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Home My WebLink About07-5170 Yoffie & Yoffie, P.C. Norman M. Yoffie, Esq. 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 ~ttomey ID #07135 Ph: (717)975-1838 Fax: (717)975-1912 KDR INVESTMENTS, LLP, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. o7.r~ 7a ~;~;L~T~,~.~ STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants CIVIL ACTION -LAW IN QUIET TITLE NOTICE TO DEFEND AND CLAIM RIGHTS 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, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 NOTICIA Le han demandado a usted en la torte. Si usted guiere 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 presenter una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defiende, la torte tomara medidas y puede entrar una Orden contra usted sin previo aviso o 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. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO„ O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 KDR INVESTMENTS, LLP, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. D?' - S'~7Z~ CwL~~ STAVROS J. KATSIFIS, HIS HEIRS, :CIVIL ACTION -LAW LEGATEES, PERSONAL : IN QUIET TITLE REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants COMPLAINT 1. Plaintiff is KDR Investments, LLP (KDR), a Pennsylvania limited liability partnership organized and existing under the laws and statutes of the Commonwealth of Pennsylvania, with it's office at 445 South Cameron Street, Harrisburg, PA 17101. 2. Defendant Stavros J. Katsifis (Stavros) now or formerly an adult individual who is believed to have resided at 1178 Kingsley Road (Lower Allen Township), Camp Hill, PA, but whose present whereabouts are unknown to Plaintiff, and who is believed to be a deceased person. 3. The other Defendants are Vasilika (also known as Vicki) Katsifis, believed to be a spouse or surviving spouse of Stavros, of 675 S. Main Street, Chambersburg, PA 17201 and the following children and issue of Decedent Stavros, to wit: Chris (also known as Hristos) Katsifis, 886 Acri Road, Mechanicsburg, PA 17050, John Katsifis, 13 Keystone Drive, Mechanicsburg, PA 17050, George Katsifis, 1717 Sheepford Road, Mechanicsburg, PA 17055, Nick Katsifis, 813 Forbes Road, Carlisle, PA 17013, Maria Georgakopoulos, 2420 Deny Street, York, PA 17408 and Helen Kalathas, 675 S. Main Street, Chambersburg, PA 17201. 4. This legal action involves a parcel of land in Lower Allen Township, Cumberland County, Pennsylvania, with a residence thereon erected, known and numbered 1178 Kingsley Road (subject real estate) and also known by the Cumberland County tax assessment designation of 13-23-0549-121. A copy of the legal description of subject real estate is attached hereto as Exhibit "A". 5. On September 21, 2006, subject real estate was owned by Stavros J. Katsifis and Bill S. Katsifis (presumably as tenants in common), having acquired their title by a deed from Blanche E. Schenk, widow, dated October 24, 1985 and recorded in Cumberland County Record Book O, Volume 31, Page 207. 6. By a deed dated November 4, 2006, Bill S. Katsifis conveyed, transferred, quit claimed and released any remaining or residual interest he may have had in subject real estate to KDR, said deed being recorded in the Office of the Recorder of Deeds in and for Cumberland County immediately before the filing of this complaint. 7. On September 21, 2006, subject real estate was sold at a Cumberland County Tax Claim Bureau (TCB) upset sale to KDR, the said sale being duly confirmed absolutely by the Cumberland County Court, and thereafter a deed dated December 1, 2006 was tendered and recorded by the TCB to KDR, the same being recorded in Cumberland County Record Book 277, Page 4003. 