HomeMy WebLinkAbout00-06509
- "J___
c__ -_-_,.___~""_,,:_,__ ""_--"'-;<_<- ; -";'_'~' ',,,,,,,;_:,_ -',,' ----'-'''"oi.~i''''\,,:;;--,;_~,,'' '" ;,,;- c _
.-:,,-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY BANK OF
PENNSYLVANIA, successor by merger to
INTEGRA MORTGAGE COMPANY,
Plaintiff,
vs.
JODY L. WARRICK,
Defendants.
TO DEFENDANTS:
YOU ARE HEREBY NOTIFIED TO PLEAD TO
THE ENCLOSED COMPLAINT IN
EJECTMENT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT
JUDGMENT MAY BE ENTERED AGAINST
YOU
~
CIVIL DIVISION
NO r" /). ,k t.u--
.: tJ-o. ~..:J07 ~
COMPLAINT IN EJECTMENT
Code EJECTMENT
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.c.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
. < " " m ~"'" ,_ ."
. .-~- '" "--,-, ":1':
...
COMPLAINT IN EJECTMElIT
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 THE ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES AND 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 SHOULD 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 LffiERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
.,-'O~~~"'o_""- ,. _ ,,_< "'",
~~-"'-",dN_,.("=<=_<O'!?"" ,-c, -
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA, :
successor by merger to INTEGRA MORTGAGE
COMPANY,
Plaintiff,
'11.0, frv. &,$"09 ~ I.u-
vs.
JODY L. WARRICK,
Defendant.
COMPLAINT IN EJECTMENT
AND NOW, comes the above-captioned Plaintiff, National City Bank of
Pennsylvania, et aI, by and through its counsel, Louis P. Vitti & Associates, P.C. and Louis P.
Vitti, Esquire, who files this Complaint as follows:
I, The Plaintiff is a corporation having a principal place of business located at
3232 Newmark Drive, Miarnisburg, OH 45342.
2. The Defendants are individuals, sui juris, whose last known address was 1404
Tridle Road, Carlisle, PA 17013.
3. On April 30, 1996, the Plaintiff's predecessor in title lent to Defendants and/or
their predecessors in title, the sum of Forty-Five Thousand, Six Hundred and 00/1 00
($45,600.00), and in consideration thereof, the Defendants and/or their predecessors in title,
executed a mortgage which was recorded on May 1, 1996, in the Office of the Recorder of Deeds
of Cumberland County in Mortgage Book Volume 1317, page 92.
4, The premises secured by the mortgage are:
See description attached hereto as Exhibit "A".
'~--. - ."'-~-''''',.-.F~;''', -.;~',-, - ',-' _'_"~"""'~'_G"; -.~-,,_';_(,"'_'," ',- '.~--.-' , ' 'w _'~- ~_"'
5, The mortgage provides generally that in the event of default of payment and/or
installment of principal and/or interest, inter alia, that it shall be lawful for Plaintiffs to institute,
inter alia, an action in mortgage foreclosure.
6. Since January 1, 1998, the mortgage has been in default by reason of the
failure of the mortgagors to make appropriate payments.
7. An action in mortgage foreclosure was instituted in the Court of Common
Pleas of Cumberland County at No. 98-2884 Civil Term, and ultimately a Sheriffs Sale occurred
on September 6, 2000.
8, Plaintiff has been caused to expend various sums of money in an effort to
pursue this action and in addition, has incurred substantial losses in money as a result of
Defendants' occupancy of the property and the termination of appropriate mortgage payments
and/or other payments.
9. Defendants and/or all other occupants continue to occupy the said premises
described in Exhibit "A".
WHEREFORE, Plaintiff prays Your Honorable Court enter Judgment in favor of
the Plaintiff, National City Bank of Pennsylvania, et aI, for sole possession ofthe property and
vesting the title of said premises to the Plaintiff as prayed for in the Complaint.
Respectfully submitted,
LOUIS P. VITTI & ASSOCIATES, P.C.
By:
q~
L . P V' . E .
oms . tttt, sqmre
Attorney for Plaintiff
^' ~
.~'-
ALL THOSE CERTAIN three parcels of ground with improvements situate in South Middleton
Township, Cumberland County, Pennsylvania, bounded and described as follows:
FA-RC'F! NO 1: BEGINNING at a point on the edge of the right of way ofTrindle Road (Pa. Route
641) in the comer ofland now or formerly of Robert C. Lebo; thence along the Trindle Road South
78 degrees 28 minutes 20 seconds East twenty and sixteen hundredths (20.16) feet to a point in the
comer ofland now or formerly ofWrn. W. Kiner; thence along land now or formerly ofWm. W.
