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HomeMy WebLinkAbout01-1923 fx ,~~ ~" J ,_, -'- ."~..;. J""'-, J ,,,I , ,,". " ~ "' "- - m-'l ~'-Ji, :"- , FEDERMAN AND PHELAN By: Prank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 Court of Common Pleas Civil Division v. CUMBERLAND County Term MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP HILL, P A 17011 No. 01- /q23 ~ CIVIl. ACTION - F..ffiCTMENT - ~010 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~. J .,.. ~ 1_ 'J.'_., f , " . ~T~ '~i;;': .~ . 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION. 2. Defendant is MICHAEL J. LONG OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession ofthe said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. 7/VVvl k -=h~~o- FRANK FEDERMAN Attorney for Plaintiff ~' ". J .... .' '. _~ .. , .l ,-I'~H' ..-, ~ 'It)- ~ I ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D. P. Raffensperger, Registered Surveyor, dated 7 April 1959, as follows: BEGINNING at a point on the Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18th Street and Second Street, also being at the dividing line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) degrees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Eastern line of a twenty feet wide alley; thence North thirty-two (32) degrees thirty (30) minutes West along same, twenty (20) feet to a point at the dividing line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) degrees thirty (30) minutes East through the center line of a partition wall between Lots Nos. 132, and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point, the place of BEGINNING. -;~ ':.~-- BEING Lot No. 133 on Plan of J. L. Hyde, said Plan recorded in Plan Book 1, Page 65, Cumberland County Records. HAVING THEREON ERECTED a two and one-half story frame dwelling house known as No. 134 South 18th Street. . .' BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T: Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Michael J. Long. ~, ~ "'~ - I~' .~ __;. ']-1-," '-' ",-. ,"-'" ,--, 'lJ "':$ - . - I VERIFICATION ROBERT CHESTER Hereby states that hel she is the is the d11IITSEtmARY Of CHASE MANHATTAN MORTGAGE CORPORATION Mortgage servicing agent for the Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his /her knowledge, infonnation and belief. The Undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date:.3f.l [b \ mISTAIIT SEemA/IV .." , ,.:". (,Ji' . ,- _ iii__ ~ ~i!ilt$'I!W<iVi'" l~o GL,.~ih,;i1".~", ,.Y(J!~lL!1 .",..~__,<,.;, _ ~ :,,~~4.11~' i T-- . ,1,,_~',A,J~1Ic:LtM-,,~~;m.lJ,1Jc~\fl,; _"" J; ..-,,',....,", ~"i!R~*'.f.!iil~'fff<lj.;, ',~MI;,~,i"""" ~~.'" I " ~< .-,',~- ~c~~ 'tv " ...... -- '--" 0 \'" w .() -...l I' 9 "" 0 " - ,,"3_,~.,.'o-.",o~... .,,-, -,,_'''_'.'~... "_..<"",.,,., I.." , ~.. kiiIiJ ill - y"-~ 1- -" 91"imitli.,MilJ--' ~..\\' sY\ "". ~ '(-v ~ r. cS' , ~ 0.~ - ' '^ t' ..~-.......~'" , . o c:. 2' ;:?:,~t ~t: C/) ,X~, -:<.'.~- f";C.i ~O .;::Cl ;J;>C 7- ::;!. C1 ? .-.~ ~.:! I f') ~,=" ,. .. ." ~" 9 (@ -t' ",.'r' '--'-'7~;j,:~ 6f~~ _~_i. ~ t..:? :.n .1'""" . 8~ "O~e ):r ~~r ~:'~.~..' 0: ::;:!1 -"t. ...," '""', . ~ '~'. ,. m~ ~: o~ , -~~,~~'~ I_~ ~ "~ "e -"" ~......~,.i.'il' ~ SHERIFF'S RETURN - NOT FOUND ..... CASE NO: 2001-01923 P 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS LONG MICHAEL J R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LONG MICHAEL J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , LONG MICHAEL J DEFENDANT MOVED HOUSE IS VACANT NO FORWARDING ADDR Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 R. homas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 04/19/2001 Sworn and subscribed to before me this ot1'l-'t... day of ~ J.. O-v ( ..11-'- ~fhonolt ~ 0610 ,.