The URL can be used to link to this page

Home My WebLink About09-8649 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: G V I 7- : ACTION TO QUIET TITLE NOTICE TO DEFEND 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. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 S Bedford St Carlisle, PA 17013-3302 (717) 249-3166 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: l? 9- n L f Q 7-e....- and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) COMPLAINT 1. The Plaintiff is ABIJAH IMMANUEL has a mailing address of 6828 Torresdale Avenue, First Floor, Philadelphia, Pennsylvania 19135. 2. Defendant(s) is/are TOWN PLANNER, a corporation with a current address believed to be at 44 Bethany Rd, Ephrata PA 17522 3. Defendant(s) is/are U.S. TREASURY DEPARTMENT, a corporation with a current address believed to be at 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 4. Defendant(s) is/are CITICORP NORTH AMERICA, INC, an corporation with a current address believed to be at 2600 Michelson Dr, Suite 1200. Irvine, California 92612. 5. Additional Defendants are all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plaintiffs title (together with Defendant TOWN PLANNER, Defendant U.S. TREASURY DEPARTMENT, Defendant CITICORP NORTH AMERICA, INC, are referred to herein as the "Defendants") 6. With regard to those properties that were purchased by Plaintiff or Plaintiffs agent at either a tax sale or repository sale, some or all of the sales conveyed title to Plaintiff, free and clear of all mortgages, judgments and other claims, pursuant to the real estate tax sale law. In the alternative it is believed and alleged that any mortgages, judgments and any other claims held by defendants have either been paid and not satisfied off record or divested by Pa statutes and should be stricken from the record. COUNT1 7. This count is ABIJAH IMMANUEL PLAINTIFF vs. TOWN PLANNER, defendants, their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 8. Defendant(s) TOWN PLANNER became judgment/creditor of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in the Cumberland county court house set forth in Docket # 2008-04428. 9. On or about September 24, 2009, the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., and said Defendant received all required statutory notices and/or had actual knowledge of foregoing Tax Claim Sale and, therefore, said Tax Claim Sale did in fact divest any interest, right, title said Defendants had in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 10. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. COUNT 2 11. This count is ABIJAH IMMANUEL PLAINTIFF vs. U.S. TREASURY DEPARTMENT., defendant(s), their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 12. Defendant(s) U.S. TREASURY DEPARTMENT. became judgment/creditor of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in the Cumberland county court house set forth in Docket # 2008-01642. 13. On or about September 24, 2009 the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant. to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., sold property to Plaintiff. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 14. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. ? tiY COUNT 3 15. This count is ABIJAH IMMANUEL PLAINTIFF vs. CITICORP NORTH AMERICA, INC, defendants, their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 16. Defendant(s) CITICORP NORTH AMERICA, INC became judgment/ creditor/mortgagee of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in a Cumberland county court house set forth in book and page # 687-1268. 17. On or about September 24, 2009 the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., sold property to Plaintiff. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 18. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. Respectfully submitted, Date: he Z // MMANUEL, Pro s 6828 Torresdale Av . Philadelphia, Pa 1913 (215)-333-2233 Verification The undersigned named Plaintiff takes this verification subject to Pa R.C.P. No. 1024 and states pursuant to 18 Pa C.S. Section 4904 that the facts set forth are true and correct subject to the following limitations, to wit: (1) facts alleged herein are taken from some of the facts alleged by Defendant in their Petition; or (2) information received from third parties, however, until further discovery is concluded, Plaintiff, cannot second party verify said facts; or (3) information from public records; or (4) belief that the Prothonotary strictly complied with Pa R.C.P. No. 236; or (5) upon review of the ci c stance involved; or (6) upon either opinion, unders ing; Said Pl intif reserves the right to amend this verification after coion of the o al de sitions. ijqKImman Ti.TAi?Y 200 4 01: C 16 PI;12: 6 3 J 0 q,), v-0 kt, ?tH V l-f'- , ;? -3 5-/0'/ f : ABIJAH IMMANUEL, Pro Se ' T? ! - 6828 Torresdale Ave Philadelphia, PA 19135 2',i 13 J A' H 21 A'l' I i 3 U (215)333-2233 Gl.''i ;:_: PSIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: 09-8649 ACTION TO QUIET TITLE AMENDED COMPLAINT IN ACTION TO QUIET TITLE 1. The Plaintiff is ABIJAH IMMANUEL has a mailing address of 6828 Torresdale Avenue, First Floor, Philadelphia, Pennsylvania 19135. 