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Home My WebLink About08-1351 JASON R. and ANN M. BEVENOUR, Husband and Wife Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IRWIN HOME EQUITY CORPORATION and HOWARD HANNA REAL ESTATE SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN, Defendants NO: 6 CIVIL ACTION PRAECIPE TO ISSUE WRIT OF SUMMONS To the Prothonotary: Please issue a Writ of Summons in the above captioned action on the following Defendants: Irwin Home Equity Corporation Howard Hanna Real Estate Services C/o C T Corporation Systems Attention: David Weaver 100 Pine Street, #325 3310 Market Street Harrisburg, PA 17101. Camp Hill, PA 17011 Patrick Herman and Kimberly Herman 4614 Berwyn Lane Macungie, PA 18062 Dated: February 28, 2008 Scott B. Granger, Esquire Attorney ID # 63641 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiffs Respectfully submitted, CERTIFICATE OF SERVICE AND NOW, this 28th day of February, 2008, I, Scott B. Granger, Esquire, hereby certify that I served a copy of the within PRAECIPE TO ISSUE WRIT OF SUMMONS this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Irwin Home Equity Corporation C/o C T Corporation Systems 100 Pine Street, #325 Harrisburg, PA 17101 Howard Hanna Real Estate Services Attention: David Weaver 3310 Market Street Camp Hill, PA 17011 Patrick Herman and Kimberly Herman 4614 Berwyn Lane Macungie, PA 18062 Defendants Aid s D. H gh , Esquire Attorney . . o. 58884 Scott . Granger, Esquire Attorney I.D. No. 63641 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiffs x4 N V) a n N B w Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas JASON R. and ANN M. BEVENOUR, Husband and Wife Plaintiff Vs. No 08-1351 IRWIN HOME EQUITY CORPORATION and HOWARD HANNA REAL ESTATE SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN In CivilAction-Law Defendant To IRWIN HOME EQUITY CORPORATION, HOWARD HANNA REAL ESTATE SERVICES, AND PATRICK HERMAN AND KIMBERLY HERMAN, You are hereby notified that JASON R. BEVENOUR AND ANN M. BEVENOUR the Plaintiff(s) has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Curtis R. Long, Prothonotary Date February 29, 2008 By eputy Attorney: SCOTT B. GRANGER, ESQUIRE Name: SALZMANN HUGHES, P.C. Address: 354 ALEXANDER SPRING ROAD SUITE 1 CARLISLE, PA 17015 Attorney for: Plaintiff Telephone: 717-249-6333 Supreme Court ID No. 63641 . 01 JASON R. and ANN M. BEVENOUR, IN THE COURT OF COMMON Husband and Wife PLEAS OF CUMBERLAND Plaintiffs COUNTY, PENNSYLVANIA V. : IRWIN HOME EQUITY CORPORATION NO: _ 3 5 and HOWARD HANNA REAL ESTATE SERVICES, CIVIL ACTION - LIS PENDENS and PATRICK HERMAN and KIMBERLY HERMAN, Defendants PRAECIPE FOR LIS PENDENS To the Prothonotary: Please list the above-captioned action as a lis pendens against the following real property: 26 Silver Maple Drive, Boiling_ Springs South Middleton Township Cumberland County, Commonwealth of Pennsylvania I hereby certify that this action affects title to or other interests in the above-described real property. Dated: February 28, 2008 Attorney ID # 58884 Scott B. Granger, Esquire Attorney ID # 63641 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiffs Respectfully submitted, CERTIFICATE OF SERVICE AND NOW, this 28th day of February, 2008, I, Scott B. Granger, Esquire, hereby certify that I served a copy of the within PRAECIPE FOR LIS PENDENS this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Irwin Home Equity Corporation C/o C T Corporation Systems 100 Pine Street, #325 Harrisburg, PA 17101 Howard Hanna Real Estate Services Attention: David Weaver 3310 Market Street Camp Hill, PA 17011 Patrick Herman and Kimberly Herman 4614 Berwyn Lane Macungie, PA 18062 Defendants Scott B. Granger, Esquire Attorney I.D. No. 63641 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiff r ?7 C, 7z> N -tzz) J James