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Home My WebLink About09-4787UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF _BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadingsCudren.com Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial --CIVIL DIVISION Mortgage Co. of Pennsylvania :Cumberland County 10385 Westmoor Drive, Suite 100 nn Westminster, CO 80021 € NO. - y1781 INIT. Plaintiff V. John Doe and/or Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant(s) CIVIL ACTION COMPLAINT IN EJECTMENT 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 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises") which address is set forth on the caption. 3. Premises, a legal description of which is attached hereto, was sold at Sheriff's Sale in accordance with law on June 10, 2009, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. (Abstract of Title). 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant (s) who have refused to deliver up the possession thereof. WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAW F ES ,-P7C . By: Stuart,, eg, E ire ATTOF?TE R INTIFF ALL THAT CERTA-D TRACT OF LAS) WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE ON THE, SOUTHEAST SIDE OF SRIRLEY AVENUE, BOROUGH OF CARLISLE, CUNMERLAND COUNTY, PENNS-ILVAN A., BEING LOT NO. 2 ON FINAL SUBDIVISION PLAN FOR HERB AND OWEN NMALS RECORDER IN PLAN BOOK 35, PAGE 38, BOUNDED AND DESCRIBED LN ACCORDAINCE ,A I T H A PLAN OF SURVEY BY I,:rk,,3CaRY V. NEIDLINGER, PROFESSIONAL EN G ER, AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE SOUTHEAST SIDE OF SHIRLEY AVENNJE (40 FOOT WIDE RIGS -OF-WAY) AT A CORNER OF PROPERTY NOW OR. FORMERLY OF PAUL BARRICK; THENCE EXTENDING FROM SAID BEGINNING POST AND ALONG THE SOUTHEAST SIDE OF SHIRLEY AVENUE, NORTH 64 DEGREES 30 AlIN€7TES EAST" 100.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF ILL. MEALS; THENCE EXTENDING ALONG SANIE SOUTH 25 DEGREES 30 MINIo'TES EAST 120.00 FEET TO PROPERTY NOW OR FORMERLY OF MOUERs; =1 , NCE EXTENDING ALONG SAME SOUTH 64 DEGREES 30 MINUTES WEST 100.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF P4.UL BART ICK, AFOREMENTIONED; THENCE EXTENDING ALONG SAIYIE NORTH 25 DEGREES 30 NII 'RTES WEST 120.00 FEET TO THE FIRST MENTIONED IRON PIN AND PLACE OF BEGPNING. BEING KNOWN AaND NIU-MBERED AS 1516 SMRLEY AVENUE. REING vgowN AS 1516 SHRLE h' AVENIM, CARLISLE, PA 17012. BEPgG ASSESSIMEN-r PARCEL NUMBER: 50-21-0326-057A. r- ev Lane, C'= 'PRCPERT='' `D No.: 50--21-0326-057A VERIFICATION Stuart Winneg, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation; that he is authorized to take this verification and does so because Plaintiff must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UD By St DATED: July 16, 2009 0 FILE:i - 2 0 l L 1 7 PIN i E, 4718.50 PD ATN CICIO 01843 W* aas Iqi R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Sheriffs Office of Cumberland County QWtt?' Gt 4Utr4brrf444 OFFICE ':.F'r E c"ERiFF FILED-U.-i ICE OF THE )NOTARY 2099 JUL 28 PH 3: 26 CUM1 - V;A' Beneficial Consumer Discount Co. , vs. John Doe Case Number 2009-4787 SHERIFF'S RETURN OF SERVICE 07/24/2009 08:52 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 2052 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: OCCUPANTS, by making known unto Greg Pianis, adult in charge at 1516 Shirley Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. 07/24/2009 08:52 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 2052 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: John Doe, by making known unto Greg Pianis, adult in charge at 1516 Shirley Lane Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same: time handing to him personally the said true and correct copy of the same. SHERIFF COST: $49.84 SO ANSWERS, 1??AcCftw;f &-Aew July 27, 2009 R THOMAS IKLINE, SHERIFF Deputy Sheriff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 . 856-669-5400 pleadings@udren.com Beneficial Consumer Discount =COURT OF COMMON PLEAS Company d/b/a Beneficial =CIVIL DIVISION Mortgage Co. of Pennsylvania ::Cumberland County 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 :NO. 09-4787 Plaintiff V. John Doe and/or Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant (s) PRAECIPE TO INDEX DEFENDANT PURSUANT TO PA.R.C.P. 410(b)(2) TO THE PROTHONOTARY: Kindly index as a Defendant, pursuant to Pa.R.C.P. 410(b)(2), Greg Pianis, who was found in possession of the real property subject of the within action in Ejectment. FI E 20e9 AUK; 1 0 F1 2: ! :: GU' , 3?Y Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial ::CIVIL DIVISION Mortgage Co. of Pennsylvania :Cumberland County 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 ::NO. 09-4787 Plaintiff V. John Doe Greg Pianis and/or Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff and against the Defendant(s),John Doe Greg Pianis, and Tenant/Occupant, for possession of the premises appearing in the caption, for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof. I hereby certify that notice has beeven in accordance with Rule 237.1, a copy of which is attache neteto. By -N? Su Atto inneg, Esquire for Plaintiff DEFAULT JUDGMENT ENTERED AS INDICATED ABOVE: DATE : $ 'J O PRO AZbTHY -` UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Beneficial Consumer Discount 'COURT OF COMMON PLEAS Company d/b/a Beneficial "CIVIL DIVISION Mortgage Co. of Pennsylvania :Cumberland County 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 NO. 09-4787 Plaintiff V. John Doe Greg Pianis and/or Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant (s) VERIFICATION OF NON-MILITARY SERVICE Stuart Winneg, Esquire, hereby verifies that he is Attorney for the Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: That the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Greg Pianis Age: Over 18 Residence: As captioned above Employment: Unknown The undersigned understands that this statem t herein is made subject to the penalties of 18 Pa.C.S. c n 904 relating to unsworn falsification to authorities. ,/ DATED: August 25, 2009 By: st'6 Winneg, Esquire UDREN LAW OFFICES, P.C. BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, Na 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 Plaintiff V. John Doe Greg Pianis and Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant (s) TO: John Doe 1516 Shirley Lane Carlisle, PA 17013 DATE of Notice: August 14, 2009 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4787 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty.,pvenue Carlisle, 17013 717- -3166 80 - 0-9107_,., '-- WO 111 WOODCREST CHERRY HILL, NEW By: Stuart W ODCREST leg, ire UP ORATE CENTER ROAD, SUITE 200 JERSEY 08003-3620 UDREN LAW OFFICES, P.C. BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 Plaintiff V. John Doe Greg Pianis and Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant(s) TO: Greg Pianis 1516 Shirley Lane Carlisle, PA 17013 DATE of Notice: August 14, 2009 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-4787 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-2?9-31 800-9 O1r By : s? _ Stuart Wi eg ire WOODCRE T C TE CENTER 111 0 CREST RO , SUITE 200 CHERRY HILL NEW,J RSEY 08003-3620 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Stuart Winneg, ESQUIRE ATTY I.D. NO. 45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856 669-5400 pleadings@udren.com Beneficial Consumer Discount '_COURT OF COMMON PLEAS Company d/b/a Beneficial =CIVIL DIVISION Mortgage Co. of Pennsylvania :Cumberland County 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 €NO. 09-4787 Plaintiff V. John Doe Greg Pianis and Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant(s) - TO: Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 DATE of Notice: August 14, 2009 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 NOTIF'ICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle // A 3 717- - 66 80 9 -91 By: / 4f / Stua eg, Esquire 111 WOODCRES19 R AD, SUTT9 200 CHERRY HILL NEW ERSE 8003-3620 R 1-11- OF )TAPY 2009 A U G 27 F l ! : 43 01-11 fl?