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Home My WebLink About08-6027 PAUL K. FETTERHOFF 1461 Pheasant Hill Road Dauphin, PA 17018 Plaintiff V. DOROTHEIA R. HUNTER; and MICHAEL: WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, individually and MICHAEL WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, as Trustees for Minors Sharlenea R. Wagner and Dakota Criley, To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C8 - loOVI Civil Term CIVIL ACTION - EQUITY PRAECIPE FOR WRIT OF SUMMONS Kindly issue a Writ of Summons in this Civil Action to the following Defendants in the above case: Dorotheia R. Hunter, Individually; Michael Wagner, II, Individually and as Trustee for Minors Sharlenea R. Wagner and Dakota Criley; Alberta Wagner, Individually and as Trustee for Minors Sharlenea R. Wagner and Dakota Criley; and Stephanie L. Gaffey, Individually and as Trustee for Minors Sharlenea R. Wagner and Dakota Criley Writ of Summons shall be forwarded to the Sheriff of Cumberland County for service. Date: D & CHERNICOFF, P.C. By: Tor D. Cunningham, Esquire I. Y. #23144 Kelly M. Knight, Esquire I.D. #87365 2320 North Second Street Harrisburg, PA 17110 Telephone: (717) 238-6570 (Attorneys for Plaintiffi r PAUL K. FETTERHOFF 1461 Pheasant Hill Road Dauphin, PA 17018 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. bg- (v0a7 L'iiilTerr-4 CIVIL ACTION - EQUITY DOROTHEIA R. HUNTER; and MICHAEL: WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, individually and MICHAEL WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, as Trustees for Minors Sharlenea R. Wagner and Dakota Criley, WRIT OF SUMMONS TO: Defendant Dorotheia R. Hunter Defendant Michael Wagner, II 42 Altoona Avenue 42 Altoona Avenue Enola, PA 17025-2501 Enola, PA 17025-2501 Defendant Alberta Wagner 42 Altoona Avenue Enola, PA 17025-2501 Defendant Stephanie L. Gaffey 204 Spruce Court Annville, PA 17003-9316 You are notified that the Plaintiff has commenced an action against you. rotho Dated: 4468"'toS F:1Home\AHEWIT7\D6CS\D-F\FETTERHOUiUNTER, DOROTHEIMCUMBERLAND CO ENOLA PROPERTY\Writ of Summons 2.wpd t = `? 0 - LA CEO n Sv p? O r C1 rT R? b co r'o W w? Jordan D. Cunningham, Esquire PA Supreme Court ID #23144 Kelly M. Knight, Esquire PA Supreme Court ID #87365 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street Harrisburg, PA 17110 Mailing Address: P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 Attorneys for Plaintiff PAUL K. FETTERHOFF 1461 Pheasant Hill Road Dauphin, PA 17018 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n NO. 08 - 60,27 C;'ja (erw• CIVIL ACTION - EQUITY DOROTHEIA R. HUNTER; and MICHAEL: WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, individually and MICHAEL WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY, as Trustees for Minors Sharlenea R. Wagner and Dakota Criley, TO THE PROTHONOTARY: PRAECIPE FOR LIS PENDENS Please index the above-captioned action as a lis pendens against the real property identified as 42 Altoona Drive, Enola, Cumberland County, Pennsylvania in which Plaintiff, Paul K. Fetterhoff, currently has an interest. I hereby certify that this action may affect title to or other interest in the above described real property interest. CUNNINGHAM & CHERNICOFF, P.C. Date: 0l`7 By: 2320 North Second Street Harrisburg, PA 17110 Telephone: (717) 238-6570 (Attorneys for Plaintiffi F:\HomeWHEWITI'\DOCS\D-F\FETrERHO\HUNTER, DOROTHEIMCUMBERLAND CO ENOLA PROPERTYU.is Pendes.WPD neny ivi. r mgni, rsquire I.D. #87365 K DEED Made the ft- day of f PMM 89F OC , in the year of our Lord two thousand and seven (2007) BETWEEN MICHAEL S. WAGNER, of Harrisburg, County of Dauphin, (hereinafter called Grantor), AND DOROTHEIA R. C. WAGNER, (hereinafter called Grantee) WITNESSETH: WHEREAS, by a Court Order dated August 9, 2007, docketed No. 2004-CV-4561-DV in