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Home My WebLink About04-2147 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA LAND HOLDING, LLC., Plaintiff, vs. KIRAN KUMAR DANDAPAT, Defendant. TO DEFENDANT You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF /.'1 (')_ / /). !~. 1'u~.z.L'{!:YJ...L,f-K-{~ ATTOR'~ PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 620 Liberty Avenue Pittsburgh, P A 15222 AND THE DEFENDANT IS: 852 Erford Road East Pennsboro, P A 17011 ,-JAl.esJ.L C filv(a./Jj-(J- A TIO~Y FOR PLAINTiFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL EST ATE AFFECTED BY THIS LIEN IS Township of East Pennsboro (CITY, BORO, TOWNSH~ . (WARD) J)I0.JMA'YJ!L(L~ ATTO~Y FOR PLAINTIFF CIVIL DIVISION NO.: O~. ~ 14 '7 TYPE OF PLEADING CIVIL ACTION-COMPLAINT IN EJECTMENT FILED ON BEHALF OF PLAINTIFF: Land Holding, LLC COUNSEL OF RECORD FOR THIS PAR TV: Kristine M. Anthou, Esquire Pa. LD. #77991 GRENEN & BIRSIC, P.c. One Gateway Center 9 West Pittsburgh, P A 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, LLC, CIVIL DIVISION NO.: Plaintiff, vs. KIRAN KUMAR DANDAPAT, Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyet Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL DIVISION NO.: OLJ ~ .21 't'" LAND HOLDING, LLC, vs. KlRAN KUMAR DANDAPAT, Defendant. CIVIL ACTION - COMPLAINT IN ETECTMENT Land Holding, LLC, by its attorneys, Grenen & Birsic, P.c., files this Complaint in Ejectment, as follows: 1. Plaintiff is a lending institution duly authorized to conduct business in the Commonwealth of Pennsylvania with a place of business located at 620 Liberty Avenue, Pittsburgh, PA 15222. 2. The Defendant, Kiran Kumar Dandapat is an individual whose last known address is 852 Erford Road, East Pennsboro, PA 1701 L 3. On or about March 3, 2004, the real property and improvements thereon commonly known as 852 Erford Road, East Pennsboro, P A 17011 (hereinafter "Premises") were sold to Plaintiff pursuant to the Sheriffs Sale in Cumberland County. A true and correct copy of the Sheriffs Deed to said property is marked as Exhibit "A", attached hereto and made a part hereof. 4. At the time of the Sheriff Sale, Defendant was occupying the Premises. 5. Plaintiff, by virtue of said Sheriffs Sale, is the owner of the Premises and therefore right to immediate possession and title to the Premises is in Plantiff and not in Defendant. 6. On April 8, 2004, counsel for Plaintiff sent written notice to the Defendant to vacate the Premises on or before April 23, 2004. A true and correct copy of said Notices are marked Exhibit "B", attached hereto and made a parr hereof. 7. Defendant is unjustly and unlawfully occupying, using and enjoying the Premises without right and to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant for possession of the Premises known as 852 Erford Road, East Pennsboro, P A 170ll, together with such other relief as this Honorable Court may deem necessary. GRENEN & BIRSIC, P.c. BY, ~/k JL L K.~~<-~__ KriS~i~. Anthou, Esquire ,. PA ID. #77991 Attorneys for Plaintiff Nine West, One Gareway Center Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT A ... " ~q a~\ e.- . . . . "'-:~';~H.T P. ZIEGLER : c:. ", ,: I" 'J'r'- 0;:' E ~Ll <:: :'.."..1.....". I,.,. ..... .:hU\~iD COUtlTY-i Tax Parcel No. 09-17-1044-060 Know all Men by these Presents 'I PiHR 23 Af'J 8 y~ That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to Land Boldinl!. LLC REAL ESTATE SALE No.7 Writ No. 2001-3821 Civil Term Washington Mutual Home Loans. VIVa PNC Mortgage Corp. of America YS Klran Kumar Dandapat Atty: Kristine Anthou DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on Erford Road at the dividing line between Lots Nos. 16 and 16 (x) on the hereinafter mentioned Plan of Lots; thence along said Erford Road South 89 degrees 50 minutes East 37.5 feet to a point at the line dividing Lots Nos. 16 (x) and 17; thence along said dividing line South 0 degrees 10 minutes West ISO feet to a point; thence North 89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees 50 minutes West 37.5 feet to a point; thence North 89 degrees 50 minutes West 37.5 feet to the line dividing Lots Nos. 16 (s) and 16; thence along said dividing line North 0 degrees 10 minutes East 150 feet to the point of BEGINNING. BEING Lot No. 16(x) on Plan No. 19 of Ridley Pork as recorded in the Cumberland County Re-corder's Office in Plan Book 22, Page 64. HAVING thereon erected a dwelling house known and num-bered as 852 Erford Road. UNDER AND SUBJECT to the Easement of a sanitary sewer line as shown on the .foresaid plan. TOGETHER with all and singulor, the tenements, heredita-ments and appurtenances to the same, belonging or in any way appertaining, and the reversion and reversions, remainder and re-mainders, rents, issues, and profits thereof; And Also, aU the estate, right, title, interest, property, claim and demand whatsoever, both in law and equity, of the