HomeMy WebLinkAbout08-7241
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL
2 RASPBERRY DRIVE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0289-020P
Defendants.
TO: DEFENDANT(s)
YOU ARE EREBY NOTIFIED TO PLEAD TO THE
ENCLOERE WITH WENTY '201T FROM RE OR DEFAULT JUDGMENT
MAY B D S
ATTORNEY FOR
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
31 E. Main Street, P.O. Box 1001
New Kingston, PA 17072-1001
AND THE DEFENDANT(S):
Raymond Prozoic
2 Rasp b rry riv echanicsburg, PA 17050
Harvey . C se
6160 S in r I4v , Apt C-6
ATTORNEY FOR PLA
CERTIFICATE OF LOCA'
I HEREB CE IFY
THE RE A A]
2 Rasab v riv Mie
THE LOCATION OF
TED BY THIS LIEN IS
csbura, PA 17050
CIVIL DIVISION
NO.: 08-5139 MLD
08 - 7A41
Oivi l lean
TYPE OF PLEADING
CIVIL ACTION - WRIT
OF SCIRE FACIAS
FILED ON BEHALF OF:
Silver Spring Township Authority, Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
JAMES, SMITH, DIETTERICK &
CONNELLY, LLP
A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff, No.: 08-5139 MLD
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL
2 RASPBERRY DRIVE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0289-020P
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 SHOULD
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
Phone (717) 249-3166
Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff, No.: 08-5139 MLD
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL
2 RASPBERRY DRIVE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0289-020P
Defendants.
AVISO
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte
por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A
LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (717) 249-3166
Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff, No.: 08-5139 MLD
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL
2 RASPBERRY DRIVE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0289-020P
Defendants.
PRAECIPE TO ISSUE
WRIT OF SCIRE FACIAS
TO: PROTHONOTARY
SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter.
By:
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
#0
S2? w
ov ?
R? CA3
R-5
0
0
p
0
ro
0
a
0
i
8 ? -n
C
?o
a
w
w ?
m
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY
31 E. MAIN STREET, P.O. BOX 1001
NEW KINGSTON, PA 17072-1001
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL
2 RASPBERRY DRIVE
MECHANICSBURG, PA 17050
PARCEL# 38-21-0289-020P
Defendants.
TO: PROTHONOTARY
SIR/MADAM: Please issue a Writ of Scire Facias ii
CIVIL DIVISION
No.: 08-5139 MLD
b$- 7A4I civil Terra
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
WRIT OF SURE FACIAS
TO: Raymond Prozoic and Harvey J. Cassell
WHEREAS, Silver Spring Township Authority, on August 26, 2008, filed its claim in
our Court of Common Pleas of Cumberland County at Municipal Claim No. 08-5139 MLD, for
the sum of $6,676.65, plus additional attorneys fees and costs incurred thereafter, for sewer rents
due the said Silver Spring Township Authority, said Claim filed against property owned by you
in Silver Spring Township, located at 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050,
as more particularly described in said Claim, and said property being further described in the
Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book
276, Page 4567, tax parcel #38-21-0289-020P, owned or reputed to be owned by you;
AND WHEREAS, we have been given to understand that said Claim is still due and
unpaid, and remains a lien against the said property;
NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense
you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days
after the service of this Writ upon you. If no Affidavit of Defense is filed within said time,
Judgment may be entered against you for the whole Claim, and the property described in the
Claim be sold to recover the amount thereof.
cps(s: 49. oo Po Arry
loo DUE co
$, oo %i- Fee, Due
(SEAL)
ROT T
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-07241 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SILVER SPRING TOWNSHIP AUTHORI
VS
PROZOIC RAYMOND 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
PROZOIC RAYMOND but was
unable to locate Him in his bailiwick. He therefore returns the
WRIT OF SCIRE FACIAS
the within named DEFENDANT
2 RASPBERRY DR
PROZOIC RAYMOND
NOT FOUND , as to
MECHANICSBURG, PA 17050
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO
SERVE DEFENDANT PRIOR TO EXPIRATION OF WRIT.
Sheriff's Costs: So answers
Docketing 18.00
Service 36.00
Not Found 5.00 R. Th mas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
69.00 JAMES SMITH DIETTERICK CONNELL
01/13/2009
Sworn and Subscribed to before
me this day of
A.D.
all
Z1:
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-07241 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SILVER SPRING TOWNSHIP AUTHORI
VS
PROZOIC RAYMOND ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
CASSELL HARVEY J
but was unable to locate Him
deputized the sheriff of DAUPHIN
in his bailiwick. He therefore
serve the within WRIT OF SCIRE FAC'TAq
County, Pennsylvania, to
On January 13th , 2009 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answers:
Docketing 6.00
Out of County 9.00 <1"
Surcharge 10.00 R.` Thomas Kline
Dep Dauphin County 47.25 Sheriff of Cumberland County
Postage .75
73.00
01/13/2009
JAMES SMITH DIETTERICK CONNELL
Sworn and subscribe to before me
this day of
A. D.
C"?
r
,?•
?.
r-;-
_ _ C?`1 -i
.. - ? 'l1l ?_'. 4
.' ? ?^^#
....;
..,,?
?,?
In The Court of Common Pleas of Cumberland County, Peninsylvabia
Silver Spring Township Authority '
vs.
Raymond Prozoic et al W y1
SERVE: Harvey J. Cassell No. 08-,-9W civil
December 15, Zoos . , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
- , 20 at
o'clock
M. served the
within
upon
at
by handing to
a
and made known to
copy of the original
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this day of , 20
COSTS
SERVICE _
MILEAGE
AFFIDAVIT
County, PA
$
?f#ire of the c*4erf
If
Mary Jane Snyder
Real Estate Depuy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
SILVER SPRING TOWNSHIP
AUTHORITY
VS
HARVEY J CASSELL
Sheriffs Return
No. 2008-T-2589
OTHER COUNTY NO. 08-5139
And now: DECEMBER 24, 2008 at 11:15:00 AM served the within WRIT OF SCIRE
FACIAS upon HARVEY J CASSELL by personally handing to HARVEY J CASSELL 1 true
attested copy of the original WRIT OF SCIRE FACIAS and making known to him/her the
contents thereof at DAUPHIN COUNTY COURTHOUSE FRONT AND MARKET STREETS
HARRISBURG PA 17101
Sworn and subscribed to
before me this 24TH day of December, 2008
A? ?
F NOTP.RIAL SEAL
AR
Y JANE SNYDER, Notary- Publi
Highspire, Dauphin County
M Commission Ex fires Sept 1 2010
So Answers,
Sheriff of Dauah >jn ounty, Pa.
By
d4sz4-L
Deputy Sheriff
Deputy: LISA BRESSLER
Sheriffs Costs: $47.25 12/18/2008
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
Plaintiff,
NO.: 08-5139 MID
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and TYPE OF PLEADING:
HARVEY J. CASSELL,
Defendants.
MOTION FOR SPECIAL
SERVICE PURSUANT TO
Pa.RC.P. 430 AGAINST DEFENDANT,
RAYMOND PROZOIC
FILE ON BEHALF OF:
Silver Spring Township Authority,
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
Scott A. Dietterick, Esquire
PA ID #55650
JAMES, SMITH, DIETTERICK &
CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, ; NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
MOTION FOR SPECIAL SERVICE PURSUANT TO Pa.R.C.P. 430 AGAINST
DEFENDANT, RAYMOND PROZOIC
AND NOW, comes the Plaintiff, Silver Spring Township Authority, by and through its
attorneys, James, Smith, Dietterick & Connelly LLP, and files the within Motion for Special
Service pursuant to Pa.R.C.P. 430 against Defendant, Raymond Prozoic as follows:
1. No other motion has been decided in this case.
2. Plaintiff attempted to obtain concurrence of Defendant, Raymond Prozoic
("Defendant'), with the Motion, but Defendant cannot be located, therefore no concurrence
was obtained.
3. On or about December 10, 2008, Plaintiff filed its original Writ of Scire Facias
("Writ') against the Defendant, at the above-captioned number and term.
2. Plaintiff directed the Sheriff of Cumberland County to serve the Defendant at the
property address, being 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 but service was
returned "Not Found". A true and correct copy of the Sheriff s Return from the Cumberland
County Sheriff s Office is marked Exhibit "A", attached hereto and made a part hereof.
3. A request for confirmation of an alternate address for Defendant was forwarded
by Plaintiffs counsel to the U.S. Postmaster for Mechanicsburg, PA 17050, but no such
information was provided by said postal authorities.