2. Defendant(s) is/are TOWN PLANNER, a corporation with a current address believed to be at 44 Bethany Rd, Ephrata PA 17522 3. Defendant(s) is/are U.S. TREASURY DEPARTMENT, a corporation with a current address believed to be at 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 4. Defendant(s) is/are CITICORP NORTH AMERICA, INC, an corporation with a current address believed to be at 8105 Irvine Center Dr Suite 350, Irvine CA 92618 5. Additional Defendants are all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to Plaintiff s ownership, or any cloud to Plaintiffs title (together with Defendant TOWN PLANNER, Defendant U.S. TREASURY DEPARTMENT, Defendant CITICORP NORTH AMERICA, INC, are referred to herein as the "Defendants"). 6. With regard to those properties that were purchased by Plaintiff or Plaintiffs agent at either a tax sale or repository sale, some or all of the sales conveyed title to Plaintiff, free and clear of all mortgages, judgments and other claims, pursuant to the real estate tax sale law. In the alternative it is believed and alleged that any mortgages, judgments and any other claims held by defendants have either been paid and not satisfied off record or divested by Pa statutes and should be stricken from the record. COUNTI 7. This count is ABIJAH IMMANUEL PLAINTIFF vs. TOWN PLANNER, defendants, their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 8. Defendant(s) TOWN PLANNER became judgment/creditor of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in the Cumberland county court house set forth in Docket # 2008-04428. 9. On or about September 24, 2009, the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., and said Defendant received all required statutory notices and/or had actual knowledge of foregoing Tax Claim Sale and, therefore, said Tax Claim Sale did in fact divest any interest, right, title said Defendants had in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 10. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. COUNT 2 11. This count is ABIJAH IMMANUEL PLAINTIFF vs. U.S. TREASURY DEPARTMENT., defendant(s), their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 12. Defendant(s) U.S. TREASURY DEPARTMENT. became judgment/creditor of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in the Cumberland county court house set forth in Docket # 2008-01642. 13. On or about September 24, 2009 the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., sold property to Plaintiff. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 14. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. COUNT 3 15. This count is ABIJAH IMMANUEL PLAINTIFF vs. CITICORP NORTH AMERICA, INC, defendants, their heirs, personal representatives, successors, executors, administrators, assigns, lien holders and generally any and all other persons having or claiming to have any right, lien, title or interest in and to real property described below. 16. Defendant(s) CITICORP NORTH AMERICA, INC became judgment/ creditor/mortgagee of real property described in this Count as follows, to wit: ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, being more fully described in a Cumberland county court house set forth in book and page # 1614-602, and 687-1268. 17. On or about September 24, 2009 the Cumberland County Tax Claim Bureau, by the powers vested in it pursuant to the Real Estate Tax Sale Law, 72 P.S. § 5860.101 et seq., sold property to Plaintiff. It is believed that the encumbrance is either paid in full but not satisfied or divested by Real Estate tax sale law in and to the foregoing real property. The Tax Claim Bureau sold the Property for nonpayment of taxes that constituted a valid lien on the Property, to Plaintiff, as the highest bidder at a public auction. 18. The legal and procedural authority pursuant to which plaintiff have filed this Action to Quiet Title is found in PA R.C.P. No. 1061 (b) (3) "to compel an adverse party to file, record, cancel, surrender or satisfy of record, or admit the validity, invalidity or discharge of, any document, obligation or deed affecting any right, lien, title or interest in land" Plaintiff seek a Court Order barring and enjoining Defendants, pursuant to PA R.C.P. No. 1066 from ever attacking the validity of Plaintiff title. WHEREFORE, Plaintiff respectfully prays that your Honorable Court will enter an Order and Decree that states that Plaintiff are the legal owner of the herein described real property and furthermore, enjoin said Defendant, his/her/their heirs, personal representatives, executors, administrators, successors and assigns and generally any and all other person(s) from having or claiming to have any type of right, lien, title or interest in and to said real property which is in any manner inconsistent with the interest, right, title of Plaintiff herein. Respectfully submitted, Date: Z5 (? (215)-333-2233 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 1913 5 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. : No: 09-8649 : ACTION TO QUIET TITLE DEFENDANT(S) NOTICE TO DEFEND 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. NAME: LAWYERS REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION ADDRESS: 32 S Bedford St Carlisle, PA 17013-3302 (717) 249-3166 Verification The undersigned named Plaintiff takes this verification subject to Pa R.C.P. No. 1024 and states pursuant to 18 Pa C.S. Section 4904 that the facts set forth are true and correct subject to the following limitations, to wit: (1) facts alleged herein are taken from some of the facts alleged by Defendant in their Petition; or (2) information received from third parties, however, until further discovery is concluded, Plaintiff, cannot second party verify said facts; or (3) information from public records; or (4) belief t the Prothonota s 'ctly complied with Pa R.C.P. No. 236; or (5) upon vie