HomeMy WebLinkAbout09-1665ej
"THIS IS NOT AN ARBITRATION CASE" I
"AN ASSESSMENT OF DAMAGES HEARING IS NOT R
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
Plaintiff,
VS.
James S. Yeatter
Defendant.
CIVIL DIVISION
ISSUE NO.:
TYPE OF PLEADIN
CIVIL ACTION - C 1VIPLAINT
IN EJECTMENT
CODE-
FILED ON BEHALF F:
Aurora Loan Services. LC
COUNSEL OF RECOID I-% FOR THIS
PARTY:
Scott A. Dietterick, Es uire; Pa. I.D. #55650
Kimberly A. Bonner, E quire; Pa. I.D. #89705
Richard P. Haber, Esq e; Pa I.D. #202567
,Eric Santos, Esquire; P I.D. #201493
Joel A. Ackerman, Esq 're; Pa I.D. #202729
ZUCKER, GOLDBER & ACKERMAN,
LLC
200 Sheffield Street, S 'te 301
Mountainside, NJ 070
(908) 233-8500; (908) 33-1390 FAX
office tucker of ber com
File No.: XCP- 103110/ a
TO: Defendant(s)
YOU ARE HEREBY NOTIFIE D TO PLEAD TO THE
ENCLOSED COMPLAINT WI IN TWENTY (20) DAYS
FROM SERVICE HEREOF O A DEFAULT JUDGMENT
MAYBE ENTERED AGAINS YOU.
Scott A. Dietterick, Esquire
Kimberly A. Bonner, Esquire
Richard P. Haber, Esquire
Attorneys for Plaintiff
Zucker, G Idberg & Ackerman, LLC
XCP-103110
103110D 1002C03122009P2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
: CIVIL DIVISION
Plaintiff,
vs.
James S. Yeatter
Defendant.
. NO..
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth
must take action within twenty (20) days after this complaint and notice are se
appearance personally or by attorney and filing in writing with the court your i
the claims set forth against you. You are warned that if you fail to do so the cE
you and a judgment may be entered against you by the court without further nc
claimed in the complaint or for any other claim or relief requested by the plain
or property or other rights important to you. YOU SHOULD TAKE THIS PA
AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFF
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
HELP.
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
the following pages, you
:d, by entering a written
senses or objections to
may proceed without
:e for any money
F You may lose money
R TO YOUR LAWYER
RD ONE, GO TO OR
)U CAN GET LEGAL
LAWYER
Cumberland Count
32 S. Bedfc
Carlisle, P.
Phone (800)
(717)
Bar Association
rd Street
? 17013
?90-9108
249-3166
Zucker, Go dberg & Ackerman, LLC
XCP-103110
10 110D1002C03122009P3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA'
Aurora Loan Services, LLC CIVIL
Plaintiff, : NO.:
VS.
James S. Yeatter
Defendant.
AV-ISO
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse d
presentan mas adelante en las siguientes paginas, debe tomar accion dentro do lc
dias despues de la notifacacion de esta Demanda y Aviso radicando personalmet
abogado una comperencencia escrita y redicanco en la Courte por escrito sus del
los demandas presentadas aqui en contra suya. Se le advierte de que si usted fall
se describe anteriormente, el caso puede proceder sin usted y un fallo por cualqu
reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por e
dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder
otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIA7
NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VA
OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCT)
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
las demandas que se
proximos veinte (20)
o por medio de un
nsas de, y objecciones a,
de tomar accion como
r suma de dinero
demandante puede ser
hero O propieded u
AMENTE. SI USTED
YA A LA SIGUEINTE
. LEGAL.
LAWYER
Cumberland Count
32 S. Bedf<
Carlisle, P.
Phone (800)
(717)
Bar Association
d Street
.17013
190-9108
;49-3166
Zucker, Go?dberg & Ackerman, LLC
XCP-103110
10 11 OD 1002C03122009P4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA'
Aurora Loan Services, LLC
Plaintiff,
vs.
James S. Yeatter
Defendant.
CIVIL DIVISION
NO.: O 9_ /G L
CIVIL ACTION - COMPLAIN T IN EJECTMENT
AND NOW, comes Aurora Loan Services, LLC, by its attorneys,
Ackerman, LLC, and files this Complaint in Ejectment as follows:
I . The Plaintiff, Aurora Loan Services, LLC, which has its n
business at 601 Fifth Avenue, Scottsbluff, NE 69361.
2. The Defendant, James S. Yeatter, is an adult individual
Commonwealth of Pennsylvania at 2 Andes Drive, Mechanicsburg, PA 1
3. By Sheriff's Deed dated February 23, 2009 Recorded on 2
200905638, the Sheriff of Cumberland County has conveyed to Plaintiff,
piece of ground, with improvements erected thereon, and as more fully di
and as purchased by Plaintiff at Sheriff Sale on December 10, 2008.
4. During the pendency of the Mortgage Foreclosure Action
Services, LLC, predecessor in interest to Plaintiff, on the aforesaid premix
3560, Defendant was served as owner of the aforesaid premises with a true
the Complaint in Mortgage Foreclosure by the Sheriff of Cumberland
Zucker,
ucker, Goldberg &
icipal place of
ing within the
)55.
7/09, Instrument#
that certain lot of
ribed in the Deed
kurora Loan
docketed at 08-
nd correct copy of
,.
Go dberg & Ackerman, LLC
XCP-103110
10 110D1002C03122009P5
5. Under the same Term and Number, Defendant was served as owner of the
aforesaid premises with a Notice of Sheriffs Sale scheduling the sale for December 12, 2008 and
Defendant was served on October 13, 2008, personally by the Sheriff of Cumberland County. A
true and correct copy of Plaintiffs Affidavit of Service is marked Exhibi "A", attached hereto
and made a part hereof.
6. Defendant has unjustly and unlawfully retained
to the detriment of Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant
premises known as 2 Andes Drive, Mechanicsburg, PA 17055, together
this Honorable Court may deem necessary and appropriate.