4. An internet person locator search provided no alternative address for Defendant.
5. Plaintiff conducted an investigation to determine the whereabouts of Defendant,
but all sources indicated no alternative address other than that of 2 Raspberry Drive,
Mechanicsburg, Pennsylvania 17050. An affidavit of Plaintiff's counsel regarding the
investigation taken to determine the whereabouts of Defendant is marked Exhibit "B", attached
hereto and made a part hereof.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit
Plaintiff to serve Defendant, Raymond Prozoic, with the Writ of Scire Facias and all future
pleadings, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy
of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing a copy to 2
Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No Signature
Required and First Class U.S. Mail, Postage Prepaid, with said service being, valid and complete
gpon such posting and mailing in accordance with Pa.R.C.P. 430.
Respectfully Submitted:
JAMES, SMl
CONNELLY
By:
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Attorney I.D. #55650
EXHIBIT "A"
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-07241 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SILVER SPRING TOWNSHIP AUTHORI
VS
PROZOIC RAYMOND 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
r?rinrr?-r/`DTVMr%NTn but was
unable to locate Him in his bailiwick. He therefore returns the
...-.rm nr nrT TT 1"'IT /`PTT the within named DEFENDANT
PROZOIC RAYMOND
2 RASPBERRY DR
MECHANICSBURG, PA 17050
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO
SERVE DEFENDANT PRIOR TO EXPIRATION OF WRIT.
Sheriff's Costs: So answers;
Docketing 18.00 -7 ? -_5 .•?'
Service 36.00
Not Found 5.00 R. Th mas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
69.00 JAMES SMITH DIETTERICK CONNELL
01/13/2009
Sworn and Subscribed to before
me this day of ,
NOT FOUND , as to
A. D.
EXHIBIT "B"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized
representative of Plaintiff, who being duly sworn according to law, deposes and says that
Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of
Defendant, which included, but was not limited to searches of the following records:
( ) Records of the U.S. Postmaster with results of same, attached to the foregoing
Motion.
( X ) Internet Person Locator Records, with results of same, attached to the foregoing
Motion.
( ) Voter Registration Records, with results of same, attached to the foregoing
Motion.
( X ) Credit Report Agency.
( X ) Telephone Directory.
( X ) Records of the County Recorder of Deeds and Prothonotary.
Finally, Affidavit deposes and says that if Defendant(s) is/are not located at the address
uncovered by this investigation, the whereabouts of Defendant(s
Sworn to and subscribed before me this
18th day of March 2009.
CkI6 ?i L/lc) c?--
Notary Public
My Commission Expires:
F OTARIAL SEAL
TINE L SPURLOCK
Notary Public
N BORO, DAUPHIN COUNTY
ion Expires Jun 23, 2012
Plaintiff.
W 111W rdge'S - 3WILCnouaruxoni - tceSUILS
® Swi t,chboar Your Digital Directory
,n a
Current & Verified Phone Number & Address found for Raymond Prozoic.
Instant access to the most up-to-date information including Address, Phone Number, Age & More.
www.intelius.com
We did not find any directory results for Raymond Prozoic in MECHANICSBURG, PENNSYLVANIA
C' d Ausiness Find a Person Mans & Directions Search by Phone Area 8 Zip Codes
Public records found for Raymond Prozoic with current & verified Phone & Address
Raymond
r N'-,e C -'y `state
Prozoic mechanicsburg Pennsylvania
C .c; *_Phone and Address Available
RAYMOND PROZOIC Click here to View Details f(,,. RAYMOND PROZO:C.in
{ MECHAN CSBUIRG, PA
1
r:l€sted Phone arld Address Availab!e
RAYMOND PROZOIC Click here to View Details `or RAYMOND PROZO4C in
MECHANiCSBURG,, PA
ied Pi one and Address Available
# RAYMOND PROZOIC i < n to View Deta.ls is RAYMOND PRO. ZOIC in
ME HAN!CSBURG, PA
N n Puloli0e d Plume and Address Available
RAYMONDPROZOIC C , k !)eye to V qn,,? Detail, fier RAYMOND PROZOIC in
MECHANICSBURG_ PA
?,d Phone and Address Available.
RAYMOND PROZOIC =?crc to-View-Details f_q RAYMOND PROZOiC it)
7: ANICSBURG. PA
rage 1 Ul I
Web Search
inTELIUS
Additional Resources
4 Search by Phone Number
-0 UIrg_round Check
Search for Email Address
i Reverse Cell Pho" Directory
Search for Rmfea¦ionat listings
' Search Business Wstirrgs
Try Your Search Again Need Help?
SUGGESTIONS: TRY THESE SPELLINGS:
ri;=t Name Last Name 4 Double check your spelling.
Raymond Prozoic 'f Try Intelius to get premium ¦ RAMON PROZOIC
results. ¦ RAMOND PROZOIC
C;ty State y Expand your search area. ¦ RAMONE PROZOIC
mechanicsburg
Pennsylvania t Search by phone number
Try similar names
inTELIUS
vel:r;.^ rc ,;rlite Pa P< ( es ( F, mess - ,'e^_
I ul .. .?- ! , iPrYl: l'. -.. _. r t C'r+ l1q
(.,. i-} .. <. S,J I.?..All Kicil-ts N,'?P•
http://switchboard. intel ius. comlresults.php?ReportType=34& qc=mechanic sburg&qf--Ray... 3/ l 8/2009
rersoll 3earcrl
raze 1 01 G
24f7 Search and Technical Assistance 1400-543-6862
Main Menu I My Account I Print I Contact Us I Loo Out
Last Name First Name Middle Name SSN
PROZOIC RAYMOND
Street Address City State Zip County Radius
2 RASPBERRY DRIVE MECHANICSBUR, PA 17050
Phone DOB Age Range
? Search for ether possible name spc;itirtgs ? include Bankruptcies
Output Type: 4 Foimatted HTMil- Paste/ Primer xt (No Reports)
Emporant. ne bi Records and co me cats sources used t s system have errors. Data is somet mes
entered pocrly r:roCeS5eC ircorrec y and is ge f CefP(,6 s S:eAuld not be relied upon as dF`inA`vely
accurate Be!o_e .e!yin_ on any data this s°ys.e' shed- be Ender,e { cd_ For Secretary of S ate documents, the
fo'[o,Y nq data for 'nfcr???a':ior purposes er c,!fic!al record. c e t,e., c pies may be obtained from ha l individual
states Deaariment of :Mate
Search completed
Reference Code:
Records: 1 to 14 of 14
SEARCH: Last Name: PROZOIC First Name: RAYMOND Street: 2 RASPBERRY DRIVE City: MECHANICSBURG State: PA Zip: 17050 Edit Search I Now Search
+. All Full Name SSN Address Phone Information
RAYMOND POZOIC JR 186 a8•torxx 2 RASPBERRY DR
7050
2792 • Relatives
• Neighbors
N Gender: Male e -
MECHANICSBURG PA 1
OW Dec 06 - Feb 09 • Associates
• Relatives,
Neighbors
Associates
• People at
Work
®r RAYMOND GRAT POZO? JR188 66-tDOrx 2 RASPBERRY DR • Relatives
4
?i Gender: Male MECHANICSBURG PA 17050-2792 • Neighbors
Jun 89 - Feb 09 • Associates
SME or--,- PAN
V
'to
VT V
s I WO
RAYMOND D POZOIC JR 186-86-xm 334 S CATHERINE ST
Gender. Male MIDDLETOWN PA 17057-1317
Jun 05 - Jan 09
RAYMOND GRAT POZOIC JR186-56-xxxx 334 S CATHERINE ST
Gender. Male MIDDLETOWN PA 17057-1317
Jun 05 - Jan 09
RAYMOND D POZOIC JR 18646-x)= 110 CEDAR HILL DR
Gender. Male DOVER PA 17315.1661
Apr 98 - Jan 08
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
Associates
• People at
https://secure.accurint.com/appibps/main 3/18/2009
rage /-01
rersun ?earcn
1 RAYMOND GRAT POZOIC JR188416 -oaex
L Gender: Male
DOB:
01/xX11969 (40)
ng
Ij RAYMOND POZAIC
Gender: Male 202 88-nacx
Irb RAYMOND PAZOIC JR
Gender: Male 188-f8aooor
RAYMOND PAZOIC JR 186 88-xtocx
Gender: Male
s W ? cm RAYMOND PAZOIC JR 186-86aooor
Gender: Mate
m qp ? IN RAYMOND D POZOIC JR 186-68-xxxx
Gander: Male COW `i__1
%z*1b
_ar" olbRAYMOND GRAT POZOIC JR186-86-mom
Gender. Male
RAYMOND PAZOIC JR 186.56-xxxx
Gender. Male
RAY GRANT POZOIC JR 186-6-xxxx
Gender. Male
110 CEDAR HILL DR
DOVER PA 17315-1661
Jan 98 - Jan 08
PO BOX 934
MECHANICSBURG PA 17055-8934
Dec 06 - Dec 07
2 RASPBERRY DR
MECHANICSBURG PA 17050.2792
Oct 07
110 CEDAR HILL DR
DOVER PA 17315-1661
Nov 98 - Aug 07
334 S CATHERINE ST
MIDDLETOWN PA 17057-1317
Jun 05 - Dec 06
1820 PAXTON CHURCH RD
HARRISBURG PA 17110-9677
Oct 95
1820 PAXTON CHURCH RD
HARRISBURG PA 17110-9677
Oct 95
1820 PAXTON CHURCH RD
HARRISBURG PA 17110.9677
Oct 95
132 W BROADWAY
RED LION PA 17356-2104
717-545-8647 - EDT
717-545-8647 - EDT
Records: 1 to 14 of 14
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
• Relatives
• Neighbors
• Associates
• Relatives,
Neighbors
8
Associates
• People at
Work
SEARCH: Last Name: PROZOIC First Name: RAYMOND Street: 2 RASPBERRY DRIVE City: MECHANICSBURG State: PA Zip: 17050 Edit Search New Search
Your DPPA Permisslble Us*: Civil, Criminal, Administrative or AdAral Proceedings
Your GLRA Permisslble Use: Persons Holding a Legal or Beneficial Interest Relating to the Consumer
https-//secure.accurint.com/app/bps/main 3/18/2009
r.>
{? ,'_7
:?