of the circa stance involved; or (6) upon either opinion, understa ?ionjof ng Said Plaintif reserve the right to amend this verification after com 1 the oral de ositions. A2WIlmanuel Ptiff ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL : No: 09-8649 : ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by certified mail, postage, prepaid was sent to: CITICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine C No# 7009-1680-0002-0437-7059 BY: ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiffs ownership. DEFENDANT(S) : No: 09-8649 : ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first class mail, postage, prepaid was sent to: TOWN PLANNER 44 Bethany Rd, Ephrata PA 17522 U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 BY: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson TH ILE0, Sheriff ?Q,?rrir al ?,rrrrbrrl??? 2. Jody JAN- `.. ,v S Smith 2,310 r Chief Deputy ' Edward L Schorpp Solicitor OFr'CE OF T µZ s."ERIFf Abijah Immanuel vs. U.S. Treasury Dept. SHERIFF'S RETURN OF SERVICE Case Number 2009-8649 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to U.S. Treasury Dept. 12/17/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Town Planner, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Lancaster County, PA to serve the within Complaint and Notice according to law. 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to Citicorp North America, Inc. 12/17/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 2600 Michelson Drive, Suite 1200, Irvine, CA 92612. This was returned to The Sheriffs Office with the defendant's new address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. 12/24/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, U.S. Treasury Department, in the following manner: On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 1500 Washington Avenue NW, Washington, DC 20220. The United States Postal Service delivered the Complaint and Notice to 1500 Washington Avenue NW, Washington, DC 20220 on December 24, 2009 at 1113 hours. 12/30/2009 Lancaster County Return: And now, December 30, 2009 I, Terry A. Bergman, Sheriff of Lancaster County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Town Planner the defendant named in the within Complaint and Notice and that I am unable to find them in the County of Lancaster and therefore return same NOT FOUND. Request for service at 44 Bethany Road, Ephrata, PA 17522 is the radio station 1105, they have never heard of the defendant. 01/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On January 5, 2010 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by and adult in charge. SHERIFF COST: $86.13 SO A WEIRS, January 25, 2010 5,4 ANDERSON, SHERIFF (C CountySuite Shenft. Tejeos&t Inc. Postal CERTIFIED R 11y; No Insurance C il 0 M i Provided) overage Ln , a c (Domest CE) N e $ 0 C3 Postmark ° Retum Receipt Fee rborsemern Require Here 0 9 7 0 ery Fee 1 a? 1 r'q (Endorsement Required) co O Total Postage & Fees $5,7 2009-8649 C03 o U . S . TREASURY DEPT. _-- -. - - - - or PO Box No. 1500 WASHINGTON --------------- --- ---- AVE. NW - - - -- ----- - Ciry State, ZlP+4 -----. WASHINGTON, DC 20220 r Ln ff" ' CERTIFIED MAIL:, RECE IPT Ln (Dc nestic Mail Only: No Insurance Provided) Coverage N Postage $ ° ° Fee ° ° ( Fee 4 Postmark Here ° ra ° RestfirctedDelivery Fee (Endorent Required) ?r7?a q Total Postage & Fees $ S, 7 / `° ° ° enr TO CITICORP NORTH AMERICA 2009-8649 , INC. weer,', No26017-7MIrHELBw--DRIVE--------------------- - or !! O!! O' SUITE 1200 City State. Z%P+4 - .. IRVINE, CA 92612 CERTIFIED MAIIL. RECEIPT (Domestic Mail Only; No Insurance Coverage Providec rl 07 F 1 77 N Postage $ - O ° ertified Fee ° Postmark ( ant Requi Here ° Restricted Delivery Fee (Endorsement Required) ° Total Postage & Fees $ 7 b 2009-8649 -a ° ° °EITICORP NORTH AMERICA, INC. ?` 5`neetApC"NO.;?05 IRVIIV ----------------- or PO Box No. - DUI ?--35a---------------------------- crfy stare zr - IRVINE CA 92618 PS F or m 3800. June 2002 See Reverse for JnstrLIC11011-5 4 2000 •? c CD =r c ?ma0 +t -ri cn "I n nCi ? ? C ?CD .i 3 °w wZ CA) O '* 0 U. ? o ? IQ C3 O O O CD C) 0 0 O O 0 Z (0 m 0 µ 0 i = D o3 In M. CD -0 Hdt••?[ < 0 ' to ]DF+LDLI?"? ? HiA-!EH c ? z HDm '? 0 M H O;u 0 CD ;9000 -? Dz"DHX O R C N mUZ" I3? p m mom -4 Z HtR-il?i oz=xz t -i Gi --1 v o 0 MD m O;oz 0 i mmµ e .e -? Z °4mHZO D .o N UNF? o 0 t} 0 rr? o f A -t on dt{H T Z140 0 (o -0 E+ to z N 3 0 L7 F+ '? o n Q • m 0y C ; ilF i 3 m mo r V Q k ?¢ o } z g o ?? ?? w u1 c n Ir Ln a 9E E z m 13[70 v 2 p c 2 > 0 a g Q 78 Ot C3 > w 8 W. S 1; 1 p g x m o -0 C3 O 0 N ? E m Z E. 00 m C H ?. CL m 8 S: o? - U C.s +' C7 m ?. Q c ? m ? 'm m eNi ? ? ? U ,r??moN O (Z N LL . fA iU+ L ,? v- y (j? [?] E .g co N CCp 02 .8 occ a r t v 04 r-? + o) Z m- i U «mo ?o a? LL E 0 CD tc'r- 0 ff 15 N U•=o_ NQ o¢ U N H ai d p Sr9rs?`e G Dee of mate X Pty Name) p Yes P co n, ?? p No 1, 2, a ehl is aem vemerse 8• F ?K?t ed_ on oa. ON as II C Gom Pa'"'- ,?ad scab to Y S%XP% ce clef 4 t ?e(e8t Me of tha rn D• YEs, etn 11 barK N Z `"1 nvi! ri gP z 50 'dam 2010 or of% to: -'?'RSCA' SUZ'i and?se ciNO- ?R vpTess ?,,tiorMer?' t • p IAA R Xce p aeturn Vk' CZ't 5 1 Z 92618 . ?eced p c o °• p ve g10 CA p aeg Ma?? Fee) S.RVS.?' D tnggred eC?venl? (? a. armed ? e?y ?b5`° ,oz5??'t? oay° °°oo $649 ?°ob a?ae??pt 2049" Dom?tt° z N ?