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HomeMy WebLinkAbout08-1123GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T BANK SB/M M&T MORTGAGE CORPORATION I Fountain Plaza Buffalo, NY 14203 Plaintiff VS. NATALIE P. KEANE TIMOTHY C. KEANE and OCCUPANTS 110 E. Countryside Drive Boiling Springs, PA 17007 CIVIL ACTION: E•tEC gT IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Defendants NOTICE Term Civi No. Id3 l lerm 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 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 maybe entered against you by the Court without farther 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 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 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA 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 QUEJAS 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 REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOSIMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. 238-6300. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 CIVIL ACTION - LAW ACTION OF EJECTMENT LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 or COMPLAINT IN EJECTMENT 1. Plaintiff is M&T BANK SB/M M&T MORTGAGE CORPORATION, 1 Fountain Plaza, Buffalo, NY 14203. 2. Defendants are NATALIE P. KEANE, TIMOTHY C. KEANE, and OCCUPANTS. 3. Plaintiff is the equitable owner of premises located at 110 E. Countryside Drive, Boiling Springs, PA 17007 ("the Property"). A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is the record owner of the Property by virtue of a Deed from the Sheriff of Cumberland County to M&T BANK SB/M M&T MORTGAGE CORPORATION recorded on 1/15/2008 at instrument # 200801487. 5. Plaintiff is entitled to immediate possession of the Property. 6. The Defendants, NATALIE P. KEANE, TIMOTHY C. KEANE and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 7. 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. McCAFFERTY & McKEEVER OF VERIFICATION on behalf of the Plaintiff corporation within named do hereby verify I, R %er 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: 'q I / eth Fisher, Vice President #0006390603- NATALIE P. KEANE and TIMOTHY C. KEANE All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right- of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way) and East Countryside Drive by the following: from said intersection along centerline of East Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point; thence across East Countryside Drive, North 02 degrees 41 minutes 11 seconds East, a distance of 25.00 feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot #38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes 11 seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South 87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side of Lot No. 40, South 02 degrees 41 minutes 11 seconds West, a distance of 121.05 feet to a point on the northern right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18 minutes 49 seconds West, a distance of 134.00 feet to the point of beginning. Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet. Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009. IMPROVEMENTS consist of a residential dwelling. BEINGPREMISES: 110 E. Countryside Drive Boiling Springs, PA 17007 SOLD as the property of TIMOTHY C. KEANE and NATALIE P. KEANE TAX PARCEL #40-10-0638-063 w r .7 _. cx? ? 00 G°3 (i 7 ? D . Mr c? 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01123 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P 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 OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the r'(-)MDTA TTTrr _ V.7L'(1'TMVNTT the within named DEFENDANT , OCCUPANT 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 THERE WERE NO OTHER OCCUPANTS. , NOT FOUND , as to Sheriff's Costs: Docketing Service Not Found Surcharge -7P ?- So answers: _ 6.00 .00 5.00 R. Thomas K lne 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 02/27/2008 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-01123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT KEANE NATALIE P DEFENDANT the , at 1954:00 HOURS, on the 22nd day of February-, 2008 at 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 NATALIE P KEANNE was served upon 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 Service Affidavit Surcharge , l/3 , 18.00 4.80 .00 10.00 .00 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/27/2008 GOLDBECK MCCAFFERTY MCKEEVER By: L -- - ?