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HomeMy WebLinkAbout07-2826 ~ GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE SOOO MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants NOTICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF EJECTMENT Term ~ No. C77 'o~bo~ Lam-( CIVIL ACTIpN: EJ~ECT~EIVT 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 the Complaint and notice are served, by entering a writtce 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 warmed that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the Court without further notice for any money claim in the Complaint of 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 TO FIlVD OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DL4S DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJA5 EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERII2A QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUIDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS Il~fPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO 1MMEDIATEAMENTE. 238-6300. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 COMPLAINT IN EJECTMENT 1. Plaintiff is TRAVELERS BANK & TRUST FSB, 1111 Northpoint Drive, Building 4 Suite 100, Coppel, TX 75019. 2. Defendants are PATRICIA A. GEORGE, STEVEN A. GEORGE, and OCCUPANTS. 3. Plaintiff is the equitable owner of premises 236 Woods Drive, Mechanicsburg, PA 17055 a legal description of which is attached. ("Property") 4. Plaintiff became the equitable owner of the Property as a result of foreclosure and judicial sale by the Sheriff of Cumberland County. The sheriff s sale of the property was held on March 07, 2007. 5. Plaintiff, by virtue of the its purchase of the property, is the equitable owner of said Property and is entitled to immediate possession thereof. The Defendants, PATRICIA A. GEORGE, STEVEN A. GEORGE and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the said Defendants, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. GOLDBECK McCAFFERTY & McKEEVER B o ph A. Gol k, Jr., Esq. VERIFICATION I, Joseph A. Goldbeck, Jr. as the Attorney of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: (1 ;~ 2007 se A. ld Jr. #4425009 - PATRICIA A. GEORGE and STEVEN A. GEORGE C/~' C ~ C7 ~ ~ ~ t t" ~~v~ \ ~ r r ~ ~ O ' - } ~ V ~ r '., ~ j -~ ~Y 1 ~ V -~ ' h ~-~~~-» y.f .~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 vs. Plaintiff PATRICIA A. GEORGE and STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF EJECTMENT Term No. 07-2826-Civil PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, TRAVELERS BANK & TRUST FSB and against the Defendants PATRICIA A. GEORGE, STEVEN A. GEORGE and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237.1, written 10 day notice of Plaintiff's intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is TRAVELERS BANK & TRUST FSB, 1111 Northpoint Drive, Building 4 Suite 100, Coppel, TX 75019 and that the names and last known address of the Defendants are PATRICIA A. GEORGE, STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive, Mechanicsburg, PA 17055. G BE K McCAF T & McKEEV R B .Joseph A. Goldbeck, Jr. Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 Plaintiff vs. PATRICIA A. GEORGE and STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF EJECTMENT Term No. 07-2826-Civil CERTIFICATION PURSUANT TO PA R.C.P. N0.237 I, Joseph A. Goldbeck, Esquire, attorney for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: PATRICIA A. GEORGE STEVEN A. GEORGE OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 GOLDBECK McCAFFERTY & McKEEVER BY: Jo ph .Goldbeck, Jr., Esq. Attorney for Plaintiff DATED: June 18, 2007 GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 Plaintiff vs. PATRICIA A. GEORGE, STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants DATE OF THIS NOTICE: June 6, 2007 TO: OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 IMPORTANT NOTICE TN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF EJECTMENT Term No. 07-2826-Civil 