Kiner South 11 degrees 35 minutes West one hundred twenty-three and forty-five hundredths
(123.45) feet to a point; thence along the boundary in common with Parcel No.2 herein; conveyed,
North 77 degrees 24 minutes West twenty and sixteen hundredths (20.16) feet to a point in common
wi.th lands now or formerly of Robert C. Lebo; thence along lands now or formerly of Robert C.
Lebo North II degrees 35 minutes East one hundred twenty-two and nine tenths (122.9) feet to the
point and place ofBEGlNNING.
SAID description is in accordance with a survey filed of record In Cumberland County
Miscellaneous Book 195 at page 472.
BEING improved with a row dwelling house.
P A RC'FI NO ": beginning at a point, being the Southwestern comer ofIand now or tCll1nerly of
Jimmy H. James and wife, Parcel No.1 above; thence by the said land, South 77 degrees 24 minutes
East 20.16 feet to a point, the Southeastern comer of said land: thence by land now or torrneriy of
William W. Kiner and wife, now or formerly of Mark A. Lebo and wife, South II degrees 3S
minutes West 40 feet to an iron pin on line of other land now or torrnerly of Erma F. Jumper. thence
by the latter lands, North 77 degrees 24 minutes West 20.16 teet to an iron pin at line of lands now
or formerly of Robert C. Lebo and wife; thence by the latter land, North II degrees 35 minutes East
40 feet to the Place of Beginning.
SAID description being from a survey thereof made by Thomas A. Neff. R.S., dated November IS,
1965 aforementioned recorded in Miscellaneous Book 195 at page 472.
PARC:FI NO 1: an undivided one-third interest as tenants in common with the other owners
mentioned in a prior deed, Deed Book "C", Volume II, Page 1111, as follows:
BEGINNING at an iron pin on the Eastern side of Township Road No. 512 and the Southwestern
comer of/and now or formerly of Robert M. Frey; thence by the latter land, South 77 degrees 24
minutes East 122.56 feet to a stake at line ofland now or formerly of Robert C. Lebo and wife;
thence by said Lebo land, South 11 degrees 35 minutes West 40 feet to an iron pin on line ofland
now orformerly of Erma F. Jumper; thence by the latter land, North 77 degrees 24 minutes West
117.20 feet to an iron pin on the Eastern side of said Township Road; thence by the latter road, North
3 degrees 57 minutes East 40.35 feet to the Place of BEGINNING.
SAID description being from a survey thereof made by Thomas A. Neff, R.S., dated November 15,
1965.
BEING the same property which Jerre D. Locke and Linda M. Locke, by their Deed dated April 30,
1996 and recorded in the Recorder's Office of Cumberland County May I, 1996 in DB 138, p. 501,
granted and conveyed unto Jod'lf L. Warrick. II
EXHIBIT -11--
- - ." .,," - -', ~-
-.-''_-'""-.,,,,;.},,-,."'. .~,,;. ";.;!b~~-'~;',
,.-"
.
YERIFICATION
AND NOW Louis P. Vitti verifies that the statements made in this Complaint in
Ejectment are true and correct to the best of his knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S, 4904, relating to
unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and
the verification cannot be obtained within the time allowed for the filing of this pleading, the
pleading is submitted by counsel having sufficient knowledge, information and belief based upon
the information provided him by the Plaintiff.
~~
Lou s P. Vitti
Dated: September 21,2000
,,,,,,-,'.,,
^"'If('o~lii"'l-iL'rJ
r~
- "-
~~
~~
<:::$
., -,~ < '~~'''--'~-~''''
.~ 0 ". _,
:tiY<~j,5j-.;jt~_
.Iii Ulj"if'-J
_ ~, c . __<
^." ^" -,.. ,,- ,,-
..
~Ne
,~:J ~,~---
()
c:
-.,$"
ri'(n5
Zf.!i
2--l,)
c/)r:::
;:$ ;".:
'EU
~\)
;t;;{)
C'
;2; 9?
::< :.v
c,.,
"""
~
"
o
o
V"J
".,
-0
i'V
c,
o
"
::'f
,;';~
~;~if)
S2;:}
(3rt)
~
.JJ
-<
8
~
Jf
"
..cOO
Yi \l\ .i
~ .'
