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Home My WebLink About09-2174 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE PO BOX 650043 Dallas, TX 75265-0043 Plaintiff vs. JOHN C. BYRNE and OCCUPANTS 142 South West Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Defendants CIVIL ACTION - LAW ACTION OF EJECTMENT Term e I/1 No. dl- d l7tl NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS. PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is FANNIE MAE, PO BOX 650043, Dallas, TX 75265-0043. 2. Defendants are JOHN C. BYRNE, and OCCUPANTS. 3. Plaintiff is the owner of property located at 142 South West Street, Carlisle, PA 17013, by virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on 2/27/2009 at Instrument # 200905640. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, JOHN C. BYRNE and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. GOLDBECK McCAFFERTY & McKEEVER L By: t ael McKeever, Esq. VERIFICATION I, 0 . '? ??`? on behalf of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4 relating to unsworn falsification to authorities. Date: `7 ?0 01 ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, wit: BEING that parcel of land bordered on the north by the property now or formerly of West Street A.M.E. Zion Church; on the East by South West Street; on the South by property now or formerly of Adin L.S. Otto and wife; and on the West by a 10 foot alley; having a frontage on South West Street of 30 feet, more or less, and extending in depth 95 feet, more or less to the alley in the rear. BEING KNOWN AS 142 SOUTH WEST STREET, CARLISLE PA 17013 TAX PARCEL NO: 04-21-0320-325 CJS OF T e F.FV 4,O10TARY 2009 APR -1 AM !Q: 41 CUf?4K? ILdLY'..t? 1vi??FY(? NSYNA NIA Pd - IS- V m ?V,? ?-N It/ op-za jl--?PU7 Sheriffs Office of Cumberland County Thomas Kline x`111%" of c'l,u+6rpf Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy FC,'=F = RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 06:30 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2009 at 1830 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Occupant, by making known unto Carrie Saussaman, adult in charge, at 142 S. West Street, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time handing to her personally the said true and correct copy of the same. 04/13/2009 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: John C. Byrne, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant John C. Byrne. Per tennant, Carrie Jean Saussaman, defendant John c. Byrne moved to Massachuseets 6 months ago. A possible address for the defendant s 27 Redwood Drive, Unit A New Haven, Connecticut 06513 per Carlisle Postmaster. SHERIFF COST: $53.50 April 24, 2009 2009-2174 Fannie Mae VS John C. Byrne SO ANSWERS R THOMAS KLINE, SHERIFF By (J ? y Deputy Sheriff I L El b'; "A PIV 2009 MAY 14 Nil 4: 24 C ? ... ,;f?, PE? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff FANNIE MAE PO BOX 650043 IN THE COURT OF COMMON Dallas, TX 75265-0043 PLEAS Plaintiff VS. of Cumberland County JOHN C. BYRNE CIVIL ACTION - LAW and OCCUPANTS 142 South West Street ACTION OF EJECTMENT Carlisle, PA 17013 Defendants Term No. 09 civil 2174 PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, FANNIE MAE and against the Defendants JOHN C. BYRNE and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237. 1, written 10 day notice of Plaintiff s intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is FANNIE MAE, PO BOX 650043, Dallas, TX 75265-0043 and that the names and last known address of the Defendants are JOHN C. BYRNE and OCCUPANTS 142 South West Street, Carlisle, PA 17013. W - /` GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff f 1L.I..??J ?.s {Ta I?, L.. ?? ZO09 HAY 2' I F -1 ?: 5 t C 3QG`72. GOLDBECK MCCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE PO BOX 650043 Dallas, TX 75265-0043 Plaintiff Vs. JOHN C. BYRNE and OCCUPANTS 142 South West Street Carlisle, PA 17013 Defendants DATE OF THIS NOTICE: May 8, 2009 TO: JOHN C. BYRNE 142 South West Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 09 civil 2174 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 -T GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attomey for Plaintiff ? ?? ?;?•? ;_}? ? s?i`: ? ??? w r ;? ?., a _ tier ?. << GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE PO BOX 650043 Dallas, TX 75265-0043 Plaintiff Vs. JOHN C. BYRNE and OCCUPANTS 142 South West Street Carlisle, PA 17013 Defendants DATE OF THIS NOTICE: May 8, 2009 TO: OCCUPANTS 142 South West Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 09 civil 2174 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 GOLDBECK WCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff uEu, ^T; 9 tk» If`?t ?,?. ?. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff FANNIE MAE PO BOX 650043 Dallas, TX 75265-0043 Plaintiff VS. JOHN C. BYRNE and OCCUPANTS 142 South West Street Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL, ACTION - LAW ACTION OF EJECTMENT Term No. 09 civil 2174 CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Michael T. McKeever, Esquire, attorney for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: JOHN C. BYRNE OCCUPANTS 142 South West Street Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: I?. Michael T. McKeever, Esq. Attorney for Plaintiff DATED: May 20, 2009 FIL,P I-C 2009 ft-Vol 2 i Fh 1: 5 f 1 e i ? J? VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JOHN C. BYRNE, is about unknown years of age, that Defendant's last known residence is 142 South West Street Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: t `,l `` , ?Py C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland SEE ATTACHED LEGAL DESCRIPTION Atelx tiIt "hk-c? i4? GOLDBECK, McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney for Plaintiff Ejectment Quiet Title A. 5 - 116 (Rev. 10/76) FANNIE MAE PO BOX 650043 Dallas, TX 75265-0043 JOHN C. BYRNE and OCCUPANTS 142 South West Street Carlisle, PA 17013 Plaintiff VS. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 09 civil 2174 Defendants PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter, for possession of 142 South West Street Carlisle. PA 17013 (describe property) C.? l? i 11 RY 2009 MAY a- it F3 a = .o 4& ? 3'? aU-1? 1??5?? ? 7x 3? d a- Y CA . a ALL THAT CERTAIN tract of land situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, wit: BEING that parcel of land bordered on the north by the property now or formerly of West Street A.M.E. Zion Church; on the East by South West Street; on the South by property now or formerly of Adin L. S. Otto and wife; and on the West by a 10 foot alley; having a frontage on South West Street of 30 feet, more or less, and extending in depth 95 feet, more or less to the alley in the rear. BEING KNOWN AS 142 SOUTH WEST STREET, CARLISLE PA 17013 TAX PARCEL NO: 04-21-0320-325 R Thomas Kline Sheriff Sheriffs Office of Cumberland County 4ova? of caaaberi,? j? 't' OFFICE OF NE SKSW Edward L Schospp Solicitor Ronny R Anderson Chief Deputy Jody S Smith CiWl Process Sergeant SHERIFF'S RETURN OF SERVICE 04113/2009 06:30 PM - Valerie Weary, Deputy Sheriff, who being duty sworn according to law, states that on April 13, 2009 at 1830 hours, she served a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Occupant, by making known unto Carrie Saussaman, adult in charge, at 142 S. West Street, Carlisle, Cumberland County, Pennsylvania, 17013, b contents and at the same time handing to her personally the said true and correct copy of the same. 04/13J2009 R. Thomas Kline, Sheriff, who being duty sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John C. Byrne, but was unable to locate him In his balliwick. He therefore retums the within Complaint and Notice as not found as to the defendant John C. Byrne. Per tenant, Carrie Jean Saussaman, defendant John c. Byre moved to Massachuseets 8 months ago. A possible address for the defendant s 27 Redwood Drive, Unit A New Haven, Connecticut 06513 per Carlisle Postmaster. SHERIFF COST: $53.50 April 24, 2009 2009-2174 Fannie Mae VS John C. Byrne SO ANSWERS R THOMAS KLINE, SHERIFF By ?? 1--y Deputy Sheriff W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE VS. No. 09-2174 Civil Term Costs Attorney's $ 170.00 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) FANNIE MAE being: (Premises as follows): 142 SOUTH WEST STREET, CARLISLE, PA 17013 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. C s R. Long, o aryCommon Pl as Court of C berland County, PA Date MAY 21, 2009 (Seal) -r 2of2 No 09-2174 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE VS. JOHN C BYRNE AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Atfy $ 170.00 Plff (sj $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T MCKEEVER ESQ 701 MARKET STREET, PHILADELPHIA, PA. 19106-1532 215-825-6319 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of , . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy Sheriffs Office of Cumberland County R Thomas Kline 1101110 of cumbrr14414 Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFCE OF f,4E S4sRJFr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/28/2009 08:52 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 2052 hours this Writ of Possession upon defendant John C. Byrne is returned not found. Per current resident, Kerry Saussaman, Byrne moved out. Per Carlisle Post Office, a possible address is 27 Redwood Drive, Unit A, New Haven, Connecticut 06513. 05/2812009 08:52 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 2052 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupant(s), by making known unto Kerry Saussaman, occupant, at 142 S West Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 2009-2174 e Mae So An r?? Fanni ,--? ? VS John Byrne R. Thomas Kline, Sfieriff By ZJOL- 'Odrp%ty Sheri m hi _ f E-D N ,., R Sheriffs Office of Cumberland County R Thomas Kline ~~~=i ~-'~)';-' i'. r Sheri 1 r - Ronny R Anderson Chief Deputy ~~ F9 ~~i_ l ~ ~"~f`i L' ~ Jody S Smith i ` ~,~' Civil Process Sergeant of=.cE :. - .: ~ ~ct~r~ ~~ ~ ~ ~. ~.. Edward L Schorpp Solicitor Fannie Mae Case Number vs. Occupant(s) 2009-2174 SHERIFF'S RETURN OF SERVICE 05/28/2009 08:52 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 2052 hours this Writ of Possession upon defendant John C. Byrne is returned not found. Per current resident, Kerry Saussaman, Byrne moved out. Per Carlisle Post Office, a possible address is 27 Redwood Drive, Unit A, New Haven, Connecticut 06513. 05/28/2009 08:52 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 2052 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupant(s), by making known unto Kerry Saussaman, occupant, at 142 S West Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 07/13/2009 03:25 PM - By virtue of this writ, on the 13th day of July, 2009, Sheriff R. Thomas Kline caused the within named Fannie Mae to have possession of the premises described as 142 South West Street, Carlisle, PA 17013. SHERIFF COST: ~ 50 .43 ,/ ryl~~ ~v rj SO ANSWERS, July 14, 2009 (~'~ a- ~~' c'.~, 707'1 L R OMAS KLINE, SHERI~`F , ~ ,,. By virtue of this writ, on the 13th day of July 2009 the within named Fannie Mae , I caused of the premises described , to have possession 1 'A 1701 Sworn and subscribed to before me this Day of Sheriff s Return Docketing Poundage Prothonotary Mileage Surcharge $ 18.00 .99 2.00 9.00 20.00 $ 50.43 So Answers, ~f j Sheriff By Advance Costs $ 150.00 Sheriffs Costs 50.43 $ 99.57 2of2 No 09-2174 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE VS. JOHN C BYRNE AND OCCUPANTS WRIT OF POSSESSION P.RC.P. 3160-3165 ETC. Costs Att'y $ 170.00 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T MCKEEVER ESQ 701 MARKET STREET, PHILADELPHIA, PA. 19106-1532 215-825-6319 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy