HomeMy WebLinkAbout09-7131FOX, ROTHSCHILD LLP
BY: EDWARD J. HAYES, ESQUIRE
IDENTIFICATION NO. 30243
2000 MARKET STREET, TENTH FLOOR
PHILADELPHIA, PA 19103-3291
(215) 299-2000
THE HUNTINGTON NATIONAL BANK
7575 Huntington Park Drive
Columbus, OH 43235
V.
JARROD CORBACIO AND
TAMARA CORBACIO
2428 Rolling Hills Drive
Mechanicsburg, PA 17055
ATTORNEYS FOR PLAINTIFF
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 6q - I / 3 I Ctu i L
PRAECIPE TO ISSUE WRIT OF SUMMONS
TO THE PROTHONOTARY:
Kindly issue a writ of summons in this matter, upon payment of your costs only.
EDWARD J. HAYES, ESQUIRE
FOX ROTHSCHILD LLP
2000 Market Street, 10th Floor
Philadelphia PA 19103
215-299-2092
Date: October 16, 2009
1
THE HUNTINGTON NATIONAL BANK
7575 Huntington Park Drive
Columbus, OH 43235
V.
JARROD CORBACIO AND
TAMARA CORBACIO
2428 Rolling Hills Drive
Mechanicsburg, PA 17055
TO: JARROD CORBACIO
SUMMONS
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 64 - '1131
TAMARA CORBACIO
YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED
AN ACTION AGAINST YOU.
PROTHONOTARY
Date:
r
,I"'
OF TH =
2009 OC T 19 PH 1: 2 9
X78. so i ?L /?-I-I?
CK? asz34C?
e? 324 4
. . _i
FOX, ROTHSCHILD LLP
BY: EDWARD J. HAYES, ESQUIRE
IDENTIFICATION NO. 30243
2000 MARKET STREET, TENTH FLOOR
PHILADELPHIA, PA 19103-3291
(215) 299-2000
THE HUNTINGTON NATIONAL BANK
7575 Huntington Park Drive
Columbus, OH 43235
ATTORNEYS FOR PLAINTIFF
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
JARROD CORBACIO AND
TAMARA CORBACIO
2428 Rolling Hills Drive
Mechanicsburg, PA 17055 No.
PRAECIPE TO INDEX AS LIS PENDENS
TO THE PROTHONOTARY:
Kindly index this action as a lis pendens in favor of Plaintiff and against Defendants, Jarrod
Corbacio an Tamara Corbacio, and their property located at 2428 Rolling Hills Drive,
Mechanicsburg, PA 17055, being more particularly described in Exhibit "A" hereto.
I hereby certify that a lien interest in the title to the real estate is ' lved.
EDWARD J. HAYES, ESQUIRE
FOX ROTHSCHILD LLP
2000 Market Street, 10th Floor
Philadelphia PA 19103
215-299-2092
Attorneys for Plaintiff
Date: October 16, 2009
SCHEDULE C
PROPERTY DESCRIPTION
The land referred to in this Commitment is described as follows:
ALL THAT CERTAIN piece, parcel and lot of land situate on the west side of Rolling Hills Drive In the Township
of Upper Allen, County of Cumberland. Commonwealth of Pennsylvania. and being Lot No. 148 on the Final
Subdivision Plan of Bowman's Hill, Phase III, recorded in the Office of the Recorder of deeds in and for
Cumberland County, Pennsylvania, In Plan Book 70, Page 39, and being more fully bounded and described as
follows, to wit:
BEGINNING at a point on the western right-of-way line of Rolling Hills Drive at the dividing tine of lot No. 149 and
Lot No. 148, herein described; thence by, soli dividing line North 52,degrees 07 minutes 15 seconds West a
distance of 92.53 feet to a point at the dividing line of lot No. 166A and Lot No. 148, herein
described; thence by said dividing line the following two courses and distances:
1. North 04 degrees 53 minutes 24 seconds East a distance of 19.97 feet to a point.
2 North 36 degrees 06 minutes 54 seconds west a distance of 8.57 feet to a point at the dividing line of Lot No.
166 (Bowman's Hill, Phase I - PLan Book 65. Page 138) and Lot No. 148, herein described; thence by said
dividing line and beyond by Lot No. 167 North 24 degrees 32 minutes 21 seconds east a distance of 49.13 feet
to a point at the dividing line of Lot No. 147 and Lot No. 148, herein described; thence by said dividing line
South 75 degrees 45 minutes 10 seconds East a distance of 115.37 feet to a point on the western right-of-way
line of Rolling Hills Drive; thence by said right-of-way line by a curve to the right having a radius of 275.00 feet
and an arc length of 113.42 feet, the chord of said curve being South 26 degrees 03 minutes 48 seconds West
a distance of
112.62 feet to a point of BEGINNING.
CONTAINING 10,049 Square feet.
BEING under and subject to all easements and restrictions of record
UNDER AND SUBJECT. NEVERTHELESS, to the same condition, restrictions, exceptions and reservations as
exist by virtue of prior recorded instruments, deeds and conveyances.
BEING THE SAME PREMISES which Patricia B. Frank by her deed dated December 22nd 1997, and recorded
in the Office of the Recorder of Deeds In deed Book 169, Page 1085, granted and conveyed unto Jamie L.
Mladenoff and Jessica A. Poinsett, herein.
ya-3n-ail2, -u3c?
r,
FILED-l1'FFICE_
T
'T TH, M9OCT 19 PH 1: 28
_ y-?y?
Cam- p25,234b
(sue .23?i?ib
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
1$0" at um6rx ?
O
OFF CE nF THE $!'ERiFF
FEl.EC:?:)??irE
T THE
2009 NOV -6 PM 2: 57
CSI'` -iU
PE, I If The Huntingdon National Bank
vs.
Tamara Corbacio
Case Number
2009-7131
SHERIFF'S RETURN OF SERVICE
10/28/2009 02:41 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 28
2009 at 1441 hours, he served a true copy of the within Summons and Praecipe to Index as Lis Pendens,
upon the within named defendant, to wit: Jarrod Corbacio, by making known unto Tamara Corbacio, wife
of defendant at 2428 Rolling Hills Drive Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to her personally the said true and correct copy of the same.
10128/2009 02:41 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 28
2009 at 1441 hours, he served a true copy of the within Summons and Praecipe to Index as Lis Pendens,
upon the within named defendant, to wit: Tamara Corbacio, by making known unto herself personally, at
2428 Roiling Hills Drive Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $53.00
SO ANSWERS,
October 29, 2009 R THOMAS KLINE, SHERIFF
Deputy Sheriff