L. Goldsmith, Esq. Attorney I.D. #27115 Karen W. Miller, Esq. Attorney I.D. # 200037 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Howard Hanna Real Estate Services JASON R. and ANN M. BEVENOUR, IN THE COURT OF COMMON PLEAS Husband and Wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 08-1351 IRWIN HOME EQUITY CORPORATION, : HOWARD HANNA REAL ESTATE : CIVIL ACTION - LIS PENDENS SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN, Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please file the Entry of Appearance on behalf of Defendant Howard Hanna Real Estate Services in the above-captioned matter. Respectfully submitted, CALDWELL & KEARNS Dated: 3 L? Dcf By: cf-?/ ? I A) - , J?A James L. Goldsmith, Esq. Attorney I.D. #27115 Karen W. Miller, Esq. Attorney I.D. # 200037 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Howard Hanna Real Estate Services CERTIFICATE OF SERVICE day of I hereby certify that I have served a copy of the within document this -254 2008, on the following by depositing a true and correct copy of the Entry of Appearance in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Scott B. Granger, Esquire Salzmann Hughes, PC 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 Counsel for Plaintiffs Patrick & Kimberly Herman 4614 Berwyn Lane Macungie, PA 18062 Defendant Irwin Home Equity Corporation c/o CT Corporation System 100 Pine Street, #325 Harrisburg, PA 17101 Defendant CALDWELL & KEARNS By_ 03432-002/130741 s""_t ra c? r _?, ?-:;., c ?; ?_-'° ---+ -?- "ri s-;? ?;? _,? ri° ? ?? "- ci _` [.,.; James L. Goldsmith, Esq. Attorney I.D. #27115 Karen W. Miller, Esq. Attorney I.D. # 200037 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Howard Hanna Real Estate Services JASON R. and ANN M. BEVENOUR, IN THE COURT OF COMMON PLEAS Husband and Wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 08-1351 IRWIN HOME EQUITY CORPORATION, : HOWARD HANNA REAL ESTATE CIVIL ACTION - LIS PENDENS SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN, Defendants PRAECIPE TO ISSUE RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon Counsel for Plaintiffs, Jason R and Ann M. Bevenour, to file a Complaint within twenty (20) days of service of said Rule, or suffer judgment of non pros. Respectfully submitted, Date: By: UV J es L. Goldsmith, Esq. Attorney I.D. #27115 Karen W. Miller, Esq. Attorney I.D. # 200037 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Howard Hanna Real Estate Services 03432-002/130743 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the within document this e?jday of 2008, on the following by depositing a true and correct copy of the Entry of Appearance in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Scott B. Granger, Esquire Salzmann Hughes, PC 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 Counsel for Plaintiffs Patrick & Kimberly Herman 4614 Berwyn Lane Macungie, PA 18062 Defendant Irwin Home Equity Corporation c/o CT Corporation System 100 Pine Street, #325 Harrisburg, PA 17101 Defendant CALDWELL & KEARNS ej?? 03432-002/130743 C") ?`' ?.? -a tw. ?? ??? ?? ?: .I? "`"? '}?_ i., __ l?? F*s't ,•_ ?;.1 :,? James L. Goldsmith, Esq. Attorney I.D. #27115 Karen W. Miller, Esq. Attorney I.D. # 200037 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Howard Hanna Real Estate Services JASON R. and ANN M. BEVENOUR, IN THE COURT OF COMMON PLEAS Husband and Wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 08-1351 IRWIN HOME EQUITY CORPORATION, : HOWARD HANNA REAL ESTATE CIVIL ACTION - LIS PENDENS SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN, : Defendants RULE To: Jason R. and Ann M. Bevenour C/O Scott B. Granger, Esquire Salzmann Hughes, PC 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service hereof, or judgment of non pros will be entered against you. Date: Prothonotar