Dated: March 12, 2009
BY: C/
Scott A. Dietterick, Es 're; PA
Kimberly A. Bonner, Esquire; P
Richard P. Haber, Esquire; PA I
Eric Santos, Esquire; PA I.D. 0
Joel A. Ackerman, Esquire; PA I
Attorneys for Plaintiff
XCP-1031 10/gg
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
(908) 233-8500; (908) 233-13901
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY
WILL BE USED FOR THAT PURPOSE.
of the premises
possession of the
such other relief as
,LLC
.D.#55650
? I.D. #89705
D.#202567
1493
D.#202729
TION OBTAINED
Zucker, G ?ldberg & Ackerman, LLC
XCP-103110
103110D1002C03122009P6
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AURORA LOAN SERVICES, LLC, CIVIL DIVISION
Plaintiff, NO.: 08-3560
VS.
Sheriff Sale #:
James S. Yeatter
TYPE OF PLEADING
Defendant.
Pa. R.C.P. RULE 3129. (C) AFFIDAVIT OF
SERVICE OF
DEFENDANT/OWNE4 AND
OTHER PARTIES OF REST
CODE:
FILED ON BEHALF OF
COUNSEL OF RECORD FOR THIS
PARTY:
ZUCKER, GOLDBERG ACKERMAN, LLC
Scott A. Dietterick, Esq ' PA I.D. #55650
Kimberly A. Bonner, Esq dre- PA I.D. #89705
Richard P. Haber, Esquire PA I.D. #202567
Eric Santos, Esquire- PA D. #201493
Joel A. Ackerman, Esquire- PA I.D. #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
o is ke of .co
File No.: XCP- 10311 0/ml
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AURORA LOAN SERVICES, LLC,
Plaintiff,
VS.
James S. Yeatter
Defendant.
CIVIL DIVISION
NO.: 08-3560
I, Marie Lindner, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC,
attorneys for Plaintiff, Aurora Loan Services, LLC, being duly sworn according to law depose
and make the following Affidavit regarding the service of Plaintiff's Notice of sheriff's Sale of
Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows:
1 • Defendant, James S. Yeatter, is the record owner of the real property.
2. On or about 10/13/2008, James S. Yeatter was served with Plaintiffs Notice of
Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by a Sheriff of
Cumberland County, at 158 Springfield Rd., Shippensburg, PA. A true an correct copy of said
Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof.
3. On or about 10/31/08, Plaintiff's counsel served all other p 'es in interest with
Plaintiff s Notice of Sheriffs 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
Zucker, GoWberg & Ackerman, LLC
XCP-103110
said Notices and Certificates of Mailing are marked Exhibit "B", attached
hereof.
Finally, the undersigned deposes and says that the Defendant>Owi
of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Pa
with Pa.RC.P. 3129.2.
Dated: November 19, 2008
Sworn to and subscribed before
me this 19th day of November, 2008
N*ary Public I
My COMMISSION EXPIRES:
SARAH J. SPOTWOOD
A NOTARY PUBLIC OF NEW JERSEY
My Commission Expires 7/19/2009
hereto and made a part
and all other Parties
rty in accordance
ZUCKER, GOLDBERG 8t ACKERMAN, LLC
Attorneys for Plaintiff
Zucker, Gol{ berg & Ackarm m, LLC
XCP-103110
EXHIBIT A
Zucker, Goldbe & Ackerman, LLC
XCP-103110
lU3110
Aurora Loan Services, LLC In the Court of Common Pleas of
VS Cumberland County, Pennsylvani
James S. Yeatter Writ No. 2008-3560 Civil Tern
Micheal Barrick, Deputy Sheriff, who being duly sworn accordu to law, states
that on October 13, 2008 at 2010 hours, he saved a true copy of the v4d on Real Estate
Writ, Notice and Description, in the above enritled action, upon. the wit * maned
defendaat, to wit: James S. Yeatter, by malong known unto James S. Y personally,
at 158 SprunPeld Road, Shippeasburg, Cumberland County, Pamnayl its its
and at the same time handing to him personally the said true and correct
same py of the
.
Robert•Bitner, Deputy Sheriff, who being duly sworn according
law, states that
on October 11, 2008 at 1052 hours, he posted a true copy of the within S AW Estate-Writ,-
Notice, Poster and Description, in the above entitled action, upon the pro oerty of James
S. Yeatter.located at 2 Andes Drive, Mechanicsburg, Cumberland Coun ty, Pennsylvania
according to law.
R. Thomas Kline, Shy who being duly sworn according to la w, states he
saved the above Rai Estate Writ, Notice, Poster and Description in the Wowing
manner: The Sheriff mailed a notice of the pendency of the action to the within named
dafamdant, to wit: James S. Yeatter, by regular mail to his last known ad drm of 158
Springfield Road, Shippensburg, PA 17257. This letter was mailed the date of
October 16, 2008 and never returned to the Sheriffs Office.
So
4g9
R. Thomas Kline, Sheriff
BY V
Real Estate etgeini
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
AURORA LOAN SERVICES, MC, : CTM DIVISION
Plaintitl; NO.: 08-3560
vs.
JAMES S. YEATTER;
Defcndant.
NOTICE OF SHERII+'F'S SALE
w_ OF REAL PROPERTY PURSUANT TO
James S. Yeatter ?
2 Andes Drive , 1t t arm TUA
Mechanicsburg, PA 17055
TAKE NOTICE:
That the Sheriff's Sale of Red Property (Real Estate) will be held a
Cumberland Coanty' Courthouse, 1 Courthouse Square, Carlisle, PA 1701:
12/10/2008 at 10:00am prevailing local-time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal 6
consisting of a statement of the mesaured boundaries of the property, bagel
brief mention of the buildings and any other major improvements erected c
(SEE LEGAL DESCRIPTION' ATTACHED AS EXI-13BIT "A").