said Parties of the First part, of, in, to or out ofthe said premises, and every part and porcel thereof. BEING the same premises which Pin Hui Kuo and Kuei Ying Kuo (aIkIa Kuei Hui Kuo), his wife, by deed dated March 29,1996 and recorded on April I, 1996 in the Office of the Recorder of Deeds for Cumberland County in Deed Book Volume 136, Page 965, granted and conveyed unto Kiran Kumar Dandapat. DBV: 136; Page 965; TAX PARCEL NO.: 09-17-1044-060. iieOK 262~rsc. 763 . . The same having been sold by me to the said grantee on the 3rd day of March Anno Domini Two Thousand and Four (2004) after due advertisement according to law, under and by Virtue ofa Writ of Execution issued on the 9th day of September Anno Domini M!l!J. out of the Court of Common Pleas ofCumberJand County, Pennsylvania, as of Civil Term, Two Thousand and ~ (200n Number 3821 at the suit of Was hi net on Mutual Home Loans, flkla PNC Mortl!al!e Corp. of America against Kiran Kumar Dandapat. BOOK 262 rAGE 764 . . . . In Witness Whereof, I have her.eunto affixed my signature this 2 2ndday of March Anno Domini Two Thousand and Four (2004) ~/ '/' .' ~L ~ . R. homas Kline, S . ff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 22ndday of Mar .Anno Domini Two Thousand and Four (2004) ~~:t pro~:~ ~ NOTARIAl PR01llONOTAllY. NOTARY pus,Ie CARUSlE CUMBERlAND COUNlY COliR; MOUSE MY COMMISSION EXPIRES JANIJMY 2, 2006 I hereby certify that the residence And Post Office address of the Within Grantee is Two PNC Plaza. 19th Floor 620 Libertv Avenue Pittsbureh, PA 15222 aOOK "6"" " I", Jr.'- .1,is to be recorded ,,''''''land County PA ~ ~~'; ~iiR:e< ofDeeds FACE 765 EXHIBIT B . . GRENEN & BIRSIC, P.c. ATTORNEYS AT LAW ONE GATEWAY CENTER NINE WEST PITISBURGH. PA \5222 (4\2)281-7650 FAX (412) 281-7657 EMAIL KA,\TIiOtHd'GRENE\'B1RSIC.COM April 8, 2004 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL, POSTAGE PREPAID Kiran Kumar Dandapat or Current Occupant 852 Erford Road East Pennsboro, P A 17011 RE: NOTICE TO VACATE Dear Mr. Dandapat or Current Occupant: As you may be aware, this firm represents Land Holding, LLC in connection with the above- captioned matter. As you may also be aware, Landing Holding, LLC purchased the property at a sale conducted by the Sheriff of Cumberland County on March 3, 2004. Accordingly, Land Holding, LLC is now the record title owner of the property. Our client has recently informed me that you remain on this property. The purpose of this letter is to notify you that you must vacate the premises on or before fifteen (1 5) days from the date of this letter. If you fail to vacate the premises on or before that date, Land Holding, LLC will institute fonnallegal action to have you removed from the premises. I trust that such will not be necessary. If you have any questions, please feel free to contact me. . Very truly yours, ~~ct1l a~tJ"L.- Kristi~M. Anthou [I U ~(/) . i ~. ~ %~ :;:) "s '); ~ ,Wi; ~ a "- ,,~ N j~~ N ~.;~ ..~- ,,\;j-- ~\f-e . .'~ 0 \)- <.'\ '" _ .:..... "\J ~ :'i jJ d\.~~' ~ L t ~ ~h~..~a!l "090 905~ 5000 0922 EOOL 1 ; - ell "" 3 "" c Z ..,;-N u",,"" Q;c~ u..a.z..... .--- ell ..._ ,~ cae... a:I;;;.c oll~e' c...~ a:Cl.= c en a:""= ~tEc5a:: u. 1 '" 1....; ,_ .", ~l t\. , J j 0 0"1 \. () ~ ~~ f) D " ;; ~ \) .. l,>~j 1l "'\l "" ~ ~ , 5 ~ r 0 ,. . \; '+~ ".:3.. .. ] 1.0+ ~5N'--' ... \) l/) Ii . '> ,\ 5~OO'-v "- t'v) ....., "- o ( ('-' '-['- 8 '" ~ . , c . ~ ,.: ~ tll E "- en tL VERIFICATION The undersigned, Kathleen S. Calhoun, a duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint are true and correct to her information and belief. Kat ets/{1to~~p ~-o""9- r; CY & . , ~ ~o() D 0 r-- 9-:> ~ --c:... ...p ,h...j ~;:~ :-~ ..JC.u ., .-{ --,-- r;': ,.-1 .. , l.-~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02147 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAND HOLDING LLC VS KIRAN KUMAR DANDAPAT R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DANDAPAT KIRAN KUMAR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , DANDAPAT KIRAN KUMAR 852 ERFORD ROAD EAST PENNSBORO, PA 17011 852 ERFORD ROAD EAST PENNSBORO IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 S~~ R. Thomas Kline Sheriff of Cumberland County GRENEN & BIRSIC OS/21/2004 Sworn and subscribed to before me this cv J.t.- ~ day of .~ ;J..w'( A. D . ,/)"7(" Q Yj,ttP"'d, ~ '-4:tothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CIVIL DIVISION LAND HOLDING, LLC., Plaintiff, NO.: 04-02147 Ys. TYPE OF PLEADING: KIRAN KUMAR DANDAPAT, Defendant. MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT TO SPECIAL ORDER OF COURT CODE- FILED ON BEHALF OF PLAINTIFF: Land Holding, LLC. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa.LD.