C1 i= C> JASON R. and ANN M. BEVENOUR, Husband and Wife Plaintiffs V. IRWIN HOME EQUITY CORPORATION; and HOWARD HANNA REAL ESTATE SERVICES; and PATRICK HERMAN and KIMBERLY HERMAN, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2008-1351 CIVIL ACTION - LIS PENDENS PRAECIPE TO DISCONTINUE AND WITHDRAW LIS PENDENS TO: OFFICE OF THE PROTHONOTARY: Please WITHDRAW the above-captioned action as a lis pendens against the following real property: 26 Silver Maple Drive, Boiling Springs, South Middleton Township, Cumberland County, Commonwealth of Pennsylvania. I hereby certify that this.action has been discontinued, settled, and withdrawn with prejudice and no longer affects title to or any other interests in the above-described real property. Dated: April 28, 2008 James /D. Hughes, Esquire A,t ey ID # 58884 ott B. Granger, Esquire Attorney ID # 63641 SALZMAW HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 2A9-6333 Attorneys for Plaintiffs a CERTIFICATE OF SERVICE AND NOW, this 29th day of April, 2008, I, Scott B. Granger, Esquire, hereby certify that I served a copy of the within PRAECIPE TO DISCONTINUE AND WITHDRAW LIS PENDENS this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Irwin Home Equity Corporation C/o C T Corporation Systems 100 Pine Street, #325 Harrisburg, PA 17101 Patrick Herman and Kimberly Herman C/o Hubert X. Gilroy, Esquire Martson, Deardorf, Williams, et. al. 10 East High Street Carlisle, PA-17013 Defendants Howard Hanna Real Estate Services C/o James I. Goldsmith, Esquire Caldwell Kearns, PC 3631 North Front Street Harrisburg, PA 17110-1533 ,Tames D. u s, Esqui Attorne . No. 5888 Scott . Granger, Esquire Attorney I.D. No. 63641 SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiffs ? ? ? ?i ` r r? ?„ .-?^? ?, 4? ...-.- i-?? -. ?} ~ ? ',_.`? ? - ?? -- ? .? ? ?? SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-01351 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEVENOUR JASON R ET AL VS IRWIN HOME EQUITY CORP 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: IRWIN HOME EQUITY CORPORATION but was unable to locate Them deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within WRIT OF SUMMONS On May 12th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answers Docketing 18.00 Out of County 9.00 Surcharge 10.00 1(--Thomas Kline Dep Dauphin County 29.25 Sheriff of Cumberland County Postage 1.91 6 8 . 16 ? z?1i-71ap C 05/12/2008 SALZMANN HUGHES Sworn and subscribe to before me this day of A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-01351 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEVENOUR JASON R ET AL VS IRWIN HOME EQUITY CORP 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: HERMAN PATRICK but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEHIGH County, Pennsylvania, to serve the within WRIT OF SUMMONS On May 12th , 2008 this office was in receipt of the attached return from LEHIGH Sheriff's Costs: So answ?- Docketing 6.00 --`" _ Out of County 9.00 Surcharge 10.00 Thomas Klin .00 Sheriff of Cumberland County .00 25.00 ? -7/0F 05/12/2008 SALZMANN HUGHES Sworn and subscribe to before me this day of , A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-01351 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEVENOUR JASON R ET AL VS IRWIN HOME EQUITY CORP 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: HERMAN KIMBERLY but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEHIGH County, Pennsylvania, to serve the within WRIT OF SUMMONS On May 12th , 2008 this office was in receipt of the attached return from LEHIGH Sheriff's Costs: So answer Docketing 6.00 Out of County .00 -G Surcharge 10.00 R. Thomas Kline .00 Sheriff of Cumberland County .00 16.00 ? L?I??D? 9- 05/12/2008 SALZMANN HUGHES Sworn and subscribe to before me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-01351 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEVENOUR JASON R ET AL VS IRWIN HOME EOUITY CORP ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HOWARD HANNA REAL ESTATE SERVICES the DEFENDANT , at 1542:00 HOURS, on the 5th day of March 2008 at ATTENTION DAVID WEAVER 3310 MARKET STREET CAMP HILL, PA 17011 by handing to CHARLES WILSON, REALTOR, ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 14.00 Affidavit .00 Surcharge 10.00 .00 6/7/0 ? 