The LOCATION of your property to be sold is:
2 Andes Drive, Mechanicsburg, PA, 17055
The JUDGMENT under or pursuant to which your property is
docketed to:
No. 08-3560
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S)
PROPERTY ARE:
t the
I on
r with a
the land.
t sold is
THIS ,
James S. Yeatter
A SCHEDULE OF DISTRIBUTION, being a list of the persona or
governmental or corporate entities or agencies being entitled to receive 1 art of the
proceeds of the sale received and to be disbursed by the Sheriff(for ple to banks
that hold mortgages and municipalities that are owed tm=), will be fil by the Sheriff
thirty (30) days after the sale, and distribution ofthe p needs of sale in with
this schedule-will, in ho, be made unless someaae objects by filing to it,
within ten (10) days of the date it is filed. Information about the ofDistribution
may be obtained from the Sheriff of the Court of Common Pleas of Cum County,
One Courthouse Square, Carlisle, PA 17013-3387.
It has been issued because there is a Judgment against you. It ma cause your
property to be held, to be sold or taken to Pay the Judgment. You may ve legal rights
.to Prevent your property from being taken. - A lawyer can advise you mot specifically of
these rights. If you wish to exercise your rigbts, you must act promptly.
. Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 & Bedford Street
Carlisle, PA 17013
Phone0w) 490-9108
(717) 249L31"
THE LEGAL RIOTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common
Cumberland County to open the Judgment if you leave a m
defense against the person or company that has entered jtW
you. You may also file a petition with the same Court if yi
a legal defect in the obligation or the procedure used again
of
not against
are aware of
YML
2. After the Sheriffs Sale, you may file a petition with, the Court of
Common Pleas of Cumberland County to ad aside the We for a grossly
inadequate price or for other proper cause. This petition mast be filed
before the Sheriffs peed is delivered.
3. A petition or petitions raising the legal issues or rig mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served n the attorney
fir the creditor'or on the creditor before presentation to Court and a
proposed order or rule must be attached to the petition. a specific return
date is desired, such data must be obtained from the Administrator's
Office, Cumberland County Courthouse, One Square, Carlisle,
PA 17013-3387, before presentation of the Court,
ZUCKER tW A , LLC
Dated: 'August 13, 2008 BY:
Scott A. Dietterick, ; PA I D. #55650
Kimberly A- Bomw F,.aquire; P I.D. #89705
Richard P. Haber, Esquire; PALL D . #202567
Eric Samos, Esquire; PA I.D. #20 1493
200 Sheffield Street, Suite 301
Mountaimide,.NJ 07092
File No.: XCP-103110
(908) 233-8500; (908) 233-1390 F
VIA CERTIFIED MAIL, RETURN RECTJP T REQ D '
AND
VIA PERSONAL SERVICE BY.THE SMM OF CUWMXRLA ND CO.
Exhibit "N'
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT, PARCEL OR TRACT OF LAND WITH IMPROV EbfENTS THEREON
ERECTED SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND CO ,
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT OF INTERSECTION OF THE NORTHERN LINE F ANDES DRIVE
AI1D THE WESTERN LINE'OF CASCADE ROAD AS SHOWN ON PLAN O SECTION 2, MT.
ALLEN HEiGM. THENCE ALONG THE. WESTERN LINE OF CASCADE OAD NORTH 3
DEGREES, 23 MINEITBS EAST 129.42 FEET TO A POINT; THENCE IN A Y
DIRECTION ALONG THE SOUTHERN LINE OF LOT 2 AND 3 ON A PLAN OF SECTION 1, MT.
ALLEN HEIGHTS 119.13 FEET TO A POINT; THENCE ALONG THE EAS LINE OF LOT NO.
19 ON PLAN OF SECTION 2, MT. ALLEN HEIGHTS SOUTH 5 DEGREES, 7 MQ?IiJ , EAST 128
FRET TO ANDES DRIVE; THENCE ALONG THE NORTHERN LINE OF ES DRIVE-NORTH
84 DECK ElES, .53 MINUTES EAST 100 FEET TO THE POINT AND PLACE BEGINNING
BEING LOT NO. 18, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID RECORbElD IN
THE RECORDER OF DEEDS OFFICE OF
CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAT
BOOK 12; PAGE 16.
HAVING THEREON ERECTED A DWEJJM HOUSE BEING KNON IN AND NUMBERED
AS 2 ANDES DRIVE, MBCHANICSBURG, PA, 17055,
BEING THE SAME PREMISES WHICH SONDRA K ERB AND R T L. ERB, WIFE
AND HUSBAM, BY DEED DATEID MARCH 30, 2007 AND RECORDED AP RU. 4, 2007 IN AND
FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 279, PAGE 2165,
GRANTED AND CONVEYED UNTO JAMES S. YEATTER
TAX MAP NO.: 42-28-2421-281.
Z??G.Wb"&A*mmk=
xce-103110
EXHIBIT B
Zucker, Cm & Ackmwn, LLC
XCP-103110
AerYn.dewet.iw6«.pw.rdbus?Nrorrt
zwK Scott A. Diettmick, Esquire
c% Zucker, Goldberg & Ackerman, LL(
200 Sheffit U Street, Suite 301
Mountainside, NJ 07092
CerNeate Of
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CORPORA2026 TION BOX Af W.^*
FFL 148
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LINT, MI 4$501
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PS Form 3817, April 2007 PSN 7530.02-0p0.g065
Es, CettiBteate Or
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200 Sheffield Stroet, Suite 30 LLC
IN 000425813 .4?
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Moude, NJ 07092 zaco°E 07092
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CORPORATION H..
603 N WILMOT RD
TUCSON, AZ $5711
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PS Form 3317. April 2007 PSN 7530424004M
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DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
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CUMBERLAND COUNTY DOMESTIC RELATIONS
OFFICE
Domestic Relations Samon
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
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l`' PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
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Harrisburg, PA 17128-0601
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
AURORA LOAN SERVICES, LLC, CIVIL DIVISION
Plaintiff, NO.: 08-3560
VS.
James S. Yeatter
Defendant.