:a
_,
+.?
:?T:
.-?-?
??
'
-?- `
s
~..
,
;:'"?
c,.
,
.?:. ,?; ,
MAR 2 0 2009
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
ORDER OF COURT
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
AND NOW, this ' day of /a 2008, upon consideration
of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
4
BY THE OURT:
J.
r
T
.
l ?
?
?
L
„?-
?
V
? ?
,
A '
-+I
+
ty
? ? C? ?., ??.'r
,
P
,
??„'? ? ''y
?
?
1 ..+
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
NO.: 08-5139 MLD /
Plaintiff, 08-7241 CIVIL TERM •/
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
PRAECIPE TO REISSUE WRIT OF SCIRE FACIAS
TO THE PROTHONOTARY:
Please mark the Writ of Scire Facias filed at the above-captioned
term and number reissued.
submitted,
JAMES, SMITE, $ ETTARICK & CONNELLY LLP
BY:
Scott A. Dietterick, Esquire
PA I.D. # 55650
Kimberly A. Bonner, Esquire
PA I.D #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
CF)
FI
OF THE '. r '-l")T,ARY
* 10. o o P O ATt7/
CLIF '7 55'79
M*
Sheriffs Office of Cumberland County
R Thomas Kline IV pt cumbe Edward L Schorpp
Sheriffs Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/2712009 09:19 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
27, 2009 at 2119 hours, he served a true copy of the within Writ of Scire Facias, upon the within named
defendant, to wit: Raymond Prozoic pursuant to Order of Court by posting the premises located at 2
Rasberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050, with a true and correct copy
of the same according to law.
SHERIFF COST: $43.00 SO ANSWERS,
April 28, 2009 R THO K N SHERIFF
De y Sheriff
Docket No. 2008-7241
Silver Spring Township Authority v Raymond Prozoic
CD
l rU ",
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
ISSUE NO.:
TYPE OF PLEADING:
AFFIDAVIT OF SERVICE OF
Defendants. WRIT OF SCIRE FACIAS PURSUANT TO
Pa.R.C.P., 430 SPECIAL ORDER
OF COURT
CODE:
FILED ON BEHALF OF:
Silver Spring Township Authority,
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
Scott A. Dietterick, Esquire
PA I.D. # 55650
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
(71) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS ON DEFENDANT,
RAYMOND PROZOIC, PURSUANT TO ORDER OF COURT
I, Scott A. Dietterick, Esquire, attorney for Plaintiff, Silver Spring Township Authority,
being duly sworn according to law depose and make the following Affidavit regarding the
service of Plaintiff's Writ of Scire Facias on Defendants, as follows:
1. On or about April 17, 2008, an Order of Court was entered granting Plaintiff's
Motion for Service of Writ of Scire Facias Pursuant to Special Order of Court. A true and
correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof.
2. Pursuant to said Order, on or about May 8, 2009, the counsel for Plaintiff served
Defendant, Raymond Prozoic, with a true and correct copy of Plaintiff's Writ of Scire Facias, via
First Class U.S. Mail and Certified Mail, Return Receipt Requested, No Signature Required to
the defendant's last known address being 2 Raspberry Drive, Mechanicsburg, Pennsylvania
17050. A true and correct copy of the Certified Mail Receipt and Certificate of Mailing are
marked Exhibit "B", attached hereto and made a part hereof.
3. Pursuant to said Order, on or about April 27, 2009, the Sheriff of Cumberland County
posted the property, being 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 with a true
and correct copy of Plaintiff s Writ of Scire Facias. A true and correct copy of the Sheriff s
Return from the Cumberland County Sheriff is marked Exhibit "C", attached hereto and made a
part hereof.
Respectfully submitted,
JAMES SMITHiDIETiTERICK & CONNELLY LLP
DATED: U I I L-1 I C) BY:
Sworn to and subscribed before
Attorneys for Pldini
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
me this 14th day of August 2009.
On ?"aAL?. spvooc'?-
Notary Public
MY COMMISSION EXPIRES:
NOTARIAL SEAL
CHRISTINE L SPURLOCK
Notary Public
HUMMELSTOWN BORO, DAUPHIN COUNTY
My Commission Expires Jun 23, 2012
Esquire
EXHIBIT "A"
MAR 2 0 200
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
ORDER OF COURT
AND NOW, this day of , 2008, upon consideration
of Plaintiff s Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
BY THE OURT:
S .
J.
EXHIBIT "B"
UNrrMSTATES
!SERVKEe Certificate of N
TY
Tt
F' LAW OFFICE
?,JAMES, SMITH, DIETTERICK &
I CONNELLY LLP
P.O. BOX 650
HERSHEY, PA 17033
6 r
0 6.
°JHasler
a4-'s `:.
J!! 0
o ?
'?<a Q
m cr,
PS Form 3817, April 2007 PSN
co
u7
ra
f?-
rA Postage
,l Receipt Fee
( rsement
p Restricted Delivery Fee
(Endorsement Required)
C3
m Tot ostage & Fees
rq 03
O Srtreet Apf ! w
p or PO Box o? . 1
C`- re,. Smr?1 ?rwen ,
I
rtif'red Fee
ecept Fee
Required)
A
EXHIBIT "C"
S.-.riff s Office of Cumberland County
R Thomas Kline 4t?t4? of cusnhct?f? Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy c`=` yr rF a s"`??F Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/2712009 09:19 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
27, 2009 at 2119 hours, he served a true copy of the within Writ of Scire Facias, upon the within named
defendant, to wit: Raymond Prozoic pursuant to Order of Court by posting the premises located at 2
Rasberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050, with a true and correct copy
of the same according to law.
SHERIFF COST: $43.00
April 28, 2009
F
Docket No. 2008-7241
Silver Spring Township Authority v Raymond Prozoic
SO ANSWER, ?
FILED-OFFICE
OF THE PFtOTHON TARY
2009 AUG 18 Ali 9: 08
rN tSyL rt;':koe
t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
No.: 08-7241 Civil Term v/
No.: 08-5139 MLD
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Municipal Lien)
Defendants.
I Hereby certify that the last known
address of Defendant(s) is/are:
Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
616prgford Drive, Apt. C-6
Ha isbu , PA 17111
FILED ON BEHALF OF:
Silver Spring Township Authority,
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
---? JAMES, SMITH, DIETTERICK & CONNELLY, LLP
Pa. I.D. #55650
ff P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Raymond Prozoic and Harvey J. Cassell, in the amount of $5,260.77,
which is itemized as follows:
Arrears through 3'a Quarter 2009 $ 1,241.55
Penalties through July 17, 2009 $ 144.22
Attorneys' Fees $ 3,465.00
Title Costs 410.00
TOTAL CLAIM $ 5,260.77
plus interest, penalties, and Quarterly bills after the 3`d Quarter 2009, and additional attorneys'
fees and costs reasonable and actually incurred.
JAMES, S , DIq ERICK &
CONNELLY„ ,/
By:
, E
Scott A. D'etteri
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
aotfitt laf the 'Iq?hvrfff
Mary Jane Snyder
Real Estate Depu
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
SILVER SPRING TOWNSHIP
AUTHORITY
VS
HARVEY J CASSELL
Sheriff s Return
No. 2008-T-2589
OTHER COUNTY NO. 08-5139
And now: DECEMBER 24, 2008 at 11:15:00 AM served the within WRIT OF SCIRE
FACIAS upon HARVEY J CASSELL by personally handing to HARVEY J CASSELL 1 true
attested copy of the original WRIT OF SCIRE FACIAS and making known to him/her the
contents thereof at DAUPHIN COUNTY COURTHOUSE FRONT AND MARKET STREETS
HARRISBURG PA 17101
Sworn and subscribed to
before me this 24TH day of December, 2008
'A!?