~ ~
t
~
r'
.~ J:t...JO!;.-
~ ,
~" ~'~""'ll\kl!i,,-:
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06509 P
COMMONWEA~TH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONAL CITY BANK OF PENNA
VS
/
WARRICK JODY L
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
WARRICK JODY L
the
DEFENDANT
, at 0014:42 HOURS, on the 28th day of September, 2000
at 1404 TRINDLE ROAD
CARLISLE, PA 17013
by handing to
JODY L. WARRICK
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
3.10
.00
10.00
.00
31.10
S:;~~~<~,
R. Thomas Kline
09/29/2000
LOUIS P. VITTI & ASSOCIATES
Sworn and Subscribed to before
By:
7j,~~ ~-/LA7/
Deputy Sheriff/
me this o''E
day of
(}~ c21r/J7J A.D.
9tt;., , a. /n<'€I~~, ~
rothonotary
;,,,',,,",
.... . .
,'/ '-"-""''''''^''-' ,,,- ,--'-o""-'j'-,,,'::ie--0','ilii..,,_~;-~_" ,___~,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY BANK OF
PENNSYL VANIA, successor by merger to
INTEGRA MORTGAGE COMPANY,
CIVIL DIVISION
No, 00-6509 CIVIL TERM
Plaintiff,
PRAECIPE FOR DEFAULT
JUDGMENT AND CERTIFICATION
OF MAILING AND AFFIDAVIT OF
NON-MILITARY SERVICE
vs.
Code 040 EJECTMENT
JODY L. WARRICK,
Filed on behalf of
Plaintiff
Defendants.
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA LD. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P,C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
,~<;"
"liilll.':
""",<,,.,'.-
ilij~~~iG'~"'j"-'-
~.",
(:) CJ 0
c: c::> ..-n
s: ;J!: ,._l
-o(";j CJ -7\
rnfT; ,.,-~
z-n I _,_,'(t'l
'&5S f'0 :.,-;_'~C?
~/..,. ::::";C)
r;;:C; '"" .,,~ -\".
~O :~ ~:} (1)
=0 ',Oc-::;,rn
:P>c: "1: ':::::'1
~ f'.' ">"'>
::0
c.n ..<
=.~'~ . ,Y'" '
. "~~. - "" ',~ ,
"'~', .
,","~ ,,~_~.~ ,,,-, ~o'
... i
i
i
i
I
I
I
!t
.
- .' ~:
...
'-~',~_/_- ------~ ,.--' --,"-~ -"-""'---",",",;",,',,",' --,- ^~ ~ ' -."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA, :
successor by merger to INTEGRA MORTGAGE
COMPANY,
NO. 00-6509 CIVIL TERM
Plaintiff,
vs.
JODY L. WARRICK,
Defendant.
PRAECIPE FOR DEFAULT JUDGMENT
TO: CUMBERLAND COUNTY PROTHONOTARY
Please enter judgment for possession and/or ejectment as a result of the Defendants'
failure to file an Answer and/or a responsive pleading.
LOUIS P. VITTI & ASSOCIATES, P.C.
~tIfO
Attorney for Plaintiff
-~~-, -
. -~~ '~IlJi.li--- J.Wi~_-l!i~Jji!at g( Jt C-"'lioiiiiffij~ld:;ei
",~+."- ~'- .,.-
'-"~ ,--;
qu_
"
'~b".Ii
(') Cl 0
C 0 ,.
;;::: - .. -j
-om C5 - .
nif!'! .' -
"'- ,.
z=c:; I -',-1 '!T\
zc ~)!.?
if) ::Z N (;t~
--<.
~C) --0
2?c! -~'"
~...,,-~
Z.C' ':? ';~.; rn
)>c l....,,)
~,
~ N :D
(Jl -<
.--.
..
....
..
.,iC
...
~_ __~ 'on, __,.k'_. -o'__'_"~",,~_,,",_~-~,,_,_,,,___,-_,_y, ,_,,_.,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA, :
successor by merger to INTEGRA MORTGAGE
COMPANY,
NO. 00-6509 CIVIL TERM
Plaintiff,
vs.
JODY L. WARRICK,
Defendant.
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice ofIntention to Take Judgment was
mailed to the Defendant(s), in the above-captioned case on October 19,2000, giving ten (10) day
notice that ju~gment would be entered should no action be taken.
LOUIS P. VITTI & ASSOCIATES, P.C.
nY~~
Attorney for Plaintiff
SWORN to and subscribed
before me this 31 st day
of October, 2000.
fA.
