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Home My WebLink About08-3705LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK vs. ROBERTA M. KLEIN Defendant NO. 09- 3(105 ivi( l+erm IN EJECTMENT N O T I C E 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TELEPHONE (717)249-3166 N O T I C I A Le han demandado a usted en la corte. Si usted quiere 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 notificacion. Usted debe presentar una apaiiencia escrita o en persona o poi abogado y archivar en la coite en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la Corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y poi cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus piopiedades o otios derechos importantes paia usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff VS. ROBERTA M. KLEIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ?Gv? ?Gvw N0. OF- -376-5 IN EJECTMENT C O M P L A I N T 1. Plaintiff, MidFirst Bank, is a corporation with an office located at Suite 100, 999 N.W. Grand Boulevard, Oklahoma City, Oklahoma 73118. 2. Defendant, Roberta M. Klein adult individual whose last known precise residence is 4830 Brian Road, Mechanicsburg, Pennsylvania 17050. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 11, 2008, Defendant was the owner of certain real property known as 4830 Brian Road, Mechanicsburg, Pennsylvania 17 050 . 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on June 11, 2008, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 07-5404 Civil at the suit of MidFirst Bank vs. Roberta M. Klein. 6. The aforesaid property was purchased at sale by MidFirst Bank, the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendant is presently in possession of the said premises, having come into said possession by virtue of her prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendant in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By: Leon P. Haller, Es re 1719 North Front Street Harrisburg, PA 17102-2392 (717 ) 234 -417 8 Attorney ID #15700 Attorney for Plaintiff Dated: June 20, 2008 ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's sale conducted by Sheriff of Cumberland County on June 11, 2008. 2. Deed from Joseph R. Fink dated April 2, 1999 and recorded April 12, 1999, in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 197, Page 323, to Roberta M. Klein. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Leon P. Haller Dated: June 20, 2008 00 o - -i cz? SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03705 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MIDFIRST BANK VS KLEIN ROBERTA M 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 unable to locate Him in his bailiwick COMPLAINT - EJECTMENT , He therefore returns the NOT FOUND , as to the within named DEFENDANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 THERE WERE NO OTHER OCCUPANTS. , OCCUPANT Sheriff's Costs: Docketing Service Not Found Surcharge 71a/oY ` , ,? So answer • 6.00 .00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 21.00 PURCELL KRUG HALLER 06/26/2008 Sworn and Subscribed to before me this day of A. D. CASE NO: 2008-03705 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK Vs KLEIN ROBERTA M DENNIS FRY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon KLEIN ROBERTA M the DEFENDANT , at 1400:00 HOURS, on the 25th day of June at 4830 BRIAN ROAD MECHANICSBURG, PA 17050 by handing to ROBERTA M KLEIN 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 1A x1b r Sworn and Subscibed to before me this of So Answers: 18.00 14.00 ,• J'.ri..?.?' -,?^^?°"'"?' .00 . .r f 10.00 R. Thomas Kline .00 42.00 06/26/2008 PURCELL KRUG HALLER By: day eputy Sh if , A.D. 2008 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA VS. capv : IN THE COURT OF COMMON PLEAS Plaintiff CIVIL ACTION - ROBERTA M. KLEIN Defendant NO. 08 3'7D5 IN EJECTMENT LAW Civil `term N O T I C E 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CARLISLE, PA 17013 , MVE COPY FROM RECORD TELEPHONE (717) 249 -319sTf INbtwsd. 'B flt'O and- ft- -,-'d ot SW COM4 at C&di&, Pa. r id 0" CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE .?+ ? ..__ ?,?? ;? N O T I C I A Le han demandado a usted en la corte. Si usted quiere 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 notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y poi cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 4 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK VS. ROBERTA M. KLEIN Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN EJECTMENT C O M P L A I N T 1. Plaintiff, MidFirst Bank, is a corporation with an office located at Suite 100, 999 N.W. Grand Boulevard, Oklahoma City, Oklahoma 73118. 2. Defendant, Roberta M. Klein adult individual whose last known precise residence is 4830 Brian Road, Mechanicsburg, Pennsylvania 17050. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 11, 2008, Defendant was the owner of certain real property known as 4830 Brian Road, Mechanicsburg, Pennsylvania 17050. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on June 11, 2008, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 07-5404 Civil at the suit of MidFirst Bank vs. Roberta M. Klein. 