8. Because of the uncertainties concomitant to tax sales generally, a cloud exists on KDR's title (with respect to the undivided one-half interest of Stavros which was not conveyed and/orquit-claimed by Bill Katsifis as hereinbefore averred). 9. Although KDR believes Stavros to be deceased, it is uncertain of that fact. 10. If in fact Stavros is deceased, KDR is unaware of any Estate being administered in his name or of any personal representative having been appointed for him. 11. If in fact Stavros is deceased, and died intestate, KDR believes that his statutory heirs would consist of the individuals named in Paragraph 3 hereof. 12. Personal representatives of Stavros have been named herein as Defendants generally, in the event that Stavros is in fact deceased and a personal representative(s) has been appointed for his Estate. WHEREFORE, KDR requests the Court to enter an Order pursuant to Pa.R.C.P. 1066(a)(1) forever barring Defendants from asserting any right, lien, title or other interest in the land inconsistent with the interest and claim of KDR as set forth in this complaint, unless any Defendant herein commences an action of Ejectment within 30 days after said Order. YOFFE & YOFFE, P.C. By ~ ~( NORMAN M. YOFFE, ESQUIRE Att+omey for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 KDR Investments\Stavros\complaint KDR INVESTMENTS, LLP, : IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, Plaintiff :PENNSYLVANIA vs. NO. STAVROS J. KATSIFIS, HIS HEIRS, :CIVIL ACTION -LAW LEGATEES, PERSONAL : IN QUIET TITLE REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants VERIFICATION I, -jo5huc~ Kesler, Partner of KDR Investments, LLP, hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. KDR INVESTMENTS, LLP Dated: ~~}y~o~ By JOS A KESLER, Partner ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the northerly line of Kingsley Road at the easterly line of Lot No. 26, Block "Q" on the hereinafter mentioned plan; said point being 587.48 feet north and east measured along Kingsley Road from the northwest corner of Kingsley and Norman Roads; thence along said lot northwazdly 166.28 feet to a point; thence along lands now or late of Gilbert Miller southeastwazdly 102.29 feet to a point; thence along the westerly line of Lot No. 28, Block "Q" southwestwazdly 135.21 feet to a point on the northerly line of Kingsley Road; thence along Kingsley Road westwardly by a curve to the south having a radius of 193.69 feet, 55 feet to the place of BEGINNING. BEING Lot No. 27, Block "Q" on the plan of lots of a portion of Highland Pazk dated June 4, 1952 and recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 39. HAVING THEREON ERECTED a single frame dwelling house No. 1178 Kingsley Road, Highland Park, Camp Hill, Pennsylvania. For title see Cumberland County Record Book O, Volume 31, Page 207. EXHIBIT "A" 1~ ~ . ~J (/~ '~ `v_7 V O ~. ~~~.~ .. i 1 't3 yT- -a 1 ~) C"y ~° ~ -_ ^... ---1 j ~ KDR INVESTMENTS, LLP, Plaintiff vs. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.07-5170 Civil Term CIVIL ACTION -LAW IN QUIET TITLE PRAECIPE Please reinstate the Complaint in this case. YOFFE & YOFFE, P.C. ~~~ ~. ~ ~ ~ By ry,,. . OR N . YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 KDR Investments\Stavros\reinstatement ,~ ,~ z.a~ /V ~ _ ~ - O G " ~ ~ ~ - q ~ \! ~ `~ ,~ ":< f..,,,, r_.~ { ~~ t.+ __ _.~~ _~ ~_ -n ~"Sl S.r `/~' . `'i r~, :~. KDR INVESTMENTS, LLP, : IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, Plaintiff :PENNSYLVANIA vs. NO. 07-5170 Civil Term STAVROS J. KATSIFIS, HIS HEIRS, :CIVIL ACTION -LAW LEGATEES, PERSONAL : IN QUIET TITLE REPRESENTATIVES AND ASSIGNS, ~' ~ a VASILIKA (ALSO KNOWN AS VICKI) ,~.f 3._,..'. A=-=V rry.