~ '-, ", .' , , ~I L c, I,' 0 ': I ~;, ,. "'. ... I FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OR 43219-6009 Court of Common Pleas Civil Division v. CUMBERLAND County Term MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP HILL, P A 170 II No. bl- /113 ~ ('Jvn, ACTION _ F,.TFCTMFNT - 1010 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. rROE c...oPY FROM RI!:COAQ :J'estImony \lthert'O:, " here unto set my hand 'seal. 01,:.,'.', t:(f;, Ca?ISIll. Pa., . \, . -d';':, 2"/ I Mal . /- CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 I: "_I , l j "I"'I~I .. ',_, "'.1 _ #, ~ "....lI , 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORA nON. 2. Defendant is MICHAEL J. LONG OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the SheriffCAbstract of Title). 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim oftitle. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. 71VVv1iL~4~ FRANK FEDERMAN Attorney for Plaintiff " J, "I. i ,~,:'.:.. ~ ;.'" '. I ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D. P. Raffensperger, Registered Surveyor, dated 7 April 1959, as follows: BEGINNING at a point on the Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18th Street and Second Street, also being at the dividing line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) degrees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hund~ed twenty (120) feet to a point on the Eastern line of a twenty feet wide alley; thence North thirty-two (32) degrees thirty (30) minutes West along same, twenty (20) feet to a point at the dividing line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) degrees thirty (30) minutes East through the center line of a partition wall between Lots Nos. 132. and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point, the place of BEGINNING. f;'-~$. BEING Lot No. 133 on Plan of J. L. Hyde, said Plan recorded in Plan Book 1, Page 65, Cumberland County Records. HAVING THEREON ERECTED a two and one-half story frame dwelling"' house known as No. 134 South 18th Street. BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T,' Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Michael J. Long. ." , L ' , ,I " ,,-.'~ l<_ d:<' ~, '~ . \ VERIFICATION ROBERT CHESTER Hereby states that he! she is the is the ~SECRETARY Of CHASE MANHATTAN MORTGAGE CORPORATION Mortgage servicing agent for the Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his /her knowledge, information and belief. The Undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date:.3-pl 10 \ ~SECRETARY "'''''f'__. . , , ~~~ . I . '-'" "'__i'_ ---' "'--;""'"~';'~-""'"""-^"".'_'.'-"'.'1MtljiJi!iI,~t",j;;;i,~l~,$i...MI!;O@~_~ ~~ {i:{:"r~ Cb'-~~~ """",,,,,,,,,,..,I<>t=__,.,< !!:!!:!f ~ ~ ~ \;'1 NVi\ 1,1 S N N3d .'} -, ,", ~ ' I ',! 1," ;; W. IN 50 9 t KJV J.lNJ1~:;' :'>"'-'~;-;.iHrlflO l.,mmiS jl;t dO J.,i.:l.:lO ~ ;".'TtIC. .. ,_.',,;,,".-",,..'.'C_~,~~~, .' ..'" .'~<< .~ _u' '." ,_ ""'",".,,,,, " '.'" <._._<" _ ~,," ,.. ,f .' "'''''..'"' ~'" '.'..' .' ~-- .' .' ~'ii!.~~U- 1 ~ "' "",J.,~.....".' .l-' "'. -, , ~,~, , ."""; o. v o I ~ ~ ~' .~< 'q' . .1' - .~ "'"""" ~~ ~. '. , FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Bonlevard Philadelphia,PA 19103-1814 (215) 563-7000 . CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, 01143219-6009 vs. MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP HILL, P A 17011 ORDER -, , _ ", ,__ r Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term, No.01-1923-CIVIL Action in Ejectment It is order this --z.q.t- day of ~ ' 200 I, that Plaintiff's Motion for Service of Complaint Pursuant to Special Order of Court is GRANTED, permitting service by: First Class and Certified Mail to MICHAEL J. LONG OR OCCUPANTS at the property which is subject to this Ejectment Action'. Service by first class and certified mail is effective upon the date of mailing. x L Posting of the property which is subject to this Ejectment Action' 'the property at 134 SOUTH 18TH STREET, CAMP IllLL, PA 11. / / BY TIffi COU ~q-O\ S-J, .' -, ,,,,~~ , - ~- ~l.h I', i,'; :1'" '! !