#7799I GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CIVIL DIVISION LAND HOLDING, LLC., NO.: 04-02147 Plaintiff, vs. KIRAN KUMAR DANDAPAT, Defendant. MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Land Holding, LLC., by and through its attorneys, Grenen & Birsic, P.C., and files the within Motion for Special Service of Civil Action - Complaint in Pursuant to Special Order of Court, under Pennsylvania Rule of Civil Procedure 430 as follows: 1. On May 14, 2004, Plaintiff filed a Civil Action, Complaint in Ejectment against the Defendant, Kiran Kumar Dandapat, at the above term and number. 2. On or about May 14, 2004, Plaintiff delivered to the Sheriff of Cumberland County a copy of the Civil Action, Complaint in Ejectment, with instructions that it be served upon Defendant at the last known address being 852 Erford Road, East Pennsboro, PA, 17011. 3. On or about May 21, 2004, the Cumberland Sheriff notified Plaintiff that they were unable to serve Defendant at 852 Erford Road, East Pennsboro, PA, 170ll, with a copy of the Complaint since Defendant could not be found at said address. A true and correct copy of Sheriff s return is marked Exhibit "A", attached hereto and made a part hereof. 4. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, Kiran Kumar Dandapat, is marked Exhibit "B", attached hereto and made a part hereof. 4. Plaintiff has received indications that the property remains occupied and only desires to serve any occupants of said property with a notice of the complaint. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Sheriff of Cumberland County to post a copy of the Complaint on the property at 852 Erford Road, East Pennsboro, P A, 17011, and permit the Plaintiff to serve Defendant, Kiran Kumar Dandapat, by mailing a true and correct copy of the Complaint by certified mail, return receipt requested and by first class mail, postage pre-paid to 852 Erford Road, East Pennsboro, P A, 17011. Service of the Complaint shall be deemed complete and valid upon posting and mailing by the Plaintiff. GRENEN & BIRSIC, P.c. BY: ~i(;x.-<-~(Lcu. dr...-. Kristme M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT "A" SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-0214~ ~ COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAND HOLDING LLC VS KIRAN KUMAR DANDAPAT R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DANDAPAT KIRAN KUMAR but was --.-- unable to locate Him In his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , DANDAPAT KIRAN KUMAR 852 ERFORD ROAD EAST PENNSBORO, PA 17011 852 ERFORD ROAD EASTPENNSBORO IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge So 18.00 10.35 5.00 10.00 .00 43.35 R. Thomas Kline Sheriff of Cumberland County GRENEN & BIRSIC OS/21/2004 Sworn and subscribed to before me this day of A.D. Prothonotary EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION LAND HOLDING, LLC., NO.: 04-02147 Plaintiff, vs. KIRAN KUMAR DANDAPAT, Defendant. AFFIDAVIT PURSUANT TO P A. R.C.P. 430 COMMONWEALTH OF PENNSYLVANIA ) ) ) SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, ofGRENEN & BIRSIC, P.C., attorneys for Plaintiff, deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, Kiran Kumar Dandapat, named in the above- captioned matter: 1. On or about August 20,2004, Plaintiff mailed to the United States Postmaster at East Pennsboro, Pennsylvania, 17011 a certain Request for Change of Address or Boxholder Information Needed for Service of Legal Process for Defendant. 2. On or about August 27, 2004, Plaintiffreceived a response from the aforementioned United States Postmaster stating that the forwarding address had expired. A true and correct copy of said response is marked Exhibit "1", attached hereto and made a part hereof. 4. A search of a nationwide computer database found a current address of 852 Erford Road, Camp Hill, P A, 17011 for Defendant, Kiran Kumar Dandapat. A true and correct copy of said search is marked Exhibit "2", attached hereto and made a part hereof. 5. The Defendant is not listed in the East Pennsboro Area telephone directory. 6. A search of the Cumberland County Voter Registration records revealed that Defendant is registered to vote in Cumberland County with an address of 852 Erford Road, Camp Hill, PA, 17011. A true and correct copy of Sheriffs return is marked Exhibit "3", attached hereto and made a part hereof. Finally, affidavit deposes and says that the last known address of Defendant, Kiran Kumar Dandapat, is 852 Erford Road, East Pennsboro, P A, 17011. Aeain the {Ilaintiff only desires to serve any remaininl! occupants of said propertv with a notice of the complaint. c/ 7LD(2LuLlt/ tl/-.. c;( (} V Krisi!ne1vt. Anth'o~, "E~uire SWORN to and subscribed before me this ~day Of~\I'(,J}:8\-;>!004. ~'\\ ~~<'~ 8Cr. ."1'1\ ~JYC5) NOTARY PUBLIC COMMONWEAl:,,'i OF PENNSYLVANIA Not1!lal Seal \ PatJicia A. Townsend. Notary PUbrlC City Of Pittsburgh, Allegheny County My Commission Expires June 2, 2007 Member, Penns"~Vaf)i8 AssodatiQn Of Notaries , Exhibit "1" Postmaster East Pennsboro, P A 17011 City, State, ZIP Code . Date August 20, 2004 . Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) for the following: Name: Kiran Kumar Dandapat Address: 852 Erford Road NOTE: The name and last known address are required for change of address infonnation. The name, if known, and post office box address are required for boxholder infonuation. The following infonuation is provided in accordance with 39 CFR 165.6(d)(8)(h). There is no fee for providing boxholder infonnation. The fee for providing change of address infonuation is waived in accordance with 39 CFR 265.6(d)(I) and (2) and corresponding Administrative Support Manual 352.44a and b. L Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a pa..'1y \ acting pro se - except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: Land Holding, LLC. vs. Dandapat 4. The court in which the case has been or will be heard: Cumberland County Common Pleas 5. The docket or other identifying number if one has been issued:04-02147 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTIJAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRlMINAL PENAL TIES INCLUDING A FINE OF UP TO $10,000 OR IMPRlSONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 D.S.C SECTION 1001). I certify that the above infonuation is true and that the address infonuation is needed and will be used solely for 72 oJflegal tx:ecti~n with actual or prospective litigation. ~Signatur - Erin J. Dauria Printed Name Grenen & Birsic, P.c., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY _ No change of address order on file. _ Not known at address given. -~"- /' ,... ~ I, / "--:'=-' POSTMARK ! // NEW ADDRESS OR BOXHOLDER'~ ! NAME and STREET ADDRESS \' < "1.,.1' _ Moved, left no forwarding address No such address. _~ t:O~ Exhibit "2" . . Page 1 of2 Source: f.'1l.l11kLFiecords > Pe9R~jl1l~,~1!~ & Asset Locators> EZFIND Combined Person Locator Nationwide CD Terms: dandapat kiran kumar (Edit Search) .Select for FOCUSTM or Delivery r DANDAPAT, KIRAN KUMAR THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY PERSON LOCATOR - P-TRAK Name: DANDAPAT, KlRAN KUMAR Also Known As: DANDAPAT, KlRAN K; DANDAPAT, KlRAN Social Security Number: 149-80-XXXX Address: 852 ERFORD ROAD CAMP HILL, PA 17011-1129 Address Updated: 11/1/1995 Previous Addresses: 327 SPRING GLEN DRIVE APT. D EPHRATA, PA 17522-9231 Address Updated: 9/1/1995 25 WELSH DRIVE APT. B LANCASTER, PA 17601-2332 Address Updated: 11/13/2000 Birthdate: 6/1965 Telephone: 728-8897 On File Since: 10/1/1989 Source: Public Records> People. Business & Asset Locators> EZFIND Combined Person Locator Nationwide OJ Terms: dandapat kiran kumar (Edit Search) View: Full DatefTime: Friday, August 20, 2004 -12:45 PM EDT About LexisNexis) Terms and Conditions ..-. - ~ .....~..-....T" ..\........rHT~__.\T Ar. A T C'.1\'T'Q""".....\(),UTh:QT VW htm 8/20/2004 . . Page 2 ot L QQgJ1ig1]t.@ 2004 LexisNexis, a division of Reed Elsevier Inc. All rights reserved. -."- - ~-~........ "''''-'T"'\TT_ - -1,.- r.ro A T co 1 VT'''''............\flU TKOT V,,,,, htrn 8/20/2004 Exhibit "3" Search - 100 Results - dandapat kiran kumar . . Page 1 of 1 Source: Public Records > !"jl,wj~"_Business & Asset Locators> Person Locator> Voter Reqistrations > US Voter Registrations, Combined OJ Terms: dandapat kiran kumar (!;glt~l2?I!<bJ .Select for FOCUSTM or Delivery C DANDAPAT, KIRAN THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY PENNSYLVANIA VOTER REGISTRATIONS Name: DANDAPAT, KIRAN Address: 852 ERFORD ROAD CAMP HILL, PA 17011 County: CUMBERLAND Date of Birth: 6/6/1965 VOTER INFORMATION Registration Number: 0001027827 Party Affiliation: DEMOCRATIC Registration Date: 6/14/1999 Congressional District: 19 State Senate District: 31 State House District: 087 Precinct: E PENNSBORO/ LOWER Source: Public Records> People, Business & Asset Locators> Person Locator> Voter Reqistrations > US Voter Registrations, Combined III Terms: dandapat kiran kumar (Edit Search) View: Full DatefTime: Friday, August 20, 2004 - 12:46 PM EDT About LexisNexis I Terms and Conditions CODvricht@ 2004 LexisNexis, a division of Reed Elsevier Inc. All rights reserved. 'u.- ".._n__' M.'_ ___'.MM_",., I_o"';o"o? m=oLl.1.11 fQr.QLll O1Ll-:P.i'R,,~Ofe"7Rh 1 50c9&docnu... 8/20/2004 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy ofthe within Motion for Service of Complaint in Ejectment Pursuant to Special Order of Court was mailed to the following on this ,.,t'IA ~ ~ day of <...Xp-t-ev>1W 2004, by first class U.S. Mail, postage pre-paid: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, P A, 17011 GRENEN & BIRSIC, P.C. J(),It2u-_d71laILL~ tf><-.-/ Kris~M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 I"? ,,-) :1"1 .