HomeMy WebLinkAbout01-05564
COLUMBIAN NATIONAL INCORPORATED
Plaintiff
vs.
ROSS E. GAHAGAN
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
1. t U ~~~£2~vY~
CIVIL ACTION - LAW
IN EJECTMENT
N O T I C E
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 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 any other claim or relief requested by the
Plaintiff. You may lose money or property or other rights important
to you.
COURT ADNINISTRATOR
FOURTH FLOOR
3RLAND COUNTY COURT HOUSE
SOUTH HANOVER STREET
CARLISLE, PA 17013
(717)240-6200
N O T I C I A
Le han demandado a usted en la torte. Si usted quiere
defenderse de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la torte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su
persona. See avisado que si usted no se defiende, la torte tomara
medidas y puede entrar una Orden contra usted sin previo aviso 0
notification y por cualquier queja o alivio que es pedido en la
petition de demanda. Usted puede perder dinero o sus propiedades o
otros derechos importantes para usted.
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LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE
ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR
ARISTENCIA Ems.
COURT ADMINISTRF
FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
SOUTH HANOVER STREET
CARLISLE, PA 17013
(717)240-6200
COLOMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. OL - .$SL~ C'~U~l.`~f~.~
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN
Defendant
C O M P L A I N T
1. Plaintiff, Columbia National Incorporated, is a corporation
with an office located at 7142 Columbia Gateway Drive, Post Office
Box 3050, Columbia, Maryland 21045-6050.
2. Defendant, Ross E. Gahagan, is an adult individual whose last
known precise residence is 170-172 Erford Road, Camp Hill,
Pennsylvania 17011.
3. Plaintiff avers that any person not set forth above, but in
possession of the premises set forth in Paragraph 2 is, and shall
become a Defendant to this action by virtue of Rule 410(b)(2) of the
Pennsylvania Rules of Civil Procedure, upon identification by the
Sheriff of Cumberland County in his Return of Service of such person,
and upon Praecipe of the Plaintiff.
4. Prior to September 5, 2001, Defendant was the owner of certain
real property known as 170-172 Erford Road, Camp Hill, Pennsylvania
17011.
5. Said premises were sold by the Sheriff of Cumberland County at
a Sheriff's Sale held at the Cumberland County Court House on
September 5, 2001, after due advertisement according to law, under
and by virtue of a Writ of Execution issued out of the Court of '
Common Pleas of Cumberland County, No. 1996-7002 Civil Term at the
suit of Fleet Mortgage Corp., formerly known as Columbia National
Incorporated vs. Ross E. Gahagan.
6. The aforesaid property was purchased at sale by Columbia
National Incorporated, the said proceedings being incorporated herein
by reference.
7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired
title to the said premises.
8. Defendant is presently in possession of the said premises,
having come into said possession by virtue of his prior ownership.
9. Plaintiff's Abstract of Title is attached hereto as Exhibit
~~ B ~~
Plaintiff demands judgment against Defendant in
Ejectment for recovery of premises described in Exhibit "A" attached
hereto and made a part hereof, plus costs of suit.
PURCELL, KRUG HALLER
By:
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: September 24, 2001
LEGAL DESCR%PT%ON
ALL THAT CERTAIN tract of land, with improvements thereon erected,
situate in East Pennsboro Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as
follows:
BEGINNING at a point on the east side of Erford Road, having a
width of 50 feet, said point being at the corner of lands now or
late of Charles G. Holmes; thence along the east of Erford Road,
North 34 degrees 40 minutes West 97 feet to a stake; thence along
the line of lands now or late of Clyde D. Smyser, et ux, North 67
degrees 20 minutes East 150 feet to a stake; thence along lands of
the same, South 34 degrees 40 minutes East 98.63 feet to a stake;
thence along the line of lands now or late of the aforesaid Charles
G. Holmes, South 67 degrees 56 minutes 27 seconds West a distance
of 150.35 feet (erroneously stated as South 63 degrees 57 minutes
West 150.24 fee in a prior deed) to a point on the east side of
Erford Road, the place of beginning.
HAVING THEREON ERECTED a four (4) family dwelling house known as
170 and 172 Erford Road, Camp Hill, PA 17011.
BEING THE SAME PREMISES which Kevin L. Stockton and Phyllis L.
