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Home My WebLink About09-7843r LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2;392 (717)234-4178 ATTORNEY FOR PLAINTIFF' MIDFIRST BANK Plaintiff VS. CHESTER A. LATCHFORD, JR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. - /1843 Owl (76-t-N CIVIL ACTION - LAW 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717 -249 -3166 A? 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 eEcrita o en persona o poi abogado y archivar en la coite en forma eEcrita 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 pE!ticion de demanda. Usted puede perder dinero o sus propiedades o ot.ros derechos importantes para usted. LLEVE ESTA DEMANDA A UN _A_BODAGO 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717 -249 -3166 nr LEON P. HALLER, ESQUIRE PtRCELL, KRUG & HALLER. 1-/19 NORTH FRONT STREET HF.RRISBURG, PA 17102-2392 (-/ 17)234-4178 A'T'TORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d - '? 3 l .tom VS. CHESTER A. LATCHFORD, JR. Defendant CIVIL ACTION - LAW IN EJECTMENT C O M P L A I N T 1. Plaintiff, MidFirst Bank, is a corporation with an office located at 999 N.W. Grand Boulevard, Suite 100, Oklahoma City, Oklahoma 73118 2. Defendant, Chester a. Latchford, Jr., is an adult individual whose last known precise residence is 148 Henry Road, Enola, Pennsylvania 17025. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall bE?come 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. AM 4. Prior to October 7, 2009, Defendant was the owner of certain rE?al property known as 148 Henry Road, Enola, Pennsylvania 17025. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on October 7, 2009, 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. 09-1037 at the suit of MidFirst Bank vs. Chester a. Latchford, Jr. 6. The aforesaid property was purchased at sale by MidFirst Bank, 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. Defendant is presently in possession of the said premises, having come into said possession by virtue of his prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit 11 B 11 WHEREFORE, Plaintiff demands judgment against Defendant 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 DE.ted: November 11, 2009 A. ALL that certain lot or piece of ground with the buildings, improvements, hereditaments and appurtenances thereon erected, situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described according to Plans thereof made by D.P. Raffensperger, Registered Surveyor, on November 17, 1955 and December 4, 1957, as follows: BEGINNING at a point on the northeasterly side of Henry Road (50 feet wide) measured the three following courses and distances along same from its intersection with the southeasterly side of Louis Lane (North) (60 feet wide): (1) extending from said point of intersection, South 21 degrees 22 minutes East, 20.05 feet to a point of curve; (2) on a line curving to the left having a radius of 235 feet, the arc distance of 101.03 feet to a point of tangent; and (3) South 46 degrees East, 232.74 feet to the point and place of BEGINNING. CONTAINING in front or breadth along the said side of Henry Road, 65 feet measured South 46 degrees East and extending of that width in length or depth northeastwardly between parallel lines at right angles to the said Henry Road, 110 feet. BEING Lot No. 148 as shown on said Plans, and on the Plan of East Pennsboro Village, recorded in Cumberland County in Plan Book 9, Page 16. HAVING thereon erected a split level single dwelling house numbered 148 Henry Road, Enola, PA 17025. PARCEL NO.: 09-13-1002-080. UNDER AND SUBJECT, NEVERTHELESS, to certain conditions and restrictions as now appear of record. EXHIBIT "A" A PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on October 7, 2009. 2. Deed from Douglas J. Wagner and Marion M. Wagner dated May 20, 2001 and recorded May 29, 2001 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 245, Page 404, to Chester A. Latchford, Jr. 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: November 11, 2009 (D 20AE2 F ;i2:l_r`) 18.50 rPr) A-rT-f co M&M I u* a333,19 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline ALED-G-: iCE Sheriff 01, THr Ppr"IT-H(' ?I FURY Ronny R Anderson 2009 HIN 24 AH 8: 38 Chief Deputy Jody S Smith CLity, Civil Process Sergeant Edward L Schorpp Solicitor Midfirst Bank Case Number vs. Chester A. Latchford, Jr. 2009-7843 SHERIFF'S RETURN OF SERVICE 11/19/2009 01:40 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on Novembei 19, 2009 at 1340 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Chester A. Latchford Jr., by making known unto himself personally, at 148 Henry Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 20, 2009 SO ANSWERS, ? " P" 611C .0? &e? R THOMAS KLINE, SHERIFF Deputy Sheriff 18) COLVIT SUte Sheriff, Teleosott. Inc- • ' ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anrerson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~ktiyX~S 4~ ~ Ii!'111; r•{ T ~ tit P".C. ~.,,s, LQ~~JwFi~~u Hit 7~ ~'J V ~JVj:.J I. ~ tL,r J V~4~ f 1• ~J ~~ ~ ~ ii Midfirst Bank vs. Case Number Chester A. Latchford, Jr. 2009-7843 SHERIFF'S RETURN OF SERVICE 0112212010 08:06 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on January 22 2010 at 1956 hours a true copy of the within writ of execution was attempted to be served upon the defendant, to wit: Chester A. Latchford, Jr„ at 148 Henry Road, Enola, Cumberland County, Pennsylvania 17025. At that time it was learned that the house is vacant. 06/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $49.47 June 25, 2010 SO ANSWERS, ~C~s%~r"`~~ RON R ANDERSON, SHERIFF ,~. /:%J B -~iZC ~" Sharon R. Lantz