{ i ~_ Iii: " , ':1, ~ ~ { ~! I"; I':: Ii I '.." 'II: " : I , i"""""-~_~_~~1'i>lil~~~lli~~~VI;;:--,t"'"1fuj~,;~1;Ii-.:Mlllli<l:l~,,;;;st.~~~~~ififllIl!IiW'- -. 'c) ..," ~!,~ -- -..- {jl, --~\ '(0 -..~\(J.... C'- 'o:~' !~~ .~, J ,~~ -" <-:, ':?~ '- >_",,",,_=,", ^~,~_,,_~~_'!"__"~,~,,~,~_.' .~ .,,~,~,~ I. -.., '" J ,. -'iIIIl~~- '~,' .' , . .J. "' , " " FEDERMAN AND PHELAN BY: MIClIELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 vs. MICHAEL J. LONG OR OCCUPANTS' 134 SOUTH 18TH STREET CAMP HILL, P A 17011 -j'- L I Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term, No.01-1923-CIVIL Action in Ejectment MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Michele M. Bradford, Esquire moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by certified mail and regular mail, and in support thereof avers as follows: I. Plaintiff commenced this action by filing a Complaint in EJECTMENT. 2. Attempts to serve Oefendant(s) with the Complaint have been unsuccessful. Plaintiff attempted to serve the Oefendant(s) on APRIL 19, 2001, as indicated by the Affidavit of Service attached hereto as Exhibit A. 3. Pursnant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting fOlth the specific inquiries made and the results from there are attached hereto as Exhibit B. 4. Plaintiff submits that is has made a good faith effort to locate the Defendant(s), but has been unable to do so. 0-'__~ l>Jl t.iaJb.ddL.':,;- :-[! 'ij1' ;llj] II,; ,ifH1 " I i~ 1,1 ');1; ," ". ~ I~ , I' I, ,: .,' f .~-=N ;' .I.~ "' S. Plaintiff verified throngh property inspection on JUNE 15, 2001 that the property was occupied by an unknown person. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail and posting of the premises. '-, ,-,,,- - "~'i: ]?f-dd7J{6ri~~ Michele M. Bradford, Esquire Attorney for Plaintiff DATE: MAY IS. 2001 I' il;' !i;i Iii; .' ; '; ; :i Ii' - ,-- ."l 'c" " li:: I FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 i'; Attorney for Plaintiff i:i '" 'I'~j I, i~ : i; ! ~ , IJ i;'i CHASE MANHATTAN MORTGAGE CORPORATION 34I5 VISION DRIVE COLUMBUS, OH 43219-6009 Court of Common Pleas Civil Division CUMBERLAND County vs. MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP ffiLL, PA 17011 Term, No.01-1923-CIVIL Action in Ejectment CERTIFICATION OF SERVICE " t' I hereby certity that a true and correct copy of the Motion for Service Pursuant to Special Order was served by first class mail on the Defendant (s) on the date listed below: I",.'."". t " " ~ ? 'I' ~f, n II, MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP ffiLL, P A 17011 DATE: MAY 15.2001 7JfACU7JI 63~ Michele M. Bradford, Esquire Attorney for Plaintiff Ii I f; , " -'--- .,. " ,-, ." '01 I ~'..'..'--~.i!L<'1i, MRY ~5 200~ 13:17 FR CUMBERLRNO CO SHER1FF717 240 5397 TO 9121555717i7 . ::;l:il;!;Kl~.~"::; !<.E'lU!U~ - ,~v, r vum.J . 'P.02/02 CASE NO: 2001-01923? COMMONWEALTH OF ?ENNSYLVANIA COI.JN'l'Y OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS LONG MICHAEL J R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LONG MICHAEL J but was un~ble to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , LONG MICHAEL S DE1"ENDANT MOVED HOUSE IS VACANT NO FORWARDING ADDR Sheriff's Costs. Docketing Service Affidavit Surcharge 18.00 9.30 ;00 10.00 _00 37.30 _.-~ R. homas Kline Sheriff of cumberland County FEDERMAN & PHELAN 04/19/2001 SWorn and subscribed to before me this day of A.D. Prothonotary ** TOTRL PRGE.02 ** - 1- " ~_. ,'. ,-j ~-, , 1"J~.....J ~. _ -~'"" ,-L__~~ ~ PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 01-1923-CIVIL Attorney Firm: TRACK STARS Case Number: Subject: MICHAEL J LONG AKA: None Last Known Address: 134 S. 18TH STREET CAMP Hill, PA 17011 lest Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2. On 05/11/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A SOCIAL SECURITY NUMBER: 191-60-4277 B. EMPLOYMENT SEARCH: Unable to locate a good employer for Michael. C. INQUIRY