Notary Public
Notarial Seal
Rebecca L. Kirch, Notary Public
Pittsburgh, Allegheny County
My Commission Expires Nov. 10, 2003
Member, Pennsylvania ASSOCiation of Notaries
;;'--,.=:'
...'tp'iJi
.I.J:laj;~lMi~-
"__~,_p_ _ '_~"."T '.' 'V,c "_,__~_ _",
-~.- --I"
"
""
.-
.,
.
(') (:::;, 0
C 0 -1'1
$:: Z .-<
-om C) ~-!:~ -'r'
mrn ..-;::: nT.?~
z:c I "....\
~~: 1'0 . ,'-;-l:;:'
:::) ,.L,
c::c: -...j>-.-'
-'0 ., ,- r ~
Po ....... ~~~~ 2;
20 ':t? c5rn
)>c -~
~ 1'0 ~
(Jl --<
,~" -
'"
'-.
-
,
" ,-,,- .~,~,,>--
~ -~
~- ~,",,';
. >.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA,
successor by merger to INTEGRA MORTGAGE
COMPANY,
NO. 00-6509 CIVIL TERM
Plaintiff,
vs.
JODY L. WARRICK,
Defendant.
IMPORTANT NOTICE
TO: Jody L. Warrick
1404 Trindle Road
Carlisle,PA 17013
Date of Notice: October 19, 2000
YOu ARE iN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITillN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
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 FOLLOWING
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
BY:
L' itti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. **
,-- .<J._ ~~, "~if~~~~j1t~illi<l;h"',i~O&~~.dAi'
-
.'"
~li!!ii!Iii
'-1
1'j
'11
Il.~
"
Ij
"
;1
i
I
,
(') 0 {J
c: CJ -n
So Z -4
-UW D --,,'
rnn1 <C -~ .,.'-
Z,:XJ I ;"'.!~
z:;:
(J) .2: r-~ ~~~~.)
~~:::-
~c:; -0 .-"..---,
~Q ::t: ~;;?~-)
):>C c..:> ,__~ln
~,
C ,., S;
~ "" :0
-< (J1 --<
'"
-~<^'
.~,- "..". .,-
';;"<'_.~ .-''-, "-,i-".";'''--":;;~,,,,, '-,'-~l'", ",,'
,.,..'.
,<"jj
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY,
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire,
who, being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of
America and not members of the Army of the United States, United States Navy, the Marine
Corps, or the Coast Guard, and not officers of the Public Health Service detailed by proper
authority for duty with the Army or Navy; nor engaged in any active military service or duty
with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 and
designated therein as military service, and to the best of this affiant's knowledge is/are not
enlisted in military service covered by said act, and that the averments herein set forth, insofar as
they are within his knowledge, are correct, and true; and insofar as they are based on information
received from others, are true and correct as he verily believes.
This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of
1940.
~G?~
SWORN to and subscribed
before me this 31 st day
of October, 2000.
Notarial Seal
Rebecca. L. Kirch, Notary Public
pittsburgh, AlleQheny County
My Commission ExpIres Nov. 10,2003
Member, pennsylVal11aAssOClatJonOf Nntariec.>
:1ulJUCc..d r){j('(jl.
Notary Public
......,. ,
.,~ ~"
'.
~ 'iliiia>;""
1lIft.1:il!"'-ll'iiR
,-. ~ ""-~.
rnl!J~~'~-~-"
'.".
~'m
....,'....
.,'.d'
.......'
-
~ ~ (') 0 ri~
~ c: 0
Z'
-00' Z
IT1 fT~ 0
z::u ,;~ :-,-i;:~2
" ZC I :..,.,
~-4: 1'0 '~)
~ r:: C~ ,L
"'-' -0 ':.;"J
of; -~ :.:z
~ . ",--U I'"''
0 ~> C)
~ >c to" ~;n
~ N
(J1 ~,
--<
~~
" l.
~
Cv C~
QE
"'t (\\
,~ -
~
..
"
";,',,.' ~'"",~"" 1"-"<;'-""0'"4">':;;' ;,' .OJ" ,ii'q "~_ _,
-.,t',:,
",.
~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY BANK OF
PENNSYLVANIA, successor by merger to
lNTEGRA MORTGAGE COMPANY,
CIVIL DIVISION
No. 00-6509 CIVIL TERM
Plaintiff,
PRAECIPE FOR WRIT OF
POSSESSION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
Code 040 EJECTMENT
vs.