/ 1 F" *E4. oo Pb A't'ty CIS -P I a4 $cfl Q7* gag 8ER oarkce, oaaO *r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Stuart Winneg, Esquire ATTY I.D. NO. 45362 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co. of Pennsylvania :Cumberland County 10385 Westmoor Drive, Suite 100 Westminster, CO 80021 ::NO. 09-4787 Plaintiff V. John Doe Greg Pianis and/or Tenant/Occupant 1516 Shirley Lane Carlisle, PA 17013 (Premises) Defendant(s) PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter, for possession of the property captioned under Defendants above, a description of which is attached hereto: By St Attorney for Plaintiff 1 R 1 Tf-? '? GARY 2009 AUG t% 1 H-i 1'. 43 4s a4 - oo Po 79.60 11 WOO Al *lto6.3q - pD at ty U-00 oueo'b CAL * 1347a 1 P,r * alaq $sa Oh+of Posses&Lc'0,. 4c/ 40taft • ALL THAT CER'T'AIN TRACT OF LAND WTI'H THE !M[PROYEMENTS THEREON ERECTED, SITUATE ON THE SOUTHEAST SIDE OF SHIRLEY AVENUE, BOROUGH OF CAR 1SLE, CUMBERLANI} COUNTY. PENNSnVANIA, BEING LOT NO. 2 ON FINAL SUBDIVISION PLAN FOR HERB AND OWEN MEALS RECORDED IN PLAN BOOK 35, PAGE 38, BOUNDED AND DESCRIBED IN ACCORDANCE WTI A PLAN OF SURVEY BY LARRY V. NEIDLINGER, PROFESSIONAL ENGn?EER, AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE SOUTHMAST SIDE OF SHIRLEY AVENUE (40 FOOT WIDE RIGHT-OF-WAY) AT A CORNER OF PROPERTY NOW OR FORMERLY OF PA7UL BARRICK; THENCE EXTENDING FROM SAID BEGINNING POINT AND ALONG THE SOUTHEAST SIDE OF SHIRLEY AVENUE, NORTH 64 DEGREES 30 MINUTES EAST 10.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF H -L. MEALS; THENCE EXTENDING ALONG SAME SOLTPH 25 DEGREES 30 Af VM-S EAST 120.00 FEET TO PROPERTY NOW OR FORMERLY OF MOUERS; THENCE EXTENDING ALONG SAME SOI,r'CH 64 DEGREES 30 MINUTES NEST 100.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF F AUL BARRICK. AFOREMENTIONED; THENCE EXTENDING ALONG SAME NORTH 25 DEGREES 30 MM-UTES WEST 120.00 FEET TO THE FIRST MENTIONED IRON PIN AND PLACE OF BEGINNING. BEING .SOWN ANT} NUMBERED AS 1516 SHIRLEY AVENUE. BEING KNOWN AS 1516 SHRILLY AVENUE, CARLISLE, PA 170n. BEV G ASSESSMENT PARCEL, NUMBER. 50-M-0326-057A„ BE:. G KNOWN Lau . 1515 Sh-irley Lane, Carllz s. , PA 17r1? 5 PROPERTY ZB NO.: 50-21-OS26-057A lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. No. 09-4787 Civil Term JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT 1516 SHIRLEY LANE CARLISLE, PA 17013 Costs Attorney's $ 166.34 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)) BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA being: (Premises as follows): SEE LEGAL DESCRIPTION ATTACHED (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. Cu s R. Long, Pro , Common Pleas Court o Cumbe and County, PA Date 8/27/09 (Seal) 2of2 No 09-4787 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 166.34 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: STUART WINNEG, ESQUIRE UDREN LAW OFFICES, PC 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ID# 45362 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of . I caused the within named , to have possession of the premises described with the appurtenances, and So Answers, Sworn and subscribed to before me this Day of , By Sheriff ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUA'T'E ON THE SOUTHEAST SIDE OF SHIRLEY AVENUE, BOROUGH OF CA,RIASLE, CUMBERLAND COUNTY, PENNSnVANIA, BEING LOT NO. 2 ON F.