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Home My WebLink About08-6857 dA GOLDBECK 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-13C4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Plaintiff CIVIL ACTION - LAW ACTION OF EJECTMENT l;1Vl I Term No.6kr Defendants NOTICE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 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 tiling 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 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. AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Sl DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AV1SO. 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 DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 Oft COMPLAINT IN EJECTMENT Plaintiff is THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Defendants are JAMES R. WILLIS, and OCCUPANTS. Plaintiff is the owner of property located at 1401 Lowther Road, Camp Hill, PA 17011, by virtue of a Deed from the Sheriff of Cumberland County to THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4 recorded on 10/22/2008 at Instrument #200834665. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, JAMES R. WILLIS and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, 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. r .46 VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for Plaintiff in this matter and has personal knowledge of the allegations of the Complaint in Ejectment based upon information supplied by Plaintiff and/or matters of public record, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Ejectment are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Michael T. McKeever, Esquire PA I.D. #56129 #74813EJ JAMES R. WILLIS . 4% ALL that certain lot of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southeasterly line of Loather Street at the southwesterly line of Manchester Road (erroneously described as the southeast corner of Manchester Road and Lowther Street in prior deed); thence southeastwardly along said line of Manchester Road by a curve to the left having a radius of four hundred forty-seven and five-tenths (447.5) feet, an arc distance of eighty (80) feet to a stake; thence south thirty- eight (38) degrees forty (40) minutes west along Lot No. 4, Block "B" on the hereinafter mentioned Plan, one hundred eight and eighty-nine one-hundredths (108.89) feet to a point thence south twenty-eight (28) degrees nine (09) minutes west along the same, ten and eighteen one-hundredths (10.18) feet to a point; thence north forty (40) degrees fifty- nine (59) minute west along property now or formerly of Robert M. Troutman and wife, one hundred two and eighty-six one-hundredths (102.86) feet to a point on the southeasterly line of Loather Street; thence along the larger line north forty-nine (49) degrees one (01) minutes east one hundred nine and forty-seven one-hundredths (109.47) feet to the place of beginning. TAX PARCEL NO: 13-23-0545-272 1401 Lowther Road o yaw i " 'v JAMES R. WILLIS a true and attested copy of COMPLAINT - EJECTMENT NOTICE CASE NO: 2008-06857 P Sheriff's Costs: Docketing Service Affidavit Surcharge )xjos*0& - COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK TRUST COMPANY VS WILLIS JAMES R ET AL KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon TATTT,T.TC ,7LMR.q R the DEFENDANT , at 1915:00 HOURS, on the 2nd day of December , 2008 at 1401 LOWTHER ROAD CAMP HILL, PA 17011 by handing to together with and at the same time directing His attention to the contents thereof. SHERIFF'S RETURN - REGULAR So Answers: 18.00 14 .4 0 00 10.00 R. Thomas Kline .00 ? 42.40 12/03/2008 GOLDBECK MCCAFFERTY & MCKEEVER Sworn and Subscibed to before me this day of , By. A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06857 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BANK OF NEW YORK TRUST COMPANY VS WILLIS JAMES R 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 COMPLAINT - EJECTMENT NOTICE the within named DEFENDANT 1401 LOWTHER ROAD , OCCUPANT NOT FOUND , as to CAMP HILL, PA 17011 THE ONLY OCCUPANT AT ABOVE ADDRESS IS JAMES R. WILLIS. Sheriff's Costs: Docketing Service Affidavit Surcharge i?2ld??OF So answers;_ --- -? 6.00- ... , ,,.. .00 , .00 --?-R. Thomas Kl.' e 10.00 Sheriff of Cumberland County .00 16.00 GOLDBECK MCCAFFERTY & MCKEEVER 12/03/2008 Sworn and Subscribed to before me this day of A. 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005- BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Defendants PRAECIPE FOR JUDGMENT IN EJECTMENT Term No. 08-6857 Kindly enter Judgment in Ejectment in favor of the Plaintiff, THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4 and against the Defendants JAMES R. WILLIS 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4, 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005 and that the names and last known address of the Defendants are JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road, Camp Hill, PA 17011. 