Stockton, by their Deed dated December 23, 1993 and recorded in
Cumberland County Recorder of Deeds Office on December 27, 1993 in
Deed Book S 36, page 491, granted and conveyed unto Ross E.
Gahagan.
EXHIBIT "A"
PLAINTIFFS ABSTRACT OF TITLE
1. Property acquired by Plaintiff at Cumberland County Sheriff's
Sale conducted by Sheriff of Cumberland County on September 5, 2001.
2. Deed from Kevin L. Stockton and Phyllis L. Stockton dated
December 23, 1993, and recorded in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, on December 27,
1993, in Deed Book 5-36, Page 7002, to Ross E. Gahagan.
EXHIBIT "B"
VERIFICATION
I verify that the statements made in the foregoing Complaint are
true and correct.
I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
Leon P. Haller
Dated: September 24, 2001
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COLUMBIAN NATIONAL INCORPORATED
Plaintiff .
vs. .
ROSS E. GAHAGAN
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-05564 P
CIVIL ACTION - LAW
IN EJECTMENT
P R A E C I P E
TO THE PROTHONOTARY:
Please index RITA RULLAN as a party Defendant to the above
action in accordance with Rule 410(b)(2) of the Pa.R.C.P.
PURCELL, KRUG & LER
~~
By: __
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: October 9, 2001
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COLUMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. 2001-05564 P
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN .
Defendant
P R A E C I P E
TO THE PROTHONOTARY:
Please index PATRICIA MATOS as a party Defendant to the above
action in accordance with Rule 410(b)(2) of the Pa.R.C.P.
PURCELL, KRUG & HALLER
By:
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: October 5, 2001
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05564 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIAN NATIONAL INCORPORATE
VS
GAHAGAN ROSS E
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT was served upon
S PATRIC
the
TERRE TENANT at 1940:00 HOURS, on the 26th day of September, 2001
at 172A ERFORD RD
CAMP HILL, PA 17011
ELIEZER MATOS. BROTHER
by handing to
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 6.00
Service 9.75
Affidavit .00
Surcharge 10.00
.00
25.75
Sworn and Subscribed to before
me this ~ ~ day of
Q~~ a A.D.
~_ 71e,~.e.~..- a-~.
P othonotary
So Answers:
R. Thomas Kline
09/28/2001
PURCELL KRUG & HALLER
By:
epu y riff
ES R~S
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CASE NO: 2001-05564 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIAN NATIONAL INCORPORATE
VS
GAHAGAN RO$S E
KENNETH GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
RULLAN RI
was served upon
the
TERRE TENANT at 1940:00 HOURS, on the 26th day of September, 2001
at 172 B ERFORD RD
CAMP HILL, PA 17011
RITA RULLAN
by handing to
a true and attested copy of COMPLAINT - EJECTMENT together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this .ti ~ day of
Oe~.<.~ ~D ( A . D .
.~ (i hl.Op...~
~othonotary
So Answers:
<•~-~'~
R. Thomas Kline
09/28/2001
PURCELL KRUG & HALLER
By:
p y S i f
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2001-05564 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COLUMBIAN NATIONAL INCORPORATE
VS
GAHAGAN ROSS E
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
GAHAGAN ROSS E but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - EJECTMENT ,
NOT FOUND as to
the within named IEFENDANT GAHAGAN ROSS E
PROPERTY AT 170 ERFORD ROAD IS VACANT.
Sheriff's Costs:
Docketing 18.00
Service 9.75
Not Found 5.00
Surcharge 10.00
nn
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f.~
So answers:
R. Thomas Kline
Sheriff of Cumberland County
PURCELL KRUG & HALLER
09/28/2001
Sworn and subscribed to before me
this :ham day of CQeL,G...,
a(to/ A.D. ~p~,~
~ ~ 71~POp~~~l
P othonotary
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COLUMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. Q( -. rs`(f l..tU~l.~£Zr,~
vs. CIVIL ACTION - LAW
ROSS E. GAHAGAN
Defendant
IN EJECTMENT
N O T I C E
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 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 far 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 DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE
SET FORTH BELO TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADNINISTRATOR
FOURTH FLOOR
CRLAND COUNTY COURT HOUSE
SOUTH HANOVER STREET
CARLISLE, PA 17013
(717)240-6200
N O T I C I A
Le han demandado a usted en la Corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la Corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su
persona. See avisado que si usted no se defiende, la Corte tomara
medidas y puede entrar una Orden contra usted sin previo aviso 0
notificacion y por cualquier queja o alivio que es pedido en la
peticion de demanda. Usted puede perde2r~~ ~~
otros derechos importantes para usted. )RT®s#30a00~~~~s~3 p ~~;~; i~:,~=r°;;;;;,°~~; hat4d
~?E~ a3 eu; m~~o UB i~uL air°.i ~~ ;j?${., d°Pl.
