HomeMy WebLinkAbout07-2807SHEILA H. LANDIS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.2007 - aM1 CIVIL TERM
JOY E. HEPFER, CIVIL ACTION -LAW
Defendant IN EJECTMENT
NOTICE TO DEFEND
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.
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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
SHEILA H. LANDIS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2007 - I N 7 CIVIL TERM
JOY E. HEPFER, CIVIL ACTION -LAW
Defendant IN EJECTMENT
COMPLAINT
AND NOW, comes Plaintiff, Sheila H. Landis, by and through her attorneys, O'BRIEN,
BARIC & SCHERER, and brings this Complaint in Ejectment against Defendant, Joy E. Hepfer,
and in support of thereof, sets forth the following:
1. Plaintiff, Sheila H. Landis (hereinafter "Plaintiff'), is an adult individual currently
residing at 16 Cobblestone Drive, Carlisle, Cumberland County, Pennsylvania, 17015-4388.
2. Defendant, Joy E. Hepfer (hereinafter "Defendant"), is an adult individual
currently residing at 36 East Keller Street, Mechanicsburg, Cumberland County, Pennsylvania,
17055-3826.
3. Plaintiff is the true and legal owner of a certain parcel of property situated at 36
East Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055-3826 (hereinafter,
"the Property"). A true and correct copy of the deed for the Property is attached hereto, marked
as Exhibit "A" and incorporated by reference. A true and correct copy of a title abstract for the
Property is attached hereto, marked as Exhibit "B" and incorporated by reference.
4. There is not and has never been a lease between Plaintiff and Defendant for the
Property.
5. Defendant does not and never has paid rent to Plaintiff since Plaintiff purchased
the Property.
6. Defendant does not and never has paid the mortgage, taxes or insurance on the
Property.
7. Defendant is living on the Property unlawfully and without right or authority.
8. Despite multiple requests by Plaintiff, Defendant has refused to abandon the
Property.
9. As a result of Defendant's refusal to abandon the Property, Plaintiff has been
forced to incur rental costs elsewhere in the amount of $300 per month since July 2006,
excluding the month of October.
WHEREFORE, Plaintiff demands judgment in ejectment for possession of the Property
in her favor and against Defendant along with the Property's fair market rental value, Plaintiff's
costs and expenses for this suit and Plaintiff's costs and expenses for alternative housing
accommodations.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
lj,
- , j. Robert . Daile squire
I.D. 203418
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
SHEILA H. LANDIS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2007 - CIVIL TERM
JOY E. HEPFER, CIVIL ACTION -LAW
Defendant IN EJECTMENT
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements made herein
are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to
authorities.
eil . Landis
Date: May 4, 2007
EXHIBIT "A"
ILI
1005 I%Y 12 Apt ii 19
Parcel Number: 17-24-0787-048
(MS DEED
THIS DEED, made the day of JWdlit!A , 2005,
BETWEEN Stanley S. Conner and Ingrid J. Conner, husband and wife,
Grantors,
AND
Sheila H. Landis, a single woman, Grantee,
WITNESSETH, That in consideration of the sum of One Hundred Three
Thousand ($103,000.00) Dollars, in hand paid, the receipt whereof is hereby
acknowledged, the said grantors do hereby grant and convey to the said
Grantee, her heirs and assigns,
ALL THAT CERTAIN tract or lot of ground situate in the Borough of
Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and
described as follows, to wit:
BOUNDED on the North by East Keller Street; on the East by Lot now or
formerly of William H. Coover; on the South by a public alley an don the West by
Lot now or formerly of the heirs of George H. Bucher. HAVING a frontage on
said East Keller Street of eighteen and one-tenth feet, more or less, a width on
said alley of nineteen and five-tenths (19.5) feet, more or less, and a depth from
said East Keller Street to said alley of one hundred thirty-nine (139) feet, more or
less.
