, or is not provided to the Plaintiff by the Respondent. " I, I: I! " . SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS-AT-LAW 26 W. High Street Carlisle, PA ,~ " "" - <". -- ,), ~~u',~ WBEREFORE, the Petitioner requests Your Honorable Court to enter an Order awarding him title to said mobile home so that he may become the owner of said vehicle. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Dated '-1- 2<f-o l ecky, uire Atto ney I . # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff 2 II SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT'LAW 26 W. High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 3 4904, relating to unsworn falsification to authorities. i DATED: 4-d5~O\ ~~ Connie Leiby II SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS'AT-lAW 26 W. High Street Carlisle. PA - On this CERTIFICATE OF SERVICE )l~'" day of ~~ t ~ , 20tL!., I hereby certify that I served a true and correct copy of the foregoing Petition upon all parties of record via United States Mail, postage prepaid, addressed as follows: Stanley E. Rickrode Administrator of the Estate Of Peggy Rickrbde R.D.3, Box 34R New Bloomfield, PA 17068 SAIDIS, SHUFF, FLOWER & LINDSAY II , ~~~Ol,-.~,>J,~~~Wltllili_'",","i~$..~"""_'iiisJ'4:~""'4",j:&.fi~~~iil!Miili!!' .~ ~.'~',~ .~,," ,,"- ~~".. , .., ,>", . ~.., . ~~-H.k =" ' -Ai.1a 1~1IIlIlIiI""".= < ~:+: I' fi lij '; I' "I h Ii p [! (') 0 C) c: "'11 ,,~ "'" ::;:1 -otu -0 ;-:clp OY"' ;U .z: :c Z~:, '" -nr--r; (p "":;~ 0', .,.:)1::',:::: , - .::..(.<:,. :,~:-,c.) ~CJ -0 ~-,.2'l )> :.J; ,'L~ :f.) -;;-Cj "-"0 ~O t.:> :.=; f71 5>e ',~", :;2: f;'" :~ -.... ;:0 "< ,;n .< -.", ,-~,~'S:/,-'f' ,._",,~. .. .>-'~ .~-".,""- . ,~. - ""' ~ . --~, ""1"", SHERIFF'S RETURN - GARNISHEE CASE NO: 2000-06390 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SANDY POINT PROPERTIES LTD VS RICKRODE PEGGY ESTATE OF And now STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, at 0924:00 Hours, on the 22nd day of September, 2000, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT ESTATE OF PEGGY RICKRODE in the hands, possession, or control of the within named Garnishee TERRY L. LIEBY 283 ECHO ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CONNIE LEIBY, WIFE OF GARNISHEE personally THREE true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So a?~~J R. Thomas Kline Sheriff of Cumberland County o%%o~ ~ ~ By /A1 LA ;1'l,~ ,Deputy erl f Sworn and subscribed to before me this Sl:t? day of ~ ,;Lbv-O A.D. ~t2.~~ Pr h notary , -- ~ ~ ..J 1~it ~ · COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag, Dist. No.: 09-2-01 OJ Name: Hon. PAULA P. CORREAL A""" EAST 'WING - CO~THOUSE 1 COURTHOUSE SQUARE CARLISLE, PA T",pho", (717) 240 - 6564 17013 - 0000 SANDY POINT PROPERTIES LTD 283 ECHO RD CARLISLE, PA 17013 'f: '~1 ' 'Il ~1 1'; ~ ,<"I~''''"Mdll,_~ <'I""~. I . l1r~, 06 - ~JqD C'U l'( NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'sANDY POINT PROPERTIES LTD ., 283 ECHO RD CARLISLE, PA 17013 L --1 VS. DEFENDANT: NAME and ADDRESS 'ESTATE OF PEGGY RICKRODE RD3 BOX 34R NEW BLOOMFIELD, PA 17068 L Docket No,: CV- 0000150 - 00 Date Filed: 4/13/00 ., --1 TliIlS IS TO NOtIFY YOU THAT: Judgment: DEFJl.m.T .TIJDGM"Rl\l'I' PJ.TF " [!] Judgment was entered for: (Name) l'IlI.NTlV l>nTN'I' l>Rnl>RR'T'TRl'I T.'T'n [!] Judgment was entered against: (Name) R!'I'I'lI.'I'R OF PRf',.GY llTf'XllOnF: in the amount ot $ 2,04" 72 on: o Defendants are jointly and severally liable, o Damages will be assessed on: o This case dismissed without prejudice, D D Amount ot Judgment Subject to AttachmenVAct 5 of 1996 $ Levy is stayed lor days or D generally stayed. o Objection to levy has been filed and hearing will be held: (Date of Judgment) "/1"/00 (Date & Time) Amount of Judgment $ 1,957.72 JudgmentCosts $ 88.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.045.72 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ Date: Place: \ Time: , 5/15/00 Date I certify that this is a true 5/15/00 Date My commission expires first Monday of January, AOPC 315-99 , District Justice taining the judgment. , District Justice 2006 SEAL ~M!I!lllif~!I<.0.