Tho `~.~~y ~s~ ~-~
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COURT ADMINISTRATOR
FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
SOUTH HANOVER STREET
CARLISLE, PA 17013
(717)240-6200
ARISTENCIA LEGAL.
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COLOMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO.
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN .
Defendant .
C O M P L A I N T
1. Plaintiff, Columbia National Incorporated, is a corporation
with an office located at 7142 Columbia Gateway Drive, Post Office
Box 3050, Columbia, Maryland 21045-6050.
2. Defendant, Ross E. Gahagan, is an adult individual whose last
known precise residence is 170-172 Erford Road, Camp Hill,
Pennsylvania 17011.
3. Plaintiff avers that any person not set forth above, but in
possession of the premises set forth in Paragraph 2 is, and shall
become a Defendant to this action by virtue of Rule 410(b)(2) of the
Pennsylvania Rules of Civil Procedure, upon identification by the
Sheriff of Cumberland County in his Return of Service of such person,
and upon Praecipe of the Plaintiff.
4. Prior to September 5, 2001, Defendant was the owner of certain
real property known as 170-172 Erford Road, Camp Hill, Pennsylvania
17011.
5. Said premises were sold by the Sheriff of Cumberland County at
a Sheriff's Sale held at the Cumberland County Court House on
September 5, 2001, after due advertisement according to law, under
and by virtue of a Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, No. 1996-7002 Civil Term at the
suit of Fleet Mortgage Corp., formerly known as Columbia National
Incorporated vs. Ross E. Gahagan.
6. The aforesaid property was purchased at sale by Columbia
National Incorporated, the said proceedings being incorporated herein
by reference.
7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired
title to the said premises.
8. Defendant is presently in possession of the said premises,
having come into said possession by virtue of his prior ownership.
9. Plaintiff's Abstract of Title is attached hereto as Exhibit
~~ B ~~
WHEREFORE, Plaintiff demands judgment against Defendant in
Ejectment for recovery of premises described in Exhibit "A" attached
hereto and made a part hereof, plus costs of suit.
PURCELL, KRUG & HALLER
By:
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: September 24, 2001
u
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, with improvements thereon erected,
situate in East Pennsboro Township, Cumberland- County,
Pennsylvania, being more particularly bounded and described as
follows:
BEGINNING at a point on the east side of Erford Road, having a
width of 50 feet, said point being at the corner of lands now or
late of Charles G. Holmes; thence along the east of Erford Road,
North 34 degrees 40 minutes West 97 feet to a stake; thence along
the line of lands now or late of Clyde D. Smyser, et ux, North 67
degrees 20 minutes East 150 feet to a stake; thence along lands of
the same, South 34 degrees 40 minutes East 98.63 feet to a stake;
thence along the line of lands now or late of the aforesaid Charles
G. Holmes, South 67 degrees 56 minutes 27 seconds West a distance
of 150.35 feet (erroneously stated as South 63 degrees 57 minutes
West 150.24 fee in a prior deed) to a point on the east side of
Erford Road, the place of beginning.
HAVING THEREON ERECTED a four (4) family dwelling house known as
170 and 172 Erford Road, Camp Hill, PA 17011.
BEING THE SAME PREMISES which Kevin L. Stockton and Phyllis L.
Stockton, by their Deed dated December 23, 1993 and recorded in
Cumberland County Recorder of Deeds Office on December 27, 1993 in
Deed Book 5 36, page 491, granted and conveyed unto Ross E.
Gahagan.
EXHIBIT "A"
PLAINTIFFS ABSTRACT OF TITLE
1. Property acquired by Plaintiff at Cumberland County Sheriff's
Sale conducted by Sheriff of Cumberland County on September 5, 2001.
2. Deed from Kevin L. Stockton and Phyllis L. Stockton dated
December 23, 1993, and recorded in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania, on December 27,
1993, in Deed Book 5-36, Page 7002, to Ross E. Gahagan.