-:\ ') , LAND HOLDING, LLC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LA W KIRAN KUMAR DANDAPAT, Defendant NO. 04-2147 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of September, 2004, upon consideration of Plaintiff's Motion for Service of Complaint in Ejectment Pursuant To Special Order of Court, the motion is granted to the extent that service of the complaint upon Defendant may be made by (I) posting the property at 852 Erford Road, East Pennsboro, PAl 70 I I, (2) certified mail, return receipt requested, and first-class mail, postage prepaid, to Defendant at 852 Erford Road, East Pennsboro, PA 1701 I, and (3) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County. SERVICE SHALL be deemed complete and valid upon posting, mailing and publication. BY THE COURT, aL esley Oler, Jr., . J. Kristine M. Anthou, Esq. GRENEN & BIRSIC, P.C. One Gateway Center Nine West Pittsburgh, PA 15222 Attorney for Plaintiff j~~u ~ 9_Jooy ---'-' 0-. :rc A.LN(;(\ 9S :S lId L \ d3S ~noz ,1\..]"..,11(..' :..11,..,,1, i'Y,";.,! ;]!, .l'l JO '\ .'_ I ,,~,' I.....V..~'-. _,,1.. ..j .j~)1-+~O-(\3lH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL DIVISION ) ) NO.: 04-02147 ) ) ISSUE NO.: ) ) ) TYPE OF PLEADING: ) PRAECIPE TO REINST ATE ) CIVIL ACTION - COMPLAINT ) EJECTMENT ) ) CODE- ) ) ) FILED ON BEHALF OF PLAINTIFF: ) Land Holding, Inc. ) ) ) COUNSEL OF RECORD FOR THIS ) PARTY: ) ) Kristine M. Anthou, Esquire ) Pa. LD. #77991 ) ) GRENEN & BIRSIC, P.C. ) Nine West ) One Gateway Center ) Pittsburgh, P A 15222 LAND HOLDING, INC., vs. KIRAN KUMAR DANDAPAT, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff, ) ) NO.: 04-02147 ) ) ) ) ) ) ) ) ) ) ) LAND HOLDING, INC., vs. KIRAN KUMAR DANDAPAT, Defendant. PRAECIPE TO REINST ATE CIVIL ACTION - COMPLAINT IN EJECTMENl[ TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Ejectment with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: 0'~~'CLu.y;'v(t~L2 'L Attorneys for Plaintiff .- 0 r--,) c: = 0 c=> !~ .;::- ." % -i 0 ~~ ...:: I :06 0 -0 ~~i :'P C) ::x 0::0 ::...C) C Y: om ~:; ~ -<'. .:::- -< , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INe., CIVIL DIVISION Plaintiff, NO.: 04-02147 VS. TYPE OF PLEADING: KIRAN KUMAR DANDAPAT, Defendant. PRAECIPE FOR DEFAULT JUDGMENT (Ejectment) FILED ON BEHALF OF PLAINTIFF: Land Holding, Inc. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. LD. #77991 GRENEN & BIRSIC, P.e. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., CIVIL DIVISION Plaintiff, NO.: 04-02147 vs. KIRAN KUMAR DANDAP AT, Defendant. PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the ejectment against Defendant, Kiran Kumar Dandapat for possession of the premises known as 852 Erford Road, East Pennsboro, P A 17011. GRENEN & BIRSIC, P.c. BY: l/ ~ Qc '--''-)>?--'.,,( (i. /-.(cGil.."..- Kristine M. Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou , 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 knowledge, information and belief and certifies that the Notices ofIntent to take Default Judgn1ent were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. l./~(;()L '- 'L<--Ji CL.: U I->-- Sworn to and subscribed before me this(~-::Jt9 day of ~l!' o~:QA.J , 2004. Q~,- ('.,....) A~ .'NJY>"'-CO Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Pa1rIda A. Townsend. NotarY PuIlIc CilyOfP~.~CoIJ1lY My (;anmiS6Ion Expires June 2, 'JJX1l _,~maAs_Of~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., CIVIL DIVISION Plaintiff, NO.: 04-02147 vs. KIRAN KUMAR DANDAP AT, Defendant. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, P A 17011 ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on lJp r _ ::l.q d(>AU \ .'1 ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: in ejectment for possession of the premises known as 852 Erford Road, East Pennsboro, P A 17011. Q. Deputy ( ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., Plaintiff, ) CNIL DNISION ) ) NO.: 04-02147 ) ) ) ) ) ) ) vs. KIRAN KUMAR DANDAPAT, Defendant. TO: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, P A 170 I I DATE OF NOTICE: December 9,2004 IMPORT ANT 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 DAYS FROM THE DATE OFTHIS NOTICE,AJUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER A T 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. IFYOU 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 By: GRENEN & BIRSIC, P.C. '-/<2i.;1<.. <",vOilL,c L L8------ Kristine M. Arithou, Esquire Pa. J.D. # 77991 Attorneys for Plaintiff One Gateway Center, 9th Floor Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID ~ _ P :-0 C If- fl c> ~ \>) F - ...0 -::J Vt VJ CL. "\)-0\ ~ --0 ~1- w ~-....t ~( . ~ 2 ':? ~J~~ ~ n; r~A C'") ~7-;';:" '" tJ:;;;r.,:, U> _/., "c.;; r;.C, ~ 1;:Q 1?'L) ;pc. ~ Q, -;::;l m:D ..,,\1; '37=> ~~~\ -0 <;4'8 ::It f~ \'11 - >::::" .- ~ o "'" 0:> - ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., CIVIL DIVISION NO.: 04-02147 Plaintiff, vs. TYPE OF PLEADING: KIRAN KUMAR DANDAP AT, Proof of Service Defendant, FILED ON BEHALF OF: Land Holding, Inc. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. J.