30.00 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 'r 05/12/2008 SALZMANN HUGHES By. (?? -411 -/ Deputy Sheriff A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Jason R. Bevenour et al vs. Irwin Home Equity Corporation et al SERVE: same No. 08-1351 civil Now, March 4, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin 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, , 20 , at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sworn and subscribed before me this day of , 20 Sheriff of COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA mtfixg 'af the'r*hcrut Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin JASON R BEVENOUR ET AL VS IRWIN HOME EQUITY CORPORATION Sheriff s Return No. 2008-T-0465 OTHER COUNTY NO. 08-1351 And now: MARCH 6, 2008 at 12:05:00 PM served the within WRIT OF SUMMONS upon IRWIN HOME EQUITY CORPORATION by personally handing to KAREN JONES 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at C/O CT CORPORATION SYSTEMS 100 PINE STREET #325 HARRISBURG PA 17101 FULLFILLMENT SPECIALIST Sworn and subscribed to before me this 6TH day of March, 2008 117? NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, Dauphin County [My Commission Expires S i 1 2010 So Answers, e??41c- Sheriff o auphis Co a. By Deputy Sheriff Deputy: B HUNTER Sheriffs Costs: $29.25 3/6/2008 In The Court of Common Pleas of Cumberland County, Pennsylvania Jason R. Bevenour et al vs. Irwin Home Equity Corporation et al SERVE: Patrick Herman No. 08-1351 civil Now, March 4, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of L:hi.gh deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Please mail return of.service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, , 20 , at o'clock M. served the within 0? pJ'? upon at by handing to k Q, (? \, \ tiP b 0\ a copy of the original and made known to the contents thereof. So answers, Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT County, PA In The Court of Common Pleas of Cumberland County, Pennsylvania Jason R. Bevenour et al vs. Irwin Home Equity Corporation et al SERVE: Kimberly Herman No. 08-1351 civil Now, March 4, 2008 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lehigh 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, at o'clock M. served the within ?v upon x 1)` at ?S by handing to n ? C a and made known to t? ?qQj copy of the original the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this day of , 20 COSTS SERVICE $ MILEAGE AFFIDAVIT _ Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas JASON R. and ANN M. BEVENOUR, Husband and Wife Plaintiff Vs. No 08-1351 IRWIN HOME EQUITY CORPORATION and HOWARD HANNA REAL ESTATE SERVICES, and PATRICK HERMAN and KIMBERLY HERMAN In CivilAction-Law Defendant To IRWIN HOME EQUITY CORPORATION, HOWARD HANNA REAL ESTATE SERVICES, AND PATRICK HERMAN AND KIMBERLY HERMAN, You are hereby notified that JASON R. BEVENOUR AND ANN M. BEVENOUR the Plaintiff(s) has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. 1,51 d" R_ (SEAL) Curtis R. Long, Prothonotary 011 Date February 29, 2008 By aQ r? 4 Deputy Attorney: SCOTT B. GRANGER, ESQUIRE Name: SALZMANN HUGHES, P.C. Address: 354 ALEXANDER SPRING ROAD SUITE 1 CARLISLE, PA 17015 Attorney for: Plaintiff Telephone: 717-249-6333 Supreme Court ID No. 63641 VMM wl Kil I here ums a ssay A fti COW At d SW SO _E d b Z 033 0001 Vd'A!h L