[NNAL SUBDIVISION PLAN FOR HERB AND OWEN MEALS RECORDED IN PLAN BOOK. 35, PAGE 38, BOUNDED AND DESCRIBER IN ACCORDANCE *"TM A PLAN OF SURVEY BY LARRY V. NEIDLINGER, PROFESSIONAL. ENGn?EER, AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE SOUTHEAST SIDE OF SHIRLEY AVENUE (40 FOOT WIDE RIGUr-OF-WAY) AT A CORNER OF PROPERTY NOW OR FORMERLY OF PAUL BARRACK; THENCE EXTENDING FROM SAID BEGINNING POINT AND ALONG THE SOUTHEAST SIDE OF SHIRLEY AVENUE, NORTH 64 DEGREES 30 MINUTES EAST 106M FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF 1U. MEALS; THENCE EXTENDING ALONG SAME SOUTH 25 DEGREES 30 MENI1TE,S EAST 120.00 FEET TO PROPERTY NOW OR FORMERLY OF MOVERS; THE, NCE EXTENDING ALONG SAME SOU'T'H 64 DEGREES 30 MINUTES WEST 100.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF PAUL BARRACK, AFOREMENTIONED; THENCE EXTENDING ALONG SAME NORTH 25 DEGREES 30 MINUTES WEST 120.00 FEET TO THE FIRST MENTIONED IRON PIN AND PLACE OF BEGINNING. BEING KNOWN AND NUMBERED AS 1515 SHIRLEY AVENUE. BEING KNOWN AS 1516 SHIPLEY AVENUE, CARLISLE, PA 17013. BEViG A.SSFSSMENT PARCEL NUMBER: 50-21-0326-057A. BEING NUN0WN AS . 1515 Shirley Lane Ca_°^- rile PPL. I7G1 Lane, r .3 PROPERTY = NO.: 50-21-0325-057A for z WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. No. 09-4787 Civil Term JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT 1516 SHIRLEY LANE CARLISLE, PA 17013 Costs Attorney's $ 166.34 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)) BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA being: (Premises as follows): SEE LEGAL DESCRIPTION ATTACHED (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. Ajdakz' Curtis . Long, Protho .wK Common Pleas Co urt-of Cumb and County, PA Date 8/27/09 (Seal) 1 2of2 No 09-4787 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 166.34 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: STUART WINNEG, ESQUIRE UDREN LAW OFFICES, PC 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ID# 45362 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, By Sheriff I ALL THAT CERTAIN TRACT OF LAND WITH THE DOROVEMENTS THEREON ERECTED, SITUATE ON THE SOUTHEAST SIDE OF SHTR.LEY AVEENIM BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA., BEING LOT NO, 2 ON FINAL SUBDIVISION PLAN FOR HERB AND OWEN MEALS RECORDED IN PLAN BOOK 35, PAGE 38, BOUNDED AND DESCRIBED IN ACCORDANCE 147TH A FLAN OF SURVEY BY LARRY V. NEIDL LAGER, PROFESSIONAL ENGRJEER, AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE SOUTHEAST SIDE OF SHIRLEY AVENUE (40 FOOT WdDE RIGHT-OF-WAY) AT A CORNER OF PROPERTY NOW OR FORMERLY OF PAUL BARRICK; THENCE EXTENDING FROM SAID BEGINNING POM AND ALONG THE SOUTHEAST SIDE OF SHIRLEY AVENUE, NORTH 64 I?EGREES 30 MINUTES EAST 106M FEET TO AN IRON PITT AT PROPERTY NOW OR FORMERLY OF H.L. MEALS; THENCE EXTENDING ALONG SAME SOUTH 25 DEGREES 30 MIlV'MS EAST 120.00 FEET TO PROPERTY NOW OR FORMERLY OF MOUER3; THENCE EXTEMING ALONG SAMX SOUTH 64 DEGREES 30 MINUTES WEST 100.00 FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF PAUL BARR.iCK, AFOREMENTIONED; THENCE EXTENDING ALONG SAME NORTH 25 DEGREES 30 MINUTES WEST 120.00 FEET TO THE FIRS1 MENT][ONED IRON PIN AND PLACE. OF REGM(ING. BEING KNOWN AND 2eFU MERED AS 1516 SHIRLEY AVENUE. BEING ]KNOWN AS 2516 SHU LEY A.VE3'?3UE, CARLISLE, PA 17013. BENG ASSESSMENT PARCEL NUMBER: 50-21-4326-057A. BE NG T-NOWN AS: 1515 Shirley Lane, Carlisle, PA 17013 PROPERTY = NO.: 30-21-0326-057A Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ?QUrtr ct +:uid6cx???4 c? ens. +Y 4 OFFICE OF THE S-ERIFF RED- 'D :lJt' TF THE: 2909 AUG 31 PH 3: 34 ,IJN D PEI J'i Edward L Schorpp Solicitor Beneficial Consumer Discount Co. Case Number vs. 2009-4787 Greg Pianis SHERIFF'S RETURN OF SERVICE 08/29/2009 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, Adult in Charge, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 08/29/2009 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, Occupant and Adult in Charge, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 08/29/2009 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. So Answers, R. '?homas Kline, Sheriff By C Jam' Deputy Sheriff Sheriffs Office of Cumberland County F11 FD-OFFICE R Thomas',Kline ?