OF CREDITORS: The creditors indicated that Michael is living at 134 S 18th Street, Camp Hill, Pa. 17011 with no valid home phone number. Michael filed chapter 13 bankruptcy in February 2000 with no attorney listed. Case # 2000-782 with a release date of September 2000. INQUIRY OF TELEPHONE COMPANY - A DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Michael long. Contacted 814-472.8914 and spoke with a relative who confirmed that Michael Long is living at the last known address. INQUIRY OF NEIGHBORS- NIA INQUIRY OF POST OFFICE - A NATIONAL ADDRESS UPDATE: As of May 9, 2001 the National Change of Address (NCOA) has no change for Michael from last known address. MOTOR VEHICLE REGISTRATION - A MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Michael listed at last known address. OTHER INQUIRIES - A DEATH RECORDS: As of May 9, 2001 the Social Security Administration has no death record on file for Michael J long under his social security number. ., ~~ , III AM--t~i /. B. PUBLIC L1CENSE~ (PILOT, REAL ESTATE, ETC. ): None Found ' C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Michael listed at last known address. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: 07/67 ~~~- ...........~,--""''''''.~.,'''.->''<,;:;>....~~''-''.....''''} 1I"N6~RY S[::l3t,L ':, ( Kr'stine M. Scoll. Not.ar-(' Publlc . ~ ! . ., ~ ~'~p I j St LOUIS Coun~;l fA:1.,E.',~ ('- Nlk.,,)fJ.ur. ..'f. ') T...") My Comm~s:1k)ll Ex-p!l es S'1:..:...f,::li1L ' ,~"'J~-""<~~'$'~;r,~'-..r,-"'" AFFIANT Michael K Gross Players National Locator 113 Old State Road, Suite 104 SI. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 ~ . __i!ltd:l'fuh~"#! !Iil :'111 'f" :I.j' - L~ ~i i . FEDE~ AND PHELAN BY: MlCHEl,E M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center@ Snbnrban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, P A 19103-1814 (215) 563-7000 Attorney for Plaintiff ., ,:', CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 Court of Common Pleas Civil Division , ~ I:,j 1"1 , f';j '! CUMBERLAND County MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP IDLL, PA 17011 Term, No.01-1923-CIVIL Action in Ejectment ", .- I,~ I;~! I", II ~. vs. MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Pennsylvania Rule of Civil Procednre 430(a) specifically provides: '" " 1.1 Accordingly, Plaintiff ordered an investigation into the whereabouts of i I :-1 I II i I ,;1 I 11 I: If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an Affidavit 'stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Although Plaintiff has attempted to serve Defendant(s) with the Complaint, Plaintiff s attempts have been unsuccessful. A true and correct copy of the Affidavit of No Service is a.ttached hereto, made part hereof, and marked Exhibit A. Defendant(s). A true and correct copy of the Affidavit of Reasonable Investigation is attached hereto, make part hereof, and marked Exhibit B. The Affidavit reflects that '--'.'" -~. """"''"< "t~Li .. . Plaintiff s investigator has make at least three types of inquiries listed under Rule 403.I(B)(1). Copies of any written responses obtained are attached to the Affidavit. The Affidavit also specifies the inquiries made, responses made, and dates Ii II' thereof, in accordance with Rule 430.1 (B)(2). As Plaintiffs within motion and its :) i c , affidavit are both in compliance with the applicable Pennsylvania and local rules, i:,i : ::1 I::: Plaintiff respectfully requests that its motion be granted. WHEREFORE, Plaintiff respectfully requests permission to serve the Complaint by certified mail and regular mail and posting of the premises. Respectfully submitted: DATE:MA Y 15.2001 ~~7J1-~~J2- Michele M. Bradford, Esquire Attorney for Plaintiff j'i (; I~'; j: !: i ii' 'I i I J '"""'~_. - , ., '1-. ',I~ 1 , ,.. '''1.1\....:1.','.. ,''( !"