6. The aforesaid property was purchased at sale by MidFirst Bank, the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. V 8. Defendant is presently in possession of the said premises, having come into said possession by virtue of her prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendant in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By : Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: June 20, 2008 ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's sale conducted by Sheriff of Cumberland County on June 11, 2008. 2. Deed from Joseph R. Fink dated April 2, 1999 and recorded April 12, 1999, in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 197, Page 323, to Roberta M. Klein. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Leon P. Haller Dated: June 20, 2008 1 0 :fi d z Nr.r 6001 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. ROBERTA M. KLEIN Defendant NO. 08- 3706 IN EJECTMENT N O T I C E Otq'lt Teri, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CIVIL ACTION - LAW CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Oi., PY FROM RECORD TELEPHONE (7 17) 249 -ill ?wher , `;WQ UntO W My h€a't(" d ft saW ref said Gow tt Genie, Pa. -,?? °1048 x ?I*athopswv ?? 1?, +' __. `. ?? N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dial de plazo al paitir de la fecha de la demanda y la notificacion. Usted debe presentai una apariencia esciita o en persona o por abogado y aichivai en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomaia medidas y puede entiai una oiden contra usted sin pievio aviso o notificacion y poi cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede peider dineio o sus propiedades o otios deiechos importantes paia usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK VS. ROBERTA M. KLEIN Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN EJECTMENT C O M P L A I N T 1. Plaintiff, MidFirst Bank, is a corporation with an office located at Suite 100, 999 N.W. Grand Boulevard, Oklahoma City, Oklahoma 73118. 2. Defendant, Roberta M. Klein adult individual whose last known precise residence is 4830 Brian Road, Mechanicsburg, Pennsylvania 17050. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 11, 2008, Defendant was the owner of certain real property known as 4830 Brian Road, Mechanicsburg, Pennsylvania 17050. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's sale held at the Cumberland County Court House on June 11, 2008, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 07-5404 Civil at the suit of MidFirst Bank vs. Roberta M. Klein. 6. The aforesaid property was purchased at sale by MidFirst Bank, the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendant is presently in possession of the said premises, having come into said possession by virtue of her prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendant in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By. Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717 ) 234 -417 8 Attorney ID #15700 Attorney for Plaintiff Dated: June 20, 2008 ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point, thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on June 11, 2008. 2. Deed from Joseph R. Fink dated April 2, 1999 and recorded April 12, 1999, in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 197, Page 323, to Roberta M. Klein. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Leon P. Haller Dated: June 20, 2008 0%?Ill 0 :? d E Z moo Hoz SEWS JAN LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERTA M. KLEIN Defendant : CIVIL ACTION - LAW NO. 2008-03705 P IN EJECTMENT PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT FOR POSSESSION OF REAL PROPERTY TO THE PROTHONOTARY: Enter default judgment in ejectment for possession of the premises 4380 Brian Road, Mechanicsburg, Pennsylvania 17050, described in the attached legal description in favor of Plaintiff and against the Defendant, Roberta M. Klein, and her successors, heirs and assigns for failure to answer the Complaint within twenty (20) days after service thereof on June 25, 2008 I hereby certify that the Notice of Default required by Pa.R.C.P. 237.1 was mailed to Defendant above named on August 8, 2008. PURCELL, KRUG & HALLER By: Leon P. Hal er, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: August 19, 2008 . . . •a LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. ROBERTA M. KLEIN Defendant To: ROBERTA M. KLEIN 4380 BRIAN ROAD MECHANICSBURG, PA 17050 DATE OF NOTICE: AUGUST 8, 2008 : CIVIL ACTION - LAW NO. 2008-03705 P IN EJECTMENT YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 PURCELL, KRUG & HALLER By Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-23 2 (717)234-4178 Attorney ID $#15700 Attorney for Plaintiff , °` a LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK VS. ROBERTA M. KLEIN Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-03705 P IN EJECTMENT AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN ) LEON P. HALLER, attorney for Plaintiff, being duly sworn according to law, deposes and says that he is a duly constituted representative for the Plaintiff in the above captioned action; that he is duly authorized to make this affidavit; that he has personal knowledge, information and belief, that Defendant of the real estate described in the Complaint are not in the military or Naval Services of the United States or its allies or otherwise within the provisions of the Soldiers, and Sailors, Civil Relief Act of 1940, as amended. Leon P. Haller Attorney for Plaintiff SWORN to ?a/nd subscribed before me /?