^ s? IBS, 2? Ran 3g?1, F?r`?aN - _ , -- - PS ¢°ctr ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 1913 5 (215)333-2233 FILED-OrrCE OF THE RpoTijJq TAF# 2010 FEB -8 P;# 3: 25 TA W AN,i riY ARBT 9?RR4ASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiffs ownership. DEFENDANT(S) ACTION TO QUIET TITLE NOTICE OF DEFAULT To: CITICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. You have been sued in court. If you wish to defend against the claims set forth, you must take action within ten (10) 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. NAME: LAWYERS REFERENCE SERVICE DAUPHIN COUNTY BAR ASSOCIATION CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL : No: 09-8649 ADDRESS: 213 North Front Street Harrisburg, PA 17101 71.7.232.7536 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. : No: 09-8649 ACTION TO QUIET TITLE DEFENDANT(S) CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: CITICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine C BY: ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE 0F ALED--,1i ricE _ ZO 10 FEB I I All 10: 13 CLJv4 'J "N Ty CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiffs ownership. DEFENDANT(S) : No: 09-8649 : ACTION TO QUIET TITLE NOTICE OF DEFAULT To: U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 You have been sued in court. If you wish to defend against the claims set forth, you must take action within ten (10) 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. NAME: LAWYERS REFERENCE SERVICE DAUPHIN COUNTY BAR ASSOCIATION ADDRESS: 213 North Front Street Harrisburg, PA 17101 717.232.7536 1, / ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiffs ownership. DEFENDANT(S) No: 09-8649 ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washing BY: 20 10 FE- B 23 n 3 7 THIS IS NOT AN Cu' 11 ARBITRATION CASE ` ` L", 4 " K. CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 ACTION TO QUIET TITLE MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) PERTAINING TO COUNT 2 AND NOW, the Plaintiff, Abijah Immanuel, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case on December 16th, 2009. (endorsed with a Notice to Plead). 2. The Respondent was served by the Sheriff of Cumberland County via certified mail with a true and correct copy of the Complaint (endorsed with a Notice to Defend) on 12/24/2009. The Sheriff's return of services is attached as exhibit "B" U.S. TREASURY DEPARTMENT. was served by sheriff via certified mail on 12/24/2009. Attached hereto and made part hereof, is a true copy of the ¦ . . . "Return receipt" and acceptance of service 3. The foregoing named Defendant is IN DEFAULT for their failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 4. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 5. Attached hereto is Plaintiffs Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as exhibit "A". 6. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Default for failure to plead to Plaintiffs Complaint. Respectfully ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 ACTION TO QUIET TITLE PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) County of Philadelphia Commonwealth of PA : ss The undersigned , being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Sheriff of Cumberland County did serve the following defendants via certified mail with Complaint endorsed with a Notice to Defend: U.S. TREASURY DEPARTMENT was served by sheriff on 12/24/2009, at 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 2. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. WHEREFORE, Defendant prays that the Court enter a judgment PA.R.C.P. 1066(b)(3) granting the relief requested by Plain ah Sworn to and subscribed before me this day of February, 2010 Notary Public COMMONWL..- ?, OF PENNSYLVANIA i'loui,,ial Seal Roland V ? Notary Public City of Philadeln. ' Aadelphia County My Commissio= Sept. 30, 2012 Member, Pennsylvania Association of Notaries ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: 09-8649 ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 BY LJ. Lill JJFM SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???ti1v of (:mnGer?? Jody S Smith ?o rrb Chief Deputy Edward L Schorpp solicitor OFFICE OF TAE SHERIFF D 2 Abijah Immanuel vs. U.S. Treasury Dept. U Case Number 2009-8649 SHERIFF'S RETURN OF SERVICE 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to U.S. Treasury Dept. 12/1712009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Town Planner, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Lancaster County, PA to serve the within Complaint and Notice according to law. 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to Citicorp North America, Inc. 12/17/2009 Ronny R. Anderson, Sheriff, who being duty sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 2600 Michelson Drive, Suite 1200, Irvine, CA 92612. This was returned to The Sheriffs Office with the defendant's new address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. 12/24/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, U.S. Treasury Department, in the following manner. On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 1500 Washington Avenue NW, Washington, DC 20220. The United States Postal Service delivered the Complaint and Notice to 1500 Washington Avenue NW, Washington, DC 20220 on December 24, 2009 at 1113 hours. 12/30/2009 Lancaster County Return: And now, December 30, 2009 I, Terry A. Bergman, Sheriff of Lancaster County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Town Planner the defendant named in the within Complaint and Notice and that I am unable to find them in the County of Lancaster and therefore return same NOT FOUND. Request for service at 44 Bethany Road, Ephrata, PA 17522 is the radio station 1105, they have never heard of the defendant. 