HomeMy WebLinkAbout08-4801GOLDBECK 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
Deutsche Bank Trust Company Americas
formerly known as Banker's Trust Company, as
Trustee and Custodian by: Saxon Mortgage
Services, Inc. f/k/a Meritech Mortgage Services,
Inc. as its attorney-in-fact
4708 Mercantile Drive
Fort Worth, TX 76137
vs.
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Plaintiff
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Defendants
NOTICE
Term
,y l Lem
No. D$ - #801 n
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 ifyou 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 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 LISTED 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.
238-6300SI 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
LEGAL SERVICES INC
8 Irvine Row, Carlisle, PA 17013
717-243-9400
COMPLAINT IN EJECTMENT
1. Plaintiff is Deutsche Bank Trust Company Americas formerly known as Banker's Trust
Compnay, as Trustee and Custodian by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage
Services, Inc. as its attorney-in-fact, 4708 Mercantile Drive, Fort Worth, TX 76137.
2. Defendants are SCOTT W. FINKENBINDER, and OCCUPANTS.
3. Plaintiff is the equitable owner of premises located at 455 Hunters Road, Newville, PA
17241 ("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 Deutsche Bank Trust Company Americas formerly known as Banker's
Trust Company, as Trustee and Custodian by: Saxon Mortgage Services, Inc. f/k/a Meritech
Mortgage Services, Inc. as its attorney-in-fact recorded on 6/20/2008 at Instrument #200820752.
5. Plaintiff is entitled to immediate possession of the Property.
6. The Defendants, SCOTT W. FINKENBINDER 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.
GOLDBECK McCAFFERTY & McKEEVER
By: Michael McKeever, Esq.
07i )Ili `l08 11 22' FAX
VERIFICATION
a 003/003
I, ; J A^ F to-, --n on behalf of the Plaintiff corporation within named do hereby verify
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 unswom falsification to authorities.
):.late: 9/'I/'o r
ALL THAT PARCEL OF LAND IN TOWNSHIP OF LOWER MIFFLIN, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA,
AS MORE FULLY DESCRIBED IN DEED BOOK 277, PAGE 4681, ID# 15-05-0415-003, BEING BOUND AND DESCRIBED AS
FOLLOWS, TO-WTI':
BEGINNING AT A POINT IN THE CENTER OF TOWNSHIP ROAD 414, SAID POINT BEING 349 FEET NORTHWEST OF THE
PROPERTY LINE OF JOHN CHESTNUT AND ALFRED GAISLET; THENCE NORTH 43 DEGREES 07 MINUTES WEST A
DISTANCE OF 129.45 FEET ALONG THE CENTER OF SAID TOWNSHIP ROAD 414 TO A PIN IN THE CENTER OF SAID
ROAD; THENCE NORTH 52 DEGREES 5 MINUTES WEST A DISTANCE OF 80.22 FEET STILL ALONG THE CENTER OF
SAID TOWN91P ROAD 474 TO A PIN IN THE CENTER OF SAID TOWNSHIP ROD AND CORNER OF OTHER LANDS OF
THE GRANTOR HEREIN, THENCE NORTH 49 DEGREES 00 MINUTES EAST A DISTANCE OF 229.20 FEET ALONG LANDS
OF THE GRANTOR HERE TO A STAKE AND CORNER OF OTHER LANDS OF TITS GRANTOR HEREIN; THENCE SOUTH 41
DEGREES 00 MINUTES EAST A DISTANCE OF 208.00 FEET STILL ALONG OTHER LANDS OF THE GRANTOR HEREIN;
THFNCE SOUTH 49 DEGREES 00 NIDQUTES WEST A DISTANCE OF 208.00 PENT STILL ALONG OTHER LANDS OF
TTIBGRANTORS HEREIN TO A PIN IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD 414 AND THE PLACE OF
BEGINNING.
COMMONLY KNOWN AS 455 HUNTERS ROAD, NEWVILLE, PA 17241
DEED FROM JAMES L. ADAMS AND TERESA M. ADAMS, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 277,
PAGE 4681 DATED 11130/2006 AND RECORDED 1211112006, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF
PENNSYLVANIA
BEING KNOWN AS: 455 HUNTERS ROAD .