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION LAND HOLDING, INC., NO.: 04-02147 Plaintiff, vs. KIRANKUMARDANDAPAT, Defendant. PROOF OF SERVICE Kristine M. Anthou, Attorney for Plaintiff, Land Holding, Inc., being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiff's Complaint in this matter on Defendant, Kiran Kumar Dandapat: 1. Pursuant to Order of Court dated September 17, 2004, service of the Complaint in Ejectment upon Defendant was deemed complete and valid upon mailing by the Plaintiff by certified mail, return receipt requested, and by first class mail, postage prepaid, addressed to 852 Erford Road, East Pennsboro, P A 17011, by posting of a copy of the Complaint, by Cumberland County Sheriff at the property located at 1438 Bridge Street, New Cumberland, P A 17070 and publication once in the Cumberland Law Journal and in a newspaper of general circulation. A true and correct copy of said Order of Court is marked Exhibit "A", attached hereto and made a part hereof. 2. On November 4, 2004, Plaintiff mailed the Complaint in Ejectment to Defendant, Kiran Kumar Dandapat at 852 Erford Road, East Pennsboro, P A 17011 by certified mail, return receipt requested and by first class mail, postage prepaid. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7004 0750 0003 5671 3701 and the Certificate of Mailing, evidencing service by certified mail and first class mail on the identified Defendant, are marked Exhibit "B", attached hereto and made a part hereof. 3. On or about November 2, 2004, Cumberland County Sheriff, posted the Complaint on the property located at 852 Erford Road, East Pennsboro, P A 170 II. A true and correct copy ofthe Sheriffs Return is marked Exhibit "C", attached hereto and made a part hereof. 4. On or about November 12, 2004, the Notice to Defend was published one time in the Cumberland County Law Journal. A true and correct copy of the proof of publication is marked Exhibit "D", attached hereto and made a part hereof. 5. On or about November 15, 2004, the Notice to Defend was published one time in the Sentinal, a newspaper of general circulation. A true and correct copy of the proof of publication is marked Exhibit "E", attached hereto and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. GRENEN & BIRSIC, P.c. BY: ,1',(U...Oc (Ii. ~)}(al... (<.-("'- Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THI~t:B'AY OF fru,.orrrJh:::JA") ,2004. (j?drtl f' P ('j.,\El~ ,m ~ Notary PUblb'bMMONWEAL TH OF PENNSYLVANIA Nolllrial S8aI Pallida A. Townsend, NolarY PublIc ~ 0lPiUslJUl\1l, AIIeQhenY Coooty My CommIssIon Expires June 2, 2!11l _r,_~varua_OI- . c ( LAND HOLDING, LLC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW KlRAN KUMAR DANDAP A T, Defendant NO. 04-2147 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of September, 2004, upon consideration of Plaintiffs Motion for Service of Complaint in Ejectment Pursuant To Special Order of Court, the motion is granted to the extent that service of the complaint upon Defendant may be made by (1) posting the property at 852 Erford Road, East Pennsboro, PAl 70 11, (2) certified mail, return receipt requested, and first-class mail, postage prepaid, to Defendant at 852 Erford Road, East Pennsboro, PA 17011, and (3) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County. SERVICE SHALL be deemed complete and valid upon posting, mailing and publication. BY THE COURT, . J. J histine M. Anthou, Esq. GRENEN & BIRSIC, P.C. One Gateway Center / Nine West Pittsburgh, PA 15222 Attorney for Plaintiff :rc TRue COPY FRO In Tlltlmon M AECORU aNI the sJ whareot, , here unto set my halld this ~ ~ of said ~~at CarUsle. Pa. . ~. "b \. ;.':,~""- Prot/JoJ $ """'._~ --- 88;l~~ ~~e) - ...-....... -- "'1"'IlllI8O .- l 3Sn 1'1101.:1.::10 J >- . . . . ., . . . (papl~OJd i'J6eHj,'IO:J iJ:;u(!JnstJ! ON AIUO flew :JIJsawoO) ldI3::l3t1 11\111\I 031.:lI.ltl3::l , <lJIAJ<lS lejSOd 's'n I r --.I l:l l:l .., l:l --.I U'I l:l l:l l:l l:l lJJ U'I a- --.I .,... lJJ --.I l:l .,... 'P~~;.:~~,~",~ CERTIFlcA n OF IIAIUNG AHD~11ClNAl foWL., DOES NOT s:: II> ." o (f) iJ C) 7/- 'fl m .. .................. ~'FRWIt ,,, Grenen . . Nine wes it ' Pillsburgh, PA 15222 ClN.... ci 0lIdr.-y nlIII--..a 10; K/;"ev-.4",-, LJ--.(",-,<7~ 2S2 D-h,/d' ,eo0.4' I:<V-I/eru'vho ,/ 7Cy,/ .c?~ PS Foom 381,7, Janual)/2001 CASE NO: 2004-02147( SHERIFF'S RETURN - REGULAR ( COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAND HOLDING LLC VS KIRAN KUMAR DANDAPAT CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DANDAPAT KIRAN KUMAR the DEFENDANT , at 1758:00 HOURS, on the 2nd day of November, 2004 at 852 ERFORD ROAD EAST PENNSBORO, PA 17011 by handing to POSTED PROPERTY AT B52 ERFORD ROAD CAMP HILL, PA 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 Service Posting Surcharge 18.00 11.10 6.00 10.00 .00 45.10 So An;;~:~,~~,~ 1~ R. Thomas Kline A.D. 11/03/2004 GRENEN & BIRSIC eG. "-.".-;-'" --7 ip-'7 By : ",/ I / - - ./~.