6A Az GOLDBECK cCAFFERTY & 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Plaintiff Defendants DATE OF THIS NOTICE: December 24, 2008 TO: JAMES R. WILLIS 1401 Lowther Road Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-6857 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 M&AFFERTY & 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-13C4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Plaintiff Defendants DATE OF THIS NOTICE: December 24, 2008 TO: OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 IMPORTANT NOTICE Term No. 08-6857 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 CIVIL ACTION - LAW ACTION OF EJECTMENT GOLDBECK WCAFFERTY & McKEEVER BY: Michael I 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. 1. That the above named Defendant, JAMES R. WILLIS, is about unknown years of age, that Defendant's last known residence is, 1401 Lowther Road Camp Hill, PA 17011, 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: JAN 0 5 ?uu? 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 THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005- BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-6857 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: JAMES R. WILLIS OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 GOLDBECK McCAFFERTY & McKEEVER BY1%' 1? G?? G Michael T. McKeever, Esq. Attorney for Plaintiff DATED: January 5, 2009 CASE NO: 2008-06857 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF NEW YORK TRUST COMPANY VS WILLIS JAMES R ET AL KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon WILLIS JAMES R the DEFENDANT , at 1915:00 HOURS, on the 2nd day of December , 2008 at 14 01 LOWTHER ROAD CAMP HILL, PA 17011 by handing to JAMES R. WILLIS a true and attested copy of COMPLAINT - EJECTMENT together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 42.40 Sworn and Subscibed to before me this day So Answers: Pool' R. Thomas ine 12/03/2008 GOLDBECK MCCAFFERTY & MCKEEVER By: of A. D. i l SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06857 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HANK OF NEW YORK TRUST COMPANY VS WILLIS JAMES R 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 COMPLAINT - EJECTMENT , NOTICE NOT FOUND , as to the within named DEFENDANT , OCCUPANT 1401 LOWT'HER ROAD CAMP HILL, PA 17011 THE ONLY OCCUPANT AT ABOVE. ADDRESS IS JAMES R. WILLIS. Sheriff's Costs: So answer ...? ;???•- Docketing 6.00 Service .00 Affidavit .00 R. omas Kl e Surcharge 10.00 Sheriff of Cumberiand County .00 16.00 GOLDBECK MCCAFFERTY & MCKEEVER 12/03/2008 Sworn and Subscribed to before me this day of IF A.D. 1 i ? ? =?f i ?? ? ?; o ? -? 4U ' "``". b ? _,_ t ? ?? t t31 w.?. ' r rr ? -ms's C°' :-x. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Curt Long -- Prothonotary THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Defendants N O T I C E Term No. 08-6857 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notifi tha ent has been entered against you in the above proceeding as indicated below: urt Prothonotary Judgment by Default - Money Judgment _ Judgment in Replevin X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY : Michael T. McKeever, Esquire at the following telephone number: (215) 825-6319 5-60 (2) (Rev. 4/78)55 C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland THE BANK OF NEW YORK TRUST COMPANY, N.A., AS SUCCESSOR TRUSTEE TO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS ORIGINAL TRUSTEE FOR THE MLMI SURF TRUST, SERIES 2005-BC4 14523 SW Millikan Way Suite 200 Beaverton, OR 97005 Plaintiff IN THE COURT OF COMMON PLEAS vs. JAMES R. WILLIS and OCCUPANTS 1401 Lowther Road Camp Hill, PA 17011 Defendants PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: OF Cumberland COUNTY 08-6857 Issue the Writ of Possession in the above matter, for possession of 1401 Lowther Road Camp Hill, PA 17011 (describe property) SEE ATTACHED LEGAL DESCRIPTION Ejectment Quiet Title A. 5 -116 (Rev. 10/76) c r GOLDBECK, McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney for Plaintiff d O d ?U do x N U ? O? a? ti O ? ?c w w H w Q N Uo, 4o0 p it. 'D w E,,, `n W ? v O 00 U 00 ?C40 w 0 x H 0 3??a a aU o o ? w o ? u W ?i W .? ?v 0 w ? ? d o m u Q ca ao 0 0 a ?Q y o ? 0-- cp a I'l k ? a ALL that certain lot of land situate in Lower Allen Township, Cumberland Colony, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southeasterly line of Loather Street at the southwesterly line of Manchester Road (erroneously described as the southeast corner of Manchester Road and Lowtha Street in price' deed), thence southeastwardly along said line of Manchester Road by a curve to the left having a radius of four hundred frnty Seve and five-tom (441.5) feet, an arc distance of eighty (80) feet to a stake; thence south thirty- eight (38) degrees forty (40) minutes west along Lot No. 4, Block "B" on the hereinafter mentioned Plan, one hundred eight and eighty-nine one--hundredths (108.89) feet to a point thence south twenty-eight (28) degrees nine (09) minutes west along the same, ten and eighteen one-hundredths (10.18) feet to a point; thence north forty (40) degrees fifty- nine (59) minute west along property now or formerly of Robert M. Troutman and wife, one hundred two and eighty-six one-hundredths (102.86) feet to a point on the southeasterly line of Loather Street; thence along the larger line north forty-nine (49) degrees one (01) minutes east one hundred nine and forty-seven ono-hundredths (109.47) feet to the place of beginning. TAX PARCEL NO: 13-23-0545-272 1401 Lowther Road lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK TRUST COMPANY, N.A., As Successor Trustee to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-BC4 VS. No. 08-6857 Civil Term JAMES R. WILLIS and OCCUPANT Costs Attorney's $ 17$. q0 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)) THE BANK OF NEW YORK TRUST COMPANY,N.A., as Successor Trustee to JPMORGAN CAHSE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-BC4, being: (Premises as follows): 1401 LOWTHER ROAD, CAMP HILL, PA 17011 (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. 