TO:
CUMBERLAND COUNTY TAX CLAIM
BUREAU COMMONWEALTH
Cumberland County Courthouse PENNSYLVANIA
One Courthouse Square DEPARTMENT OF 'Y
Carlisle, PA 17013 P.O. Box 2675
Hg, PA 17105
UNKNOWN SPOUSE
2 Andes Drive PA DEPT. OF REVEL`
Mechanicsburg, PA 17055 INHERITANCE TAX
Dept. 280601
MERS, AS NOMINEE FOR FIRST Harrisburg, PA 17128
MAGNUS FINANCIAL CORPORATION
PO BOX 2026 UNKNOWN TENAN'
FLINT, MI 48501 2 Andes Drive
Mechanicsburg, PA 1;
MERS, AS NOMINEE FOR FIRST
MAGNUS FINANCIAL CORPORATION CUMBERLAND COL
603 N WILMOT RD RELATIONS OFFICE
TUCSON, AZ 85711 Domestic Relations So
13 N. Hanover Street
UPPER ALLEN TOWNSHIP PO Box 320
100 GETTYSBURG PIKE Carlisle, PA 17013
MECHANICSBURG, PA 17055
ARE
OR TENANTS
DOMESTIC
Zucker, 00kH j & Ackerman, LLC
XCP-103110
103110D1004C1031200SPI
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 o Cumberland County,
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
Carlisle, Pennsylvania 17013-3387
On 12/10/2008 at 10:00am, the following described real estate which Jams S. Yeatter are the
owners or reputed owners and on which you may hold a lien or have an intmcg which could be
affected by the sale of-
2 Andes Drive,
Mechanicsburg, PA 17055
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
& Ackerman, LLC
XCP-103110
Zucker, G7110DIO04CIO31200SP2
1
The said Writ of Execution has been issued on a judgment in the lion of
Aurora Loan Services, LLC
Plaintiff
vs.
James S. Yeatter, et al
Defendant(s)
at EX. NO. 08-3560 in the amount of $184696.01 plus interest and costs.
Claims against property must be filed at the Office of the Sheriff fore above sale date.
Claims to proceeds must be made with the Office of the Sheriff be re 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 ale or this Notice,
you should contact your attorney as soon as possible.
LLC
r.....:
Dated: October 31, 2008
,.. wc
11:
AIM 11
Scott A. Dietterick, Esquire; PA I. . #55650
Kimberly A. Bonner, Esquire; P I.D. #89705
Richard P. Haber, Esquire; PA I. . #202567
Eric Santos, Esquire; PA I.D. #201 493
Joel A. Ackerman, Esquire; PA I. D . #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: XCP-103110
(908) 233-8500; (908) 233-1390 FA 3X
Zucker, 0,61dberg & Ackerman, LLC
XCP-103110
10110D 100401031200V3
a
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT, PARCEL OR TRACT OF LAND WITH IM
ERECTED SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT OF INTERSECTION OF THE NORTHERN LIN
AND THE WESTERN LINE OF CASCADE ROAD AS SHOWN ON PLAN
ALLEN HEIGHTS; THENCE ALONG THE WESTERN LINE OF CASCAD:
DEGREES, 23 MINUTES EAST 129.42 FEET TO A POINT; THENCE IN A
DIRECTION ALONG THE SOUTHERN LINE OF LOT 2 AND 3 ON A PLA
ALLEN HEIGHTS 119.13 FEET TO A POINT; THENCE ALONG THE EAS
19 ON PLAN OF SECTION 2, MT. ALLEN HEIGHTS SOUTH 5 DEGREES
FEET TO ANDES DRIVE; THENCE ALONG THE NORTHERN LINE OF)
84 DEGREES, 53 MINUTES EAST 100 FEET TO THE POINT AND PLACI
BEING LOT NO. 18, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID
THE RECORDER OF DEEDS OFFICE OF CUMBERLAND COUNTY, PO
BOOK 12, PAGE 16.
HAVING THEREON ERECTED A DWELLING HOUSE BEING
AS 2 ANDES DRIVE, MECHANICSBURG, PA, 17055.
BEING THE SAME PREMISES WHICH SONDRA K. ERB AND R(
AND HUSBAND, BY DEED DATED MARCH 30, 2007 AND RECORDED
FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOI
GRANTED AND CONVEYED UNTO JAMES S. YEATTER.
TAX MAP NO.: 42-28-2421-281.
THEREON
OF ANDES DRIVE
IF SECTION 2, MT.
ROAD NORTH 3
WESTERLY
v OF SECTION 1, MT.
TRN LINE OF LOT NO.
7 MINUTES EAST 128
LADES DRIVE NORTH
OF BEGINNING.
RECORDED IN
VANIA, IN PLAT
AND NUMBERED
T L. ERB, WIFE
[L 4, 2007 IN AND
3 279, PAGE 2165,
Zucker, Goldberg & Ackerman, LLC
XCP-103110
• 4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1. COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Imstr msemt Number - 200903638
Remodel On 2127t2M At 1:W:1 8 PM
* Instrument Type - DEED4NM1t rS
Invole a Number - 38119 User ID - MSW
Grantor - YRAT M4 JAMES S
*. Grantee - AURORA LOAN SER LLC
* Customer - SIKRIFF OFFICE
* lass
82ATa M= TALC $0.50
STA?a JCS/ACCi88 TO $10.00
imicz
RECONDnO F88S - $12.50
I tz a c o r or alms
PAR= CWTIFICATION $10.00
rug
AF a ROWING $11.50
COONT? ARcHrvas Fos $2.00
am AR mrm FR $3.00
D IC83M SCAOOL -$0.00
DISTRICT
UP`PL'R ALL= TOWSHIP $0:00
TOTAL PA;D $49.50
* Total Pages - 5
I Certify this to be
in Cumberland Ca
". Inbrw0un denoted by an aetwMImay cheap daring
the verMaaion pmons and may be rdNcled oa this page.