~_;. ~' KATSIFIS, CHRIS (ALSO KNOWN AS ~ ~~ JOHN KATSIFIS, HRISTOS KATSIFIS - ~ ~ ~''T' ~ , GEORGE KATSIFIS, NICK KATSIFIS, ~ G} ' ~ --~t:._~ MARIA GEORGAKOPOULOS AND HELEN : ~ `- ~' 'c _. ~ Defendants ~ -' ~~~ ~~ AFFIDAVIT REQUESTING NISI ORDER PURSUANT TO Pa.R.C.P. 1066(a) and (b)(1) TO THE HONORABLE JUDGES OF SAID COURT: 1. The Affidavit of Plaintiff, KDR Investments, LLP (KDR), by its attorney, Norman M. Yoffie, Esquire, respectfully represents: 2. That a Complaint containing a notice to defend has been served on all Defendants, with no Defendant filing an answer (or other pleading) thereto (including Defendant Maria Georgakopoulos and Helen Kalathas, who have accepted service of the Compalint). 3. The Plaintiff herein has been in sole and exclusive possession of subject real estate continuously from a time prior to the commencement of this action. 4. I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Affidavit are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. WHEREFORE, Plaintiff requests the Court to enter an order pursuant to Pa.R.C.P. 1066(a) and (b)(1) forever barring Defendants, of any of them, from asserting any right, lien, title or interest in real estate known and numbered as #1178 Kingsley Road, Lower Allen Township, Cumberland County, Pennsylvania, and as further described in the complaint, inconsistent with the interest or claim of Plaintiff KDR, unless such respective Defendant(s) commence an action of ejectment against KDR within fifteen days of this order, all in accordance with the aforesaid Pa.R.C.P. and R.C.P. 248. YOFFE & YOFFE, P.C. By~ '1~~ I NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 KDR INVESTMENTS, LLP, Plaintiff vs. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5170 Civil Term CIVIL ACTION -LAW IN QUIET TITLE CERTIFICATE OF SERVICE The undersigned hereby certifies that on December 5, 2007 it mailed first class to each of the below named Defendant parties in this case, at their respective addresses, a copy of the within Affidavit requesting a Nisi Order pursuant to Pa.R.C.P. 1066(a) and (b)(1), and the proposed Court Order concomitant thereto: Vasilika (a/k/a Vicki) Katsifis 675 South Main Street Chambersburg, PA 17201 Chris (a/k/a Hristos) Katsifis 886 Acri Road Mechanicsburg, PA 17050 John Katsifis 13 Keystone Drive Mechanicsburg, PA 17050 Nick Katsifis 813 Forbes Road Carlisle, PA 17013 Helen Kalathas 675 South Main Street Chambersburg, PA 17201 George Katsifis 1777 Sheepford Road Mechanicsburg, PA 17055 Maria Georgakopoulos 2420 Derry Street York, PA 17408 YOFFE Y FFE, P.C. B (. AN M. YOF E, QUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 KDR INVESTMENTS, LLP, Plaintiff vs. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFlS, JUHN KATSIFIS, GEORGE KATSIFIS,,,f~:ICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07-5170 Civil Term CIVIL ACTION -LAW IN QUIET TITLE ACCEPTANCE OF SERVICE I accept service of the Complaint. Dated: ~~ ,, a ITNESS COMMONVV~AI~TH A~ ~ENN~YLViANIA NOTARIF,I SEAL LISA L. GET;_, Notary Public West Manchester Twp., York County My Commission Expires Jan. 4, 2009 b /' nn MARIA GEORGAKOPOULO 2420 Derry Street York, PA 17408 ~- ~ ~':~ ; c.:. ~ ~,r ~ ,; ~ ~ ~ , ~,. ,, s ^ ~.,.y . r f . q i~ f~' ~~~ ~ , M1 +- a. j H KDR INVESTMENTS, LLP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants N0.07-5170 Civil Term CIVIL ACTION -LAW IN QUIET TITLE ACCEPTANCE OF SERVICE I accept service of the Complaint. Dated: ~- ~- e ~ ~~ ITNESS HELEN KALATHAS 675 S. Main Stree# Chambersb~:rg, rA 17209 ab ~.G T e a+e ~~7 ,S~]tn4~0~119 NOTAFgAL SEAL RONALD E. MULL, Notary Public Chambereburg Bono, County of Franklin My Commission Expires August 17, 2009 , C ..' ~ ue ' 'r' s ' ~ ~ '~ s .- ~' ~, . ~ ~.~ ,, ~, ~~f~' ..~ _=,; ~f , ~,~a . .~" _~ KDR INVESTMENTS, LLP, PLAINTIFF V. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS) KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEFENDANTS : 07-5170 CIVIL ORDER PURSUANT TO Pa.R.C.P. 1066(b)(1) AND NOW, this 7th day of December, 2007, upon consideration of the within Affidavit filed by the Plaintiff pursuant to Pa.R.C.P. 1066(a) and (b)(1) and it appearing that a complaint containing a notice to defend was served on all Defendants, and that no such Defendant filed an answer (or other pleading in response thereto), IT IS HEREBY ORDERED that each Defendant is forever barred from asserting any right, lien, title or interest in the real estate known and numbered as #1178 Kingsley Road, Lower Allen Township, Cumberland County, Pennsylvania, and as further described in the complaint, inconsistent with the interest or claim of Plaintiff, KDR Investments, LLP (KDR), unless such respective Defendant(s) commences an action of ejectment against KDR within 30 days of this order pursuant to Pa.R.C.P. 1066(a) and 248. By the Court, 'V` M .L. Ebert, Jr., J. ~~ ~rh €,~~ f a ~i~ ~''y ~ ~~ ~- ~~(~ l.~~Z `~1 ~~ ,~>~'~ L` 1t a~ r'~;.,. r ~ ~ Norman M. Yoffie, Esquire 214 Senate Avenue Suite 404 Camp Hill, PA 17011 Vasilika (a/k/a Vicki) Katsifis 675 South Main Street Chambersburg, PA 17201 Chris (a/k/a Hristos) Katsifis 886 Acri Road Mechanicsburg, PA 17050 John Katsifis 13 Keystone Drive Mechanicsburg, PA 17050 George Katsifis 1777 Sheepford Road Mechanicsburg, PA 17055 Nick Katsifis 813 Forbes Road Carlisle, PA 17013 Maria Georgakopoulos 2420 Derry Street York, PA 17408 Helen Katathas 675 South Main Street Chambersburg, PA 17201 l2~'~la~ KDR INVESTMENTS, LLP, : IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, Plaintiff :PENNSYLVANIA vs. NO. 07-5170 Civil Term STAVROS J. KATSIFIS, HiS HEIRS, :CIVIL ACTION -LAW LEGATEES, PERSONAL : IN QUIET TITLE REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants AFFIDAVIT REGARDING INVESTIGATION MADE TO DETERMINE HEIRS OF ESTATE OF STAVROS KATSIFIS AND NON-EXISTENCE OF ANY PERSONAL REPRESENTATIVE FOR HIM The undersigned certifies that with respect to this quiet title action he made a thorough investigation of Courthouse records in Cumberland County, Pennsylvania, to determine if any personal representative had ever been appoinfied for Stavros Katsifis (wherein such investigation revealed that he died in June 1987, a domiciliary and resident of Cumberland County, PA at 1178 Kingsley Road, Lower Allen Township), and no record of such was found the same being confirmed by discussions with several of the sibling Defendants of Stavros in this suit. The foregoing investigation which consisted of inquiries to all individual Defendants in this suit and particularly of conversations with Bill Katsifis and Chris Katsifis established that Vasilika (Vicki) Katsifis is the surviving spouse of Stavros Katsifis and each of the other individual Defendants in the above suit, together constitute all of the heirs of Stavros Katsifis; and further, that with the assurance that all of the heirs of Stavros Katsifis have been served in the foregoing quiet title action, the r •„ necessity of serving Stavros Katsifis and "His Heirs, Legatees, Personal Representatives and Assigns" and taking a judgment against them generally has been obviated. This Affidavit is dated December 12, 2007. I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Affidavit are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. PHILIP J. DO S Partner of KDR vestments, LLP KDR Investments\Stavros\affidavit of investigation C7 rv o C7 .1..,. . ~, r : C7 ~T3 ~. r _ {1 ~ ~~ 11 - ro_~_ ~"h l ~ r.~4T`J1 V ' ~ P ~ 5 ~'-' l~ ~ . ~ ~ tQ -.