the Court of Common Pleas, Dauphin County, Pennsylvania and signed by the Honorable Scott Arthur Evans of the Court of Common Pleas, Dauphin County, Pennsylvania, it was ordered that wife, Dorotheia R.C. Wagner, Grantee herein, shall receive the fortnet marital residence located at 42 Altoona Avenue, Enola, Pennsylvania and husband, Michael S. Wagner, Grantor herein, shall transfer title to said residence. THAT the said Grantor for and in consideration of the sum of One and 00/100 Dollar ($1.00), lawful money of the United States of America, unto him well and truly paid by the said Grantee, at or before the sealing and delivery hereof; the receipt whereof is hereby acknowledged, granted, bargained and sold, released and confirmed, and by these presents does grant, bargain and sell, release and confirm unto the said Grantee, her heirs and assigns, ALL THAT CERTAIN lot or parcel of land situate in the Township of East Pennsboro, C ounty of Cumberland and Commonwealth of Pennsylvania, bounded and described in accordance with a Penns survey and plan prepared by Roy M. H. Benjamin, Registered Engineer, of Harrisburg, y1ania, dated August 18, 1965, as follow, to wit. BEGINNING at a point on the eastern line of Altoona Avenue, said point being seventy (70) feet in a southedy direction from the southeast comer of the intersection of Altoona Avenue and Perry Street; thence North 79 degrees 40 minutes East, One Hundred Twenty-Five (125) feet to a point; thence South 10 degrees 20 minutes East, Fifty (50) feet to a point; thence through the center of a partition will separating the premises No. 40 and No. 42 Altoona Avenue, South 79 degrees 40 minutes West, One Hundred Twenty- Five (125) feet to a point on the eastern line of Altoona Avenue; thence along the eastern line of Altoona Avenue, North 10 degrees 20 minutes West, Fifty (50) feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a two and one-half story frame semi-detached dwelling house known and numbered as No. 42 Altoona Avenue, Eno* Pennsylvania. BEING the same premises which J. Dean Bluestone and Debra Ann Bluestone, his wife, by their Deed dated August 9, 1995 and recorded in the Cumberland County Recorder of Deeds Office -1- • v on August 10, 1995 in Record Book 126, Page 545, granted and conveyed unto Michael S. Wagner, Grantor herein. THIS TRANSFER IS EXEMPT FROM TRANSFER TAX AS IT IS A TRANSFER FROM HUSBAND TO WIFE PER COURT ORDER. And the said grantor hereby covenants and agrees that she will warrant specially the property hereby conveyed. TOGETHER with all and singular the buildings and improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belorigin$ or in anywise ApPettainings and the reversions and remainders, rests, issues, and profits thereof and all the estate, right tide, interest property, claim and demand whatsoever of the, said Grantor, as wen at law as in equity, of, in and to the same. TO HAVE AND TO HOLD the said lot or piece of ground described with the baikhV and improvements thereon erected, hereditments and premises hereby granted, or mentioned and intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, to and for the only proper use and behoof of the said Grantee, her heirs and assigns, forever. AND the said Grantor, his heirs, executors and administrators do covenant, promise and agree, to and with the said Grantee, her heirs and assigns, by these presents, that the said Grantor and his heirs, all and singular the heredittnents and premises herby granted or mentioned and intended so to be, with appurtenances, unto the said Grantee, her heirs and assigns, against the said Grantor and his heirs, and against all and every person and persons whosoever lawfully claiming or to claim the same Or any part thereof by, from or under or any of therm, shall and will SPECIALLY WARRANT and forever DEFEND. IN WITNESS WHEREOF, said Grantor has herrunto set his hand and seal the day and year first above written. Sealed and Delivered in the presence of (SEAL) Michaeof Residence I hereby certify that the precise residence of the Grantee is as follows: 42 Altoona Avenue Enola, PA 17025 -2- ..'h Y AYO ZA Attomey or Grantee ACKNOWLEDGMENT Commonwealth of Pennsylvania ss: County of U4 6CP-A4W On this, the 7 day of --'?P1`INB?'