BEING THE SAME PREMISES which John F. Woodward and Marilyn Sue
Woodward, husband and wife, by Deed dated November 17, 2003 and recorded
in the Office of the Recorder of Deeds in Cumberland County on December 30,
2003 in Book 261, Page 109, granted and conveyed to Stanley S. Conner,
grantor herein. By virtue of Ingrid J. Conners' marriage to Stanley S. Conner,
said Ingrid J. Conner does hereby join in this conveyance, relinquishing any and
all right, title and interest she may have in said premise.
aoox 268 wr4193
TO HAVE AND TO HOLD the said premises with all and singular the
appurtenances, unto the said Grantee, party of the second part, its successors
and assigns, to and for the only proper use and behoof of the said party of the
second part, its successors and assigns forever. AND the said party of the first
part, for itself, its heirs, executors, and administrators, does by these presents,
covenant, grant and agree to and with the said party of the second part, its heirs
and assigns, that he, the said party of the first part, and its heirs, all and singular
the hereditaments and premises herein above described and granted, or
mentioned and intended so to be, with the appurtenances unto the said party of
the second part, its heirs and assigns, against the said party of the first part and
its heirs, and against all and every other person or persons, whomsoever,
lawfully claiming or to claim the same or any part thereof, by, from or under him,
her, them, or any of them, shall and will, by these presents, SPECIALLY
WARRANT AND FOREVER DEFEND.
IN WITNESS WHEREOF, said Grantor has hereunto set his hand and seal, the
day and year first above-written.
Sealed in the presence of:
Witness
B"?
Witness
to ley Conner, Grantor
Ingrid J. Co er, Grantor
Certificate of Residence
I hereby certify, that the precise residence of the Grantee herein is:
Mirl( IQ C' ka 11 -7
Agent for Gr tee
BOOK 268 Pacr4x94
..
Commonwealth of Pennsylvania :
ss
County of C.wwt
On this, the .ZU- day of /11 a t-k , 2005, before me, a notary
public, the undersigned officer, personally appeared Stanley S. Conner and
Ingrid J. Conner, known to me (or satisfactorily proven) to be the person(s)
whose name(s) he/she/they subscribed to the within instrument, and
acknowledged that he/she/they executed the same for the purpose therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
Notary
My Commission Expires:
Ccman, Meft lvanis
!!gmr?Tv M-
Commonwealth of Pennsylvania
. ss.
County of '
RECORDED in the Office for Recording of Deeds, etc., in and for said County, in
Record Book No. , Page
WITNESS my Hand and Official Seal this day of 2003.
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BOOK 268 PavF4:.55
REV-183 E% 16.961 RECORDER'S USE ONLY
Star Tax Po' /.?
V
REALTY TRANSFER TAX gas Norther
COMMONWEALTH OF PENNSYLVANIA STATEMENT OF VALUE
DEPARTMENT OF REVENUE Page u
BUREAU OF INDIVIDUAL TAXES
DEPT. Recorded
HARRISGU G, P8AD1177128.0603 See Reverse for Instructions °'•
Complete each section and file in duplicate with Recorder of Deeds when (1) the full valuelconsideration is not set Forth in the deed, (2) when the deed
is without consideration, or by gift, or 3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax
based on: (1) family relationship or (2) public utility easement. If more space is needed, attach additional sheet(s).
A CORRESPONDENT - All inquiries mayAbeMdirected to the following person:
hCode ( l [ Number: I 3?6 ro
Area t3
Street OAddress t Zip Code
ysA-- ,-
B TRANSFER DATA Acceptance ° Document
Graroor(s)fl•ssor s ? c t 1 ? ? ?
,V) crant..(s n.u•• s k?t `? 4 ?A?f
st AScIrdst ?
T
a Street ress
State Zip Code
it
y
C f? & 1ZOa City A
j A D • Zip Co •
V`? dj
6
C PROPERTY LOCATION
City, Township, Borough
Street Address
3 AL/ E4-.. I A" A-","
County Schoo District
Tax Parcel Num EW- %J
'7 a y o? 97 aye,
?c6 I?_ S- r
DATA
2. Check Appropriate Box Below for Exemption Claimed
? Will or intestate succession
iName of Decedent) I?Nwn r)
El Transfer to Industrial Development Agency.
? Transfer to a trust. (Attach complete copy of trust agreement identifying oil beneficiaries.)
? Transfer between principal and agent. (Attach complete copy of agency/straw party agreement.)
? Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or in lieu of condemnation.
(If condemnation or in lieu of condemnation, attach copy of resolution.)