EXHIBIT "B"
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VERIFICATION
I verify that the statements made in the foregoing Complaint are
true and correct.
I understand thaC false statements herein are made subject to the
penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to
authorities.
Leon P. Haller
Dated;: September 24, 2001
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COLOMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. 2001-05564 P
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN .
Defendants
PRASCIPE-FOR DEFAULT JUDGMENT IN EJECTMENT
FOR POSSESSION OF REAL PROPERTY
TO THE PROTHONOTARY:
Enter default judgment in ejectment for possession of the
premises 172 Erford Road, Camp Hill, Pennsylvania 17011, described in
the attached legal description in favor of Plaintiff and against the
Defendant, Patricia Matos and Rita Rullan, and their successors,
heirs and assigns for failure to answer the Complaint within twenty
(20) days after service thereof on September 26, 2001. I hereby
certify that the Notice of Default required by Pa.R.C.P. 237.1 was
mailed to Defendant above named on October 18, 2001.
PURCELL, KRUG & HALLER
By:
Leon P. Hallexj, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: October 30, 2001
COLOMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. 2001-05564 P
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN
Defendants
NOTICE OF ENTRY OF JUDGMENT BY DEFAULT
TO: Patricia Matos and Rita Rullan
Defendants in the above action
You are hereby notified that on c.J~fic~h~---~ ~ 2001,
Judgment by Default has been entered against you in the above action
for possession of the real property described in the attached legal
description, for the reason that you failed to file an Answer to the
Complaint within 20 days after the said Complaint was served upon you
on September 26, 2001.
Prothonotary ~m
T hereby certify that the names and address of the proper
persons to receive this notice under Pa.R.C.P. 236 is:
PATRICIA MATOS
172 A ERFORD ROAD
CAMP HILL, PA 17011
RITA RULLAN
172 B ERFORD ROAD
CAMP HILL, PA 17011
Leon I
Attorney for 'ntiff
i
COLUMBIAN NATIONAL INCORPORATED
Plaintiff
vs.
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN
Defendants
TO: PATRICIA MATOS
172 A ERFORD ROAD
CAMP HILL, PA 17011
RITA RULLAN
172 B ERFORD ROAD
CAMP HILL, PA 17011
. IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-05564 P
CIVIL ACTION - LAW
IN EJECTMENT
DATE OF NOTICE: OCTOBER 18, 2001
IffiPORTANT NOTICE
XOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO-ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IAT WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGATNST
YOU. UNLESS YOU ACT WITHIN TEN (IO) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAX 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.
COURT ADMINISTRATOR
FOURTH FLOOR
SRLAND COIINTY COURT HOUS&
SOUTH HANOVER STREET
CARLISLT, YA 17013
T8L&PHONE (717)240-6200
PURCELL, RRUG & HALLER
By:
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
COLUMBSAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN
Defendants
NO. 2001-05564 P
CIVIL ACTION - LAW
IN EJECTMENT
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
LEON P. HALLER, attorney for Plaintiff, being duly sworn
according to law, deposes and says that he is a duly constituted
representative for the Plaintiff in the above captioned action; that
he is duly authorized to make this affidavit; that he has personal
knowledge, information and belief, that Defendant of the real estate
described in the Complaint are not in the Military or Naval Services
of the United States or its allies or otherwise within the provisions
of the Soldiers' and Sailors' Civil R Act of 1940, as amended.
-~/~
Leon P. 1 x_~
Attorney for Pfl`aintiff
(SEAL)
NoTarlel8~1
Bonita E. Prussack~ Notary Publ~
~~y{~p,, of Harrisburg. Countr~(yy
My CSommission EaWtes~.28, 2605
fAr. Patu~sylYasia Association of Notaries
My commission expires:
i
COLUMBIAN NATIONAL INCORPORATED IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. 2001-05564 P
vs. CIVIL ACTION - LAW
IN EJECTMENT
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN
Defendants
ENTRY OF JUDGMENT BY DEFAULT
AND NOW, on this 31~s~ day of ~~~ 2001,
-o-~,
default judgment is hereby entered against the Defendants, PATRICIA
MATOS and RITA RULLAN, and their successors, heirs and assigns, in
ejectment for possession of the premises described in the attached
legal description.