(LOWER MIFFLIN TWP) NEWVILLE, PA 17241
PROPERTY ID NO.: 15-05-0415-003
TITLE TO SAID PREMISES IS VESTED IN SCOTT W. FINKENBINDER AND
STEPHANIE FINKENBINDER, HUSBAND AND WIFE BY DEED FROM JAMES L.
ADAMS AND TERESA M. ADAMS, HUSBAND AND WIFE DATED 11/30/06 RECORDED
12/11/06 IN DEED BOOK 277 PAGE 4681.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04801 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK TRUST COMPANY
VS
FINKENBINDER SCOTT W ET AL
KENNETH GOSSERT heriff or Deputy Sheriff of
Cumberland County,Pennsylvania, ho being duly sworn according to law,
says, the within COMPLAINT - EJECTM NT was served upon
FINKENBINDER SCOTT W the
DEFENDANT at 0833:00 HOU S, On the 23rd day of August 2008
at 455 HUNTERS ROAD
NEWVILLE, PA 17241
STEPHANIE FINKENBINDER
a true and attested copy of
by handing to
ITT - EJECTMENT together with
and at the same time directing Fer attention to the contents thereof.
Sheriff's Costs:
Docketing / 18.00
Service I41 13.00
Affidavit ?
pt'b .00
Surcharge 10.00
41.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R.?Thomas Kline
8/25/2008
OLD ECK MCCAFFERTY * rtrrvr,EVr-iR
By.
.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04801 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK TRUST COMPANY
VS
FINKENBINDER SCOTT W ET AL
KENNETH GOSSERT ,
Cumberland County,Pennsylvania,
says, the within COMPLAINT - EJE
OCCUPANT
DEFENDANT at 0833:00 HOUE
at 455 HUNTERS ROAD
NEWVILLE, PA 17241
STEPHANIE FINKENBINDER,
a true and attested copy of COM
ze iff or Deputy Sheriff of
to being duly sworn according to law,
CM NT was served upon
the
the 23rd day of August , 2008
by handing to
ANT
VT - EJECTMENT together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service JOB .00
Affidavit ?I .00
Surcharge A 10.00
16.00
Sworn and Subscibed to
before me this day
of ,
Answers:
Thomas Kline
5/2008
BECK MCCAFFERTY MCKEEVER
By.
D.
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney ID #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6319
Attorney for Plaintiff
Deutsche Bank Trust Company Americas formerly known as
Banker's Trust Compnay, as Trustee and Custodian by: Saxon
Mortgage Services, Inc. f/k/a Meritech Mortgage Services,
Inc. as its attorney-in-fact
4708 Mercantile Drive
Fort Worth, TX 76137
Plaintiff
vs.
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Defendants
PRAECIPE FOR JUDGMENT IN EJECTMENT
Term
No. 08-4801
Kindly enter Judgment in Ejectment in favor of the Plaintiff, Deutsche Bank Trust Company
Americas formerly known as Banker's Trust Compnay, as Trustee and Custodian by: Saxon Mortgage
Services, Inc. f/k/a Meritech Mortgage Services, Inc. as its attorney-in-fact and against the Defendants
SCOTT W. FINKENBINDER 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 Plaintiff's
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 Deutsche Bank Trust Company Americas formerly known as Banker's Trust Compnay,
as Trustee and Custodian by: Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services, Inc. as its
attorney-in-fact, 4708 Mercantile Drive, Fort Worth, TX 76137 and that the names and last known address of
the Defendants are SCOTT W. FINKENBINDER and OCCUPANTS 455 Hunters Road, Newville, PA
17241.
X" T-, & rak-?
GOLDBEC MCCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF EJECTMENT
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
Deutsche Bank Trust Company Americas formerly
known as Banker's Trust Compnay, as Trustee and
Custodian by: Saxon Mortgage Services, Inc. f/k/a
Meritech Mortgage Services, Inc. as its attorney-m-
fact
4708 Mercantile Drive
Fort Worth, TX 76137
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Term
No. 08-4801
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Defendants
DATE OF THIS NOTICE: September 15, 2008
TO: OCCUPANTS
455 Hunters Road
Newville, PA 17241
IMPORTANT NOTICE
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
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever, Esq.
Attorney 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
Deutsche Bank Trust Company Americas formerly
known as Banker's Trust Compnay, as Trustee and
Custodian by: Saxon Mortgage Services, Inc. f/k/a
Meritech Mortgage Services, Inc. as its attorney-m-
fact
4708 Mercantile Drive
Fort Worth, TX 76137
Plaintiff
vs.