- Sheriff C}r ?1 E P, ?'???'` OTARY R nderson jr ?or ,? rr Ronny ,,tr 2009 OCT -9 PM 3. 36 Chief Dep?ty Jody S S ith C?,? Civil Proc ss Sergeant FF'!C E F S"E RIFF Edward L ?Schorpp Solicitor Consumer Discount Co. Greg lPianis Case Number 2009-4787 SHERIFF'S RETURN OF SERVICE 1 SHERI 09 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, Adult in Charge, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, Occupant and Adult in Charge, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09 10:50 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1050 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Greg Pianis, by making known unto Greg Pianis, at 1516 Shirley Lane, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09 By virtue of this writ, on the 7th day of October, 2009, Sheriff R. Thomas Kline caused the within named Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania, to have possession of the premises described as 1516 Shirley Avenue, Carlisle, PA 17013 being known as 1516 Shirley Lane, Carlisle, PA 17013. COST: $102.82 SO ANSWERS, 08, 2009 ? /b/ R THOMAS KLINE, SHERIFF' a /Y n R. Lant 4oSha Sworn before of and Subscribed to me this day 2009 A.D. Notarvi Public 7.2 96q ,3/?7L ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUA'T'E ON TEM SOUTHEAST SIDE OF SHIRLEY AVENUE, BOROUGH OF CARLISLE, CUNLONR : AND COUNTY, PENNft1VANLA,,, BEING LOT NO. 2 ON FINAL SURil?NWON PLAN FOR HERB AND OWEN MEALS RECORDED IN PLAN BOOK 35, PAGE 38, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN OF SURVEY BY LARRY V. NEIDLINGER, PROFESSIONAL ENGnEER, AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE SOUTHEAST SIDE OF SEW" AVENUE (40 FOOT WME RIGHT-OF-WAY) AT A CORNER OF PRO"AITY NOW OR FORMERLY OF PAUL BAIMCX; T M ENDING FROM SAID BEGINNING POINT AND ALONG THE SOUTHEAST SIDE OF SHIRLEY AVENUE, NORTH 64 DEGREES 3$ haNUTES EAST I FEET TO AN IRON PIN AT PROPERTY NOW OR FOR.NIMY OF S.L. -NUCALS; THENCE EXTENDING ALONG SAME SOUTH 25 DEGREES 30 A11NUM- EAST 120.00 FEET TO PROPERTY NOW OR FORMERLY OF MOUERS; THENCE EXTENDING ALONG SAME SOUTH 64 DEGREES 30 MINUTES NEST 14COO FEET TO AN IRON PIN AT PROPERTY NOW OR FORMERLY OF PAUL BAIiR M AFOREM NTIONED; T=NCE EXTENDING ALONG SAME NORTH 25 DEGREES 30- M WTES WEST IWA0 FEET TO THE FIRST MENTIONED IRON PIN AND PLACE OF BEGINNING, BEING KNOWN AND NUMBERED AS 1516 SHIRLEY AVENUE. BEING KNOWN AS 1516 SE91"Y AVENUE, CARLISLE, PA 170133. BMG ASSESSMENT PARCEL NUMBER 50-21-4326-457A. BEING KNOWN A5: 1515 Shirley Lane, Carlisle, PA 17013 PROPERTY ID NO.: 50-21-0326-057A r 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT 1516 SHIRLEY LANE CARLISLE, PA 17013 Attorney's Plaintiff's Prothonotary Costs No. 09-4787 Civil Term $ 166.34 $ 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)) BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA being: (Premises as follows): SEE LEGAL DESCRIPTION ATTACHED (2) To satisfy the costs against the defendant (s) you are directed to levy upon any 4r property of the defendant (s) and sell his/her (or their) interest therein. - ?)-/J ?? C7 ix. Long, Pro , Common Pleas Court of umb and County, PA Date 8/27/09 W T " V,. FRO M RECORD (Seal) In TiAmmy whoreo!, I hera.1..nih) set ryly haw and ! of ul? "'t at Cark.ilfl, N. .hq 0 oZoo? ' rret?rsr? , ?t _ _ 2of2 No 09-4787 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO of PENNSYLVANIA VS. JOHN DOE GREG PIANIS and/or TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 166.34 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: STUART WINNEG, ESQUIRE UDREN LAW OFFICES, PC 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ID# 45362 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Sworn and subscribed to before me this Day of , Where papers may be served day of . I caused the within to have possession of the premises described with the So Answers, By Sheriff