-;; ,>,'1 , ?! . VERIFICATION Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this verification, and that the statements made in the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court are true and correct to the best of her knowledge, information and belief. DATE: MAY 15,2001 711~7J{ Gl~.-C? Michele M. Bradford, Esquire Attorney for Plaintiff li,E !H .J 'J i: , Ii ;:::J! I'i " 1m ~I' ,'!'; I:' ! ~: The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. , I, n 1.'1 i!: '1 :1: I; !,' i I:: i ~ II' F .l . L"I',,-I '-0-__ 'lI'i:',i , f FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Snite 1400 ONE PENN CENTER@SUBURBANSTATION 1617 JOHN F. KENNEDY BOULEVARD Philadelphia, PA 19103-1814 (215) 563-7000 Attomey for Plaintiff Chase Manhattan Mortgage Corporation COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. TERM. NO.01-1923-civil Michael J. Long Or occupants Cumberland COUNTY Defendants PR A F,CTPR TO RRTNST A TF, C1VTT, ACTTONIF.TF.CTMli'NT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. ~~~- Frimk Federman, Esquire Attorney for Plaintiff Date: III"" 4 7001 . " - ~ "-p I I, '.-do,"_; ;;'-';",>1<',' Jh'-" _'.~ " .. . . . FEDERMAN AND PHELAN By: Frank Federman, Esquire ' Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff 0 <:J C '; -0 :s:: "'. cr. -"I.J rI'!(;-; ~-"" ~ ~S:>; "".~ I -<,' .- f"v r~"'---; ~c~ -~J ~Q _'n"" pU :,..> C .-"" ~ '-'1 --I -< ~ CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 Court of Common Pleas Civil Division v. CUMBERLAND County Term MICHAEL 1. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP HILL, PA 17011 No. t)/- /115 ~ CTvn, ACTION - F.TFCTMFNT - 1020 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. J;.,,-_" You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FEDERMAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN J ~ f ~~ ~. ,;, 1 '-';"""::i:- I. Plaintiff is CHASE MANHA T'r AN MORTGAGE CORPORATION. 2. Defendant is MICHAEL 1. LONG OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 170 11, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). i , ,j , , , "-j I :1 :.:1 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. ::', II H 1-'1 " H "-j I I ~:! Ii ,I i 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. :1 \1 , ,:1 i I I I ,::! ,I ! Ilvv.J\.~ J1^~ FRANK FEDERMAN Attorney for Plaintiff FEDERMAN AND PHELAN ATTORNEY FilE COpy PLEASE RETURN ,. "' ~-, .-.,,1 -. ' '-"-ld,'- , ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D. P. Raffensperger, Registered Surveyor, dated 7 April 1959, as follows: BEGINNING at a point on the Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18th Street and Second Street, also being at the dividing line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) degrees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Eastern line of a twenty feet wide alley; thence North thirty-two (32) degrees thirty (30) minutes West along same, twenty (20) feet to a point at the dividing line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) degrees thirty (30) minutes East through the center line of a partition wall between Lots Nos. 132, and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point, the place of BEGINNING. .:.'" ~::- .~- .;;-- BEING Lot No. 133 on Plan of J. L. Hyde, said Plan recorded in Plan Book 1, Page 65, Cumberland County Records. HAVING THEREON ERECTED a two and one-half story frame dwelling'~ house known as No. 134 South 18th Street. BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T: Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland . County, granted and conveyed unto Michael J. Long. FEDERMAN AND PHELAN ATTORNEY FILE COpy PLEASE RETURN '. " VERIFICATION ROBERT CHESTER Hereby states that he/ she is the is the ~SECmAR'{ Of CHASEMANHATTANMORTGAGE CORPORATION Mortgage servicing agent for the Plaintiff in this rnatter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his /her knowledge, information and belief. The Undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date::3-pl I b \ .rr ROBERT CHESTER ASSI5TAIlT SECmARr FEDERMAN AND PHELAN ATTORNEY FILE COpy PLEASE RETURN ;~ ~'""""'liiiilt~lmJli~~BJ "[-['.li&Hf~lI~jJ!il.'hlii"ri~;-i~;,il;~~,1llliiili!r--'"'''' ~, ~''-''';1Hlliill1.