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Defendants
DATE OF THIS NOTICE: September 15, 2008
TO: SCOTT W. FINKENBINDER
455 Hunters Road
Newville, PA 17241
IMPORTANT NOTICE
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Term
No. 08-4801
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
S Irvine Row
Carlisle. PA 17013
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney ID #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6319
Attorney for Plaintiff
Deutsche Bank Trust Company Americas formerly known as
Banker's Trust Compnay, as Trustee and Custodian by: Saxon
Mortgage Services, Inc. f/k/a Meritech Mortgage Services,
Inc. as its attorney-in-fact
4708 Mercantile Drive
Fort Worth, TX 76137
Plaintiff
vs.
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Defendants
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Term
No. 08-4801
CERTIFICATION PURSUANT TO PA R.C.P. NO. 237
I, Michael T. McKeever, Esquire, attorney 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:
SCOTT W. FINKENBINDER
OCCUPANTS
455 Hunters Road
Newville, PA 17241
GOLDBECK McCAFFERTY & McKEEVER
BY:
ichael T. McKee er, Esq.
Attorney for Plaintiff
DATED: September 25, 2008
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, SCOTT W. FINKENBINDER, is about unknown
years of age, that Defendant's last known residence is, 455 Hunters Road Newville, PA 17241, 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:
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C.P. 109 - P
Praecipe for Writ of Possession
(ACTION OF EJECTMENT)
THE COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland
Deutsche Bank Trust Company Americas formerly known
as Banker's Trust Compnay, as Trustee and Custodian by:
Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage
Services, Inc. as its attorney-in-fact
4708 Mercantile Drive
Fort Worth, TX 76137
Plaintiff
IN THE COURT OF COMMON PLEAS
vs.
SCOTT W. FINKENBINDER
and OCCUPANTS
455 Hunters Road
Newville, PA 17241
Defendants
PRAECIPE FOR WRIT POSSESSION
TO THE PROTHONOTARY:
OF Cumberland COUNTY
08-4801
Issue the Writ of Possession in the above matter, for possession of 455 Hunters Road Newville, PA 17241 (describe
property)
SEE ATTACHED LEGAL DESCRIPTION
1A h. P G
ECK, cCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
Ejectment
Quiet Title
A.
5 - 116 (Rev. 10/76)
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ALL THAT PARCEL. OF LAND IN TOWNSHIP OF LOWER MIFFLIN, CUMBERLAND COUN'T'Y, STATE OF PENNSYLVANIA,
AS MORE FULLY DESCRIBED IN DEED BOOK 277, PAGE 4681, ID# 15-05-0415.003, BEING BOUND AND DESCRIBED AS
FOLLOWS, TO-WIT:
BEGINNING AT A POINT IN THE CENTER OF TOWNSHIP ROAD 414, SAID POINT BEING 349 FEET NORTHWEST OF TI4E
PROPERTY LANE OF JOHN CHESTNUT AND ALFRED GAISLET; THENCE NORTH 43 DEGREES 07 MINUTES WEST A
DISTANCE OF 129.45 FEET ALONG THE CENTER OF SAID TOWNSHIP ROAD 414 TO A PIN IN THE CENTER OF SAID
ROAD; THENCE NORTH 52 DEGREES 5 MINUTES WEST A DISTANCE OF 80.22 FEET STILL ALONG THE CENTER OF
SAID TOWNSHIP ROAD 474 TO A PIN IN THE CENTER OF SAID TOWNSHIP ROD AND CORNER OF OTHER LANDS OF
TIM GRANTORHBREIN, THENCE NORTH 49 DEGREES 00 MINUTES EAST A DISTANCE OF 229.20 FEET ALONG LANDS
OF THE GRANTOR HERE TO A STAKE AND CORNER OF OTHER LANDS OF THE GRANTOR HEREIN; THENCE SOUTH 41
DEGREES 00 MINUTES EAST A DISTANCE OF 208.00 FEET STILL ALONG OTHER LANDS OF THE GRANTOR HEREIN,
TIMNCE SOUTH 49 DEGREES 00 MINUTES WEST A DISTANCE OF 208.00 FEET STILL ALONG OTHER LANDS OF
TBEGRANTORS HEREIN TO A PIN IN THE CENTER OF THE AFORESAID TOWNSHIP ROAD 414 AND THE PLACE OF
BEGINNING.