Prothonotary
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, with improvements thereon erected,
situate in East Pennsboro Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as
follows;
BEGINNING at a point on the east side of Erford Road, having a
width of 50 feet, said point being at the corner of lands now or
late of Charles G. Holmes; thence along the east of Erford Road,
North 34 degrees 40 minutes West 97 feet to a stake; thence along
the line of lands now or late of Clyde D. Smyser, et ux, North 67
degrees 20 minutes East 150 feet to a stake; thence along lands of
the same, South 34 degrees 40 minutes East 98.63 feet to a stake;
thence along the line of lands now or late of the aforesaid Charles
G. Holmes, South 67 degrees 56 minutes 27 seconds West a distance
of 150.35 feet (erroneously stated as South 63 degrees 57 minutes
West 150.24 fee in a prior deed) to a point on the east side of
Erford Road, the place of beginning.
HAVING THEREON ERECTED a four (4) family dwelling house known as
170 and 172 Erford Road, Camp Hill, PA 17011.
BEING THE SAME PREMISES which Kevin L. Stockton and Phyllis L.
Stockton, by their Deed dated December 23, 1993 and recorded in
Cumberland County Recorder of Deeds Office on December 27, 1993 in
Deed Book S 36, page 491, granted and conveyed unto Ross E.
Gahagan.
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COLUMBIAN NATIONAL INCORPORATED
Plaintiff
vs.
ROSS E. GAHAGAN, PATRICIA
MATOS and RITA RULLAN .
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-05564 P
CIVIL ACTION - LAW
IN EJECTMENT
PRAECIPE FOR LPRIT OF POSSESSION
TO THE PROTHONOTARY:
Issue a Writ of Possession against PATRICIA MATOS and RITA
RULLAN in the above matter for the possession of the premises set
forth in the attached legal description.
PURCELL, KRUG &
By:
Leon P. Idler, squire
1719 North Fron treet
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
Dated: October 30, 2001
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, with improvements thereon erected,
situate in East Pennsboro Township, Cumberland County,
Pennsylvania, being more particularly bounded and described as
follows:
BEGINNING at a point on the east side of Erford Road, having a
width of 50 feet, said-point being at the corner of lands now or
late of Charles G. Holmes; thence along the east of Erford Road,
North 34 degrees 40 minutes West 97 feet to a stake; thence along
the line of lands now or late of Clyde D. Smyser, et ux, North 67
degrees 20 minutes East 150 feet to a stake; thence along lands of
the same, South 34 degrees 40 minutes East 98.63 feet to a s,take;-
thence along the line of lands now or late of the aforesaid Charles
G. Holmes, South 67 degrees 56 minutes 27 seconds West a distance
of 150.35 feet (erroneously stated as South 63 degrees 57 minutes
West 150.24 fee in a prior deed) to a point on the east side of
Erford Road, the place of beginning.
HAVING THEREON ERECTED a four (4) family dwelling house known as
170 and 172 Erford Road,. Camp Hill, PA 17011.
BEING THE SAME PREMISES which Kevin L. Stockton and Phyllis L.
Stockton, by their Deed dated December 23, 1993 and recorded in
Cumberland County Recorder of Deeds Office on December 27, 1993 in
Deed Book S 36, page 491, granted and conveyed unto Ross E.
Gahagan.
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By virtue of this writ, on the day of ,
I caused the within named , to
have possession of the premises described with the appurtenances,and Writ of Possession returned
Stayed as per Attorney. Adsr r * ~ra® ~0
Sheriff's Cost's 59.92
Sheriff's Costs: -~-~-
Docketing: $
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Refunded to Atty on 1/9/02
Sworn and subscribed to before me this
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Prothonotary
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WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
Coltunbian National Incorporated
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-5564 Civil Term
No. Term
Costs
Ross E. Gahagan, Patricia
Matos and Rita Rtzllan
172 Erford Road
Came Hill. PA 17011
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
Atty. $ 154.00
PPff (s) $
Prothy. _ $ 1.00
To the Sheriff of Ctnnberland 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:
Coltmtbian National Incorporated
being: (Premises as follows):
172 Erford Road
Camp Hill, PA 17011
Plaintiff (s)
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen-
dant (s) and sell his/her (or their) interest therein.
Date October 31, 2001
(SEAL)
Curtis R. Lonq
Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania
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