?? , 2007, before me, a Notary Public for the Commonwealth of Pennsylvania, personally appeared Michael S. Wagner, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. 1 hereunto set my hand and official seal. Notary Public My Commission Expires: W? MINeK. P.ww^*.a (SEAL) -3- ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200735549 Recorded On 9/1212007 At 10:28:34 AM * Instrument Type - DEED Invoice Number - 4320 User ID - KW * Grantor - WAGNER, MICHAEL S * Grantee - WAGNER, DOROTHEIA R C * Customer - DOROTHEIA WAGNER * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $38.50 * Total Pages - 4 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O? " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OMBX 111111111111111 96 ? v 1 co t t I CN.,7 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06027 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FETTERHOFF PAUL K VS HUNTER DOROTHEIA R ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HUNTER DOROTHEIA R the DEFENDANT , at 1735:00 HOURS, on the 9th day of October , 2008 at 42 ALTOONA AVENUE ENOLA, PA 17025 by handing to DOROTHEIA HUNTER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge /obvv 9, 4- Sworn and Subscibed to before me this of So Answers: 18.00 15-00 00 10.00 R. Thomas Kline .00 43.00 10/10/2008 CUNNINGHAM & CHERNICOFF By: day Deputy Sfteriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-06027 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FETTERHOFF PAUL K VS HUNTER DOROTHEIA R ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon WT("_TTVV MT(WhWT. TT the DEFENDANT , at 1735:00 HOURS, on the at 42 ALTOONA AVENUE ENOLA, PA 17025 MICHAEL WAGNER by handing to 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 .00 Affidavit .00 Surcharge 10.00 00 10111-16s, 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/10/2008 CUNNINGHAM & CHERNICOFF By Deputy Sheriff 9th day of October , 2008 of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-06027 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FETTERHOFF PAUL K VS HUNTER DOROTHEIA R ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS WAGNER ALBERTA was served upon the DEFENDANT , at 1735:00 HOURS, on the 9th day of October , 2008 at 42 ALTOONA AVENUE ENOLA, PA 17025 by handing to ALBERTA WAGNER a true and attested copy of WRIT OF SUMMONS 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 !b f P??O y',, 16. 00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/10/2008 CUNNINGHAM & CHERNICOFF By. 4i?i T Deputy Sheri. of A. D. PAUL K. FETTERHOFF 1461 PHEASANT HILL ROAD DAUPHIN, PA 17018, Plaintiff V. DOROTHEA R. HUNTER; and MICHAEL WAGNER, II; ALBERTA WAGNER and STEPHANIE L. GAFFEY, INDIVIDUALLY And MICHAEL WAGNER, II; ALBERTA WAGNER; and STEPHANIE L. GAFFEY as TRUSTEES FOR MINORS SHARLENA R. WAGNER and DAKOTA CRILEY, Defendants THE COURT OF COMMON LEAS, CUMBERLAND COUNTY, PENNSYLVANIA 08-6027 CIVIL TERM CIVIL ACTION - EQUITY IRAECIPE AND RULE TO FILE COMPLAINT TO THE PROTHONOTARY/CLERK OF SAID COURT Issue Rule on Plaintiff Paul K. Fetterhoff to file within twenty (20) days after service of the rule or sul December 17, 2008 NOW, December 17, 2008, RULE ISSUED AS ABOVE. .omplaint in the above case a judgment of non pros. eter B. Foster, Esquire .ttorney for Defendants Dorothea R. Hunter, Michael Wagner, II; and Alberta Wagner 14 South Street [arrisburg, PA 17101 17-234-9321 D.#15357 Deputy r"? -? ?? ? =1S ?? ? ?` 3 ?--?, {.RR .?? 4,i