COMMONLY KNOWN AS 455 HUNTERS ROAD, NEWVI LLE, PA 17241
DEED FROM JAMES L. ADAMS AND TERESA M. ADAMS, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 277,
PAGE 4681 DATED 11/30/2006 AND RECORDED 12111/2006, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF
PENNSYLVANIA.
BEING KNOWN AS: 455 HUNTERS ROAD
(LOWER MIFFLIN TWP) NEWVILLE, PA 17241
PROPERTY ID NO.: 15-05-0415-003
TITLE TO SAID PREMISES IS VESTED IN SCOTT W. FINKENBINDER AND
STEPHANIE FINKENBINDER, HUSBAND AND WIFE BY DEED FROM JAMES L.
ADAMS AND TERESA M. ADAMS, HUSBAND AND WIFE DATED 11/30/06 RECORDED
12/11/06 IN DEED BOOK 277 PAGE 4681.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04801 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK TRUST COMPANY
VS
FINKENBINDER SCOTT W FT AL
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsyivania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT was served upon
_FINKENBINDER SCOTT W the
DEFENDANT at 0833:00 HOURS, on the 23rd day of August 2008
at 455 HUNTERS ROAD
NEWVILLE, PA 17241
STEPHANIE FINKENBINDER
by handing to
a true and attested copy of COMPLAINT - EJECTMENT
together with
am ?t i- hP _,(3mP r1111.F d17"F'Ci.7nQ Her attention to the CO;'ite37tS t±1e-eC.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04801 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK TRUST COMPANY
VS
FINKENBINDER SCOTT W ET AL
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT was served upon
OCCUPANT the
DEFENDANT at 0833:00 HOURS, on the 23rd day of August , 2008
at 455 HUNTERS ROAD
NEWVILLE, PA 17241 by handing to
STEPHANIE FINKENBINDER, OCCUPANT
a true and attested copy of COMPLAINT - EJECTMENT together with
u;/a ar. the carne time directing Her aute,, L;o t `mac- f_e
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WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
vs. No. 084801 Civil Term-
SCOTT W. FINKENBINDER and
OCCUPANTS
Costs
Attorney's $ 173.
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))
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
being: (Premises as follows):
455 HUNTERS ROAD, NEWVILLE, PA 17241
(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 R. Long, Praft otary,
Common Pleas Court of Cumb rland County, PA
Date 9/26/08
2of2
No 08-4801 Civil Term
By virtue of this writ, on the
VS.
named
appurtenances, and
WRIT OF POSSESSION
P.R.C.P. 3160.3165 ETC.
Costs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
SCOTT W. FINKENBINDER and
OCCUPANTS
Att'y $113.50
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
Attorney for Plaintiff (s)
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
So Answers,
Sheriff
By
Deputy
t . I*&
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
Writf Pnccaecinn Returned stayed 12/4/08 Per Atty
Sworn and subscribed to before me this
Day of ,
Sheriff's Return
1. 1
Docketing 18.00
Prothy 2.00
Milage 10.00
Poundage 1.00
Surcharge 20.00
So Ans
heriB
Advance Costs: 150.00
Sheriff's Costs: 51.00
99.O0
Refunded Atty 12/4/08
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No 08-4801 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
vs.
SCOTT W. FINKENBINDER and
OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $173.50
Plff (SA $
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
Attorney for Plaintiff (s)
By virtue of this writ, on the
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
So Answers,
Sheriff
By
Deputy
/-" r 4 w V
lnf 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
vs. No. 084801 Civil Term-
SCOTT W. FINKENBINDER and
OCCUPANTS
Costs
Attorney's $ X73.
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))
DEUTSCHE BANK TRUST COMPANY
AMERICAS f/k/a/ BANKER'S TRUST
COMPANY, as Trustee and Custodian by:
SAXON MORTGAGE SERVICES, INC f/k/a
MERITECH MORTGAGE SERVICES, INC as its
attorney-in-fact
being: (Premises as follows):
455 HUNTERS ROAD, NEWVILLE, PA 17241
(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.
R. Long, Protlr6 otary,
Common Pleas Court of Cumb rland County, PA
Date 3/26/08