01/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On January 5, 2010 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. The certified mail return receipt card was received by the Cumberland County Sheriff's Office signed by and adult in charge. SHERIFF COST: $86.13 January 25, 2010 SO ANSWERS, RONNY R ANDERSON, SHERIFF (c) roiNry$1.11195nenIT. Te1e050, Inc. USPS - Track & Confirm U14117?l???7, POSTAL SERVICEe Page 1 of 1 Home i Help i Sign In ---? Track & Confirm FAQs Track & Confirm Search Results Label/Receipt Number: 7006 0810 0000 7881 7588 Service(s): Certified Mail' Track & Confirm Status: Delivered Enter Label/Receipt Number. Your item was delivered at 11:13 AM on December 24, 2009 in WASHINGTON, DC 20220. (Gn Detailed Results: • Delivered, December 24,2009,11:13 am, WASHINGTON, DC 20220 • Arrival at Unit, December 24, 2009, 9:07 am, WASHINGTON, DC 20022 Natification Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go Site Ma Customer Service Forms Gov't Services Careers Privacy Policy Terms of Use Business customer Gateway Copyright0 2010 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA 19 F m ! i I' T http : //trkcnfrm 1. smi . usp s. com/PT SIntemet W eb/InterLabelInquiry. do 1/25/2010 . ¦ uae ? q IIPIIN?NII uner eaia sALE i3 A3-osW-u1] 00099W Cl;ax Ttatm Tsurran 43prb Y$ 1?dr Made this ...................... .......... day of .......Am.wb.1 ........, 20......, 09 between the TAX CLAIM BUREAU, of the County of Cumberland, Pennsylvania, as Trustee, GRANTOR, and. Abijah Tafari Immanuel ............................................................................s ............................................ Grantee i#YIE$M4, that in consideration of $ .. ,,,,,,$12,221:07 " ... in hand paid, receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantee, ...... bi.S..... heirs and assigns, the certain premises situate in ....................,,,,,.,,_ Lower Allen Township Cumberland County, Pennsylvania, as follows 2313 Gettysburg Road tax parcel # 13-23-0549-077 see Appendix A for Legal Description Owner or reputed owner as returned to said Bureau KBL Petroleum Incorporated 645 Philadelphia Street Indiana PA 15701 the wine having been sold by the Tax Claim Bureau to the said grantee, on the .............2.4............... day of .....,September ............................... Anno Domini two thousand and ............ 42009 .. . ........................ after due advertisement according to law, the period of redemption for the payment of tax claims having expired without the property having been redeemed, or any tax judgements heretofore having been entered against the described property having not been satisfied, or no agreement to stay the sale of the within described property having been entered into, or the within described real estate no longer remaining in possession of a sequestrator, by Upset Price Sale. under and by virtue of the Act of 1947 PL 1368 (Real Estate Tax Sale Law), ,?l'i I#2tE88 4PrED#, said Grantor has hereunto caused this Deed to be executed by its Director the day and year first above written. Signed, Sealed and Delivered in the presence of TAX CLAIM BUREAU OF CUMBERLAND COUNTX, PENNSYLVANIA, L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ....... (SEAL) On this, the ........... q..+h ........................... day of ... .. ..........................................., 20..,7 before tne, the Prothonotary of the County of Cumberland, the undersigned officer, personally appeared ..Meli.ssa... F....Mixell .............................. 1)irPrtnr e,f 10- T- Cl-'. '.................... ,,, ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 1,47 TL } "?If",1I ? a I 2010 F E 3 23 A.i' 9: 36 THIS IS NOT AN ??Ty ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: 09-8649 ACTION TO QUIET TITLE MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) PERTAINING TO COUNT 3 AND NOW, the Plaintiff, Abijah Immanuel, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case on December 16th, 2009. (endorsed with a Notice to Plead). 2. The Respondent was served by the Sheriff of Cumberland County via certified mail with a true and correct copy of the Complaint (endorsed with a Notice to Defend) on 01/05/2010. The Sheriffs return of services is attached as exhibit "B". CITICORP NORTH AMERICA, INC was served by sheriff via certified mail on 01/05/2010. Attached hereto and made part hereof, is a true copy of the I , "Return receipt" and acceptance of service 3. The foregoing named Defendant is IN DEFAULT for their failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 4. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 5. Attached hereto is Plaintiff's Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as exhibit "A". 6. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Default for failure to plead to Plaintiffs Complai Respectfully Exhibit A ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 ACTION TO QUIET TITLE PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) County of Philadelphia Commonwealth of PA : ss The undersigned , being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Sheriff of Cumberland County did serve the following defendants via certified mail with Complaint endorsed with a Notice to Defend: CITICORP NORTH AMERICA, INC was served by sheriff on 1/05/2010, at 8105 Irvine Center Dr Suite 350, Irvine CA 92618 2. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. WHEREFORE, Defendant prays that the Court enter a judgment pursuant to PA.R.C.P. 1066(b)(3) granting the relief requested by Sworn to and subscribed before me this /6 day of February, 2010 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Roland V. Oris, Notary Public City of Philadelphia, Philadelphia County My Commission Expires Sept. 30, 2012 Member, Pennsylvania Association of Notaries Exhibit B Jan, Z). Lulu i,u7fM Nn, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor i:uinGerlQNO OFFICE OF THE SPERIFF Abijah Immanuel vs. U.S. Treasury Dept. SHERIFF'S RETURN OF SERVICE 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to U.S. Treasury Dept. 12/17/2009 R. Thomas Kline, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Town Planner, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Lancaster County, PA to serve the within Complaint and Notice according to law. 12/17/2009 On this date R. Thomas Kline, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to Citicorp North America, Inc. 12/17/2009 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 2600 Michelson Drive, Suite 1200, Irvine, CA 92612, This was returned to The Sheriffs Office with the defendant's new address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. 12/24/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, U.S. Treasury Department, in the following manner. On December 17, 2009 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 1500 Washington Avenue NW, Washington, DC 20220. The United States Postal Service delivered the Complaint and Notice to 1500 Washington Avenue NW, Washington, DC 20220 on December 24, 2009 at 1113 hours. 12/30/2009 Lancaster County Return: And now, December 30, 2009 I, Terry A. Bergman, Sheriff of Lancaster County, Pennsylvania, do hereby certify and retum, that I made diligent search and inquiry for Town Planner the defendant named in the within Complaint and Notice and that I am unable to find them in the County of Lancaster and therefore return same NOT FOUND. Request for service at 44 Bethany Road, Ephrata, PA 17522 is the radio station 1105, they have never heard of the defendant. 01/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Citicorp North America, Inc., in the following manner: On January 5, 2010 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 8105 Irvine Center Drive, Suite 350, Irvine, CA 92618. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by and adult in charge. SHERIFF COST: $86.13 January 25, 2010 Case Number 2009-8649 SO ANSWERS, RONNY R ANDERSON, SHERIFF (c) C.o,nWSLI1E 5nenR. Teleoson, hna. ¦ Complete items 1, 2, and 3. Also complete signature item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse X 11 Agent so that we can return the card to you. ? Addressee ¦ Attach this card to the back of the maiiplece, B R ived?(printed Name) C. Date'of Delivery or on the front if space permits. ti 1. Article Addressed to: D. Is delivery add t? m 1? ? Yes If YES, enter I add ? No CITICORP NORTH AMERICA, INC. 2 N - --. 8105 IRVINE CENTER DRIVE SUITE tO >- rIj - IRVINE, CA 92618 3. Spe Ice Type_ ?- gnrtifled Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 2009-8649 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Transfer from service rage!, 7 0 0 6 0 810 0000 7881 7656 PS Form 3811, February 2004 Domestic .Return Receipt 102595-02-M-1540 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER No: 09-8649 U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: CITICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. BY vob a q m wser rxi¢sn? !3-a3-m&6-0'77 0099W (71 ax tv".T?'Ittim Tsurran +eeb t'S PlUb Made this ......................4.............. day of .............. J.)PrW b.qr ......... 20......, 09 between the TAX CLAIM BUREAU, of the County of Cumberland, Pennsylvania, as Trustee, GRANTOR, and Abij.ah.Tafhr.i.Immanuel ............................................................................................................ ........................................................................................................................ Grantee it esset4, that in consideration of $......$12,221;07 i n hand paid, receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantee, ......his..... heirs and assigns, the certain premises situate in ................... Lower Allen Township ............................................... Cumberland County, Pennsylvania, as follows : 2313 Gettysburg Road tax parcel# 13-23-0549-077 see Appendix A for Legal Description Owner or reputed owner as returned to said Bureau KBL Petroleum incorporated 645 Philadelphia Street Indiana PA 15701 the same having been sold by the Tax Claim Bureau to the said grantee, on the .............24............... day of ......September Anno Domini two thousand and ..........2009 after due advertisement according to law, the period of redemption for the payment of tax claims having expired without the property having been redeemed, or any tax judgements heretofore having been entered against the described property having not been satisfied, or no agreement to stay the sale of the within described property having been entered into, or the within described real estate no longer remaining in possession of a sequestrator, by Upset Price Sale. under and by virtue of the Act of 1947 PL 1368 (Real Estate Tax Sale Law), 4n Wititeez heYeIIf, said Grantor has hereunto caused this Deed to be executed by its Director the day and year first above written. Signed, Sealed and Delivered in the presence of: TAX CLAIM BUREAU OF CUMBERLAND COUNT,', PENNSYLVANIA, t ... .....,. .......... ..................... COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ........ (SEAL) On this, the ...........1. ........................... day of . 20,0..,7 before me, the Prothonotary of the County of Cumberland, the undersigned officer, personally appeared .... , elissa F... ..M... ll;rP.-*,,,. „f «t.e -r .. i=i::_ ............................ ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT ARBITRATION CfAS' ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: 09-8649 ACTION TO QUIET TITLE MOTION FOR COURT ORDER PA. R.C.P. NO. 1066(b)(3) PERTAINING TO COUNT 2 AND NOW, the Plaintiff, Abijah Immanuel, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case on December 16th, 2009. (endorsed with a Notice to Plead). 2. The Respondent was served by the Sheriff of Cumberland County via certified mail with a true and correct copy of the Complaint (endorsed with a Notice to Defend) on 12/24/2009. The Sheriff's return of services is attached as exhibit "B". U.S. TREASURY DEPARTMENT. was served by sheriff via certified mail on 12/24/2009. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service 3. The foregoing named Defendant is IN DEFAULT for their failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 4. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 5. Attached hereto is Plaintiff's Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as exhibit "A". 6. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Default for failure to plead to Plaintiffs Complai Respectfully ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) No: 09-8649 : ACTION TO QUIET TITLE PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) County of Philadelphia Commonwealth of PA : ss The undersigned , being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Sheriff of Cumberland County did serve the following defendants via certified mail with Complaint endorsed with a Notice to Defend: U.S. TREASURY DEPARTMENT was served by sheriff on 12/24/2009, at 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 2. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. WHEREFORE, Defendant prays that the Court enter a judgment pursua t to PA.R.C.P. 1066(b)(3) granting the relief requested by Pla n i . biiah Imman e Sworn to and subscribed before me this day of February, 2010 CCML40WJEALTH OF PENNSYLVANIA Notarial Sea' Roland V. Oris, Notary Public City 01 Philadelphia, Philadelphia County Notary Public My Commission Expires Sept 30, 2012 Member, ennsylvania Association of Notaries ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 : ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 BY ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 i ?U C.v i l i j THIS IS NOT AN G P..' 7y ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) No: 09-8649 : ACTION TO QUIET TITLE MOTION FOR COURT ORDER PA RCP NO 1066(b)(3) PERTAINING TO COUNT 3 AND NOW, the Plaintiff, Abijah Immanuel, files the following Motion for Order under PA R.C.P. No. 1066(b)(3). 1. Plaintiffs filed their Complaint in the above captioned case on December 16th, 2009. (endorsed with a Notice to Plead). 2. The Respondent was served by the Sheriff of Cumberland County via certified mail with a true and correct copy of the Complaint (endorsed with a Notice to Defend) on 01/05/2010. The Sheriff's return of services is attached as exhibit "B". CITICORP NORTH AMERICA, INC was served by sheriff via certified mail on 01/05/2010. Attached hereto and made part hereof, is a true copy of the "Return receipt" and acceptance of service 3. The foregoing named Defendant is IN DEFAULT for their failure to plead to said Complaint within the time period provided by the Rules of Civil Procedure. 4. PA. R.C.P. No. 1066 provides, inter alia, that the Court may enter an Order in favor of Plaintiffs when said Defendant, as here, have failed to plead to the Complaint within the appropriate time permitted by the Rules of Civil Procedure. 5. Attached hereto is Plaintiffs Affidavit which is being filed under PA R.C.P. No. 1066(a), marked as exhibit "A". 6. For the foregoing legal reasons, Plaintiffs respectfully pray that the Court will issue an Order under Rule 1066(b) (3), a proposed copy attached hereto for review. WHEREFORE, Plaintiffs respectfully request a Court Order pursuant to Rule 1066(b)(3) with respect to these Defendants who is now in Defa for failure to plead to Plaintiffs Complaint. Respectfully Su Abijah Exhibit A ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 ACTION TO QUIET TITLE PLAINTIFFS' AFFIDAVIT FILED PURSUANT PA R.C.P. NO 1066(b)(3) County of Philadelphia Commonwealth of PA : ss The undersigned , being authorized to take this Affidavit on behalf Plaintiffs, takes this Affidavit under PA R.C.P. No 1066(a) and states that the following facts are true and correct: 1. The Sheriff of Cumberland County did serve the following defendants via certified mail with Complaint endorsed with a Notice to Defend: CITICORP NORTH AMERICA, INC was served by sheriff on 1/ 05/ 2010, at 8105 Irvine Center Dr Suite 350, Irvine CA 92618 2. Said Defendants have not filed an Answer or otherwise pleaded to said Complaint within twenty (20) days from service. Now, said Defendant is in DEFAULT under the Rules of Civil Procedure. WHEREFORE, Defendant prays that the Court enter a judgment pursuan PA.R.C.P. 1066(b)(3) granting the relief requested by Sworn to and subscribed before me this day of February, 2010 COMMONIIVE. - -H OF PENNSYLVANIA ^'..tarial 8NI Rolon )ris. NOftry Public