EXHIBIT "B"
I o?Vl?
w
5LI t
Tax Parcel No.
Know all Men by these Presents
That I, R. Thomas Kline, Sheriff of the County of
Pennsylvania, for and in consideration of the sum of $1.00, (One
paid, do hereby grant and convey to Aurora Loan Servieea, LLC
Real Estate Sele No. 57
Writ No. 2008-3560 CIA Term
Aurora Loan Services, LLC
VS
James S. Yeetter
Attorney Scott Dietteridc
LEGAL DESCRIPTION
ExIdbit "A"
ALL THAT CERTAIN LOT, PARCEL OR TRACT OF LAND WITH IMPROVE
ERECTED SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNT
BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT OF INlMMCTION OF THE NORTHERN LINE OF
TIIE WESTERN LINE OF CASCADE ROAD AS SHOWN ON PLAN OF SBCTI,
HEIGHTS; THENCE ALONG THE WESTERN LINE OF CASCADE ROAD Na
MINUTES EAST 129.42 FEET TO A POINT; THENCE IN A WESTERLY DIRB
SOUTHERN LINE OF LOT 2 AND 3 ON A PLAN OF SECTION 1, MT. ALLEN
FEET TO A POINT; THENCE ALONG THE EASTERN LINE OF LOT NO. 19 C
SECTION 2, MT. ALLEN HEIGHTS SOUTH 5 DEGREES, 7 MINUTES EAST 1
DRIVE; THENCE ALONG THE NORTHERN LINE OF ANDES DRIVE NORT'F
M04UTM EAST 100 FEET TO THE POINT AND PLACE OF BEGINNING.
BEING LOT NO. I8; PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID. PLA
THE RECORDER OF DEEDS OFFICE OF CUMBERLAND COUNTY, PENNS)
BOOK 12, PAGE 16.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND
AS 2 ANDES DRIVE, MECHANICSBURG, PA, 17055.
BEING THE SAME PREMISES WHICH SONDRA K. ERB.AND ROBERT L. El
HUSBAND, BY. DEED DATED MARCH 30, 2007 AND RECORDED APRIL 4,:
CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 279;
GRANTED AND CONVEYED UNTO JAMES S. YEATTER
TAX MAP NO.: 42-28-2421-281.
6GK
In the State of
to me in hand
HNTS THEREON
, PENNSYLVANIA,
ANDES DRIVE AND
)N 2, MT. ALLEN
TH 3 DEGREES, 23
,MON ALONG THE
HEIGHTS 119.13
V PLAN OF
8 FEET TO ANDES
84 DEGREES, 53
RECORDED IN
VAPIIA, IN PLAT
B, WIFE AND
007 IN AND FOR
PAGE 2165,
The same having been sold by me to the said grantee on the 10th day
Domini Two Thousand and Eight (2008) after due advertisement aco
under and by Virtue of a Writ of Execution issued on the 20th day of
Domini 2008 out of the Court of Common Pleas of Cumberland Cour
of Civil Tenn, Two Thousand and Eight (2008)Number 3560 at the s
Services, LLC against James S. Yeatter.
Anno
Mung to law,
?agust Anno
y, Pennsylvania, as
it of Aum.ra Loan
In Witness Wereof, I have hereunto affixed my signature this 23rd
Anao Domini Two Thousand and Nine (2009)
R. Thomas Kline
Commonwealtlt of Pennsylvania, as.
County of Cumberland
Before the undersigned, Curtis R. Long, Prothonotary of the C
1
Pleas of Cumberland County, Pennsylvania, personally appeared R. TJ
Sheriff of Cumberland County aforesaid, and in due form of law decla
Set forth in the foregoing Deed are true, and that he aclmowledged the
Said deed might be recorded.
Witness my hand and seal of said Court, this 23rd day of F
Domini
Two Thousand and Nine (2009)
st :,.r t^ARUqLE MMUM
HY cOMaats" a
All
I hereby certify thu
i ' • :M y:? ; -? ; • And Post OM6 w
Within Grantee is
t 2617 College Par]
Scottsbluff, NE 6!
day of Fry
t of Common
ias Kline,
that the facts
in order that
Anno
the residence
rem of the
Solicitor
XCW103110 RECONERB USE OXY
• -'viii."vANU? REALTY TRANSFER TAX M PW -"`
osr?uerrarrrr or eNe?ae ..
STATEMENT OF VALUE
..
KMWAS r"d ,?rar.001 Bee Reveres for instructions
Compbloseali teadon end IM lndspa O with Reoader of Deeds when (1) ft U ratosroorrsiaerallon "not ferer 1n the n #w
deW is without darldorspork a byil k er (I) s tax w om---- is daft W A IE Iii alit of Yalse b net aqulred / hunts. 1swholly woMpt hem
tw awed os spa ft, lhp or pu , uOy essomenf. N more spsoo is mfr spsatr atrsstB
Name Zucker, Goldberg & Ackerman, LLC dephone Number 988-
. _ ....w .. _ ._ -. tote
so" Address Tty
20001111111111 a Mountainside NJ 07092
ofAccepbnoe ofDocumen
sl?t esaee(8
OrsawKsyt.esior(s) urora Lean Services, LLC
SberMl of CUMBERLAND County
Street Address Strut Address
One Courthouse Square 2617 Colleen Park Drive
City State zip ity State Zip
am PA 17013338? N
Street Address , Toww6ip,.Bormrgie
2 Andes Drive--__. _ ecbaaiuaburg_, _.
County chool Diwet Tax
t Number
CUN39RLAW
1. Actual Cash Consideration 2 Other Consideration
5 1.00 1: S 1.00
4. County Assessed Value . Common Lave) Ratio Factor
$154
39
00
$122,650.00 X 1.26 .
is.'*AwNwerrrlb?cwmd t of WAN" GWA"o d.
100X 1lM°?.