Under penalties of law, I declare that 1 have examined this Statement, ir(cluding accompanying leWormation, and to the best of my knowledge
and belief, it is true, come and compote.
FAILURE TO COMPLETE THIS
TO RECORD THE DEED.
REFUSAL
D VALUATION DATA r
? Transfer from mortgagor to a holder of a mortgage in default. Mortgage Book Number , Page Number
? Corrective or confirmatory deed. (Attach complete copy of the prior deed being corrected or confirmed.)
? Statutory corporate consolidation, merger or division. (Attach copy of articles.)
? Ctther (Please explain exemption claimed. if other than listed above.l
EXHIBIT "B"
-j ingCo.,Jnc.
1035 Wayne Avenue Chambersburg, PA 17201
Phone: (717) 264-3290 Fax: (717) 264-1985
Titled in name o£: Lo-,,d ?_T Sh Q i I a.... /J,,- s «o? /e 0%cma.v w
Property Address: 36 E' f i e8e_ r S f ee-I 06v4
City: M e dlo_n 1 es Lcr a Pennsylvania Zip: ! 7 o s s-
Municipality:
ro
Acquisition of Title
Dated of deed: -3 131 / cs Date Recorded: s 1 r.z I os- Book: 268 Page: 419.3
Consideration: $ 10 3, 00 0 , 0 b
Recorded in: c1MJ31LM
County
Grantor(s): C nnel•? 51a?le:cf ?.? ?MC rrd ]ia.w _
Assessment: Land: 3pdoo Improvements: ssi50 Total: R5?s4
Tax Map: l7-,? y -0 7 k-7 Parcel: O Y S
Mortgages
I. Amount:$ lv3?G0o,oa Date of Mortgage: 4 laq I n5_ Date Recorded: 9-l 1.1 /as-
Boolc: 1 r1C6 Page: y-73S Terms: OPEN-END C M0_ '
Held By: i11EFS lnc for rjr,t Horizon b6 e Loan, C-rPo,, Ln
Signed as: .s«
Assignment: _,-io,u
2. Amount: $_
Boole:
Held By:
Signed as: _
Assignment:
Date of Mortgage Date Recorded: /
Page: Terms: OPEN-END CLOSED-END
3. Amount: $ Date of Mortgage, Date Recorded: I 1
Boole. Page: Terms: OPEN-END CLOSED-END
Held By: _
Signed as:
Assignment:
Tax Liens (real estate) MortLmEes - S (satisfied)
(if current tax amounts are required, contact appropriate tax collector)
') core county school p" e__ IReb- 4135
Secured/,Recorders <J -,-
Adverses: cit -
?J Judgments: c (ems
For Information purposes only:
Report for: C?'(?r e», liar c +SGQ u To: Date requested. S- / 7 / o7
Date covered: 1? / 3 o f/ o, Reported: T/ 1 1-0 1 Searcher: r,,, .-
This is a Property Report. This is NOT a Title Search and this is NOT a certification of Title to this orooerty.
_ v 2CC- 4 42P?VIra??l ?i 3ea ??ta`e gar 'is
a'
Prepared By.
FIRST HORIZON HOME LOAN CORPORATION
681 ANDERS$N DRIVE, SUITE 420
PITTSBURGH, PA 15220
Return To:
FRRLC - POST CLOSING MAIL ROOM
1S55 1t. WALNUT HILL LN. #200 MC 6712
IRVING, Tx 75038
Parcel Number: County: 17-24-0787-048 City;
n E,n '/4
r 17
? , 1`I1 1Y 12 H19 11 19
[Space Above This Line For Rm6rdit Daja)
MORTGAGE 0053130894
DEFINITIONS MIN 10008320053130a940
Words used in multiple sections of this document are defined below and other words arc defined in Sections
3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document fi
in Section 16 also provided
.
(A) "Security Instrument" mheans this document, which is dated April 29th, 2005
together with all Riders to this document. '
(B) "Borrower" is
SHEILA H LJUMIS
Borrower is the mortgagor under this Security Instrument.
(C) "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate corporation that is acting
solely as a nominee for Lender and Lender's successors and assigns. MERS is the tgortgagee under this
Security Iustrtaftnt. MERS is organized and existing under the laws of Delaware, and has an address and
telephone number of P.O. Box 2026, Flint MI 48501-2026, tel. (888) 679-MERS.