JODY L. WARRICK,
Filed on behalf of
Plaintiff
Defendants.
Counsel of record for this
party :
Louis P. Vitti, Esquire
PA J.D. #3810
Supreme Court #0 I 072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
-~--~~
-I "~
, --"v.i-",i,,"';~
~i:iilIi!lii~-_Iftl~li.Ji_hj$iil',.u.; iii ~..
I,__
""" ".~,~~ "'.",...,,~~" ,~
y-"-
,-
_,c.c,
., .~'"'"
~
(') L"J C'I.
C <::I -'
<" "f'!
CJj'f; ;,e
mrn L"J
Z:::r; "c:: fQ
Z ., I
We 'I"tl-;j
,'-, -~;, l:=-r
:-< ;.2~ <~-~{~
~c
)3: ." ~-j-,
ZO :x ,-, Tj
pO ::~i'()
c: ~ brn
z N s;!
::<! <.1'1 :n
-<
'-~
-I
~
....
,_.~ .~, _"'. .,--,- -_,~_o ''-0 ..-' ,',._ ,~,__~""-" .-_o,___,__,,,,~, ""__
'" ,,"-,_.
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA, :
successor by merger to INTEGRA MORTGAGE
COMPANY,
NO. 00-6509 CIVIL TERM
Plaintiff,
vs.
JODY L. WARRICK,
Defendant.
PRAECIPE FOR WRIT OF POSSESSION
TO: CUMBERLAND COUNTY PROTHONOTARY
Please issue a Writ of Possession in the above-captioned case for the property situate in
South Middleton Township, Cumberland County and Commonwealth of Peunsylvania. Having
erected thereon a dwelling known as 1404 Trindle Road, Carlisle, PA 17013. Pin 40-22-0119-
004.
LOUIS P. VITTI & ASSOCIATES, P.C.
....
~(1~
Attorney for Plaintiff
.
~~~'""
- "ilk
.:...;..""'...
-",- ~-,,' ~-,-,
,.~"".
-'--~:M:~'--''-"
, , ~" ~--" .
" i~1::iJ l'~ll.itil!l
~iilliili"Jl.
,."
-~ .,~~
":;~
'O"flit"
--~ .'
......
(') <::> ()
c: Cl ~n
-o~ ~
C.)
f11r,-; ,~ ''::'-:::::
2-1~
:z: C- 1 --:";c'Tl
~j~:" 1'0 ~i~
r-'o -0
<S:
2(') :J'.:
-0 ~51f1
5>c::: ~
:z: N S!
=< :i.,
(J'i -<
'"
~;
._ u_,_ ~'".
,,-
., -.',>. -~ "-~-n- -,' ;,';' e;k'- - ,-.', ".":;" <_~ ',-,,,,", __' , '_'_'.
- '~;
-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY BANK OF PENNSYLVANIA,
successor by merger to INTEGRA MORTGAGE
COMPANY,
NO. 00-6509 CIVIL TERM
Plaintiff,
vs.
JODY L. WARRICK,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information
and belief, the Defendant, Jody L. Warrick, is/are the owners of the real property on which the
Plaintiff seeks to execute. That the Defendants' last known address is 1404 Trindle Road,
Carlisle, PA 17013.
SWORN to and subscribed
before me this 31 st day
of October, 2000.
'-..
Notarial Seai
Rebecca L. Kirch, Notary Public
Pittsburgh, Allegheny County
My Commission Expires Nov, 10, 2003
MAmhp.f, Pennsylvania AE~sociajDl1ot Nr;~;:F;f.'-.',
1~tUv- rd, AlJu);u
Notary Public
(, <"~-'--ii~T'
'1lliU "tilillli''''-'''
"''''
'" . ~"_ ..". 'H~_'__ _~,~.' '. ,
iWX!l_Ill.tl[Ji;.tr~IS._liilll1.i.i -i1r'
"'-,,,'~" ",-,--, ...." '"- - "
--
, .--C~"
, .-
-
"- ~;
, ~
~ 1:0 ~ ~ ~
, , ':' ~
~ ~
~ B "-
~ 0 0 ~~
~ C) C c:>
~:, z
. -au; c:> ~Q
~ '\ 2'" .co
r r ~ - ::1:' I ~'~l(-'(
. :Z;:'::. ;~~5~
':Q ~~ N
. , yC,\ -0 ~:--: :"r,
\
~ 1>C- 4' g~
, Z-' -'
---0 '-:?