211 Jb Curtis R. Lon o otar , Common Pleas Court of Cu berland County, PA Date 1/07/09 (Seal) 2of2 No 08-6857 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK TRUST COMPANY, N.A., As Successor Trustee to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-BC4 VS. JAMES R. WILLIS and OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 17q.90 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL 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) 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 , Prothonotary Sheriff By Deputy ALL that certain lot of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southeasterly line of Leather Street at the southwesterly line of Manchester Road (erroneously described as the southeast corner of Manchester Road and Lowther Street in prior deed); thence southeastwardly along said tine of Manchester Road by a curve to the left having, a radius of four hundred forty-seven and five-tenths (447.5) feet, an arc distance of eighty (80) feet to a stake; thence south thirty- eight (38) degrees forty (40) minutes west along Lot No. 4, Block "B" on the hereinafter mentioned Plan, one hundred eight and eighty-nine one-hundredths (108.8.9) feet to a point thence south twenty-eight (28) degrees nine (09) minutes west along the same, ten and eighteen one-hundredths (10.18) feet to a point; thence north forty (40) degrees fifty- nine (59) minutb west along property now or formerly of Robert M. Troutman and wife, one hundred two and eighty-six one-hundredths (102.86) feet to a point on the southeasterly line of Loather Street; thence along the larger line north forty-nine (49) degrees one (01) minutes east one hundred nine and forty-seven one-hundredths (109.47) feet to the place of beginning. TAX PARCEL N4: 13-23-0545-272 1401 Lowther Road Sworn and subscribed to before me this Day of , F 0, 0 ?00 0 " -. " 0 0 ?- Prothonotary Sheriff's Return Docketing $ 18.00 By Poundage 1.98 Prothy 2.00 Surcharge 20.00 Possession 30.00 Mileage 28.80 $ 100.78 ? `'??r?° ??" Deputy Advance Costs: $ 150.00 Sheriff's Costs: 100.78 $ 49.22 Refunded to Atty 04-02-09 w 3 By virtue of this writ, on the 1 s t day of Apr i 1 2009 I caused the within named Bank of New York Pt- a 1 , to have possession of the premises describedllftft * " WKXX& 'as 1 401 Lowther Rna , Came Hi 1 1 , PA 17011 So Answers, ? :z 0 .,a .?.? fT? r m33 lot z WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK TRUST COMPANY, N.A., As Successor Trustee to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-BC4 VS. No. 08-6857 Civil Term JAMES R. WILLIS and OCCUPANT Costs Attorney's $ 17#.90 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)) THE BANK OF NEW YORK TRUST COMPANY,N.A., as Successor Trustee to JPMORGAN CAHSE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-BC4, being: (Premises as follows): 1401 LOWTHER ROAD, CAMP HILL, PA 17011 (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. urtis R. o iono ry, Common Pleas Court of Cumberland County, PA Date 1/07/09 (Seal) 2of2 No 08-6857 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK TRUST COMPANY, N.A., As Successor Trustee to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, as Original Trustee for the MLMI SURF TRUST, SERIES 2005-13C4 VS. JAMES R. WILLIS and OCCUPANT WRIT OF POSSESSION P.P C.P. 3160-3165 ETC. Costs Att' y $ 174.96 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL 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) Where papers may be served ALL that certain lot of land situate in Lower Allen Township, Cumberland County, Pamylvania, bounded and described as follows: BEGINNING at a point on the southeasterly line of Loather Street at the southwesterly line of Manchester Road (erroneously described as the southeast corner of Manchester Road and Lowther Street in prior deed); thence southeastwardly along said line of Manchester Road by a curve to the left having a radius of four hundred forty-seven and five-tenths (447.5) feet, an arc distance of eighty (811 feet to a stake, thence south thirty- eight (38) degrees forty (40) minutes west along Lot No. 4, Block "B" on the hereinafter mentioned Plan, one hundred eight and eighty-nine one-hundredths (108.89)_ feet to a point thence south twenty-eight (28) degrees nine (09) minutes west along the same, ten and eighteen one-hundredths (10.18) feet to a point; thence north forty (40) degrees fifty- nine (59) minutb west along property now or formerly of Robert M. Troutman and wife, one hundred two and eighty-six one-hundredths (1.02.86) feet to a point on the southeasterly line of Loather Street; thence along the larger line north forty-nine (49) degrees one (01) minutes east one hundred nine and forty-seven one-hundredths (109.47) feet to the place of beginning. TAX PARCEL NO: 13-23-0545-272 1401 Lowther Road v ? l ? I :E d 8 - Ur 001