NOTARIAL SEAL
ARY JANE SNYDER, Notary Publi
Highspire, Dauphin County
[My Commission Ex fires Se t I, 2010
So Answers,
Sheriff of Dauphin:County, Pa.
By ?..
Deputy Sheriff
Deputy: LISA BRESSLER
Sheriffs Costs: $47.25 12/18/2008
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
IMPORTANT NOTICE
TO: Harvey J. Cassell
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
DATE OF NOTICE: May 28, 2009
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 NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
AVISO IMPORTANTE
A. Harvey J. Cassell
FECHA DEL AVISO: May 28, 2009
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
JAMES SMITV ?IE7RICK & CONNELLY LLP
DATE: May 28, 2009 BY:
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
,p,Ot A.`gietterick, Esquire
S
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
IMPORTANT NOTICE
TO: Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
DATE OF NOTICE: May 28, 2009
NO.: 08-5139 MLD
08-7241 CIVIL TERM
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 NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
AVISO IMPORTANTE
A. Raymond Prozoic
FECHA DEL AVISO: May 28, 2009
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENDS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
- (800) 990-9108
JAMES S ITH DI ERI & CONNELLY LLP
DATE: May 28, 2009 BY:
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
Scott A. Dietterick, Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
Plaintiff,
ISSUE NO.:
VS.
TYPE OF PLEADING:
RAYMOND PROZOIC and
HARVEY J. CASSELL,
AFFIDAVIT OF SERVICE OF
Defendants. WRIT OF SCIRE FACIAS PURSUANT TO
Pa.R.C.P., 430 SPECIAL ORDER
OF COURT
CODE:
FILED ON BEHALF OF:
Silver Spring Township Authority,
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
Scott A. Dietterick, Esquire
PA I.D. # 55650
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
(71) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS ON DEFENDANT,
RAYMOND PROZOIC, PURSUANT TO ORDER OF COURT
I, Scott A. Dietterick, Esquire, attorney for Plaintiff, Silver Spring Township Authority,
being duly sworn according to law depose and make the following Affidavit regarding the
service of Plaintiff's Writ of Scire Facias on Defendants, as follows:
1. On or about April 17, 2008, an Order of Court was entered granting Plaintiff s
Motion for Service of Writ of Scire Facias Pursuant to Special Order of Court. A true and
correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof.
2. Pursuant to said Order, on or about May 8, 2009, the counsel for Plaintiff served
Defendant, Raymond Prozoic, with a true and correct copy of Plaintiffs Writ of Scire Facias, via
First Class U.S. Mail and Certified Mail, Return Receipt Requested, No Signature Required to
the defendant's last known address being 2 Raspberry Drive, Mechanicsburg, Pennsylvania
17050. A true and correct copy of the Certified Mail Receipt and Certificate of Mailing are
marked Exhibit "B", attached hereto and made a part hereof.
3. Pursuant to said Order, on or about April 27, 2009, the Sheriff of Cumberland County
posted the property, being 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 with a true
and correct copy of Plaintiff s Writ of Scire Facias. A true and correct copy of the Sheriff s
Return from the Cumberland County Sheriff is marked Exhibit "C", attached hereto and made a
part hereof.
Respectfully submitted,
JAMES SMITIIDIET4ERICK & CONNELLY LLP
DATED: U 11 L-1 ? C) q BY:
Esquire
Attorneys for Mini
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Sworn to and subscribed before
me this 14`h day of August 2009.
('Ai /6 Sls' iA L SPo-J0L-V-
Notary Public
MY COMMISSION EXPIRES:
NOTARIAL SEAL
CHRISTINE L SPURLOCK
Notary Public
HUMMELSTOWN BORO, DAUPHIN COUNTY
My Commission Expires Jun 23, 2012
EXHIBIT "A"
MAR 2 0 200q?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
ORDER OF COURT
AND NOW this day of y rw?k
, 2008, upon consideration
4R
of Plaintiffs Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa R C P 430.
BY THE IOURT-
J.
EXHIBIT "B"
AIL U.,?,rs
lal5 cr
UNr7EDSTATES
POSTdLSiERVICE® Certificate Of N
Tr
TI
F, LAW OFFICE
.JAMES, SMITH, DIETTERICK &
I CONNELLY LLP
P.O. BOX 650
HERSHEY, PA 17033
::-)
PS Form 3817, April 2007 PSN
€rt"' i
?! _y I`'
C)
°J
S
`x
c 10
,a r
U.S. Postal Service
CERTIFIED MAIL_ RECEIPT
-? (Domestic Mail Only; No Insurance Coverage Provided)
information visit our website at www.usps.com,
IFS
Mir 3WTV
r-
rq
m Receipt Fee
( rsement Required)
Fee
C3 Restricted
(Endorsement Required)
O
C3
M
0
0
N
is
c?
cD
to
A
EXHIBIT "C"
S.: riff s Office of Cumberland County
R Thomas Kline ?,}tta rfat.rir7Fr Edward L Schorpp
Sher Solicitor
Ronny R Anderson = Jody S Smith
Chief Deputy IFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/27/2009 09:19 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
27, 2009 at 2119 hours, he served a true copy of the within Writ of Scire Facias, upon the within named
defendant, to wit: Raymond Prozoic pursuant to Order of Court by posting the premises located at 2
Rasberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050, with a true and correct copy
of the same according to law.
SHERIFF COST: $43.00
SO ANSWER.,,-
April 28, 2009
R THO N K?NE? SHERIFF
y- Sher
Docket No. 2008-7241
Silver Spring Township Authority v Raymond Prozoic
FILED-OFFICE
OF THE ? 0TA&
200 AUG 18 AM 9: 08
N, rly
+Woo Po ATM
rn its
? aa?3a?
fJo?k.ee, wax"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
Vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Raymond Prozoic
( ) Plaintiff
(X) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on l8+4 52009.
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $5,260.77
plus interest, penalties, and Quarterly bills after the 3d Quarter of 2009, plus additional
attorneys' fees and costs reasonable and actually incurred and for foreclosure and sale of the
Premises.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants. :
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Harvey J. Cassell
( ) Plaintiff
(X) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on SR`N` 12009.
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $5,260.77
plus interest, penalties, and Quarterly bills after the 3'd Quarter of 2009, plus additional
attorneys' fees and costs reasonable and actually incurred and for foreclosure and sale of the
Premises.
thonotary
IN THE COURT OF COMMON PLEAS OF CiMB XAND COUNTY, PENNSYLVANIA
Silver Spring Township CIVIL DIVISION
Authority : File No. 08-5139 MLD / 08-7241 Civil Term
v
Raymond Prozoic and Harvey J.
Cassell
(Plaintiff)
( Defendant (s )
TO THE PROTHONOTARY OF THE SAID COURT:
Amount Due $ 5,260.77
Interest from to $
date of sa e
: Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s)
See Exhibit "A" attached.
PRAEr= FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custod or control of the
said garnishee(s). A-- ?
(Indicate) Index this writ against the garnish (s as s pendens against
real estate of the defendant(s) described in the attached it. ---?
DATE: August 14, 2009 Signature-._
Print Name:
Address: James Smith Dietterick & Connelly LLP
P O Box 650, Hershey PA 17033
Attorney for:
Telephone:
Plaintiff
(717) 533-3280
Supreme Court ID No.: 55650
RD-WCE
OF THE (3TARY
20D9 AUG IS AM 9: U8
tJJ JNTY
rENtv5>`1 VA:NA
* ol4 . oo PD ATT{
1q. oo CBF
(A . 00 ?
'73.Oo «
q3.00
aq. 00
10-00
'
Woo "
01-SO
N
PO Arty
$ 8.oo bLv-- SA-' FEE"
*j/.oo Qvpsov
5o U-
Zi E c.at?t jjjj4.uj
s A.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date
the Praecipe for Writ of Execution was filed the following information concerning the real
property located at 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050:
1. Name and Address of Owner(s) or Reputed Owner(s):
RAYMOND PROZOIC 2 Raspberry Drive
Mechanicsburg, PA 17050
HARVEY J. CASSELL 6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
2. Name and Address of Defendant(s) in the Judgment:
RAYMOND PROZOIC 2 Raspberry Drive
Mechanicsburg, PA 17050
HARVEY J. CASSELL 6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
3. Name and Address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
SILVER SPRING TOWNSHIP AUTHORITY Plaintiff
4a
PENN WASTE, INC.