&_~,*til~~~MimOii:aiiM~'lit'i*'kr.;,"',to.M&'rjfij~~,"~~~i%,J..~~"~F""'-!f_,l~"~! 11 'ill.!i~""""-' ~-JllUlil!l l"_ -, . , C') 0 c- O S~ -i" ~e.:J en t ~ ~ "'iq, m I"TI :,;::1 ...... 3j:J.? ""0 h1;7] ;.t ;:s~: <.D 'of1; ::no r-.> ~C, C) I ;r". ---:0 0 )So ;!:'=H - ~8 ::ll: !O .. )..,- ~ ...... 9 ;2'0 0 ~m "if! ~ v ..... & g j IV c..;, " -<: ~ ll' ~ - if 0 '<.. _,."'".,'.'.' -'"",,;'-_.0 ;.,", , SANDY POINT PROPERTIES, LTD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vi. Civil Action - Law ESTATE OF PEGGY RICKRODE, NO,: OO-I.J?O (!;(.)l{ Defendant RULE 236 NOTICE To: Estate of Peaav Rickrode Defendant(st You are hereby notified that on l1.p-+- 19 ' 2~, the following (Judgment) has been entered against you in the above-captioned case, DATE: (( lIe, /60 I I kf (J_--L.2 72. ~ ' I Prothonotary " I hereby certify that the name and address of the proper person(s) to receive this notice is: Estate of PeQav Rickrode R,D.3. Box 34R New Bloomfield. PA 17068 \ '\ . SAIDIS,i! SHUFF & :i MASLAND 'i ATJ'ORNEYSIIAr-LAW !i 26 W. Higb Street Carlisle, PA '. ,,-", SANDY POINT PROPERTIES, L TO Plaintiff v, ESTATE OF PEGGY RICKRODE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No,; CX:> - l-~'i6 C?;;;,~l PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Plaintiff, Sandy Point Properties, Ltd. in the above-captioned matter and enter judgment against Defendant by reason of attached Notice of Judgment / Transcript in the amount of $2,045,72. Date 9- r3-a-u Respectfully submitted, SAlOIS, SHUFF, FLOWER & LINDSAY .czJ By: Jo a 'J, K ecky, Esquire Attorney 1.0. No,: 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff ,,<-'~, '"-*iit_;i~~ """"'~U."~' - ri,-"".~~ '" ~..;,;; "-~""'....... 0 0 () C- O -,., ~ en '2 ~(D ...... ~8 -0 rniJJ, zy -om C/)> '" ;>!y -<': ~o ~:::;o 1> .---r' ~(5 ::x i'~-tI " 0 -( S? c3m PC: -~ -..; "'- ~> :~ en ::cr -<; ,- ,.0"0.,,,,,, "I',' 1 iJ it !i ,"__, ,~ ' l , ' , .',". --.j,-'",-, . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION SANDY POINT PROPERTIf:S, L TO, Plaintiff () Confessed Judgment vs, ( x) Other CV-0000150-00 , Mag, Dist. No, 09-2-01 /'). I File No,: ~- (.,J'fO ~/(,.>I L. Amount Due: $2,045,72 ESTATE OF PEGGY RICKRODE Interest: N/A Defendant Atty's Comm: N/A Cost: TO BE ADDED TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1996 as amended; and for real property pursuant to Act 6 of 1974 as amended, Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendants(s), All that certain Mobile Horne and contents of same located at the corner of Wilbert Drive and Lucinda Drive, in a vacant field, Carlisle, Cumberland CQunty, PA 17013. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberiand County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, suppiy six copies of the description; supply four copies of lengthy lJersonality list) All that certain Mobile Home and contents of same located at the corner of Wilbert Drive and Lucinda Drive, in a vacant field, Carlisle, Cumberland CCilunty, PA 17013 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: September 19, 2000 Signature Y~~J$s- Print Name: Johnn ,Kopecky Address: 26 West High Street Carlisle, PA 17013 Attorney for: Plaintiff Telephone: 717-243-6222 Supreme Court ID No,: 53147 ~~it~J.I~~lIillil-_<iffil~l,m~MllIialli1t~liiIli~eJ~~""-'"~'lir-~"""'~'~'~~~'-~'''''' ~ ~~ ,~ I .h. 11."'-..... ,,'" 'i':: I' I I II: I' , i " Notes: If real property, supply Six copies of description including Improvements and an original and copy of affidavit of ownership (PaR,C,P,No, 3129), If lengthy personality list, supply four copies of iist To index writ, file separate Praecipe with writ ~'~ ~ -0 6' :-<:} ~ Q; i:- f ~ I' ~ :'-. o C ~ ~ Uv :--. '-~ ~-t!-i () ~ 0 I 7 () ~ ~~ , r>::J ~ .... 1- ',:f(. ~ - - " --. () ~ 2m ~~ :;:;::c::: ~o 5>;;;; Z :;? I',' Ii o <::> en rrJ -0 ~~ '--l :1:-. tll..,..!.J; F -:r,p:{ .,11V c=J6 ~~~A t5iM ~-f' :!fi -< \D :t>> :x S> (Jl