~. DiU Sl'ieri Sworn and Subscribed to before me this day of Prothonotary ( ( PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2,1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz NOVEMBER 12, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 12 day of NOVEMBER. 2004 NOT AR,AL SEAL LOIS E. SNYDER, Notary Public Carlisle Bora, Cumberland County My Commission Expires March 5, 2005 ( CUMBERLAND LAW JOURNAL ( NOTICE In the Court of Common Pleas of Cumberland County. Pennsylvania CIvil DivisIon No.: 04-02147 LAND HOLDING, INC.. Plalntlff. vs. K1RAN KUMAR DANDAPAT, Defendants Notice If you wish to defend. you must enter a written appearance person. ally or by attorney and file your de- fenses or objections 1n wrtting with the court. You are warned that if you fail to do so the case may pro- ceed without you and a judgment may be entered agatnst you without further notice for the rel1ef request- ed by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PROVlDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVlDE YOU WIlli INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV- ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVlCE Cumberland County Bar Association 2 Uberty AVenue CartIste, PA 17013 I (800) 990-9108 4 Nov. 12 ( ( PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following date(s) November 15. 2004 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of P1cationare~~. _ 1_ A .... '~ ~( Sworn to and subscribed before me this 17th day of November, 2004 rJu~A'(l);f 1LJr:ti Notary lie My commission expires: 9(/ (ur COMMONWEALTH OF PENNSYLVANIA NofariaI Seal Christina L. Wolfe, NoIary Public CaIfisIe Boo, Cumbelta.1d County My CanmIssion Expires 5epL 1, 2008 Member. Pennsvlvanla Association Of Notaries CERTIFICATION OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Proof of Service was mailed byU.S. First Class Mail, postage pre-paid, on the 22 ""'Day of 0 eo elhber, 2004, to the following: Kiran Kumar Dandapat 852 Erford Road East Pennsboro, PA 17011 GRENEN & BIRSIC, P.C. BY: ."-,, /- , , ..., . . ^ I ,v .,.). / , "-{ "^:- \Vi.. c......- '- /;(__ C~ .c. (. Kristine M. Anthou, Esquire Attorneys for Plaintiff / / x.... (") "" ~ G'-> c: = ;1:'" .&" --r.:\\~,:! c:;l ~-:n rni'il ~ ;Z.~T' rt1 r:: :;:':!_'.,: N .."m (1)0, '<L' ;~'I -", ," , ~~~ 'i~ (:~ '"t"! :r" .. c,:::D :;,.t.' :>:: ~r~ ."'0 ')>-7~ - ~- :::~ ~ C> 55 -' .< SHERIFF'S RETURN - REGULAR CASE NO: 2004-02147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAND HOLDING LLC VS KIRAN KUMAR DANDAPAT CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DANDAPAT KIRAN KUMAR the DEFENDANT , at 1758:00 HOURS, on the 2nd day of November, 2004 at 852 ERFORD ROAD EAST PENNSBORO, PA 17011 by handing to POSTED PROPERTY AT 852 ERFORD ROAD CAMP HILL, PA 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 Service Posting Surcharge 18.00 11.10 6.00 10.00 .00 45.10 So An~2~.~;,,,.!: ,~J j ;'''''-.---\', . .I R. Thomas Kline Sworn and Subscribed to before 11/03/2004 GRENEN & BIRSIC By: 00/;/~ -~ /~.- D~{y ,2tp ~ me this /()- day of ~.k ,;) {JO If A.D. i},/(( (l /'h,p;,,> ~ Prothonotary , > \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., CIVIL DIVISION Plaintiff, NO.: 04-02147 vs. ISSUE NUMBER: KIRAN KUMAR DANDAPAT, TYPE OF PLEADING: Praecipe for Writ of Possession Defendant. CODE- FILED ON BEHALF OF PLAINTIFF: Land Holding, Inc. COUNSEL OF RECORD FOR THIS PARTY: Kristine A. Anthou, Esquire Pa. J.D. #77991 GRENEN & BIRS1C, P.C. One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 , . ~ \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAND HOLDING, INC., CIVIL DIVISION Plaintiff, NO.: 04-02147 vs. KIRAN KUMAR DANDAPAT, Defendant. PRAECIPE FOR WRIT OF POSSESSION TO: PROTHONOTARY Kindly issue a Writ of Possession in the above-captioned matter for the premises known as 852 Erford Road located in the Township of East Pennsboro, County of Cumberland, Pennsylvania and more particularly described in Plaintiffs Complaint in Ejectment filed in the instant proceeding. GRENEN & BIRSIC, P.C. BY: ij;'/ LVI.. LA//X/1./.{,(IJ--..., Krist! M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 . t'" 10 . . LAND HOLDING, LLC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW KIRAN KUMAR DANDAPAT, Defendant NO. 04-2147 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of September, 2004, upon consideration of Plaintiffs Motion for Service of Complaint in Ejectment Pursuant To Special Order of Court, the motion is granted to the extent that service of the complaint upon Defendant may be made by (1) posting the property at 852 Erford Road, East Pennsboro, PA 17011, (2) certified mail, return receipt requested, and first-class mail, postage prepaid, to Defendant at 852 Erford Road, East Pennsboro, P A 170 I I, and (3) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County. SERVICE SHALL be deemed complete and valid upon posting, mailing and publication. BY THE COURT, . 1. ;/ J<,ristine M. Anthou, Esq. /GRENEN & BIRSIC, P.C. One Gateway Center Nine West Pittsburgh, P A 15222 Attorney for Plaintiff :rc TA':JE COpy FROM ReCOo.