/5:f- My commission expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal eonRa E Pn wack, Notary Public CIr Of Hafraburg, Dauphin County NmmisWon Expires Sept 26, 2009 MWWW, Pennsylvania Association of Notaries w ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 * C) . oo 0 K7 ?, . 09 D na Q "TJ c-n CrIt 1 41%. LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW ROBERTA M. KLEIN NO. 2008-03705 P Defendant IN EJECTMENT NOTICE OF ENTRY OF JUDGMENT BY DEFAULT TO: Roberta M. Klein Defendant in the above action You are hereby notified that on Aur, a.D , 2008, Judgment by Default has been entered against you in the above action for possession of the real property described in the attached legal description, for the reason that you failed to file an Answer to the Complaint within 20 days after the said Complaint was served upon you on June 25, 2008. Pr thonota I hereby certify that the names and address of the proper persons to receive this notice under Pa.R.C.P. 236 is: ROBERTA M. KLEIN 4380 BRIAN ROAD MECHANICSBURG, PA 17050 Leon P. Haller Attorney for Plaintiff LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK vs. ROBERTA M. KLEIN Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-03705 P IN EJECTMENT ENTRY OF JUDGMENT BY DEFAULT AND NOW, on this ? day of ?f 2008, k1i default judgment is hereby entered against the Defendant, Roberta M. Klein, and her successors, heirs and assigns, in ejectment for possession of the premises described in the attached legal description. I'd 8-44-Z o t h ry • 14 , 4 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 ('717)234-4178 AT'T'ORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW ROBERTA M. KLEIN : NO. 2008-03705 P Defendant : IN EJECTMENT PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue a Writ of Possession against Roberta M. Klein in the above matter for the possession of the premises set forth in the attached legal description. PURCELL, KRUG & HALLE By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (7 17 ) 234 - 417 8 Attorney ID #15700 Attorney for Plaintiff Dated: August 19, 2008 9 ° 0 0 0 0 _ L L ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 10f2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK VS. No. 08-3705 Civil Term ROBERTA M. KLEIN Costs Attorney's $ 179.50 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)) MIDFIRST BANK being: (Premises as follows): 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 **SEE 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. C s R. Long o notary, Common Pleas Court of Cu erland County, PA Date 8/19/08 (Seal) .1 -. 2of2 No 08-3705 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK VS. ROBERTA M. KLEIN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 179.50 P1ff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ID #15700 Attorney for Plaintiff (s) Where papers may be 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 Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' 5" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 k. t •1 ? 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 Possession re'turne y a y So Answers, Sworn and subscribed to before me this Day of , Sher' By ClU -7, Sheriff's Return Advance Costs: 160.00 Sheriff's Costs: 54.06 Docketing 18.00 + 115. Surcharge 20.00 Prothy 2.00 Refunded to Atty on 9/22/08 -? Milage 13.00 Poundage 1.06 a? y 2 . IS 113 2of! . No 08-3705 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK VS. ROBERTA M. KLEIN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 179.50 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ID #15700 Attorney for Plaintiff (s) Where papers may be 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 , Sheriff By Prothonotary Deputy 10 2 WAIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK VS. No. 08-3705 Civil Term ROBERTA M. KLEIN Costs Attorney's $ 179.50 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)) MIDFIRST BANK being: (Premises as follows): 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 **SEE 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. Date 8/19/08 (Seal) ??62AC - I s R. Lo r thono , Common Pleas Court of mberland County, PA LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff vs. ROBERTA M. KLEIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3705 CIVIL TERM IN EJECTMENT P R A E C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendant satisfied of record. PURCELL, KRUG HALLER BY: Leon P. Haller ID #15700 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 Dated: November 12, 2008 ? co, T -?ti