~, ~l"~~' " -,':'~r, ;/'," ,J'~'-~:';o In --- n ~ l_ ,~ ~ ~ ';":x ~~~ < +,- .. 0 0 n C -n ~ '- ~, -om c: ~'l " rnrr' :;,e:; {~l~ Z:I1 I -,~fTl 6'i~ ...... S1"6 :sZ !;20 -0 -r' .....-, 5:!J ~o ::J>:: .7(") ~~ '.:? OfT1 ~ ~ .r;:- '< ,~ ' " , . I ~"., ." " -. .~.~-' -, -, -~J"-' Ti--o"'"?--i FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE !.D. #12248 ATTORNEY FOR PLAINTIFF SUITE 1400 ONE PENN CENTER@SUBURBANSTATION 1617 JOHNF. KENNEDY BOULEVARD PHILADELPHIA, PA. 19103-1814 (215) 563-7000 Chase Manhattan Mortgage Corporation : COURT OF COMMON PLEAS : CIVIL DNISION : Cumberland COUNTY V. Michael J. Long or occupants : No. 01-1923-civil AFFIDAVIT OF SF.RVICF. VIA RF.GTlT.AR & CF.RTTFTF.D MATT. I hereby certify that a true and correct copy of the Civil Action in Ejectment in the above captioned matter was sent by Regular and certified Mail, return receipt requested, to the Following person(s) Mieh"eJ.I I ,oog or oeenpaof<l at 134 Sonth l11th Street Camp Hill, P A 171111 on .Tnoe 13. 2001 In accordance with the Order of Court dated MAY J9 JOOl . The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. -~~ -=r~ Frank Federman, Esquire Attorney for Plaintiff Date: Inne 11. J001 ..~.~,. :... {' :~,.' . . . , ~" ..;"".m~;iJi:mililllli\iL,*"'"*--'!i'~"Mj';i:m~~€lt;~_.f~!!li<Wilil"!ffl,;Ak'-).'''~",,<''1,d-"A'"l:8>';;;b!!"',~M'.,."c!il!! ~ ,.;':,_,_;,",.J_~Ip.~~~;~~}'.!lR, ~ "JJ~1Jt1tJ Jl.CA,.,j,_,,,, " ~"'!""'-,_V ",,_,,_,~, ~_v,,1 ~ ...... """" ~~'drm' :raB-~ ,^... ""., '''*'~~,- -'I~rr:~'iS4!J o c: -? ..~ -ocr" I>H;", -:r ':-::C' ~~ l.2U C"CJ 20 S>C ~ c::.: <-- ,'- -::2 Jlil: ' ,~<- ~ . -"'-<, (j -'.) - _~n\ ',<:; .;- j '-~~~ S~ '~~i r~ 1::2\ :?; ~ ~ Q:l -0 -,- '..:"? l1Ii -""'.,~- - .- ~... i..:. . ~. . :L~ ~ - H'" .--, M(. SHERIFF'S RETURN - REGULAR. CASE NO: 2001-01923 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS LONG MICHAEL J GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon LONG MICHAEL J the DEFENDANT , at 1700:00 HOURS, on the 13th day of June , 2001 at 134 SOUTH 18TH ST CAMP HILL, PA 17011 by handing to PROPERTY POSTED a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Posting So Answers: 18.00 9.30 .00 10.00 6.00 43.30 .r~~ R. Thomas Kline 06/18/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By:. . ~~ JJ~ . ~ Deputy Sh iff me this ~ te.. day of ~" ?Mr! A.D. C)~... 0 (J 71...M.. / Jt 9~ P othonotary '. " . < "'- -" ,; .1 ". ,,' ~, -t -:'11' ... ... FEDERMAN AND PHELAN BY: FRANKFEDERMAN IDENTIFICATION NO. 12248 One Penn Center @ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, P A 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION vs MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMPHILL,PA 17011 No. 01-1923-CIVIL CUMBERLAND County PR A RCTPF. FOR .rrmGM1i'.NT TN RlRCTMlCNT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, CHASE MANHATTAN MORTGAGE CORPORATION and against the Defendant(s) MICHAEL J. LONG and OR OCCUPANTS for possession of premises 134 SOUTH 18TH STREET , CAMP HILL, P A 17011 for failure to file an Answer within twenty (20) days of service. I hereby certiJy that according to Rule 237.1, written 10 day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE . ~ - I~ " .i ,,_I .,~,,:,,;,.,.' ~ ~-. jf;illilf.l!Jil&.\" - FEDERMAN AND PHELAN Frank Federman, Esquire Identification Number 12248 ATTORNEY FOR PLAINTIFF One Penn Center @ Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DMSION v. CUMBERLAND COUNTY MICHAEL J. LONG OR OCCUPANTS NO. 01-1 923-CIVIL TO: MICHAEL J. LONG OR OCCuPANTS 134 SOUTH 18TH STREET CAMP HILL, PA. 17011 DATE OF NOTICE: nIT.v 6, 2110l THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIfAT PURPOSE. IMPORT ANT NOTICF, 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 within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, P A 17013 (717) 240-6200 ..