GMAC, LLC
RYAN HOSPODAVIS
EMC MORTGAGE CORPORATION
88 Brickyard Road
York, PA 17402
480 Jefferson Blvd, RJE 350
Warwick, RI 02886
and
c/o Michael J. Dougherty
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
6420 Gallop Road
Harrisburg, PA 17111
800 State Highway
121 Bypass
Lewisville, TX 75067
and
c/o Gregory Javardian
1310 Industrial Boulevard, I' Floor
Suite 101
Southampton, PA 18966
4. Name and Address of the last record holder of every mortgage of record:
EMC MORTGAGE CORP 800 State Highway
121 Bypass
Lewisville, TX 75067
MERS NOMINEE FOR EQUIFIRST CORP 500 Forest Point Circle
Charlotte, NC 28273
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY 'TAX CLAIM BUREAU Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
DEPARTMENT OF REVENUE
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
46
COMMONWEALTH OF PA
CURRENT OCCUPANTS/TENANTS
UNKNOWN SPOUSE OF RAYMOND PROZOIC
UNKNOWN SPOUSE OF HARVEY J. CASSELL
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
2 Raspberry Drive
Mechanicsburg, PA 17050
2 Raspberry Drive
Mechanicsburg, PA 17050
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
7. Name and Address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
JAMES,
DATED: 1 ILI
I oq--
BY:
& CONNELLY, LLP
Esquire
Pa. I.D`ft55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
RLED-O F
t)F THE PRIOTHO?T'AW
2909 AUG 18 AM g: 08
curhl,_ u a L?Un
PENNSYLVAN A
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
I
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
0
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, IffiEATERICK & CONNELLY, LLP
DATED: (? I I L-1 I0 _ 1 BY:
Scott. Iytteric?Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA ORDER OF COURT
OF
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. If
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
MAR 2 0 200q
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
ORDER OF COURT
AND NOW, this day of 2"'1 , 2008, upon consideration
of Plaintiff s Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
BY THE OURT:
s I 2,Q If n'12
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Harvey J. Cassell
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
w
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
If,
THE LEGAI, RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, I?IET/TVRICK & CONNELLY, LLP
DATED: Ym)ch BY:
Scott M. EWterick, N
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED AND
PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF VIA
DEPUTIZING THE SHERIFF OF DAUPHIN COUNTY
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7241 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff (s)
From RAYMOND PROZOIC and HARVEY J. CASSELL
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $5,260.77
Interest
Atty's Comm %
Atty Paid $46.5. 50
Plaintiff Paid
Date: 8/18/09
(Seal)
REQUESTING PARTY:
L.L. $.50
Due Prothy $4.00
Other Costs : 3A'r FEE DUE A-00
1171"A ?0?
urtis R. Long, Pro notary
By:
Deputy
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY LLP
PO BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
f ?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP CIVIL DIVISION
AUTHORITY,
Plaintiff, NO.: 08-5139 MLD
NO.: 08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants
ISSUE NO.:
TYPE OF PLEADING:
Pa.R.C.P. RULE 3129.2(C)
AFFIDAVIT OF SERVICE OF
DEFENDANTS/OWNERS AND
OTHER PARTIES OF INTEREST
CODE:
FILED ON BEHALF OF:
Silver Spring Township Authority,
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
JAMES, SMITH, DIETTERICK &
CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
Pa.R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE OF
DEFENDANTS/OWNERS AND OTHER PARTIES OF INTEREST
I, Scott A. Dietterick, Esquire, attorney for Silver Spring Township Authority, Plaintiff,
being duly sworn according to law depose and make the following Affidavit regarding service of
Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendants/Owners and
Other Parties of Interest as follows:
1. Defendants, Raymond Prozoic and Harvey J. Cassell, are the record owners of the
real property.
2. Per Order of Court, dated April 17, 2008, on or about September 25, 2009,
Defendant, Raymond Prozoic, was served with Plaintiffs Notice of Sheriffs Sale of Real
Property Pursuant to Pa.R.C.P. 3129, via POSTING by the Sheriff of Cumberland County, at 2
Raspberry Drive, Mechanicsburg, Pennsylvania 17050. A true and correct copy of said Order,
Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof.
3. Per Order of Court, dated April 17, 2008, on or about August 24, 2009,
Defendant, Raymond Prozoic, was served with Plaintiff's Notice of Sheriff's Sale of Real
Property Pursuant to Pa.R.C.P. 3129, via Certified Mail, Return Receipt Requested, No Signature
Required and First Class U.S. Mail, Postage Prepaid at the address of 2 Raspberry Drive,
Mechanicsburg, Pennsylvania 17050. A true and correct copy of the Certified Mail Receipt and
Certificate of Mailing are marked Exhibit "B", attached hereto and made a part hereof.
4. On or about, October 1, 2009, Defendant, Harvey J. Cassell, was served with
Plaintiff's Notice of Sheriff s Sale of Real Property Pursuant to Pa.R.C.P. 3129, personally by
the Sheriff of Cumberland County deputizing the Sheriff of Dauphin County at the address of
6160 Springford Drive, Apt C6, Harrisburg, Pennsylvania 17111. A true and correct copy of said
Notice and Sheriff s Return are marked Exhibit "C", attached hereto and made a part hereof.
5. On or about September 4, 2009, Plaintiffs counsel served all other parties in
interest with Plaintiff's Notice of Sheriff s Sale according to Plaintiff's Affidavit Pursuant to
Rule 3129. 1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and
correct copies of said Notices and Certificates of Mailing are marked Exhibit "D", attached
hereto and made a part hereof.
r
Finally, the undersigned deposes and says that Defendants/Owners and all Other Parties
of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance
with Pa. R.C.P. 3129.2.
JAMES, SWTH, DA TERICK & CONNELLY LLP
Dated: October 28, 2009 BY
Sworn to and subscribed before me this
28?h day of October, 2009.
0y\ vdo?-?
Notary Public
MY COMMISSION EXPIRES:
TINE L SPURLOCK
EHUMMELSTOWN OTARIAL SEAL
Notary Public
BORO, DAUPHIN COUNTY
ion Expires Jun 23.2012
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
EXHIBIT "A"
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
FIG ,;F?H 5r cF.iFF
OF
Silver Spring Township Authority
vs.
Raymond Prozoic
Case Number
2008-7241
SHERIFF'S RETURN OF SERVICE
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the
above entitled action, upon the property of Paymond Prozoic & Harvey J. Clouser, located at 2 Raspberry
Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law.
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Raymond Prozoic, located at 2
Raspberry Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law
10/1512009 R. Thomas Kline, Sheriff who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Harvey J. Cassell, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real
Estate Writ, Notice of Sale and Description according to law.
Dauphin County Return and now the, 1 st day of October 2009, served the within Real Estate Writ, Notice
of Sale and Description upon Harvey J. Cassell, the defendant, by making known unto Harvey J. Cassell
at 6160 Springford Drive, Apt C6, Harrisburg, Pennsylvania its contents and at the same time handing to
him a true and correct copy of the same. So Answers: J.R. Lotwick, Sheriff of Dauphin County,
Pennsylvania.
,MAR 2 0 200Q
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
ORDER OF COURT
AND NOW, this day of , 2008, upon consideration
of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
BY THE OURT:
s
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, IffiEATERICK & CONNELLY, LLP
DATED: 0 t I L-1 `y 9 BY:
Scott/4,. lpytteric\Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA ORDER OF COURT
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an are distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
EXHIBIT "B"
v
JAMES, SMITH, DIETTE
CONNELLY LLP Hasler
AYIN: CHRIS SPURLOC
P.O. BOX 650
Pl 17033 -,
HERSHEY
'EJ$
(/J
.
,
.?
To. ?,
CD
/ co y --.& to
i D -i
C}1
n
/ T) G { (Z) O
M Q
uM_
?pps?( TERVIICE• Certificate Of AN
This Certificate of Mailing provides avidence that mail has been presented to USPS® for it
This form may be used for domestic: and international mail. ?pp..
From ?',tv."Form 3817, April 2007 PSN 7532-000-70 O
(77 t[?Ir7?t7lyallllt rr?•
O
ra
r) Postage
tU
? fled Fee
r'] \. `gRecelpt Fee
C3
O
(Endorsement Required)
M Restricted Delivery Fee
(Endorsement Required)
0
0
m Tot Postage & Fees
rq
0
co
o -- --. --------
E3 or
J Postmark .
` Here
EXHIBIT "C"
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff Y?ytitr oq ?"attuti? f?r'td
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant F`?cE aF '4
Edward L Schorpp
Solicitor
Silver Spring Township Authority Case Number
vs.
Raymond Prozoic 2008-7241
SHERIFF'S RETURN OF SERVICE
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the
above entitled action, upon the property of Paymond Prozoic & Harvey J. Clouser, located at 2 Raspberry
Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law.