\ - --/ puty Sheriff A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-01123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon KEANE TIMOTHY C the DEFENDANT , at 1954:00 HOURS, on the 22nd day of February-, 2008 at 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 NATALIE P KEANE, WIFE 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 Subscibed to before me this day of , So Answers: R. Thomas Kline 02/27/2008 GOLDBECK MCCAFFERTY MCKEEVE-R{ By ?'-z put Sheriff A. D. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite MN - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff M&T BANK SB/M M&T MORTGAGE CORPORATION 1 Fountain Plaza Buffalo, NY 14203 vs. Plaintiff NATALIE P. KEANE and TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Defendants PRAECIPE FOR JUDGMENT IN EJECTMENT Term No. 08-1123 Kindly enter Judgment in Ejectment in favor of the Plaintiff, M&T BANK SB/M M&T MORTGAGE en CORPORATION and against the Def dants NATALIE p. KEANE, TIMOTHY C. KEANE 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 Plaintiffs 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 M&T BANK SB/M M&T MORTGAGE CORPORATION, 1 Fountain Pl NY 14203 and that the names and last known address of the Defendants are NATALIE P. KEANE, Buffalo, TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive, Boiling Spring, PA 17007. v AFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney 111) #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff M&T BANK SB/M M&T MORTGAGE CORPORATION 1 Fountain Plaza Buffalo, NY 14203 vs. Plaintiff NATALIE P. KEANE and TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-1123 CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Joseph A. Goldbeck, Esquire, attomey 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: NATALIE P. KEANE TIMOTHY C. KEANE OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Richard Koch, Esquire 101 S. Market Street Mechanicsburg, PA 17055 GOLDBECK McCAFFERTY & McKEEVER By.,: wk? Michael T. McKeever, Esq. DATED: March 28, 2008 Attorney for Plaintiff GOLDBECK MCCAMRTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T BANK S/B/M M&T MORTGAGE CORPORATION 1 Fountain Plaza Buffalo, NY 14203 Plaintiff vs. NATALIE P. KEANE, TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Defendants DATE OF THIS NOTICE: March 17, 2008 TO: OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 IMPORTANT NOTICE CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-1123 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY GOLDBECK McCAFFERTy & MCMEVER BY: Michael T. McKeever, Esq. Attomey for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T BANK SB/M M&T MORTGAGE CORPORATION 1 Fountain Plaza Buffalo, NY 14203 Plaintiff VS. NATALIE P. KEANE, TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Defendants DATE OF THIS NOTICE: March 17, 2008 TO: NATALIE P. KEANE and TIMOTHY C. KEANE 110 East Countryside Drive Boiling Spring, PA 17007 IMPORTANT NOTICE CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-1123 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY i0? --j V, t f 0?4 GOLDBECK McCAFFERTY & MCKEEWR BY: Michael T. McKeever, 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. I . That the above named Defendant, NATALIE P. KEANE, is about unknown years of age, that Defendant's last known residence is, 110 East Countryside Drive Boiling Spring, PA 17007, 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: ?,? fl ?? ?"/'"`G ?Q?? 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, TIMOTHY C. KEANE, is about unknown years of age, that Defendant's last known residence is 110 East Countryside Drive Boiling Spring, PA 17007, 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: Aj,' J ??a ?-?. SLR Cl? W W J 0 **9. 0 O v a D { r;wr - C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland M&T BANK S/B/M M&T MORTGAGE CORPORATION 1 Fountain Plaza Buffalo, NY 14203 Plaintiff vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY NATALIE P. KEANE TIMOTHY C. KEANE and OCCUPANTS 110 East Countryside Drive Boiling Spring, PA 17007 Defendants PRAECIPE FOR- WRIT POSSESSION 08-1123 TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter, for possession of 110 East Countryside Drive Boiling Spring, PA 17007 (describe property) SEE ATTACHED LEGAL DESCRIPTION l? IN "Ai GOLDBECK, McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney for Plaintiff Ejectment Quiet Title A. 5 - 116 (Rev. 10/76) R 4 W W 0 O p -4. J 00 00 xw Q 0 7-r:, p ` - 1A d 00 SHERIFF'S RETURN - REGULAR . CASE NO: 2008-01123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon KEANE NATALIE P the DEFENDANT at 1954:00 HOURS, on the 22nd day of February .1 2008 at 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 by handing to NATALIE P KEANNE 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 4.80 Affidavit .00 Surcharge 10.00 .00 32.80 