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Home My WebLink About00-05005FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. Vs. CIVIL ACTION - LAW BRADEN R. KING AND BECKI J. KING IN EJECTMENT Defendants N O T I C E 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 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 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. COURT C?wr,S . Co .?-so VeHRT-HLOaR 2 ?C b ,Qv? . C4?-Q?{?]?6'Q44AT HO74CF ??? SOUTH A !k?lb CARLISLE, PA 17013 (717)240-6200 N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes Para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE SOUTH HANOVER STREET CARLISLE, PA 17013 (717)240-6200 FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 0a0- sus( VS. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants C O M P L A I N T 1. Plaintiff, Fleet Mortgage Corp., is a corporation with an office located at Post Office Box 1169, Milwaukee, Wisconsin 53201- 1169. 2. Defendants, Braden R. King and Becki J. King, are adult individuals whose last known precise residence is 141 East North Street, Carlisle, Pennsylvania 17013. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 7, 2000, Defendant was the owner of certain real property known as 141 East North Street, Carlisle, Pennsylvania 17013. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on June 7, 2000, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 95-4919 Civil Term at the suit of Fleet Mortgage Corp. vs. Braden R. King and Becki J. King. 6. The aforesaid property was purchased at sale by Fleet Mortgage Corp., the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendants are presently in possession of the said premises, having come into said possession by virtue of their prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "BIT. WHEREFORE, Plaintiff demands judgment against Defendants in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: July 13, 2000 ALL THAT CERTAIN MESSAUGE AND LOT OF THE GROUND IN THE FIRST WARD OF THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND THE COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE SOUTH BY EAST NORTH STREET; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN REMPER; ON THE NORTH BY AN ALLEY; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF ROY F MCCOY. CONTAINING 24 FEET IN FRONT ON EAST NORTH STREET AND EXTENDING IN DEPTH AN AN EVEN WIDTH 118 FEET. KNOWN AS 141 EAST NORTH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Richard A. Fair by deed dated and recorded 5/30/89 in Cumberland County Deed Book Y-33 Page 1145 granted and conveyed unto Braden R. King and Becki J. King. EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on June 7, 2000. 2. Deed from Richard A. Fair dated May 30, 1989 and recorded May 30, 1989, in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book Y-33, Page 1145, to Braden R. King and Becki J. King. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.s. §4904 relating to unsworn falsification to authorities. Leon P. Hal er Dated: July 13, 2000 SHERIFF'S RETURN - REGULAR CASE NO: 2000-05005 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE CORP VS KING BRADEN R ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon KING BRADEN R DEFENDANT the , at 0018:33 HOURS, on the 25th day of July , 2000 at 141 EAST NORTH ST CARLISLE. PA 17013 by handing to BRADEN R. KING (ONLY OCCUPANT) a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31.10 Sworn and Subscribed to before 0 So Answers:??? R. Thomas Kline 07/26/2000 PURCELL, KRUG & E By: eputy Sheriff FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. OCR--51665 OIU VS. CIVIL ACTION - LAW BRADEN R. KING AND BECKI J. KING Defendants IN EJECTMENT N O T I C E 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 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 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. n-- evURT OR l_Lc?vve . W 3??FRSO[E?tcav TRUE COPY FROM RECORD a. ki t" Aor, in TestNroony whereof, I tyre 010 silt my HOUSE IJ U i 3 Sod ;toe s®ai of said C rf W Cariisie, Pa- CARLISLE, PA 17013 a t{9_ 3 !1. (. T -7,1 , day pfi LEPHONE (717)240-6200 onowy? N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fe,cha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE SOUTH HANOVER STREET CARLISLE, PA 17013 TELEPHONE (717)240-6200 I FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. vs. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants C O M P L A I N T 1. Plaintiff, Fleet Mortgage Corp., is a corporation with an office located at Post Office Box 1169, Milwaukee, Wisconsin 53201- 1169. 2. Defendants, Braden R. King and Becki J. King, are adult individuals whose last known precise residence is 141 East North Street, Carlisle, Pennsylvania 17013. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 7, 2000, Defendant was the owner of certain real property known as 141 East North Street, Carlisle, Pennsylvania 17013. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on June 7, 2000, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the court of Common Pleas of Cumberland County, No. 95-4919 Civil Term at the suit of Fleet Mortgage Corp, vs. Braden R. King and Becki J. King. 6. The aforesaid property was purchased at sale by Fleet Mortgage Corp., the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendants are presently in possession of the said premises, having come into said possession by virtue of their prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendants in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: July 13, 2000 ALL THAT CERTAIN'MESSAUGE AND LOT OF THE GROUND IN THE FIRST WARD OF THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND THE COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE SOUTH BY EAST NORTH STREET; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KEMPER; ON THE NORTH BY AN ALLEY; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF ROY F MCCOY. CONTAINING 24 FEET IN FRONT ON EAST NORTH STREET AND EXTENDING IN DEPTH AN AN EVEN WIDTH 118 FEET. KNOWN AS 141 EAST NORTH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Richard A. Fair by deed dated and recorded 5/30/89 in Cumberland County Deed Book Y-33 Page 1145 granted and conveyed unto Braden R. King and Becki J. King. EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on.June 7, 2000. 2. Deed from Richard A. Fair dated May 30, 1989 and recorded May 30, 1989, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book Y-33, Page 1145, to Braden R. King and Becki J. King. EXHIBIT "B" ' T VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Leon P. Haller Dated: July 13, 2000 L rUIA A o '?i11 to A FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00 -:CDO5 Cecjil? VS. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants N O T I C E 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 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 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. TRUE COPY FROM RECORD In Te irmny whereof, I here unto set my and the Seal of said Co4rt at Carlisle, ?_Pa. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249 3166 or 1 800 990 9108 00 N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de Is demands y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes pars. usted. r LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE SOUTH HANOVER STREET CARLISLE, PA 17013 (717)240-6200 (. FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. BRADEN R. KING AND BECKI J. KING Defendants NO. CIVIL ACTION - LAW IN EJECTMENT C O M P L A I N T 1. Plaintiff, Fleet Mortgage Corp., is a corporation with an office located at Post Office Box 1169, Milwaukee, Wisconsin 53201- 1169. 2. Defendants, Braden R. King and Becki J. King, are adult individuals whose last known precise residence is 141 East North Street, Carlisle, Pennsylvania 17013. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to June 7, 2000, Defendant.was the owner of certain real property known as 141 East North Street, Carlisle, Pennsylvania 17013. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on June 7, 2000, after due advertisement according to law, under and by virtue _ au of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 95-4919 Civil Term at the suit of Fleet Mortgage Corp. vs. Braden R. King and Becki J. King. 6. The aforesaid property was purchased at sale by Fleet Mortgage Corp., the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendants are presently in possession of the said premises, having come into said possession by virtue of their prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendants in Ejectment for recovery of premises described in Exhibit "A" attached hereto and made a part hereof, plus costs of suit. 1 11 PURCELL, KRUG & HALLER By: Leon P,. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: July 13, 2000 ALL THAT CERTAIN''MESSAUGE AND LOT OF THE GROUND IN THE FIRST WARD OF THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND THE COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE SOUTH BY EAST NORTH STREET; ON THE BAST BY PROPERTY NOW OR FORMERLY OF JOHN KEMPER; ON THE NORTH BY AN ALLEY; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF ROY F MCCOY. CONTAINING 24 FEET IN FRONT ON EAST NORTH STREET AND EXTENDING IN DEPTH AN AN EVEN WIDTH 118 FEET. KNOWN AS 141 EAST NORTH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Richard A. Fair by deed dated and recorded 5/30/89 in Cumberland County Deed Book Y-33 Page 1145 granted and conveyed unto Braden R. King and Becki J. King. EXHIBIT "A" Y PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on June 7, 2000. 2. Deed from Richard A. Fair dated May 30, 1989.and recorded May 30, 1989, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book Y-33, Page 1145, to Braden R. King and Becki J. King. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Leon P. Haller Dated: July 13, 2000 .. _ ?? L FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-05005 P VS. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT FOR POSSESSION OF REAL PROPERTY TO THE PROTHONOTARY: Enter default judgment in ejectment for possession of the premises 141 East North Street, Carlisle, Pennsylvania 17013, described in the attached legal description in favor of Plaintiff and against the Defendant, Braden R. King, and his successors, heirs and assigns for failure to answer the Complaint within twenty (20) days after service thereof on July 25, 2000. I hereby certify that the Notice of Default required by Pa.R.C.P. 237.1 was mailed to Defendant above named on August 16, 2000. PURCELL, KRUG & HALLER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: August 28, 2000 FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-05005 P VS. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants NOTICE OF ENTRY OF JUDGMENT BY DEFAULT TO: Braden R. King Defendant in the above action You are hereby notified that on , 2000, Judgment by Default has been entered against you in the above action for possession of the real property described in the attached legal description, for the reason that you failed to file an Answer to the Complaint within 20 days after the said Complaint was served upon you on July 25, 2000. 2• othonotary I hereby certify that the names and address of the proper persons to receive this notice under Pa.R.C.P. 236 is: BRADEN R. KING 141 EAST NORTH STREET CARLISLE, PA 17013 i Lel5n P' Haller Attorney for Plaintiff FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-05005 P vs. BRADEN R. KING AND BECKI J. KING Defendants TO: BRADEN R. KING 141 EAST NORTH STREET CARLISLE, PA 17013 CIVIL ACTION - LAW IN EJECTMENT DATE OF NOTICE: AUGUST 16, 2000 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 NOTICE TO A 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. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE SOUTH HANOVER STREET CARLISLE, PA 17013 TELEPHONE (717)240-6200 PURCELL, KRUG & LER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-05005 P vs. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN ) LEON P. HALLER, attorney for Plaintiff, being duly sworn according to law, deposes and says that he is a duly constituted representative for the Plaintiff in the above captioned action; that he is duly authorized to make this affidavit; that he has personal knowledge, information and belief, that Defendant of the real estate described in the Complaint are not in the Military or Naval Services of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. Leon P. Haller a Attorney for Plaintiff SWORN to and subscribed before me this ? f3ay of , 2000. Notary Public my commission expires: (SEAL) Notarial Seal 7Bonita E. Prussack, Notary Public Harrisburg, Dauphin County y ommission Expires Sept. 24, 2001 FLEET MORTGAGE CORP. IN THE COURT OF COMMON PLEAS COUNTY, PENNSYLVANIA Plaintiff NO. 2000-05005 P Vs. CIVIL ACTION - LAW IN EJECTMENT BRADEN R. KING AND BECKI J. KING Defendants ENTRY OF JUD/GLMENT BY DEFAULT AND NOW, on this &; day of 2000, default judgment is hereby entered against the Defendant, Braden R. King, and his successors, heirs and assigns, in ejectment for possession of the premises described in the attached legal description. ?P