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 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. LEGAL SERVICES [NC 8 Irvine Row Carlisle. PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CNIL ACTION -LAW ACTION OF EJECTMENT vs. PATRICIA A. GEORGE, STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants DATE OF THIS NOTICE: June 6, 2007 TO: PATRICIA A. GEORGE and STEVEN A. GEORGE 236 Woods Drive Mechanicsburg, PA 17055 IMPORTANT NOTICE Term No. 07-2826-Civil 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 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 HIlZING 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PATRICIA A. GEORGE, is about unknown years of age, that Defendant's last known residence is, 236 Woods Drive Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: ~~ _ ~ g " ~~ ~• ~ VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, STEVEN A. GEORGE, is about unknown years of age, that Defendant's last known residence is 236 Woods Drive Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments Date: ~~ ' ~ ~ ~ 1` ~.. C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 Defendants PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter, for possession of (describe property) SEE ATTACHED LEGAL DESCRIPTION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 07-2826-Civil G D CK, McCA TY & McKEEVE Joseph A. Goldbeck, Jr. ttorney for Plaintiff Ejectment Quiet Title A. 5 - 116 (Rev. 10/76) "tQ. ~' .. a .,s !u xs w 9v :==~ o ~ ~ _ = ~ ~-- ~: ~, ~/^^J V• u ~., H b W C! ~ 0° r ~~~~~ m~~~~~~ o~~~~a~ m~~~~~~ ~~~~~. J~~~~~~ ~~~"°~ b ~~s~~~ m~~o~'y~Y.~ C7H NM~~O Kv~~~y.m° ~x~°aa ~'r ~~~d~~ ,~~ ~~~~~b ~w~"s~~ J H` H Q `~i 1 Iof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRAVELERS BANK & TRUST FSB VS. No. 07-2826 Civil Term_ PATRICIA A. GEORGE STEVEN A. GEORGE AND OCCUPANTS 236 WOODS DRNE MECHANICSBURG, PA 17055 Costs Attorney's $ 195.14 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) TRAVELERS BANK & TRUST FSB being: (Premises as follows): 236 WOODS DRIVE, MECHANICSBURG, PA 17055 SEE ATTACHED LEGAL DESCRIPTION (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Curtis R. Long, Pro , Common Pleas ourt of Cumberland County, PA Date ,DUNE 19, 2007 (Seal) 2of2 No 07-2826 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRAVELERS BANK & TRUST FSB 1111 NORTHPOINT DRIVE BUILDING 4 SUITE 100 COPPEL, TX 75019 VS. PATRICIA A. GEORGE STEVEN A. GEORGE AND OCCUPANTS 236 WOODS DRIVE MECHANICSBURG, PA 17055 WRIT OF POSSESSION P.RC.P. 3160-3165 ETC. Costs Att'y $ 195.14 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: JOSEPH A. GOLDBECK, JR., ESQUIRE GOLDBECK, MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for Plaintiff {s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , So Answers, Sheriff By Prothonotary Deputy x 0 H N . y ~ Q P X0+1 T„ ~~~~®s ttt~~ N QQ77 ~~4~~~ a~e~wa r~nv~~Or~ o •~~a~ca ~"~ ~ ~ h. C~ O ~ ~ E ~~~~~~ spa ~. ~~~~ ~. . iS LY~"!QQ~ ggR~~~O ai 'ffiAp"'~ ~ ~ ~~ sM~~~~ H ~~~~ o~~ H M ~ A~ ~~ SHERIFF'S RETURN - REGULAR CASE•NO: 2007-02826 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon GEORGE PATRICIA A the DEFENDANT at 1939:00 HOURS, on the 16th day of May 2007 at 236 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to PATRICIA GEORGE 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 8.64 Affidavit .00 Surcharge 10.00 .00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/17/2007 GOLDBECK MCCAFFERTY M FEVER By: Deputy Sheriff of A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02826 P ~OMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA ET AL 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 GEORGE STEVEN A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT FOUND as to the within named DEFENDANT GEORGE STEVEN A 236 WOODS DRIVE MECHANICSBURG, PA 17055 PATRICIA GEORGE IS THE ONLY OCCUPANT. Sheriff's Costs: Docketing Service Not Found Surcharge 1~~16 ~ 9~ So answers..,. ~~''' _ 6.00 ...----..''f--,--Y.. ~";:~ .00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 05/17/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02826 P EOMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TRAVELERS BANK & TRUST FSB VS GEORGE PATRICIA ET AL 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 OCCUPANTS but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT OCCUPANTS 236 WOODS DRIVE NOT FOUND as to MECHANICSBURG, PA 17055 PATRICIA GEORGE IS THE ONLY OCCUPANT. Sheriff's Casts: Docketing Service Not Found Surcharge 5~a r~bn q,.~ `l So answers :.~~--~ ..__. ~ ;~~ 6 . 0 0 ~ ! __.-. 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 05/17/2007 Sworn and Subscribed to before me this day of A.D. GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Joseph A. Goldbeck, Esquire Attorney LD. # 16132 Suite 5000- Mellon Independence Center 701 S. Market Street Philadelphia, PA 19106 215-825-6321 ATTORNEY FOR PLAINTIFF TRAVELERS BANK & TRUST F5B 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75019 vs. PATRICIA A. GEORGE and STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 07-2826-Civil Kindly mark the judgment in the above matter satisfied of record. GOLDBECK McCAFFERTY & McKEEVER BY: ECK, ttorn for Plaintiff G ° ~s r. Q ' L. -, •, ,~ t tJ" ::~ ~ ~C7 .,,~ ~. ~ C~ ` ~ ~\ ~- ~- GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff TRAVELERS BANK & TRUST FSB 1111 Northpoint Drive Building 4 Suite 100 Coppel, TX 75QI9 Plaintiff vs. PATRICIA A. GEORGE STEVEN A. GEORGE and OCCUPANTS 236 Woods Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County No. 07-2826-Civil PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JOSEPH A. GOLDBECK, JR., ESQUIRE a 0 v W C:) ~ -~ , ~ ~ ~~ ~` - c~ rrr r - [~ C'1 r~-~ °~= ---t GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION ATTORNEYS AT LAW SurrE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHII,ADELPHGI, PA 19106 (215) 627-1322 FAX (215) 627-7734 w•ww_cr~~.neFCxi ,~w.~rn~ August 1, 2007 ATTENTION: LAURA Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: TRAVELERS BANK & TRUST FSB vs. PATRICIA A. GEORGE and STEVEN A. GEORGE CCP Cumberland COUNTY, NO.: 07-2826-Civil To the Prothonotary: Enclosed please fmd for filing Plaintiffs Praecipe to Discontinue and End and Praecipe to Satisfy Judgment relative to the above matter. ~nldbeek Mef'9ff .rty &,_,_M~K_ v r Barbara Roach Manager -Eviction Dept. 215-825-6319 (direct phone) 215-825-6419 (Eviction Dept. Fax) (email) Fvirtinncfalnnlrlharklaw rnm (alt. Email) 215-627-1322 -Main Number ~.~.. ,. 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 PO~SE~~, L PROPERTY IS VACANT. ' Sworn and subscribed to before me this Day of , So Answe r Sheriff By Sheriff's Return: Advance Costs: 150.00 Docketing 18.00 Sheriff's Costs: 61.78 Surchargg 30.00 88.22 Prothy 2.00 Milage 10.56 Poundage 1.22 Refunded to Atty on 8/1/07 0 / Y~/3~a7 ~ J ~. ¢`'~ ~ ~ ~ y ~~g v r?,,,,, 1 ~u ~ 2of2 No 07-2826 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRAVELERS BANK & TRUST FSB 1111 NORTHPOINT DRIVE BUILDING 4 SUITE 100 COPPEL, TX 75019 PATRICIA A. GEORGE STEVEN A. GEORGE AND OCCUPANTS 236 WOODS DRIVE MECHANICSBURG, PA 17055 VS. WRIT OF POSSESSION P.RC.P. 3160-3165 ETC. Costs Att'y $ 195.14 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: JOSEPH A. GOLDBECK, JR., ESQUIRE GOLDBECK, MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for Plaintiff (s) Where papers maybe served 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 So Answers, Sworn and subscribed to before me this Day of , ~. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRAVELERS BANK & TRUST FSB VS. No. 07-2826 Civil Term PATRICIA A. GEORGE STEVEN A. GEORGE AND OCCUPANTS 236 WOODS DRIVE MECHANICSBURG, PA 17055 Costs Attorney's $ 195.14 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) TRAVELERS BANK & TRUST FSB being: (Premises as follows): 236 WOODS DRIVE, MECHANICSBURG, PA 17055 SEE ATTACHED LEGAL DESCRIl'TION (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. C Is R. Lo ro ono , Common P eas Court of C berland County, PA Date JIJNF. 19, 2007 (Seal)