2. Clock Appropriate BOx for Exsmpaon Clolmed
? WIN or intestate succession
errm a o.o•urip ?w w wnrtM
? Transfer to industrial Developmertt Agency
? Twirler to a trust (Attach Complete copy of atilt agreement kkwdffyrtp ON beneAdwies.)
? Transfer between principal and agent/straw party. (Attach copy a9orw0straw party agree ment)
? Transfers to the Conx cmalatth, the United States, and i»trumenta l ltlss by gift, ded , condom-oft or lieu of
condemnation. Of condemnoillon or in Neu of Condemnation, attach copy of resolution.)
® Transfer from mortgagor to a holder of a mortgage in defawil, (Attach copy of Mortgage notelAesignmertt)
Mortgage Book 1967, Pape 2®04
? Corrective or coMirmsto y deed (Attach copy of prior deed tiring corroded or confirmed)
? Statutory corporate consolidation, merger or division (Attach copy of articles.)
® Other (Please explain exemption claimed, N other than Paw above.)
? armh Jedleial Sa1e_ usutrauent tus 72 P.S. Secular 8102 Cif 161.
under penslhes of low, I deelans that I have uanttirrsd this 8hlenwnt, kn>kift scoamponying Inlomadlon, and to the beat of my
wC['a doom lets
krwwlsdse andbboYef, it to true
,
ar esartpMwA o IIM?rW? M
c Sett Esquire 7 _
1J2
PAR W TO COMPLEM T148 PORM PROPERLY OR ATTACH APPLICABLE DOCUMEIITATION MAY REBU T IN THE RECORDER`S RERIBAL
TO RECORD THE DEED
)13 a --j
(Al
r
ti
Py?
-J'J
Sheriffs Office of Cumberland County
R Thomas Kline ?Q tiiIV 01 ?urrtb"'/ i:uwaiu L o?iiutpp
Sheri 14 Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy c'rY; "r Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/19/2009 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: James S. Yeatter, 2 Andes Drive, Mechanicsburg, Cumberland
County, Pennsylvania, 17055 but was unable to locate him in his bailiwick he therefore returns the within
Complaint as not found as to the defendant, James S. Yeatter. Current resident advises the defendant no
longer resides here and the Post Office advises that mail is delivered to this address.
SHERIFF COST: $42.00
April 02, 2009
SO ANSWERS,
J
R THOMAS KLINE, SHERIFF
Docket NO. 2009-1665
Aurorua Loan Services, LLC v James S. Yeatter
FlLED--OF F IC?E.
OF THE P ROT :11"' OTA Y
2009 APR -3 Pik 3 37
`
PE4,13YEV i141i?
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AURORA LOAN SERVICES, LLC, CIVIL DIVISION
Plaintiff, NO.: 09-1665-CIVIL TERM
vs.
James S. Yeatter, et al :
Defendant. :
PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT
TO THE PROTHONOTARY:
Please mark the Complaint In Ejectment filed at the above-captioned
term and number reinstated.
Dated: April 17, 2009
ZUCKER, G BE & ACKERMAN, LLC
BY:
Scott A. Dietterick, squire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Richard P. Haber, Esquire; PA I.D. #202567
Eric Santos, Esquire; PA I.D. #201493
Joel A. Ackerman, Esquire; PA I.D. #202729
Attorneys for Plaintiff
XCP-103110/gg
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OR PIECE OF GROUND SITUATE IN-THE TOWNSHIP OF
KIDDER, COUNTY OF CARBON AND COMMONWEALTH OF PENNSYLVANIA,
BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN ON THE SOUTHERLY SIDELINE OF LAKE DRIVE, SAID
IRON PIN BEING NORTH 59 DEGREES, 50 MINUTES WEST A DISTANCE OF 100 FEET
FROM THE INTERSECTION OF THE SOUTHERLY SIDELINE OF LAKE DRIVE AND
THE WESTERLY SIDELINE OF OSCEOLA STREET. THENCE (1) ALONG THE .
WESTERLY SIDELINE OF LOT 5, ON A PLAN OF LOTS HEREINAFTER RECITED,
SOUTH 30 DEGREES, 10 MINUTES WEST, A DISTANCE OF 200 FEET TO AN IRON PIN
ON THE NORTHERLY SIDELINE OF LAKE VIEW STREET, THENCE (2) ALONG THE
NORTHERLY SIDELINE OF LAKE VIEW STREET, WEST 59 DEGREES, 50 MINUTES
WEST, A DISTANCE OF 50 FEET TO A PIPE; THENCE (3) ALONG LOT 1, NORTH 30
DEGREES, 10 MINUTES EAST, A DISTANCE OF 200 FEET TO AN IRON PIN ON THE
SOUTHERLY SIDELINE OF LAKE DRIVE; THENCE (4) ALONG THE SOUTHERLY
SIDELINE OF LAKE DRIVE, SOUTH 59 DEGREES, 50 MINUTES EAST, A DISTANCE OF
50 FEET TO THE POINT AND PLACE OF BEGINNING.
BEING ALL OF LOT 3 BETWEEN OSCEOLA AND CHURCH STREETS ON A PLAN OF
LOTS ENTITLED "PLAN OF BUILDING AT LAKE HARMONY" BASED ON SURVEY
MADE BY W.B_ TOMBLER, C.E. IN 1906, 1907, AND 1922 IN MAP BOOK 1, PAGE 17,
(FORMERLY MAP BOOK 1, PAGES 132 AND 133) OFFICE OF THE RECORDER OF
DEEDS, CARBON COUNTY, JIM THORPE, PENNSYLVANIA.
Tax Parcel I.D.: 19A-21C34
Being known as: 165 South Lake Drive, Lake Harmony, PA 18624.
BEING the same premises which HUGH A. CRAIG, JR., SINGLE, by Deed dated October 7,
1986 and recorded October 7, 1986 in and for Carbon County, Pennsylvania, in Deed Book
Volume 473, Page 417, granted and conveyed unto James T. Martino.