~ , I. ' , .'1' . ~.t ',,^,,, ,__,Ow ~" ';, '. ,'c_ ~''''Q,.~,'' ~ FEDERMAN AND PHELAN L.L.P. BY: FRANKFEDERMAN IDENTIFICATION NO. 12248 One Penn Center Plaza @ Snburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, P A 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CNIL DNISION vs MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMPHILL,PA 17011 No. 01-1923-CIVIL CUMBERLAND County VF,RTFWA TTONOF~ON-MTT ,IT A RV SF.RVTC'F, FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: - (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant MICHAEL J. LONG Or occupants, is over 18 years of age, and resides at 134 SOUTH 18TH STREET, CAMP IllLL, PA 17011. This statement is made subject to the penalties of 18 P A. C.S.S 4904 relating to unsworn falsification to authorities. i'~",.."wl1m\";J",~,,-;'#~_,,lik:.i6_'idJf~,JoitJ,j~,';\lJliii!,l#:m~"'ilij['W&;l;;,*,",""'-"~Il{',;~,;~l,",~ihill"l1;~~"M2i'Wl..~dl~Wsrl:!WiliitI~~""""~'i ..-- > r: (C") (-) ""- [jt-~~ f,- " 8 1') '- ~ 3 ~ V) ;p 9r.:ji ~ r" - '"'" 1"';' ~ ~ 1- ---., ;",",." "~~,<,, '-,"",'_"" ,.~ ~, ~~ '" ~, ~_~_ ~~._^_. . - ,,~>~,'" h"''''''_'__'~_"','= ~ .,,"~' .1 ,,- ><_""I;;.";';,cl,J Li: ~1iI!~ ~......~.. - l:1 , c,~~-, ,- ~< -', " ~': ,:~-- ~~ . . -" I. ., , -~ "L I. ~ ". -" . -',,~, liJ ' ~r-~-i PRAECIPE FOR WRIT OF POSSESSION COMMONWEALlH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION vs MICHAEL J. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMPlIILL,PA 17011 No. 01-1923-CIVIL CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 134 SOUTH 18TH STREET, CAMPHILL,PA 17011 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 134 SOUTH 18TH STREET ... ). ~. . < ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cuml;lerland County, pe!nnsylvania, more particularly bounded and described according to survey of D. P. Raffensperger, Registered Surveyor, dated 7. April 1959, as follows: BEGINNING at a point on the. Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18th Street and ~econd Street, also being at the dividing line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence south fifty-seven' (57) degrees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet ,to a 20int on the Eastern line of a twenty feet wide alley; thence North thirty-two (32) degrees thirty (30) minutes West along same, twenty (20) feet to a point at the dividing line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) degrees thirty (30) minutes East through the center line of a partition wall between Lots Nos. 132. and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point, the place of BEGINNING. ~;.. ~t:-__ BEING Lot No. 133 on Plan of J. L. Hyde, said Plan recorded in Plan Book 1, Page 65, Cumberland County Records. HAVING THEREON ERECTED a two and one-half story frame dwelling < house known as No. 134 South 18th Street. " . BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T." Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland . County, granted and conveyed unto Michael J. Long. "~I , ~..~,} . :".,) . ~~fiI:m~Iil':;i,!'U;-~_;t>1-'i>it.t~.li..wl.il~~iliI!~",;tt-;,i,~y;,f)&'Ii""-"hIH'J"""I~'""j~"_jW,ilif",~j?j!Milliiiii1iilllllliifi~~~~ ~-~ -, 1: ......... ...... 'f. ~ ~ - ~~ ::j::~ 0,; ~~ -J ~ " C) \) ~ ...... (} ~ D ~ ~ ...0 . 8 ... ~ ... ~ & I ct Vv ~ ~ ~ ~ w' C 0 0 I t D ~[))r , :t :t) ~'f... ".~~ ... ... -- - ",.,~~__"",~~~~"~._ '~^ .~ _",~,,,,,,,,,,,_~,-c-,,__,_,,,=_,,,.,,_,~_, ~,~ ". .~_~", 1"0_",,. _= ____M...~ __^.. ,-~ ~ i... , ,~ ~Dr-' ~/' ,'--- ~~ ~~ "'--..,- :1.:;.- ~-' t:...,;. il;~~II" ,., , ..... ( , o C, , ....,;:, ..........~o.~~. h' ~~~"""'.. '-.- =" w-;..'~ - -- - -- .' .~ ~ :4 ;? ~~~ ~ - ~ i :.: -. - :z .... '"'tol il ~ -:< - "" :; ....5 '"' ~ ~ ~~~ - - tol - - ~~ ~ ~ ." I -" --. ~ ;;:: - -= - t" .... 1 == n .