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Home My WebLink About07-5299IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - (X) Law ( ) E9~t3' Vallery Clouse 1104 Chelmsford Drive Mechanicsburg, PA 17050 Joseph Katkocin verses 3803 Pamay Drive Mechanicsburg, PA 17050 Plaintiff Defendant PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Kindly issue a writ of summons in the above captioned action. JONATHAN W. CRISP, ESQUIRE sy: o athan W. Crisp ID No. 83505 3601 Vartan Way Harrisburg, PA 17110 (717) 909-8227 Date: ~ ~. n~ ..p ^Z R~ ~? ~ t7 cw o -~ ~7 ~Y 1<~. l1tj.' VI 'f7 ~ ~ ~~ ~ . 'O . ~~ ' ~ ~ ~ ~S_ 2 _, ~ y ~~~~---' J n n ---t c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .~ No. 07 - ,~a ~~ Civil Action - (~ Law ( )Equity Va11ery Clouse Joseph Katkocin 1104 Chelmsford Drive verses 3803 Pamay Drive Mechanicsburg, PA 17050 Mechanicsburg, PA 17050 Plaintiff Defendant WRIT OF SUMMONS To: Joseph Katkocin You are hereby notified that Vallery Clouse has commenced an action against you. By:~,~ DATE: 4/507 ~~ M 0 ~ 3 S"Zi ~ -z 1"2 -S v q ~ ~a~d--l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. f) 7 • So2~'9 Civil Action - (~ Law ( ) Equity Vallery Clouse 1104 Chelmsford Drive Mechanicsburg, PA 17050 Joseph Katkocin verses 3803 Pamay Drive Mechanicsburg, PA 17050 Plaintiff . Defendant PRAECIPE FOR LIS PENDENS To the Prothonotary: Please index the above-captioned matter as a Lis Pendens against the following real property: 4 Souder Court, Mechanicsburg, Pennsylvania, 17050 See legal description attached hereto and incorporated herein by reference. I hereby certify that this action affects title to or other interest in the above- described real property. JONATHAN W. CRISP, ESQUIRE sy: o athan W. Crisp ID No. 83505 Date: _ ~ ~,~,,.,..9~ o~ 3601 Varian Way Harrisburg, PA 17110 (717) 909-8227 ~, 1 ~ ~ Z~ THLSDEEb ~E~,ORGER OF t}El?S ...~..rt ~• .~.I " (17~1DE this 31~" of IM11'Y ~~ ~~~ ~ ~ 11 1~ day , in the year of our Lord, Two Thousand the ( OS~. :BETWEEN: GREATER KEYSTONE PROPERTIES, INC., a Pennsylvania business corporation, party of the first part, hereinafter called the "GraY1tOI", AND JOSEPH K. KATKOCIN, single person, party of the second part, reinafter called he "Grantee": WITNESSETH, that in consideration of the sum of Forty-two Thousand and No/100 ($42,000.00) Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the Grantee, his heirs and assigns, ALL that certain lot of unimproved land situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as foTows: BEGIlV1vING at a point on the northern dedicated right-of-way line of Souder Court at the dividing line between Lots Nos. 11 and 12, as shown on the hereinafter mentioned plan of cots; thence along said northern dedicated right-of--way line of Souder Court, North 87 degrees 14 minutes Wf:st, a distance of 138 feet to a monument on the same at the beginning of a curved comer of the northeast corner of the intersection of Souder Court with Keystone Drive; thence along said comer of int~:rsectian on a curve to the right, having a radius of 12 feet, an arc distance of 18.85 feet to a point on the eastern dedicated right-of--way line of Keystone Drive; thence along said eastern dedicated right-of--way tine of Keystone Drive, the following three (3) courses and distances: (a) North 2 degrees 46 minutes East, a distance of 242.63 feet to a monument; (b) on a curve to the left having a radius of 300 feet. an arc distance of 238.41 feet to a monument; and (c) North 42 degrees 46 mi~~utes West, a distance of 40.11 feet to a point on the same at the dividing line between Lots Nos. 11 and 12 as shown on said plan of lots; thence along said dividing sine between Lots Nos. 11 and 12 as ;shown on said plan of lots, North 47 degrees, I4 minutes East, a distance of 29.53 feet to an iron pin at corner of sands now or formerly of Milton E. Homer; thence along said latter lands, South 85 deE;rees 22 minutes 45 seconds East, a distance of 247.92 feet to a point at the dividing line between Lors Nos. 11 and 12 as shown on said plan of lots; thence along said dividing line between Lots Nos. 11 and 12 as shown on said plan of lots, South 2 degrees 46 minutes West, a distance of 509.88 feet to ~i point on the northern dedicated right-of--way line of Souder Court, the place of BEGINNING. BEING Lot No. 12 as shown on a certain plan of lots entitled "Final Subdivision of Enchanted Hills" as recorded in the Office of the Recorder of Dceds in and for Cumberland County, Penmsylvania, in Plan Book 76, Page 37. BEING a portion of that certain larger premises which John P. Hall (and Sherill Hall, his wife) by deed dated October 19, 1990 and recorded in the Recorder's Office aforesaid in Deed Book "V", Volume 34, Page 344 granted and conveyed unto Greater Keystone Properties, Inc., the Grantor herein. t1JG'~ tidy PdGEi j ... (1} The building set-back lines and utility easements and drainage easements, if any, as more fully shown, located and defined on the above mentioned plan of lots; (2) The applicable restrictions, covenants and conditions as more fully set forth on the above mentioned plan of lots; (3) The easements and rights-of--way heretofore granted to public utility companies for the use of providing utility services to the subdivision shown on the above described plan of lots; and (4) The restrictions, conditions aad covenants as more fully set forth in a certain Amended Declaration of Covenants and Restrictions dated January 15,1999, and recorded in the Recorder's Office aforesaid in Miscellaneous Record Book Volume 601, Page 770. AND the said Grantor hereby covenants and agrees that it will warrant specially the premises hereby conveyed. IN WITNESS WHEREOF, the said Grantor has caused these presents to be signed in its name by its President, attested by its Secretary and sealed with its seal the day and year fast written above. GREATER IfEYSTONE PROPERTIES, INC. ATTEST: eaxtary (Corporate Seal) sy ~r. , euox 2fi9 ~~~e1~.6'i C7 ti c_~ K' ~ `~/ ` ~ ~ ~' ~ ~ " ( t Q -.i ~67 O '~ ~ "; 6' ~ - ~ jr ~ :: ~ c~ `xi (.,.s -~ SHERIFF'S RETURN - REGULAR CASE N0: 2007-05299 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLOUSE VALLERY VS KATKOCIN JOSEPH DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon TrTmunrrrT .Tnc~~u the DEFENDANT at 2046:00 HOURS, on the 27th day of September, 2007 at 3803 PAMAY DRIVE MECHANICSBURG, PA 17050 by handing to a true and attested copy of WRIT OF SUMMONS PRAECIPE FOR LIS PENDENS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit ~ Surcharge ~p/q'D DIl1l Sworn and Subscibed to before me this of So Answers: 18.0 0 ~ rr~-,..eCaC 12.48 .00 10.00 R. Thomas Kline .00 40.48 09/28/2007 JONATHAN CRISP By • ~~ day Deputy S riff A.D. ,v . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5299 Civil Action Vallery Clouse 1104 Chelmsford Drive Mechanicsburg, PA 17050 Plaintiff Joseph Katkocin verses 3803 Pamay Drive : Mechanicsburg, PA 17050 Request for Release of Lis Pendens To the Prothonotary: Defendant For valuable consideration, to wit: an escrow agreement rec sufficiency of which is hereby acknowledged, that certain Lisp eipt and reocorded in the official records of the Office of the Prothonota endens Cumberland County, Pennsylvania on 5 Spetember 2007 is ry ~n released. hereby Said Office is kindly requested and hereby authorized to en satisfaction of and cancel of record that Praecipe for Lis Pende ter in Cumberland County, Pennsylvania on 5 September 2007 ns recorded This 30th day of November 2007 JONATHAN W. CRISP, ESQUIRE Jonathan W. Crisp I D No. 83505 3601 Vartan Way Harrisburg, PA 17110 (717) 909-8227 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vallery Clouse • 1104 Chelmsford Drive verses Mechanicsburg, PA 17050 Plaintiff No. 07-5299 Civil Action Joseph Katkocin 3803 Pamay Drive Mechanicsburg, PA 17050 Defendant CERTIFICATE OF SERVICE I, JONATHAN W. CRISP, ESQ. attorney for the Plaintiff in the above described action hereby certify that I mailed on November 30 2007 ,a stamped copy of Request for Release of Lis Pendens on counsel for the Defendant, Lorin Snyder, Esq., at 28 South Pitt Street, Carlisle, PA 17013 <- '~~ JO i~CT AN W. CRISP, ESQ. ~` ~ C~ ..,.., ..~'.' -i ~~~ _ ~-r, ~ _ Q .t ,.~ ' ~. P `5R+ .. n..*2~ -: ' ~' 1 ..~ ~~ • J L "^~ F " i ~ ~ . ~