PENNSYLVANIA - Single Family - Fannie Mae/Fraddle MAC UNIFORM INSTRUMENT 1MTN MERS
CI-4A(PA) (o4o7) Form 3038 1101
Pepe t of 1B Initw,
VMP Mortgage Solutions, Inc. (eoo)521.7291
BKI906PG4735
?n -
(D) "Lender" is FIRST 13ORTZON HODS LOAN CORKRATION
Lender is a CORPORATION
organized and existing under the laws of TFtB STATt; of XANSAS
Lender's address is 4000 HerizOn Way, Irving, Texas 75063
(E) "Note" means the promissory note signed by Borrower and dated April 29t:h, 2005
The Note states that Borrower owes Lender
ONE BUMMID TI XZE THOUSAND & 00/100
U, S. $ 103,000.00 Dollars
plus interest. Borrower has promised to pay this debt in regular Periodic
Payments and to pay the debt in full not later tban MAY 1, 2035
M Vro"Y" Umas the property that is described below under the heading "Transfer of Rights in the
Property."
(G) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all sums due tinder this Security Instrument, plus interest.
(H) "Riders" means all Riders to this Security Instrument that are executed by ,Borrower. The following
Riders are to be executed by Borrower [check box as applicable]-
7-1 Adjustable Raw Rider ? Condominium Rider ? Second Horm Rider
Balloon Rider ? Planned Unit Development ]cider ? 1-4 Family Rider
?? VA Rider ? Biweekly Payment Rider ? Other(s) [specify]
(I) "Applicable Law" means all controlling applicable federal state and local sramtes, reg ulations,
ordinances and administrative rules and orders (that have the effec,
t of law) as well as all applicable final,
uon-appealable judicial opinions.
(.) "Conwitnity Association Dues, Fees, and Assessments" means all dues, fees, asse&4k= s and other
charges that are imposed On Borrower or the Property by a condominium association, homeowners
association or similar organization.
(I{) "Electronic Fundy Transfer" means any transfer of funds, other than a transaction originated by check,
draft, r similar paper instrument, which is initiated through an electronic terminal, telephoi is instrument,
computer, Or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an
account. Such term includes, but is not limited to, point of-sale transfers, automated teller machine
transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers,
(L) "Escrow Items" means those items that are described in Section 3.
(1VA "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by
aAY patty (other than insurance proceeds paid under the coverages described in Section 5 for: t
damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property;
(iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or
condition of the Property,
(N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the
Loan,
(0) "Periodic )Payment" means the regularly scheduled amount due for (i) principal and interest under the
Note, p () any amounts under Section 3 of this Security Instrument.
0053130894
Ck-SA(PA) (cons) inivals: _
Pepe 2 of to Form 3039 1N1
BK I 906PG4736,
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SHEILA H. LANDIS IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2007 - 2807 CIVIL TERM
JOY E. HEPFER CIVIL ACTION -LAW
Defendant IN EJECTMENT
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
To: Joy E. Hepfer, Defendant
36 East Keller Street
Mechanicsburg, Pennsylvania 17055
Date of Notice: MU 30, 2007
IMPORTANT NOTICE
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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
? ? I
Robert J. Bailey, Esq
I.D. 203418
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Cn_' ° p
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SHEILA H. LANDIS IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2007 - 2807 CIVIL TERM
JOY E. HEPFER CIVIL ACTION -LAW
Defendant IN EJECTMENT
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
To: The Prothonotary of Cumberland County, Pennsylvania
Please enter a judgment for the Plaintiff, Sheila H. Landis and against the Defendant, Joy
E. Hepfer, in the above-captioned case for failure of the Defendant to file a responsive pleading
to Plaintiffs complaint.
A true and correct copy of the Notice of Praecipe to Enter Judgment by Default is
attached hereto as Exhibit "A" and was sent on May 30, 2007 to the Defendant by Plaintiff's
counsel.
Plaintiff requests judgment in ejectment against the Defendant.
Additionally, Plaintiff requests damages in the amount of $14,717.50 as set forth in the
Plaintiffs Complaint for the property's fair market rental value, Plaintiff's costs and expenses
for alternative housing accommodations and Plaintiff s costs and expenses for this suit.