othonotary ALL THAT CERTAIN HESSAUGE AND LOT OF THE GROUND IN THE FIRST WARD OF THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND THE COMMONWEALTH OF PENNSYLVANIA, BOUNDED_AND DESCRIBED AS FOLLOWS: ON THE SOUTH BY EAST NORTH STREET; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KEMPER; ON THE NORTH BY AN ALLEY; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF ROY F MCCOY. CONTAINING 24 FEET IN FRONT ON EAST NORTH STREET AND EXTENDING IN DEPTH AN AN EVEN WIDTH 118 FEET. KNOWN AS 141 EAST NORTH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Richard A. Fair by deed dated and recorded 5/30/89 in Cumberland County Deed Book Y-33 Page 1145 granted and conveyed unto Braden R. King and Becki J. King. FLEET MORTGAGE CORP. Plaintiff VS. BRADEN R. KING AND BECKI J. KING Defendants X, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-05005 P CIVIL ACTION - LAW IN EJECTMENT PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue a Writ of Possession against Braden R. King in the above matter for the possession of the premises set forth in the attached legal description. PURCELL, KRUG & HALLER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: August 28, 2000 ALL THAT CERTAIN MESSAUGE AND LOT OF 196 GROUND IN THE FIRST WARD OF THE BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND AND THE COMMONWEALTH OF PENNSYLVANIA, BOUNDED.AND DESCRIBED AS FOLLOWS: ON THE SOUTH BY EAST NORTH STREET; ON THE EAST BY PROPERTY NOW OR FORMERLY OF JOHN KEMPER; ON THE NORTH BY AN ALLEY; AND ON THE WEST BY. PROPERTY NOW OR FORMERLY OF ROY F MCCOY. CONTAINING 24 FEET IN FRONT ON EAST NORTH STREET AND EXTENDING IN DEPTH AN AN EVEN WIDTH 118 FEET. KNOWN AS 141 EAST NORTH STREET, CARLISLE, PA. BEING THE SAME PREMISES WHICH Richard A. Fair by deed dated and recorded 5/30/84 in Cumberland County Deed Book Y-33 Page 1145 granted and conveyed unto Braden R. King and Becki J. King. C7 azru G:D 1 I J t ^ ? 1 N• z ro I 1 1 1 1 1 G I 1 1 1 1 1 1 I 1 I I - - I ? I ?-` I H I I 1 I ' !( D ? Ip1f I t 1 I j ? I 1 l I 1 I I I F- rt V i I i+ ? I r J i i t? I Ul F' i 1 I I I I 3 - 1 - I I N 1 1 0 l rt ,LR ? I ? ' ? 1 ? N I h' I. I . I I v T I ? I (p i ? ? 1 I I I i CO d .a i i t -pq--za I 1 -W I 1 Q I I 1 1 I I I I I 1 1 I ? I 1 I I C=>; i m ?i r V U -y n Z H ?- ? ? y ? yTiil 1 CTJHM O I oz v io yx ;° J x G7 b7 n `"1 i ? f? O U1 n X n 1 `' W A ? ? ^ i I w n r H p ># I 4 z c? > :17 z n i 1 By virtue of this writ, on the _--kpurth_ ----------dav of _--___ October--------------------- M-2001 I caused :he within n=ed -------------' ----------------------------------------------- to have possession of the premises described with the appurtenances- and --------------------------------------- NO ACTION TAKEN IN SIX MONTHS ----------------------------------------------------------------------------------------------------- Sheriff's Costs-:---$-42.94 Refund:-$--57.06 - ----------------------------------------------- R I r dgS tiworn and subscribed ro beto*e me this l--'-?-.---__ dav of Cgzz wa_-------- dYd3k '-S I -- .. s_ KF.L.?T ------_---- ' prcahonotarr o. Afls5YC*3: _______________________-_ yilerlif id ___-_________.___-- B--uty. (? ?t \ d? WRIT OF POSSESSION (Ejectment Proceedings PRC P 3160 - 3165 etc) FLEET MORTGAGE CORP. IN THE COURT OF CONnION PLEAS OF --------- ------- - - -------------------- CUMBERLAND COUNTY. PENNSYLVA: ' ,A 00=5005 -CI'd ______---- Term 19______ ---------------------------------- - - No. ------------------------------- Term 19------ Costs BRADEN-R. KING AND BECKI J. KING 141 EAST NORTH STREET f CARLISLE,.2A_17013-- Att'v. Pl'ff (S' Prothy. ,3_122 - __ 100_ 60 - 3-----•------- x_____1=00 CO;Vr V[0NWE,UTH OF PENNSYLV ANLA.; COUNTY OF CUNI'SERL.-vD: To the Sheriff of ------ Cumberland --------- County, Penna. i;1) To satisfy the judgment for possession in zhe above matter you are directed to deliver possession aif the fo4lowing described property to: Fleet Mortgage Corp. being : ( Premises as follow) : 141 East North Street Carlisle, PA 17013 Plaintiff !sl (2) To satisiv the casts against the defendant (s) you are directed to levy upon any pmperv of the defen- dant -,s) and Ses; his her :;or their) interest merein. Curtis R. Long .--------------------------------------------------. Prothonotary, Common ?teas Court of Cumberland County. Penna. September 6, 2000 Date --------_-----------------SE..i, `---'------- (, ) DePtry