~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-05170 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KDR INVESTMENTS LLP VS KATSIFIS STAVROS J ET AL SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon KATSIFIS CHRIS AKA HRISTOS KATSIFIS the DEFENDANT at 1124:00 HOURS, on the 22nd day of October 2007 at 886 ACRI ROAD MECHANICSBURG, PA 17050 JO KATSIFIS, WIFE by handing to a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge ja/io/d 7 ~...'t Sworn and Subscibed to before me this of So Answers: 18.00 9.60 _ ~" c . 0 0 ~ ~ _..:_~"' '...~ 10.00 R. Thomas Kline .00 37.60 11f27f2007 YOFFE & YOFFE By ' ~f . ~.~~//( ~~ day /'" Deputy Seri f f~ A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-05170 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KDR INVESTMENTS LLP VS KATSIFIS STAVROS J ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon KATSIFIS JOHN the DEFENDANT at 1655:00 HOURS, on the 25th day of October 2007 at 13 KEYSTONE DRIVE MECHANICSBURG, PA 17050 by handing to FANI KATSIFIS, WIFE a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 9.60 Affidavit .00 Surcharge 10.00 /~ ~ . 0 0 Sworn and Subscibed to before me this day of , So Answers: ~. c. R. Thomas Kline 11/27/2007 YOFFE & YOFFE Deputy $'heriff A.D. SHERIFF'S RETURN - REGULAR CASE N0: 2007-05170 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KDR INVESTMENTS LLP VS KATSIFIS STAVROS J ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon KATSIFIS GEORGE the DEFENDANT at 1518:00 HOURS, on the 26th day of October 2007 at 1777 SHEEPFORD ROAD MECHANICSBURG, PA 17055 by handing to GEORGE KATSIFIS a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 ia~/%~ ~ / 25.60 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 11/27/2007 YOFFE & YOFFE B 0~~.1 ~eputy Sheriff A.D. SHERIFF'S RETURN - REGULAR CASE N0: 2007-05170 P COMMONWEALTH OF PENNSYLVANIA: ._ COUNTY OF CUMBERLAND KDR INVESTMENTS LLP VS KATSIFIS STAVROS J ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -QUIET TITLE was served upon KATSIFIS NICK the DEFENDANT at 1835:00 HOURS, on the 24th day of October 2007 at 813 FORBES ROAD CARLISLE, PA 17013 by handing to NICK KATSIFIS a true and attested copy of COMPLAINT -QUIET TITLE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 11/27/2007 YOFFE & YOFFE B ~ ~~ Deputy Sheriff A.D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-05170 P C0~`4MONWEALTH OF PENNSYLVANIA: ,, COUNTY OF CUMBERLAND KDR INVESTMENTS LLP VS KATSIFIS STAVROS J ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KATSIFIS VASILIKA AKA VICKI but was unable to locate Her KATSIFIS in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT -QUIET TITLE On November 27th 2007 this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: So a ers Docketing 6.00 Out of County 9.00 _ "~ Surcharge 10.00 ~ R: as Kline Dep Franklin Co 27.05 e ff of Cumberland County Postage 1.77 5 3. 8 2 / l z~fa1 ? 11/27f2007 YOFFE & YOFFE Sworn and subscribe to before me this day of A.D. In The Caurt of Common Pleas of Cumberland County, Pennsylvania I{DR Investments LLP VS. Stavros J . Kats if is et al SERVE: Vicki (aka Vasilika ) Katsifis No• 07-5170 civil Now, OctobAr 10. 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~/~ Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, ~1~~ (Z... , ~ , 20~, at o'clock _! __~__ M. served the within ~? P'~ ~ ~ ~ ~ ti~ upon ~-~~~Itl ~ /~~!-7'~,~-,C ~~~~b~~'~~12. ~~ ~'D vc.T l~ C~-~~~~ or o~FGJA~ at ~Q~ S~ S• M~~~ ST' by handing to ~~~~-- a copy of the original Co^1~L~41 h~~ and made known to ~ ~ ~. Commonwealth of Pennsylvania: County of Franklin Sworn and subscribed before this ~~ of DC°ToeE~1 ?~~ ~.. ~ ~~ ,~.~F~eeS f~xt Richard D. McCarty, Notary Pu6EiC' Chambersturc i3oro, Franklin Grlur~iy My Commission Expires Jan. 29, `i~~'•ia the contents thereof. So answers, ~,- (art' ~ ~ She ff o ~`'~' '~-~~ ~~+ NCounty, PA COSTS SERVICE $ MILEAGE AFFIDAVIT _$ SHERIFF'S RETURN - REGULAR CASE NO: 2007-00210 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN KDR INVESTMENTS LLP VS KATSIFIS STAVROS J. ET AL JOHN E STRINE Curn~.rlanc~ ~aur+~ ~ D'1- 51'70 c~.,;l Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT QUIET TITLE was served upon KATSIFIS VICKI A/K/A VASO;OLA VICKI the DEFENDANT at 0016:00 Hour, on the 17th day of October 2007 at 675 SOUTH MAIN STREET CHAMBERSBURG, PA 17201 by handing to HELEN KALATHAS a true and attested copy of COMPLAINT QUIET TITLE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and Subscribed to before me this ~~~ day of 00 C~~ A.D. ~o~ana`i deal ~ Richard D. McCarty, Notary Public Chamberst!vrg Boro, Franklin County My Commission Expires Jan. 29 ? ~+~ So Answers: JOHN ~i-NCE ~"~~ By i~ C._ I 1 ep~ y Sheer f f 10/30/ 00 CUMBER D CO SHERIFF'S OFFICE ../ --~ PRAECIPE FOR FINAL JUDGMENT IN QUIET TITLE ACTION Enter a final judgment in favor of Plaintiff, KDR Investments, LLP and against KDR INVESTMENTS, LLP, : IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, Plaintiff :PENNSYLVANIA vs. NO. 07-5170 Civil Term STAVROS J. KATSIFIS, HIS HEIRS, :CIVIL ACTION -LAW LEGATEES, PERSONAL : IN QUIET TITLE REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants Defendants, VASILIKA (also known as Vicki) KATSIFIS, CHRIS (also known as Hristos) KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS and HELEN KALATHAS, forever barring each of them from asserting any right, lien, title or interest in real estate known as 1178 Kingsley Road, Lower Allen Township, Cumberland County, Pennsylvania (and as further described in the Complaint in this case) inconsistent with PlaintifFs interest and/or claim as set forth in the Complaint, because of the failure of each and all said Defendants taking the action required by the Court's Order of December 7, 2007. YOFFE & YOFFE, P.C. NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 KDR Investments\Stavros\praecipe / ~~ KDR INVESTMENTS, LLP, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5170 Civil Term STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, Defendants CIVIL ACTION -LAW IN QUIET TITLE Judgments entered against all Defendants as directed by Plaintiffs Praecipe of this date. CUMBERLAND COUNTY PROTHONOTARY Dated: ~~ ~ By ~s~ ~~ ~ ~° a ~ ~' c ~ _ ~ ~ .~ Art\ (~ ~; ~ ._..~ tw ~ "'" ~7 r_° _ ~ ~k~ -W ~. ~ i ; ~ ` ~ ~ f` J ...._, -~ y \ .~ ~l KDR INVESTMENTS, LLP, PLAINTIFF V. STAVROS J. KATSIFIS, HIS HEIRS, LEGATEES, PERSONAL REPRESENTATIVES AND ASSIGNS, VASILIKA (ALSO KNOWN AS VICKI) KATSIFIS, CHRIS (ALSO KNOWN AS HRISTOS) KATSIFIS, JOHN KATSIFIS, GEORGE KATSIFIS, NICK KATSIFIS, MARIA GEORGAKOPOULOS AND HELEN KALATHAS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEFENDANTS 07-5170 CIVIL ORDER PURSUANT TO Pa.R.C.P. 1066(b)(1) AND NOW, this 7th day of December, 2007, upon consideration of the within Affidavit filed by the Plaintiff pursuant to Pa.R.C.P. 1066(a) and (b)(1) and it appearing that a complaint containing a notice to defend was served on all Defendants, and that no such Defendant filed an answer (or other pleading in response thereto), IT IS HEREBY ORDERED that each Defendant is forever barred from asserting any right, lien, title or interest in the real estate known and numbered as #1178 Kingsley Road, Lower Allen Township, Cumberland County, Pennsylvania, and as further described in the complaint, inconsistent with the interest or claim of Plaintiff, KDR Investments, LLP (KDR), unless such respective Defendant(s) commences an action of ejectment against KDR within 30 days of this order pursuant to Pa.R.C.P. 1066(a) and 248. By the Court, January 8, 2008, Final judgment is hereby against the Defendants. `v M .L. Ebert, Jr., J. entered in favor of the Plaintiff and Cu is R n thonotary l'1~^A~ ~"' Pe... 1: if i'.s "'~ "~~3'sk~