Robert J. ail uire
I.D. 203418
O'BRIEN, BARIC & SCHERER
19 West South Street
Carlisle, PA 17013
Phone: (717) 249-6873
Date: June 12, 2007 Attorney for Plaintiff
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CERTIFICATE OF SERVICE
I hereby certify that on June 12, 2007, I, Robert J. Dailey, Esquire, of O'Brien, Baric &
Scherer, did serve a copy of the Praecipe to Enter Judgment by Default by first class, U.S. mail,
postage prepaid, to the party listed below, as follows:
Joy E. Hepfer
36 East Keller Street
Mechanicsburg, PA 17055
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SHEILA H. LANDIS
Plaintiff
V.
JOY E. HEPFER
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007 - 2807 CIVIL TERM
CIVIL ACTION - LAW
IN EJECTMENT
NOTICE OF JUDGMENT
TO: Joy E. Hepfer
36 East Keller Street
Mechanicsburg, PA 17055
Notice is hereby given to you of entry of a judgment against you in the above matter.
Date: is 0; of June 2007
SZ l!ice?te U tz
Prothonotary ?,,,
EXHIBIT "A"
SHEILA H. LANDIS IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2,007 - 2807 CIVIL TERM
JOY E. HEPFER CIVIL ACTION - LAW
Defendant IN EJECTMENT
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT _
c ° o
To: Joy E. Hepfer, Defendant z, ?'
36 East Keller Street { r ,
-< MM
Mechanicsburg, Pennsylvania 17055 C w
-c o 23T
Date of Notice: May 30, 2007 o
?- OR
IMPORTANT NOTICE o
o
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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
ax&
Robert J. Bailey, Esq
I.D. 203418
19 West South Street
Carlisle, PA 17013
(717) 249-6873
f s ..?
SHEILA H. LANDIS
Plaintiff
V.
JOY E. HEPFER
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007 - 2807 CIVIL TERM
CIVIL ACTION - LAW
IN EJECTMENT
PRAECIPE FOR WRIT OF POSSESSION
To: The Prothonotary of Cumberland County, Pennsylvania
Please issue writ of possession in the above matter.
?w t? (&i (ems a.
l eL?aP71 CS?r PA
Robert J. Dairy, squire
I.D. 203418
O'BRIEN, BARIC & SCHERER
19 West South Street
Carlisle, PA 17013
Phone: (717) 249-6873
Fax: (717) 249-5755
Attorney for Plaintiff
Date: June 12, 2007
T'
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WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
/ Sheila H. Tandis
16 Cobblestone Drive
Carlisle, Pa. 17015
vs.
Joy E. Hepfer
36 East Keller Street
Mechanicsburg, Pa. 17055
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07-2807 Civil Term
No. Term
Costs
Att'y. $ 169.45
Pl' ff (s) $ 2.00
Prothy. $
To the Sheriff of nrrnherland 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:
Sheila H. Landis 16 Cobblestone Drive, Carlisle, Pa. 17015
Plaintiff (s)
being: (Premises as follows):
36 East Keller Street
Mechanicsburg, Pa. 17055
(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.
s
Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania
Date June 12, 2007 By: (
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(SEAL) Deputy
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By virtue of this writ, on the day of
I caused the within named
have possession of the premises described with the appurtenances, and
So Answers,
Sworn and subscribed to before me this
day of
. to
Sheriff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-02807 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LANDIS SHEILA H
VS
HEPFER JOY E
STEPHEN BENDER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT was served upon
TI-ruin TlnV V the
DEFENDANT , at 2020:00 HOURS, on the 9th day of May 2007
at 36 EAST KELLER STREET
MECHANICSBURG, PA 17055-3826 by handing to
JOY HEPFER
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 18.00
Service 10.56
Postage .39
Surcharge 10.00
.00
s?3??o? ?., ? 38.95
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
05/10/2007
O'BRIEN BARIC SCHERER
By:
D uty Sheriff
A. D.
0- •
SHEILA H. LANDIS
Plaintiff
V.
JOY E. HEPFER
Defendant
-> 3q E. Ke-iw s+.