"Exhibit A"
Orr THE?' `" ?,ti,niAFY
2(309 APR 23 H 31 ' 4 i
r, ^, i. e F s n
{^ al i ,•
(?k ? do?i9a-
Sheriffs Office of Cumberland County
R Thomas Kline 0088 tits of C114(hr.., Edward L Schorpp
Sheri $ Solicitor
. "Y
Ronny R Anderson j Jody S Smith
Chief Deputy OFF SUE cr, '"E S4CRIrr Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/27/2009 09:00 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
27, 2009 at 2100 hours, he served a true copy of the within Complaint in Ejectment, upon the within
named defendant, to wit: Kristen Bisker, by making known unto Kristen Bisker, Occupant, at 2 Andes
Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $38.80
April 28, 2009
Docket No. 2009-1665
Aurora Loan Services, LLC v James Yeatter
SO ANSWE ,
A
R THOMAS IN , SHERIFF
D ty S eri
C)
c --n
- o -? ,
F17 i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
Plaintiff
VS.
James S. Yeatter
CIVIL DIVISION
No.: 09-1665-CIVIL TERM
ISSUE NUMBER:
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Ejectment)
Defendant(s).
I Hereby certify that the last known address
of Defendant(s) is/are:
2 An rive
MLefhanicsburg, PA 17055
At46fney for Plaintiff
FILED ON BEHALF OF:
Aurora Loan Services, LLC
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa I.D.# 55650 ,
Kimberly A. Bonner, Esquire
Pa I.D. 489705
Eric Santos, Esquire
Pa I.D. 4201493
Joel A. Ackerman, Esquire
Pa I.D. #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
(908) 233-8500
AttyFile No.: XCP-103110
Zucker, Goldberg & Ackerman, LLC
XCP-103110
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
Plaintiff,
VS.
James S. Yeatter
Defendant(s).
CIVIL DIVISION
NO.: 09-1665-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 Defendant(s), James S. Yeatter, for possession of the premises known as 2 Andes Drive,
Mechanicsburg, PA 17055.
ZU=.Dietterick, ERG & ACKERMAN, LLC
BY:
Dated: June 5, 2009 SEsquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Eric Santos, Esquire; PA I.D. #201493
Joel A. Ackerman, Esquire; PA I.D. #202729
Attorneys for Plaintiff
XCP- 10311 0/gg
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Zucker, Goldberg & Ackerman, LLC
XCP-103110
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire,
Eric Santos, Esquire, Joel Ackerman, Esquire, attorney for and authorized representative of
Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in
the military service of the United States of America to the best of his/her knowledge, information
and belief and certifies that the Notice of Intent to take Default Judgment was mailed in
accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
ZUCKER, BERG & ACKERMAN, LLC
Dated: June 5, 2009 By:
Sco A. ietterick, quire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Eric Santos, Esquire; PA I.D. #201493
Joel A. Ackerman, Esquire PA I.D. #202729
Atty File No.: XCP-103110
Sworn t and subscribed before me
This V)O
) of June, 2009
-E L My
Gamalielle G9'"mrd
A NOTARY PUBLIC res NEW JERSEY
My commision Expo
Zucker, Goldberg & Ackerman, LLC
XCP-103110
Exhibit "A'
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT, PARCEL OR TRACT OF LAND WITH IM(PROVENIENTS THEREON
ERECTED SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT OF INTERSECTION OF THE NORTHERN LINE OF ANDES DRIVE
AND THE WESTERN LINE OF CASCADE ROAD AS SHOWN ON PLAN OF SECTION 2, MT.
ALLEN HEIGHTS; THENCE ALONG THE WESTERN LINE OF CASCADE ROAD NORTH 3
DEGREES, 23 MINU rES EAST 129.42 FEET TO A POINT, THENCE IN A WESTERLY
DIRECTION ALONG THE SOUTHERN LINE OF LOT 2 AND 3 ON A PLAN OF SECTION 1, MT.
ALLEN HEIGHTS 119.13 FEET TO A POINT; THENCE ALONG THE EASTERN LINE OF LOT NO.
19 ON PLAN OF SECTION 2, MT. ALLEN HEIGHTS SOUTH 5 DEGREES, 7 MINUTES EAST 128
FEET TO ANDES DRIVE; THENCE ALONG THE NORTHERN LINE OF ANDES DRIVE NORTH
84 DEGREES,.53 MINUTES EAST 100 FEET TO 'THE POINT AND PLACE OF BEGINNING.
BEING LOT NO. 18, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID PLAN RECORDED IN
THE RECORDER OF DEEDS OFFICE OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAT
BOOK 12; PAGE 16.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 2 ANDES DRIVE, MECHANICSBURG, PA, 17055,
BEING THE SAME PREIVIISES WHICH SONDRA K ERB AND ROBERT L. ERB, WIFE
AND HUSBAND, BY DEED DATED MARCH 30, 2007 AND RECORDED APRIL 4, 2007 IN AND
FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 279, PAGE 2165,
GRANTED AND CONVEYED UNTO JAMES S. YEATTER
TAX MAP NO.: 42-28-2421-281.
Zudw, Ool&ag & A&amon, LLC
XCP-103110
Sheriffs Office of Cumberland County
R Tkomas Kline ? ? a, of lEi1t 8? Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy cz s it; ct "-i= SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/27/2009 09:00 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
27, 2009 at 2100 hours, he served a true copy of the within Complaint in Ejectment, upon the within
named defendant, to wit: Kristen Bisker, by making known unto Kristen Bisker, Occupant, at 2 Andes
Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $38.80
April 28, 2009
SO ANSWER ,
s
Docket No. . 2009-1665
Aurora Loan Services, L.LC v James Yeatter
R THOMAS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC CIVIL DIVISION
Plaintiff,
VS. NO.: 09-1665-CIVIL TERM
James S. Yeatter
Defendant.
IMPORTANT NOTICE
TO: , James S. Yeatter
2 Andes Drive
Mechanicsburg, PA 17055
DATE OF NOTICE: 5/19/2009
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 MAYBE 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 & LAWYE R RE FE RRAL SERVICE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
VS.