'" >c ~,,(
~ ,,-, ,;;-
::D
<)1 -(.
~~
~ ~
~ V\:
~ ~
;; ~
"Q
., -' -,,'--~-"
'n
, ~-"
"--""
~-- "
,-
~N
~
::r
"
@
'0
.,
'0
"
..,
en
>-
0.
0.. "tl 1.0 t"I
""1 1-'- ...... 0
(tI rt 0\ c::
g; rt 1-'-
" "l"
- 0' 1-'-
M::o c: Hl "tl
...... 11 rt.
N to ::r
-.::ri!:::.-;;:
N "tl 8" <: rt
oo:l>'...,CDrt
I-' ='::l 1-'-
I I--'ctl c:
...... U1'< CD i2"l
-.JN~
N 1--'0'
'" "'..,
3!
.,
5'
~
Si
~
en
~
~ "
,-."
- ;,;LM~-' .'__r ",.,~,c:",'-_--_
By virtue of this writ, on the
I caused the within mimed
have possession of the premises described with the appurtenances, and
R. Thomas Kline, Sheriff, who being duly sworn according to
law, states this writ is returned STAYED per instructions from Atty Vitti.
3
.,
'<
cr
"
en
"
..,
-<
"
0.
Sheriff's Costs:
Docketing
Poundage
Prothonotary
Service
Surcharge
,,It=-_
subscribed to before me this }5
,~
day of
(" :-
CIl "tJ "tJ >-
:::J ..., ....... .-+
(tI 0 ~ .-+'"
:::. g. (;;' ~
~ ':< '-'
'-'
o
~
t"
'" " z ("l ....
0" OJ ~ Z
-Bg~.~,..,
OJ (1) 0 I:l:I II:
~ ~ ~ ~ trI
o f-''''' .....
t1 t"'''
_"'>-0__
~ ~Z C:((~)
3 '< 0 ~ c::u;]
~ g' ("l oc:;:;:;]
to ='0....=
CD ~-~,
t1 '--<("l=
OZO\::lCl
rt H>,..,
o .,,~~ ~ij;:;:i)
H (1)"':1 ~
~ StrI 0
Jl~~Z
t1 f-'-"< "':I
OJ <: tIl t"'
:;: ~~ trI
o f"~ >-
:+ .'" ;;;: tIl
<g ~ 9
~ >-~'
:.-
"
"
o
Cl
("l
o
en
~
en
:tl::;;
~~
("l-
. ,..,
:tlO
",,"'l
...."':1
<:1\0
~tIl
""tIl
....trI
<:1\tIl
tIltll
trI....
,..,0
r;z
-<
'"
::;:
OJ
t1
t1
f'.
Cl
~
."
'"
~ ~ ~ ~
f-'
o
f-' 0
. .
o '"
o 0
o
"
(1)
day of
$18.00
.64
1.00
3.10
10.00
$32.74
Advance Costs:
Sheriff's Costs:
$150.00
32.74
$117.26
t2~
(
Prothonotary
So?~~
~
By 9oJ; ~~. D~puty :\
\.15~
z z
o "
o
o
I
'"
'"
o
'"
'"
f'.
<:
f'.
f-'
;J ;;l
.., ..,
3 :3
, to
(,.,'<.., 30971
'~.I/):>~iq
:' ,;~
~~'iil,n~~~~MjillliliillM
. ., ,'^ ............
~ ~, ->
~ - -
WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 3165 etc.)
National City Bank of Pennsylvania
successor by merger to Integra Mortg e
Company
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6509 Civil
Term
No.
No.
Term
vs.
Costs
$100.60
Jodv L. Warrick
Att'y.
Pl'ff (s)
Prothy.
$
$ 1. 00 Due
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sherif[ of
Cumberland
County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the
following described property to:
National City Bank of Pennsylvania, successor by merger to Integra Mortgage Company
Plaintiff (s)
being: (Premises as follows):
For the property situate in South Middleton Township, Cumberland County and Commonwealth
of Pennsylvania. Having erected thereon a dwelling known as 1404 Trindle Road, Carlisle
PA 17013. Pin 40-22-0119-004
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any property ofthe defen-
dant (s) and sell hislher (or their) interest therein.
Curtis R. Long
Prothonotary, Common Pleas Court of Cwnberland County, Pennsylvania
November 2, 2000
By:
'~;AAA
K-~~, W
Date
(SEAL)
Deputy
~ '
'". ~ "d, ..~
~