INPc,6,fticSDw PA
170-65
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007 - 2807 CIVIL TERM
CIVIL ACTION - LAW
IN EJECTMENT
PRAECIPE FOR WRIT OF EXECUTION
To: The Prothonotary of Cumberland County, Pennsylvania
Please issue writ of execution in the above matter,
(1) directed to the sheriff of Cumberland County;
(2) against Joy E. Hepfer, Defendant.
Amount Due: $14,717.50.
rev y a?a?nS+ al I fuso
Q11b P'pX+y.
Robert J. Dailey, quir
I.D. 203418
O'BRIEN, BARIC & SCHERER
19 West South Street
Carlisle, PA 17013
Phone: (717) 249-6873
Fax: (717) 249-5755
Date: July 18, 2007
Attorney for Plaintiff
.--- . A
CERTIFICATE OF SERVICE
I hereby certify that on July 18, 2007, I, Robert J. Dailey, Esquire, of O'Brien, Baric &
Scherer, did serve a copy of the Praecipe for Writ of Execution by first class, U.S. mail, postage
prepaid, to the party listed below, as follows:
Joy E. Hepfer
34 East Keller Street
Mechanicsburg. PA 17055
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2807 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SHEILA H. LANDIS, Plaintiff (s)
From JOY E. HEPFER, 34 E. KELLER ST., MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST ALL
PERSONAL PROPERTY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $14,717.50 L.L.
Interest
Atty's Comm % Due Prothy $2.00
Atty Paid $24.00 Other Costs
Plaintiff Paid
Date: JULY 18, 2007
Curti( R. Long, Prothonotary
(Seal) By: -'010? -P
Deputy
REQUESTING PARTY:
Name ROBERT J. DAILEY, ESQUIRE
Address: O'BRIEN, BARIC & SCHERER
19 WEST SOUTH STREET
CARLISLE, PA 17013
Attorney for: PLAITNIFF
Telephone: 717-249-6873
Supreme Court ID No. 203418
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By virtue of this writ, on the
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2007
I caused the within named Sheila H. Landis , to
have possession of the premises described 36 F Keller Street
Mechanicsburg. PA 17055
Advance Costs: 150.00
Sheri ff 'c Befur„ col'- SAS £-.- Q? ??
Docketing 18.00 59.01
Prothonotary 2.00
Possession 30.00
Surcharge 20.00 /
? `L, j/jf So Ans
Sworn and subscribed to before me this
day of
Prothonotary
Sh ' f ?hygM
ty
By
--J?LM? If
Deputy 1,010
WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.)
16 Cobblestone Drive
Carlisle, Pa. 17015
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07-2807 Civil Term
No.
Costs
Joy E. Hepfer I Att'y.
36 East Keller Street
Mechanicsburg, Pa. 17055
Pl'ff (s)
Prothy.
$ 169.45
$ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of cimberland 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:
Sheila H. Landis 16 Cobblestone Drive, Carlisle, Pa. 17015
being: (Premises as follows):
36 East Keller Street
Mechanicsburg, Pa. 17055
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.
Y
Prothonotary, Common Pleas ourt of Cumberland County, Pennsylvania
Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs 107.12
Docketing 18.00 42.88
Poundage 2.10
Advertising 10.00
Law Library
Prothonotary 2.00 Refunded to Atty on 04/02/08
Mileage 19.20
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale 15.00
Certified Mail
Postage .82
Garnishee
TOTAL 107.12 ? y/a v?o P
So Ans er .?
R. Thomas Kline, Sheriff
By C.
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113
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2807 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SHEILA H. LANDIS, Plaintiff (s)
From JOY E. HEPFER, 34 E. KELLER ST., MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST ALL
PERSONAL PROPERTY., 2003 Mazda Miata, Big Screen Television.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $14,717.50
Interest
Atty's Comm %
Atty Paid $24.00
Plaintiff Paid
Date: JULY 18, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT J. DAILEY, ESQUIRE
Address: O'BRIEN, BARIC & SCHERER
19 WEST SOUTH STREET
CARLISLE, PA 17013
Attorney for: PLAITNIFF
Telephone: 717-249-6873
L.L.
Due Prothy $2.00
Other Costs
-vFULy
Supreme Court ID No. 203418