~ ~ " , ::- "" '"'s: >oj ~ - - '"' - ~ !" - :z - 2L . ;:oot" , "" ..., liHl - : Q:i: .~ - en ~ - -= - '" - - ;; '. - '"'~o ~ - :;, i '"' l'O ~ Z 110><1'" .:; 0 .~ - - 5=da " .. - '"'tolO ... "" .~ '" '"'...n ~ -<: - wt"~ t' :!l I . ~ ., :; ,!.~ ~ft :ii - ~ ~; t<I ..:- ~ =". 5; " J: .... - :~ ... ... ... ... " - ~ ::z - ~ ~g", . ..,. ~ , , , , :; -- ::z - ~ ; ~ ::z '" :r. . ........ '", :f-' < ~Hi :;1 : .~ :... .'. .... ::.: ::- ....0 'f-' , , ... :r. 01>021 '.,. ,0 l-' .... :z - 0 :0 ,0 0 @ - q ,0 ;;.. '. .It~ -'. -~' -",..j-~. ~ ~ '0 ;'"' .1 ,,", '110 'N 'w 'I :n .... :;:1 :t" , ...: ~ - . N N 0 0 B~ .';rt:Ie of :11.'0 ',~'rit, on :".. .___________________da'. ,,{ ____-"_______n_____n____________n. ~_~~2~_ r C:lwed :b.e wit.;"in :'13Ined ...___:;..___.:._____:._______ _,_________________________. :(\ i-ta~:~ ?O'Ssemon of ~hl" ?r~i5e ci~~ _YlRIT IS _ EE:I'URNED AS .E8B..A'lTL ____ STAYED, Pl'OPERTY IS Vl'Cmr. ----------~--------------------------------------_._-----------------------------------------------'-_. Sheriff's Costs, Advance Costs: 150.00 --9~ti~-------~--lS.~-----------------------------------~FiEiJ~~86~~-31.~~.---------. Poundag~ 3.00 98.25 _.P..1.!J;"gWJ~<;j<a________ _ _ _J_Q~Q9__ _____ ______ __ ____ __ ._nn_ ______ - _____ -- -- - ---- --- --- ---- - -- - - -- - - - - - -. ! ". prothonotary 1. 00 . __~~~a~:_____ ._______~~~~~~~-------------------.--------------F~-~~g~__tq_~~~J!_Qn_Bj_~LQl______. '1!:!bD . (~ V1Wi"1~SNN3cl .~ ";-',_1"_\-,'',.':) fIdb -. '.. -. " Ch!!;", \.. ,..' '. ":% Hpl1 6 ~lll\r . .;.~d ~.o_"..""ct .~ ..e.!>" ...< .ntS .1.____________ -,'.' ~.. L. ~1 ,,,.l,h",' 'i., I .!s.,nw '1.' ,)( ___ _ _ """"'________......-',,=--_~.-,..,."I''-<:k..---- . ;i:W !lBHSO';" <'! ,.,1). "", l>'W' ..-----~~-~--~7-~--------...-.--. P:,(".4honoc::lry . :',L lVL1j ~"\'b'~~~,,~ ~ . r"'- lY.L ~',-C1;;;;~;Jj~f[;:J~-~~ .--/L33/,3:) 1,1nJ fL, I!S')6~ &$iI'i)l;;;"',,0'Ir'l'f;;'i~$'i'.;ffiD,,-;,,,;,","'Vl..fll-~,'i,;~_',iG''-;-I''1&I\,~J:!!,~ri~"-"'<Wi!\i',~",,,j,_,"0i~', _""'Li"'",,,;u';'.;j,i0\'J'fu.d,U_""~Il<>J~Jii!~~~~~~lli~Ill~'" ~, 'vv"RIT OF POSSESSIO:'-i . Ejecnnenr Proceedings PRe P 3160.3163 etc.1 G.~g_~lI~_~9~E~~~~_~.9~<?~!!_O!-.___ D: THE COCR: OF CO:.[:.fO); ?LE\3 Or CL,,[BEl<.L.-I.c-.LJ COl"'lY, ?O",'S'iL \'.-I..."L_I. - ~ - - --...-- ---. ----- - - - -- - - ------ -- ----- - - ----. ,"<0. _____0).:!2n_-_~~y!~_____________ T~= 20______ );0. T = 20______ ,..,. C""3 ij!1:fu\.J;J;,._J ~_J&:ti(L 9~_ _Q.G.G.!!!.'Ml}_ ~ __ _____ ___ __ .\::'1.'. ~___~~Q;~.9___ 01"; .. . .~ , ----------------------------- s___________ lJ4 SQQIE_J~~ttl_~J~~~!____________________ CAMP HILL, PA 17011 ?co,~v" ______________________________ $_____1~9~___ CO~Oi{O:'"i'WE._I.L TH OF ?E.."","SYL V.-I...'H.-\.; COc),n' OF CC)'[5E.."U...-\_"TI: Tv :he She~ oi --------u~~~~:.~~.::~~___________Counc:.-, P",n3.. : 1 '. To :3o.a:cisiv :he iudxme-::.: ~o: ;:J~on in :...~e .loa tie :n:Lr:e':' 'IOU :L:e '~:.:ec:~:i :0 .:e~\"e:'" ?OS~sion of :ne :oi,~..n!l dex.d>ed proPer::, .:0: - " CHASE MANHATTAN MORTGAGE CORPORATION -----_..~------------------------------ ---------------------------------------------.----------------- --.-----.-----,---------- - -- - ------ -- --- - - -- - - ---- ---- --- -- - - ----- - - - - --- -- ---- -- ---- - ------- ?!3.in "if b~~:1g: {. P':e:I:tises 3S follows; 134 SOUTH 18TH STREET CAMP HILL, PA 17011 ~ :,'2' To j~i.-i:si:,l :.:.~~ wSts ~:.i'-~')t me: de!endant :5 ~ you 3.!-:: d.i~e.j to :e--;9: ':'?Jr~ J:...y ?ro~':'::; ot :r~e e.~.e:"'.a d:l-::C _. i.: J.C-G. ie~l::.:.,i n.e: .(Jr ::.'1--=:-' :CC...~...5... :..h..er~i;],. 5E.-\L ) . -: _ ___ ___ _ _ ___ _:_ ~U?_ B~_J;.QI1..9. _ _ ________ _____~. I?:-ochonoc-:". C.:"l::"'-~rr p!~ C..:-i..I:--: vi Cu:nbe:-:;1..~C Courr.r. .~ n. 7/;" fl, ~f'1/'Yl1? ..r=.. ~~. f ""-- -- - . . epucy D;1'. ~fu1y 20, 2901 HJ Jift __=~ ..N'_" "~,='w,, ~,~_..,'<_" ,."""..~=_,,..~,,"~..~~___~~.'_ ~' " .-~.~""