[) In Tlntu!1Cfl' ,..,,, r;;: n '. .r ,:"<.<Teot, Hmre Ullto set my h<1~ , .' ihc set' Vi :laiD L:vuft <At <:..ill""! r. 'h'~ ~- d ~ _e, r'a ~' cr' 2i <i ;,;~<vY: ProtlJoh ?:;-' .. ~ ~ ~. ,0 -.. C'" ~. \J\.. - ......::t f'_. C" -'V -. ~ ~. V\. \" . . . C -.:" t \t~ '[} c; " r::> p ~) ~j, ~~; c.. ~1'; '-- , . -- \ _l r:-? 1'.) r,..) --;,\ WRIT OF POSSESSION (Ejectment Proceedings PRep 3] 60 - 3165 etc.) Land Holdino, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~.-2147 Civil Term No. Term vs. Costs Kir.1f'1 Kllmr3r f);:mc1ApnT Att'y. $ 852 Erford Road Pl'ff (s) $ CiJl11p Hill. Pa. 17011 Prothy. $ 79.50 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (]) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: Cenen & Birnie. P. C. Kristine M. Anthou, Esq. Land Holding, Inc. Plaintiff (s) being: (Premises as follows): 852 Erford Road located in Township of East Pennsboro, County of Cumberland County, Pennsylvania (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell hislher (or their) interest therein. Curtis R. Lonq Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Date January 7. 2005 By 9'1",-Q)~ (SEAL) >- Q. Q. @ ~ '" Cj ?: ~ ~. Z(]) ". ~;:?'5'Cl,>- ::J ,.p.rt([)O;l", ~I-'rt rt:::::J::' OlNW:E: fi) 0 . '0- 0' t<:I:E: ~ ~ c:: m OJ ~ ~ 'i::l1\J 11 rt~,-< ~ ~~~ 02' g :-;~. ~::g ;::l Q"l '1:1 rt '" ~U1 OJ (t) j3;j tI1 0- 11-. UJ 0' '" (} l-' ::-. r..n (J1 -+, j-i- (tI N '"'"1)11 ~ N ~ CO ri N '-- Q. C/l "0 "0 >- g- a ~ ~ ""'l 5- ....--.. ~ ~ :< ~ () o '" ;:; ~~ ~::o ()- . ..., ~O ","" -":I <:>\0 r1J1 "'1J1 =:'t"l ~, 1J1 1Jt1J1 t"l- ...,0 ("lZ -V7 f:FJ ..sA- f:/) -...] I-' <<> . o IJ1 o 0 By virtue of this writ, on the I caused the within named have possession of the premises described with the appurtenances. and day of o t<:Ioo X ~ 01 U1 /-I- OJ '-' '1 ;t OJ t<:I::J ::t:'OCj ....(]) H1 X i-'::JO@ :-'tila~ '08'::<1 ?' 8 g 5i' 0,::J 1-'>-3 0, ~~ ~ 0 I-' OJ ;t 0' .... '1j ()- r-<cz OJ ~..., ::J ee::::: o,t"lt"l ::<:::0,.., g,t"'o 0,;"- 5" z!iS lQ ~..., HO()O ::J "" ('J c () ~o .-< ~ ":I~ t"lo Zz Z 1J1":1 -<t"' S;;~ ;"1J1 zo >~ z z " 0 <=> .... I '-' I-' .... -...] o ~. .... i-' ;:;l ;:;l ~ ~ :3 3 , to Sworn and subscribed to before me this day of So Answers, Sheriff By Deputy Prothonotary " WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 3155 etc.) Land Holdino, Inc. IN THE COURT OF COMM N PLEAS OF CUMBERLAND COUNTY, PI NNSYLVANIA ~,-2147 Civil erm No. erm vs. Costs Ki rfln K1J~r Dnnrlrwn-r All'y. $ 852 Erford Road Pl'ff(s) $ Carnn Hill. Pa. 17011 Prothy. $ 79.50 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (]) To satisfy the judgment for possession in the above matter you are directed to deliver po session of the following described property to: Genen & Birsic. P. C. Kristine M. Anthou, ESG. Land Holdinq, Inc. Plaintiff (s) being: (Premises as follows): 852 Erford Road located in Township of East Pennsboro, County of Cumberland County, Pennsylvania (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of th defen- dant (s) and sell hislher (or their) interest therein. (SEAL) Curtis R. Lona Prothonotary, Common Pleas Court of Cumberland County, P nnsylvania By: (), . Q.~ ~7T Deoutv Date January 7. 2005 ~ -... ":.) , t._ Ie- (c \ . 1 ;J> 0. 0. (6 " r..r 1-\ r..r 1-'. .. 0 rJ1 ::l rt- Z(I) !:1' ~ ;:g' c).,....<O :J"',s::.. rt (D Ol .".. ~~Gi:z:fti5' 1" "'0- 0' tr1:g :2 -6N ~ ~SJ~ ~ ~:::~ OO.."EJ: (/"J I... (t) 0 3-...J ::1"" c: ,"'''tl rt-"l:1 ,-~Ul OJ co ~ tr1 ---0. 11-- (I) 0' ::1 ~ f-> ::::. l.J1 -+., \-'- ~ 2 ~ N ~ C/l "l:1 "l:1 ;J> g- 0 ~ ~ :::. s- ,-.. ~ ~ '-:< ~ n o ~ c.r. :-=::; ?~ (j- o .., :-=0 ",,"!'J -"':l go ,00 ""00 ~~ Ul'Jl 00 1:"1- ..,0 0Z 'J' (1l ~ < (1l 0. Vt Vl f/) -bA ...... o o --..) <!) . lJ1 o d' , \' ~ 6..... ~{,~ :; [/?- ... r'V ~@ \Lu (')tTJCO" ~ ()) Ul t-J" rJ1 N'i rt- Qj tTJ::l :I:"tl'i ....(1) Hl '" f-'::lO[;:l !;-'ffi 8..1il "tl8':o'i ?' 8 @ & P,::> ......., p, 8~ ~ i ......rJ1 rt- ::r .... '0 By virtue of this writ, on the 9th I caused the within named day of February Land Holding, Inc. have posscssion of the premises descrihed ~JtIm<~m<1X#lX~~~<X l,rlffip HilI, PAl 7011 Sheriff's DocketiniS Pro thy Poundage ~lEage Possession Posting Surcharge (")- t"CZ Qj a:.., s.t=:::: i:"l1:"1 :I:~(") ~5:g !:1' Z~ LO 0.., H (")00 ::> "!'J () C (j . ~o ~iS: "':liS: 1:"10 Zz Z"':l ~t"" t""1:"1 ~~ ZO ;;~ 85< Edord Iload - i----->' '~_.-:;::Y =t:n1 ~'-;;:lTH .:..::.:::.;~ -:_~:::~) lflrlJ Z Z " 0 '0 ... I tv ...... ... --..) (') !<. .... ...... r;l r;l ~ ~ ? ? 2005 . to Advance Costs: 150.00 Sheriff's GOSLS: 87.~3 62.17 Return: 10.00 1.00 1. 73 11. to 3~ : gg (z :( d L - tWI' SfinI 20.00 .,Ij "td ", 1_,'.\iU., ...."., ;d,~";~~~LJ 87. 83'.:l:lIB3HS3iU jfj 3JU:lO SoA~X'./ /~ Sworn and subscribed to before me this 1 r r .~ III -~ b' --.t' day of '/'Y]6>A ",J-_ . Ii( 00,) ~ ('i ~ -... S~ff , / O~~. ~ ~~ ...-~ By _.f/.ImJ4Ll-l' ANW...)k:a.Lr:.~ Prothonotary Refunded to Atty 2/11/04