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 02/27/2008 GOLDBECK MCCAFFERTY MCKEEVER By puty Sheriff A.D. SHERIFF'S RETURN - REGULAR .. CASE NO: 2008-01123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon V-WAN = TTMOTAY C the DEFENDANT at 1954:00 HOURS, on the 22nd day of February 2008 at 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 NATALIE P KEANE, WIFE 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 Subscibed to before me this day of By: A. D. So Answers: R. Thomas Kline 02/27/2008 GOLDBECK MCCAFFERTY MCKEEVER put Sheriff t SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01123 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND M&T BANK ET AL VS KEANE NATALIE P 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 but was OCCUPANT unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT OCCUPANT 110 E COUNTRYSIDE DRIVE BOILING SPRINGS, PA 17007 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing Service Not Found Surcharge So answers : 6.00 .00 5.00 R. Thomas e 10.00 Sheriff of Cumberland County .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 02/27/2008 Sworn and Subscribed to before me this day of A. D. All that certain tract of land situate in South Middletown Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point located on the northern right of way lien of East Countryside Drive, (50 foot right- of-way), said point being referenced from the centerline intersection of Jane Lane (50 foot right-of-way) and East Countryside Drive by the following: from said intersection along centerline of East Countryside Drive, South 87 degrees 18 minutes 49 seconds East, a distance of 163.00 feet to a point; thence across East Countryside Drive, North 02 degrees 41 minutes I 1 seconds East, a distance of 25.00 feet to a point on the southern right-of-way line of East Countryside Drive at the southeast corner of Lot #38 and the point of beginning; thence along the East side of Lot No. 38, North 02 degrees 41 minutes 1 I seconds East, a distance of 121.05 feet to a point; thence along the South side of Lot No. 33, South 87 degrees 18 minutes 49 seconds East, a distance of 134.00 feet to a point; thence along the West side of Lot No. 40, South 02 degrees 41 minutes I 1 seconds West, a distance of 121.05 feet to a point on the northem right-of-way of East Countryside Drive; thence along said right-of-way, North 87 degrees 18 minutes 49 seconds West, a distance of 134.00 feet to the point of beginning. Being Lot No. 39 of the Plan of Lots known as Misty Meadows, Phase 1 as recorded on the Office of Recorder of Deeds for Cumberland County, in Plan Book 77, page 95; containing 16,220.05 square feet. Subject to building and use restrictions set forth in Miscellaneous Book 606, page 1009. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 110 E. Countryside Drive Boiling Springs, PA 17007 SOLD as the property of TIMOTHY C. KEANE and NATALIE P. KEANE TAX PARCEL #40-10-0638-063 .a -.1 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M&T BANK s/b/m M&T MORTGAGE CORPORATION VS. No. 08-1123 Civil Term NATALIE P. KEANE and TIMOTHY C. KEANE and OCCUPANTS Costs Attorney's $ 188.80 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)) M&T BANK s/b/m M&T MORTGAGE CORPORATION being: (Premises as follows): 110 EAST COUNTRYSIDE DRIVE, BOILING SPRING, PA 17007 (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. 12'??2t4 Curt's R. Long, notary Common Pleas Court of Cu Berland County, PA Date 3/31/08 (Seal) 2 of 2 No 08-1123 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M&T BANK s/b/m M&T MORTGAGE CORPORATION VS. NATIALIE P. KEANE and TIMOTHY C. KEANE and OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC Costs Att'y $ 188.80 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK, MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 215-825-6319 ID# 56129 Attorney for Plaintiff (s) named appurtenances, and Where papers may be served day of I caused the within to have possession of the premises described with the Sworn and subscribed to before me this Day of Prothonotary By virtue of this writ, on the So Answers, Sheriff By Deputy e . ..., , . By virtue of this writ, on the _2_1_s_tiay of May , 2 0 0 8 I caused the within named ,M & T Bank et al -______,to have possession of the premises described A&W )MV" LMXK i 110 Past Countryside Drive, Boiling Springs, PA 1 So Ans??r Sworn and subscribed to before me this ?"'??= ?? Day of , By.. Sheri ff ?,, ? q Sheriff's Return Advance Costs: 150.00 Docketing 18.00 Sheriff's Costs 102.00 Surcharge 40.00 48.77 Poundage 2.00 Prothy 2.00 Refunded on 5/22/08 Milage 10.00 Possession 30.00 102 . 00 V- C--,, 41'a?o? ??-. 8 ?t d L - ddb SuflE. ?.?005?