James S. Yeatter
Plaintiff,
Defendant.
TO: James S. Yeatter
2 Andes Drive
Mechanicsburg, PA 17055
CIVIL DIVISION
NO.: 09-1665-CIVIL TERM
AVISO IMPORTANTE
FECHA DEL AVISO:5/19/2009
USTED ESTA EN REBELDL4 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 DAPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO n0aDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFIaNA
ABAJO MICADA PARA QUE LE MFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
ZUCKER, GOLDBERG & ACKERMAN
BY: Scdt A. DIetta idk
Scott A. Dietterick, Esquire
Attorneys for Plaintiff'
PA I.D. # 55650
200 Sheffield Street, Suite 301
P. O. Box 1024
Mountainside, NJ 07092-0024
(717) 533-3560
FIRST CLASS U. S. MAIL, POSTAGE PREPAID 103110
FLED- Of"IC£
OF THE PEA z_I ; "-NO T APY,
2009 JUN 12 AM 10: 4 9
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
CIVIL DIVISION
Plaintiff, NO.: 09-1665-CIVIL TERM
VS.
James S. Yeatter
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: James S. Yeatter
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the
above captioned proceeding on U ?? h
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: for possession of the premises known as 2
Andes Drive, Mechanicsburg, PA 17055
putt'
Zucker, Goldberg & Ackerman, LLC
XCP-103110
~ ~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC
Plaintiff,
vs.
James S. Yeatter
Defendant.
Docket No.: 09-1665-CIVIL TERM
Execution No.:
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary of Cumberland County:
Please issue a Writ of Possession in the above-referenced matter for Plaintiffls possession
of the real property known and numbered as 2 Andes Drive, Mechanicsburg, PA 17055 and
more particularly described on Exhibit "A" attached hereto.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: June 5, 2009 BY:
Scott iettenck, Es re; PA I.D. #55650
Kimberly A. Bonner, Esquire; P.A.I.D. #89705
Eric Santos, Esquire; PA I.D. #201493
Joel A. Ackerman, Esquire; PA I.D. #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: XCP-103110
(908) 233-8500; (908) 233-1390 I~AX
Zucker, Goldberg & Ackerman, LLC
XCP-103110
Docket No.
09-1665-CIVIL TERM
Aurora Loan Services,-LLC
Plaintiff
Vs.
James S. Yeatter
Defendant
Where papers may be served:
Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
908-233-8500
Zucker, Goldberg & Ackerman, LLC
XCP-103110
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Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTA~T LOT, PARCEL OR TRACT OF LAND WITH IlvIPROVEMENTS THEREON
ERECTED SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT OF INTERSECTION OF THE NORTHERN LINE OF ANDES DRIVE
AND THE WESTERN LINE OF CASCADE ROAD AS SHOWN ON PLAN OF SECTION 2, MT.
ALLEN HEIGHTS;IT~NCE ALONG THE WESTERN LINE OF CASCADE ROAD NORTH 3
DEGREES, 23 NIINUTES EAST 129.42 FEET TO A POINT; THENCE IN A WESTERLY
DIRECTION ALONG THE SOUTHERN LINE OF LOT 2 AND 3 ON A PLAN OF SECTION 1, MT.
ALLEN HEIGHTS 119.13 FEET TO A POINT; THENCE ALONG THE EASTERN LAVE OF LOT NO.
19 ON PLAN OF SECTION 2, MT. ALLEN HEIGHTS SOUTH 5 DEGREES, 7'MINUTES EAST 128
FEET TO ANDES DRIVE; "THENCE ALONG THE NORTHERN LINE OF ANDES DRIVE NORTH
$4 DEGREES,.53 M]INU'I~S EAST 100 FEET TO THE POINT AND PLACE OF BEGINNING.
BEING LOT NO. 18, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID PLAN RECORDED IN
THE RECORDER OF DEEDS OFFICE OF CUMBERLAND COUNTY, PENNSYLVANIA, IIV PLAT
BOOK 12; PAGE 16.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 2 ANDES DRIVE, MECHANICSBURG, PA, 17055.
BEING THE SAME PREMISES WHICH SONDRA K. ERB AND ROBERT L. ERB, WIFE
AND HUSBAND, BY DEED DATED MARCH 30, 2007 AND RECORDED APRIL 4, 2007 IN AND
FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 279, PAGE 2165,
GRANTIED AND CONVEYED UNTO JAMES S. YEATTER.
TAX MAP NO.: 42-28-2421-281.
Zudktt, Go(dbttg 8c Adcortnan, I.I.C
XCP-103110
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Aurora Loan Services, LLC .
Docket No.: 09-1665-CIVIL TERM
Plaintiff, .
vs.
Execution No.:
James S. Yeatter .
Defendant.
WRIT OF POSSESSION
To the Sheriff of Cumberland County:
To satisfy the judgment for possession in the above matter you are directed to take
possession of the real property known and numbered as 2 Andes Drive, Mechanicsburg, PA
17055 and more particularly described on Exhibit "A" attached hereto.
rothonotary
Seal of the Court
Date: ~/a0~0~'
L'os~ts ~$ ao? . 3o P~ ~m
~ a.oo DUE C',d
Zucker, Goldberg & Ackerman, LLC
XCP-103110
AURORA LOAN SERVICES, LLC.,: IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 09-1665 CIVIL TERM
JAMES S. YEATTER,
Defendant CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this 10th day of August, 2009, by
agreement of the parties, hearing on the request for a
preliminary injunction is continued to November 12, 2009,
at 1:00 p.m. Pending said hearing, Plaintiff, Aurora Loan
Services, LLC, shall not enforce the writ of possession.
Edward E. Guido, J.
/ Evan C. Pappas, Esquire
For Petitioners Sondra K. Erb and Robert L. Erb
~ Scott A. Dietterick, Esquire
For the Plaintiff
James S. Yeatter
158 Springfield Road
Shippensburg, PA 17257
Defendant, Pro se
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