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Raymond Prozoic, located at 2
Raspberry Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law
10/15/2009 R. Thomas Kline, Sheriff who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Harvey J. Cassell, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real
Estate Writ, Notice of Sale and Description according to law.
Dauphin County Return and now the, 1 st day of October 2009, served the within Real Estate Writ, Notice
of Sale and Description upon Harvey J. Cassell, the defendant, by making known unto Harvey J. Cassell
at 6160 Springford Drive, Apt C6, Harrisburg, Pennsylvania its contents and at the same time handing to
him a true and correct copy of the same. So Answers: J.R. Lotwick, Sheriff of Dauphin County,
Pennsylvania.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Harvey J. Cassell
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, PIETITFRICK & CONNELLY, LLP
DATED: (? I IL-() DCI BY:
Scott A' I i9fterick, Rs
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED AND
PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF VIA
DEPUTIZING THE SHERIFF OF DAUPHIN COUNTY
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an are distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
EXHIBIT "D"
-n
V
r ;g
0
CF)
z
7
i$
a
A?
O(? ZIH
Ffziz CsJt?"
`.tikr?n Cr"d
ro
..- ? .ro tr ?"I
J O ?
O ? b Cy
W
V
C o
^
Z
v
Z
V
O
0
N
0
0
4
0
M 5
39VJ(SOci SO
3
W
P01ST111:SERME• Certificate Of Mk
Th,S Certificate of Mailinq provides evidence that mail has been presented to USPS®for
hr and infornational mail.
From
...•„
JAMES, SMITH, DIETTE
CONNELLY LLPF&
x_
A'ITN: CHRIS SPURIA s '
P.O. BOX 650
HERSHEPA 1703
To.
•
r _ t
g P
sa. .?
33
a
m?
?m
m3
a
I I I
Z O in
SOd SS
r Ja
aN
t ?m
3?
ZZ
y im
m
rPf ? r
.? a
ro
0
3m
h
"
'
o
o ?C
r1)
?I
w
a
7'C G=? a
?i
a?
•
PS =orm 38'7, April 2007 ( PpSN'7530-02-000-9065
L uu ? V
M?
id;i fier
car =s ?,
M
UANTW SM7W
APOSMSERWICE• Certificate Of Ma
This Certificate of Mailing provides evidence that mail has been presented to USPO for %
This form may be used for domestic and international mail
From
JAMES, SMITH, DIETT??&I
CONNELLY L
ATI'N: CHRIS SPUR Hasler
_ P.O. BOX 65 `'
To: HERSHEY, PA 170?? m d3 {,
?. u3
.n tn pro Lt-c- C)
a, Fv
012
? ? 2n
P Form 3817, April 2007 PSN 7530-02-000-9069'
UNITEDS7=
_ POS ALSERIiii E• Certificate Of Nia
This certificate of Meiling provides evidence that mail has been presented to USPS®forr
I hls rorm may be used for domestic and international mail. l
From:
JAMES, SMITH, DIETTE
CONNELLY LLP
ATTN: CHRIS SPURL0fN Hasler
Ih 71tv
P.O. BOX 650
To: HERSHEY, PA 170 C ?
d1) m
F3
O o
,..A 0
j 0
PO C,
C
/I A ca
1f1'1 CSC
PS Forms 5
??WZL'`1? l?loh
3
V
x a QO
rn 5nv,
?xox zy
>V r d
o??ro???
A
N
3? I?
3Ia
no
nj •
m3
m
3N
n
a
s ?
se O
? v V
d iSCid S n
Ci _ _7 lli6l Dal1e;
3
V
j o
Z `(poi
V ?
fh
W
0
N
P
_o
i
O
1 I I I T S
? gym'
3 a.
c
x a ? on°
Nm
?
•
? b 0 ? nm
xo? z
y m?
?
y??yy
ro W o
3
nd
c
>
?
3N
...,.n
iL1d" o
f [
SP C
O
}
n 1"
j a
f
V
}
161
UNrrEDSMM
POSM• 11? i -? "`:, %,
Certificate Of Mai
?
This 'artificate of Mailing provides evidence that mail has been presented to USPS®forn
This 'orm may he used lot domestic and international mail F
m
?
Fron
r
w
JAMES, SMITH, DIETTERICK & '
CONNELLY LLP
ATIN: CHRIS SPURLOCIC '',
P.O. BOX 650
- HERSHEY
PA
70
,
1
To: ,7
Y?C a /Z ? ? CSI
l3tu ? I
PS Form 0 /
P U ZvL` C/ l rg
",j",'w
UANTIEDSTAM ? .• E
PCUMSERYKE• Certificate Of F&
This Certificate of Mailing provides evidence that mail has been presented to USPSa forn ""I•';
This form may be used for domestic and international mail.
From: ?•
_ JAMES, SMITH, DIETTERICK
CONNELLY LLPL.' Hasler
ATTN: CHRIS SPURWC 1
P.O. BOX 650,,. C A
To: HERSHEY, PA 13? cn {
?. ...? ?:
8bD
G7 0
12-1
(III
1(yy,77 ran, 771
PS Form 381 , April 2007 PSN 7530-02-000-9065
? ??? ZU t ? / vVVIIIYYY/
UNIrEDSMITES
POSTAL• Certificate Of Mai
The Cemficate of Mailing provides evidence that mail has been presented to USPO forn
Th'.s form maybe used for domestic and international mail
From:
JAMES, SMITH, DIETTERIC.K &z
CONNELLY LLP- ,',? : ", r
ATTN: CHRIS SPURLPP HdSlht
_ P.O. BOX 650
To 9'?3 C
To. HERSHEY, PA I
r cn _: 3 c 7
L ,
r?
f L 0 D
?"? 0
At, 4 ?ry
_"} 10/ ? >
G7 ?; I C?
Q) &p
PS =orm 3817, April 2007 S
r UiWTEDSTATES r
?POSTALSERVICE• Certificate Of Mai
Thls Certificate of Mailing or ides evidence that mail has been presented to USPS® for in
o e N This form may be used for domestic and international mail.
%
3 ° m From ??tl•
\ > '9!
® e JAMES, SMITH, DIETTERICK & -.ak's;
CONNELLY LLP
p ATIN: CHRIS SPURLOCK Hasler
P.O. BOX 650
n o x a HERSHEY A 17033 C3
CD T
n=
C1 Z ?'3 3s
O
d dm
'
`ty
cn r
C m
,
m
W ?.
A c-_
(lo
F F
4 0 G)
PJ
a
071-1 -, U7 ? ?? cxi
U1 J
' 6./ A C?
4- ??( Q I -:? EIE! 4-
/ Whc 1 Q W
?f d'
PS Form 3817, April 2001 PSN 7530-02-000-9065
ZV
M C-
UN/TEDSTATO • •?
OSTdCSERVKE• • Certificate Of Mai r
This Certificate of Mailing provides evidence that mail has been presented to USPSM torn
This form may be used for domestic and intemational mail.
From:
JAMES, SMITH, DIETTERICK &
CONNELLY LLP Hasler
ATM CHRIS SPURLOCK
P.O. BOX 650
To: HERSIJEy, PA 17033y ?- ==
C,
007
n'PSN 7530-0 6wu-auoo
17, April l22
P Form 388
1
jj
)
n
3 g UNnwsmTfs
apel5 L SIERVi Certificate Of Mai
?° n • This Certificate of Mailing Provides evidence that mail has been presented to USPSm for n
This orm maybe used for domestic and international maB.
d? From
3 SMITH, DIETTERICK &
JAMES
,
CONNELLY LLP
m n ATI'N: CHRIS SPURLOCK ,
P.O. BOX 650
033
PA 17
Y,
HER
,
c joa
0 n
n
zy
co?rxI..1
?y?ro rd
Y ° ? r y
°
w .yh
v;?Y
zip
?r
P Form 17, April 200
I(?.? 7-t} t G
0
Cy 4? A
+? ca I0 c.7
M rn
r
Hasler
CP " } >
+
V 9't
o c . iw P'J
'
' Cr)
9
f
i ?
?SD
_` `
Q 99V ISOd Sn
`? y'" yi ° y 1tin1d .L981i?9w<i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: PENN WASTE, INC.
88 Brickyard Road
York, PA 17402
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIETTERICK &
CONNELLY LLP
Dated: September 4, 2009
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: GMAC, LLC
480 Jefferson Boulevard, RJE 350
Warwick, RI 02886
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland. County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIETTERICK &
CONNEL Y LLPl
Dated: September 4, 2009 By: V I -k-/
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: GMAC, LLC
c/o Michael J. Dougherty
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH DIETTERICK &
CONNELRY 6Y
Dated: September 4, 2009 By:
Sco . Dietterick,
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: RYAN HOSPODAVIS
6420 Gallop Road
Harrisburg, PA 17111
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DIETTERICK &
Y
Dated: September 4, 2009 By: / l/
Se (K6,. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO. Pa.R.C.P. 3129(b)
TO: EMC MORTGAGE CORPORATION
800 State Highway
121 Bypass
Lewisville, TX 75067
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES SMITH, DIETTERICK &
CONNXLYXLV
Dated: September 4, 2009 Byk / V--? V
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: EMC MORTGAGE CORPORATION
c/o Gregory Javardian
1310 Industrial Boulevard, 1St Floor, Suite 101
Southampton, PA 18966
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES,MI DIETTERICK &
CONNE L LL
Dated: September 4, 2009 By: /11 V
Scott A nck, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. If
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champs S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
NO.: 08-5139 MLD
08-7241 CIVIL TERM
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: EMC MORTGAGE CORP
800 State Highway
121 Bypass
Lewisville, TX 75067
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITtl,,DIETTERICK &
Y
Dated: September 4, 2009 By: V
Sco A. , Esquire
PA ID # 5650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: MERS NOMINEE FOR EQUIFIRST CORP
500 Forest Point Circle
Charlotte, NC 28273
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMIXI, DIETTERICK &
Dated: September 4, 2009 By: V
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITA, DIETTERICK &
Dated: September 4, 2009 By: `
Scott A. ietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: DEPARTMENT OF REVENUE
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad,. Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: COMMONWEALTH OF PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of.
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMI/TV, DIETTERICK &
Dated: September 4, 2009 By: _
Scott . D'ietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an are distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: CURRENT OCCUPANTS/TENANTS
2 Raspberry Drive
Mechanicsburg, PA 17050
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITU,.,DIETTERICK &
Dated: September 4. 2009 By:
Scott A. D Renck, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: UNKNOWN SPOUSE OF RAYMOND PROZOIC
2 Raspberry Drive
Mechanicsburg, PA 17050
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
vs
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMI , IETTERICK &
CONNEL)?, LLP
Dated: September 4, 2009 By: ,
Scott bietterick"17
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
•
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: UNKNOWN SPOUSE OF HARVEY J. CASSELL
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of.
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
r a
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMIT IETTERICK &
CONNELLY LP
Dated: September 4. 2009 By:
Scott ietterick, Esquire
PA V #5 650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
. •
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and :
HARVEY J. CASSELL,
Defendants.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on December 9, 2009 at 10:00 a.m., the following described real estate which Raymond Prozoic
and Harvey J. Cassell are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of-
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
. , •
The said Writ of Execution has been issued on a judgment in the action of
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
at EX. NO. 08-7241 in the amount of $5,260.77, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITIK DIETTERICK &
Y
Dated: September 4, 2009 By:
Scott . tterick, E
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
w • - *
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
o- v,, P-o7rc)NOTAPY
2009 OCT 29 PM 2' 11
PE NN LVAN
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
E;?E
LAC ""Y
J
)F THE
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
t?tp of ?urnt?er! ?
NOY 25 Aril 8: 0
OFF.I.E C-F `rE S-ERIFF T'"t?i'v tL?' r•`. ;?''t
Silver Spring Township Authority
vs.
Raymond Prozoic
SHERIFF'S RETURN OF SERVICE
Case Number
2008-7241
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the
above entitled action, upon the property of Paymond Prozoic & Harvey J. Clouser, located at 2 Raspberry
Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law.
09/25/2009 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at
1136 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Raymond Prozoic, located at 2
Raspberry Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law
10/15/2009 R. Thomas Kline, Sheriff who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Harvey J. Cassell, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real
Estate Writ, Notice of Sale and Description according to law.
10/26/2009 Dauphin County Return and now the, 1st day of October 2009, served the within Real Estate Writ, Notice
of Sale and Description upon Harvey J. Cassell, the defendant, by making known unto Harvey J. Cassell
at 6160 Springford Drive, Apt C6, Harrisburg, Pennsylvania its contents and at the same time handing to
him a true and correct copy of the same. So Answers: J.R. Lotwick, Sheriff of Dauphin County,
Pennsylvania.
11/10/2009 Property sale cancelled on 11/10/2009
11/10/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law states this writ is returned STAYED, per
letter of instruction from Attorney Scott A. Dietterick.
SHERIFF COST: $834.97 ? /-1/ o a /o q (-;.
November 23, 2009
SO ANSWERS,
R THOMAS KLINE, SHE IFF?.
iC; Goun±ySuite Sheriff. 1'eleo ,oft. Inc. CX, / 3 /,?Y
411 z 3 4L,;j a3
WRIT OF EXECUTION and/or ATTACHMENT
{ R
COMMONWEALTH OF PENNSYLVANIA) NO 08-7241 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff (s)
From RAYMOND PROZOIC and HARVEY J. CASSELL
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $5,260.77
Interest
Atty's Comm %
Atty Paid $a8A50
L.L. $.50
Due Prothy $4.00
Other Costs. SAT FEE MW $8. o0
Plaintiff Paid
Date: 8/18/09
urtis R. Long, oth no ary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY LLP
PO BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
Real Estate Sale #
On September 9, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA
Known and numbered as, 2 Rasberry Drive,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 9, 2009
By:
Real Estate oordina or 'C
Fj?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY,
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
CIVIL DIVISION
NO.: 08-5139 MLD
08-7241 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date
the Praecipe for Writ of Execution was filed the following information concerning the real
property located at 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050:
1. Name and Address of Owner(s) or Reputed Owner(s):
RAYMOND PROZOIC 2 Raspberry Drive
Mechanicsburg, PA 17050
HARVEY J. CASSELL 6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
2. Name and Address of Defendant(s) in the Judgment:
RAYMOND PROZOIC 2 Raspberry Drive
Mechanicsburg, PA 17050
HARVEY J. CASSELL 6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
3. Name and Address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
SILVER SPRING TOWNSHIP AUTHORITY Plaintiff
.
PENN WASTE, INC.
GMAC, LLC
RYAN HOSPODAVIS
EMC MORTGAGE CORPORATION
88 Brickyard Road
York, PA 17402
480 Jefferson Blvd, RJE 350
Warwick, RI 02886
and
c/o Michael J. Dougherty
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
6420 Gallop Road
Harrisburg, PA 17111
800 State Highway
121 Bypass
Lewisville, TX 75067
and
c/o Gregory Javardian
1310 Industrial Boulevard, 1st Floor
Suite 101
Southampton, PA 18966
4. Name and Address of the last record holder of every mortgage of record:
EMC MORTGAGE CORP 800 State Highway
121 Bypass
Lewisville, TX 75067
MERS NOMINEE FOR EQUIFIRST CORP 500 Forest Point Circle
Charlotte, NC 28273
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
DEPARTMENT OF REVENUE
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
COMMONWEALTH OF PA
CURRENT OCCUPANTS/TENANTS
UNKNOWN SPOUSE OF RAYMOND PROZOIC
UNKNOWN SPOUSE OF HARVEY J. CASSELL
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
2 Raspberry Drive
Mechanicsburg, PA 17050
2 Raspberry Drive
Mechanicsburg, PA 17050
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
7. Name and Address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
JAMES, SNIL.T41DIETTERICK & CONNELLY, LLP
DATED:_ 11m 1C)q BY:
Scoti(Al. etteri& Esquire
Pa. I.D. 55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
w
7
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff,
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriffs Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, IffiEXTERICK & CONNELLY, LLP
DATED: -S I ILI `D -1 BY:
Scott
f4. Iitteric?Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA ORDER OF COURT
J
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an are distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
MAR 2 0 200
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff,
vs
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NO.: 08-5139 MLD
08-7241 CIVIL TERM
ORDER OF COURT
AND NOW, this day of p,' ' , 2008, upon consideration
of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND
DECREED that Plaintiff shall serve its Writ of Scire Facias and all future pleadings, if
necessary, on Defendant, Raymond Prozoic, by instructing the Sheriff of Cumberland County to
POST a copy of same on 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050 and by mailing
a copy to 2 Raspberry Drive, Mechanicsburg, Pennsylvania 17050, via Certified Mail, No
Signature Required and First Class U.S. Mail, Postage Prepaid, with said service being valid and
complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
BY THE OURT:
s
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Harvey J. Cassell
6160 Springford Drive, Apt. C-6
Harrisburg, PA 17111
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,
December 9, 2009, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
2 Raspberry Drive
Mechanicsburg, Pennsylvania 17050
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 08-7241 Civil Term No. 08-5139 MLD
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Raymond Prozoic and Harvey J. Cassell
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person
or company that has entered judgment against you. You may also file a petition
with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or
for other proper cause. This petition must be filed before the Sheriff s Deed is
delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor
or on the creditor before presentation to the Court and a proposed order or rule
must be attached to the petition. If a specific return date is desired, such date
must be obtained from the Court Administrator's Office, Cumberland County
Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013,
before presentation of the petition to the Court.
JAMES, SMITH, I?IET]ITVRICK & CONNELLY, LLP
DATED: D 11H ) Ch BY:
Scott M. qi9 terick, E-,s
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED AND
PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF VIA
DEPUTIZING THE SHERIFF OF DAUPHIN COUNTY
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Silver Spring Township, Cumberland
County, Pennsylvania, bounded and described according to the Subdivision Plan for Holly
Estates prepared by Walker Associates, dated January 24, 1986 and thereafter revised and
recorded in Cumberland County Plan Book 53 at Page 67, as follows to wit:
BEGINNING at a point on the dedicated right of way line of Raspberry Drive at the
corner of Lot No. 15 of the above referred to Plan; thence along the said Raspberry Drive, on a
line curving to the left and having a radius of 175 feet, an arc distance of 39.08 feet to an iron
pin; thence along same South 35 degrees 45 minutes 00 seconds West 145.11 feet to an iron pin;
thence along the legal right of way line of Hogestown Road, Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to an iron pin; thence along land now or formerly of Kreitzer
North 35 degrees 45 minutes 00 seconds East 202.54 feet to an iron pin; thence along Lot No. 15
of the above referred to Plan of Lots South 41 degrees 27 minutes 13 seconds East 81.36 feet to
an iron pin, the point and place of BEGINNING.
BEING Lot No. 16 of the above referred to Plan of Lots and containing 14,584.1 square
feet, more or less.
HAVING thereon erected a dwelling house being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.R. Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-in-Fact, Husband and Wife and Kasaragod
Janardhana and Usha Janardhana, by Kasaragod Janardhana, her Attorney-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and recorded on September 29, 2006 in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed Book 276, Page 4537, granted and
conveyed unto Harvey J. Cassell, Single and Raymond Prozoic, Single.
Parcel No.: 38-21-0289-020P
Exhibit "A"
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 23, October 30 and November 6, 2009
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
isa arie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
6 da of November, 2009
e 4: ?1'4
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
Mk 11s. *19640" l
Silver Spring Township Authority
vs.
Raymond Prozoic
Harvey J. Cassell
Atty: Scott Dietterick
ALL THAT CERTAIN tract of land
situate in Silver Spring Township,
Cumberland County, Pennsylvania,
bounded and described according to
the Subdivision Plan for Holly Estates
prepared by Walker Associates, dated
January 24, 1986 and thereafter
revised and recorded in Cumberland
County Plan Book 53 at Page 67, as
follows to wit:
BEGiNNING at a point on the
dedicated right of way line of Rasp-
berry Drive at the comer of Lot No. 15
of the above referred to Plan; thence
along the said Raspberry Drive, on
a line curving to the left and having
a radius of 175 feet, an arc distance
of 39.08 feet to an iron pin; thence
along same South 35 degrees 45
minutes 00 seconds West 145.11 feet
to an iron pin; thence along the legal
right of way line of Hogestown Road,
Pa. Route 114, North 54 degrees 45
minutes 00 seconds West 75 feet to
an iron pin; thence along land now
or formerly of Krekw North 35 de-
w 45 minutes 00 adoorift East
202.54 feet to an iron pin; thence
aloe` Lot No. 15 of the above referred
to F%n of Lots &mth 41 depees 27
minutes 13 seconds East 81.36 feet
to an iron pin, the point and place of
BEGINNING.
BEING Lot No. 16 of the above re-
ferred to Plan of Lots and containing
14,584.1 square feet, more or less.
HAVING thereon erected a dwell-
ing house being known and num-
bered as 2 Raspberry Drive, Mechan-
icsburg, Pennsylvania 17050.
BEING the same premises which
S.R. Subrahmanya Prasad and
Champa S. Prasad, by S.R. Sub-
rahmanya A. Prasad, Her Attorney-
in-Fact, Husband and Wife and
Kasaragod Janardhana and Usha
Janardhana, by Kasaragod Janard-
hana, her Attorney-in-Fact, Husband
and Wife, by Deed dated August 31,
2006, and recorded on September 29,
2006 in the Office of the Recorder of
Deeds in and for Cumberland Coun-
ty, in Deed Book 276, Page 4537,
granted and conveyed unto Harvey
J. Cassell, Single and Raymond Pro-
zoic, Stile.
Paroei No.: 38-21-0289-020P.
The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
the Patriot-News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Leslie Kramer, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
10/23/09
10/30/09
11/06/09
........?.. ..... >. l......?. ,c:. ......
Sworn to and subscribed before me this 1ETd4y of:, November, 2,009 A.D.
R
Notary Public
..ofl9rJi ?tW r:°_7: 0F ':'F-: NN3YLIA '
<.
fiotsra! SP,?I
Shur L Kisnc Notary Public,
' iy Q'ttamsf?,, 0,3UPhin Coc,rty
My comrnf vsior C)ypr Nov. 16.201
secia?, .
Writ No. 2008-7241 Civil Term
Slkw Spring Township
Authority
Vs
Raymond Prozoic
Harvey J. Cassell
Atty: Scott Dietterick
ALL THAT CERTAIN tract of land situate i-?
Silver' Spring Township, Cumberland County.
Pennsylvania, bounded and described according
to the Subdivision Plan for Holly Estate
prepared by Walker Associates, dated Januar.
24, 1986 and thereafter revised and recorded ir,
Cumberland County Plan Book 53 at Page 67,
follows to wit:
BEGiNNING at a point on the dedicated right o;
way line of Raspberry Drive at the comer of Lo'
No. 15 of the above referred to Plan; thence
along the said Raspberry Drive, on a line
curving to the left and having a radius of 174
feet, an are distance of 39.08 feet to an iron pin,
thence along same South 35 degrees 45 minute,
00 seconds West 145.11 feet to an iron pan,
thence along the legal right of way line w
Hogestown Road, Pa. Route 114, North 5
degrees 45 minutes 00 seconds West 75 feet to
an iron pin; thence along land now or formerly
of Kreitzer North 35 degrees 45 minutes 011
seconds East 202.54 feet to an iron pin; thence
along Lot No. 15 of the above referred to Plan oi
Lots South 41 degrces 27 minutes 13 second,
East 81.36 feet to an iron pin, the point and
place of BEGINNING.
BEING Lot No. 16 of the above referred to Plao
of Lots and containing 14,584.1 square feet.
more or less.
HAVING thereon erected a dwelling house
being known and numbered as 2 Raspberry
Drive, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which S.P.
Subrahmanya Prasad and Champa S. Prasad, by
S.R. Subrahmanya A. Prasad, Her Attorney-
j,-Fact, Husband and Wife and Kasaragod
Janaidhana and USha Janardbana, by Kasaragoa
Janardhana, her Attomey-in-Fact, Husband and
Wife, by Deed dated August 31, 2006, and
recorded on September 29, 2006 in the Office o+
the
Recorder of Deeds in and for Cumberland
County, in Deed Book 276, Page 4537, granted
and
conveyed unto Harvey J. Cassell, Single ano
Raymond Prozoic, Single.
Parcel No.: 38-21-0289.020P
v - ?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL, : c co
Defendants. Z=
rn-
vs?
? rv :Oo
°
-z
r w a
PRAECIPE TO SATISFY MUNICIPAL LIEN z z'?
a °rn
TO THE PROTHONOTARY:
SIR/MADAM: Please mark the Municipal Lien filed at the above - captioned term and number
satisfied.
By:
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and ;
HARVEY J. CASSELL,
Defendants.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy
Municipal Lien was served on the following this 22nd day of March, 2011, via First Class U. S.
Mail, Postage Pre-paid:
Raymond Prozoic
2 Raspberry Drive
Mechanicsburg, PA 17050
Harvey J. Cassell
6160 Springford Drive, Apt. C6
Harrisburg, PA 17111
Respectfully S itted:
JAMES, SM , I TTERICK & CONNELLY, LLP
By:
Scott A c Esquire
Attorney I. 55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SILVER SPRING TOWNSHIP AUTHORITY, : CIVIL DIVISION
Plaintiff, NO.: 08-5139 MLD
08-7241 CIVIL TERM
VS.
RAYMOND PROZOIC and
HARVEY J. CASSELL,
Defendants. 20
PRAECIPE TO DISCONTINUE ACTION c c "
r'no s rn-
z ?D -vim
-<X>
TO THE PROTHONOTARY: r-x w o°
ZO o-n
ocl
v
Please mark the above captioned matter settled and discontinued.
Respectfully Submitted:
DATE: a a I C
JAMES, SMITH, ETTERICK &
CONNELLY LLP I
BY:
ScottlA. Diatterick, Esquire
PA I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280