Ph++a,,,u,snia, Pfhdelphia County L Notary Public 'o "' `'' 'EXPiros Sept. 30, 2012 Member, Ps ii asp r nia Ass i ti oc a on of Notaries COMMONWEALTH OF PENNSYLVANIA Notarial Seal Roland V. Oris, Notary Public City of Philadelphia, Philadelphia County MY Commission Expires Sept. 30, 2012 Member, Pennsylvanle Association of Notaries Exhibit B ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) : No: 09-8649 : ACTION TO QUIET TITLE CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing pleading was served upon counsel of record in this action. Service by first-class mail, postage, prepaid was sent to: CITICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. BY ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE FEB 2 6 2010 G ABIJAH IMMANUEL PLAINTIFF ¦ VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL No: 09-8649 n o } 0 O ?? ACTION TO QUIET TIT co JUDGMENT AND ORDER AND NOW, this ;? day of /?? 1 , 2010, it appearing that the following named Defendants have been duly served in accordance with the Rules of Civil Procedure governing Actions to Quiet Titles; have NOT filed an Answer, or otherwise pleaded to Plaintiff s Complaint within the time period required by the Rules of Civil Procedure, it is hereby ORDERED and DECREED that FINAL JUDGEMENT is entered against the following Defendants: U.S. TREASURY DEPARTMENT, The Prothonotary is hereby ORDERED to satisfy or discharge any judgments or liens as herein described on the following properties, pursuant to PA R.C.P. No. 1066(b)(3). The real property included in this Order is as follows: ALL THAT CERTAIN tract of ground, located at ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, described in a Deed among the land records of the county and state set forth above. The Lien/ Judgment to be satisfied by the Recorder of Deeds being more fully described in a Cumberland county court house set forth in Docket # 2008-01642. A certified copy of this Court Order shall be recorded of public record in the Cumberland County Prothonotary's Office under the name of the Defendant herein named. All filing and recording fees to record this Court Order shall be paid by Plaintiffs. THE COURT J. Dist ibution List S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 _,,-f'(WN PLANNER 44 Bethany Rd, Ephrata PA 17522 _,-TTICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. 3 f 3?[v `.U ? mss' r?.?! C£GC h? FEB 2 4 2010 6 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE CUMBERLAND COUNTY, ABIJAH IMMANUEL PENNSYLVANIA. COURT OF COMMON PLEAS PLAINTIFF TRIAL DIVISION - CIVIL 0 arc ` a a VS. ?v TOWN PLANNER No: 09-8649, U.S. TREASURY DEPARTMENT w CITICORP NORTH AMERICA, INC 3 and all other persons unknown claiming any va ,{ right, title, estate, lien or interest in the real property described in the complaint adverse ACTION TO QUIET TITLE to plaintiff's ownership. DEFENDANT(S) JUDGMENT AND ORDERA AND NOW, this y day of , 2010, it appearing that the following named Defendants have been duly served in accordance with the Rules of Civil Procedure governing Actions to Quiet Titles; have NOT filed an Answer, or otherwise pleaded to Plaintiff s Complaint within the time period required by the Rules of Civil Procedure, it is hereby ORDERED and DECREED that FINAL JUDGEMENT is entered against the following Defendants: U.S. TREASURY DEPARTMENT, The Prothonotary is hereby ORDERED to satisfy or discharge any judgments or liens as herein described on the following properties, pursuant to PA R.C.P. No. 1066(b)(3). The real property included in this Order is as follows: I. , ALL THAT CERTAIN tract of ground, located at ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, described in a Deed among the land records of the county and state set forth above. The Lien/ Judgment to be satisfied by the Recorder of Deeds being more fully described in a Cumberland county court house set forth in Docket # 2008-01642. A certified copy of this Court Order shall be recorded of public record in the Cumberland County Prothonotary's Office under the name of the Defendant herein named. All filing and recording fees to record this Court Order shall be paid by Plaintiffs. BY THE COURT J. Di ibution List S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 TOWN PLANNER 44 Bethany Rd, Ephrata PA 17522 -,--ViTICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. V- i5 rna ( LC 314Iw FEB ? 4 2010 ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiffs ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLE o TRIAL DIVISION - CIVIL s r w s• M No: 09-8649 ACTION TO QUIET TITLE JUDGMENT AND O AND NOW, this day of ? , 2010, it appearing that the following named Defendants have been duly served in accordance with the Rules of Civil Procedure governing Actions to Quiet Titles; have NOT filed an Answer, or otherwise pleaded to Plaintiffs Complaint within the time period required by the Rules of Civil Procedure, it is hereby ORDERED and DECREED that FINAL JUDGEMENT is entered against the following Defendants: CITICORP NORTH AMERICA, INC, The Recorder of Deeds is hereby ORDERED to satisfy or discharge any judgments or liens as herein described on the following properties, pursuant to PA R.C.P. No. 1066(b)(3). The real property included in this Order is as follows: ALL THAT CERTAIN tract of ground, located at ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, described in a Deed among the land records of the county and state set forth above. The Mortgage to be satisfied by the Recorder of Deeds being more fully described in a Cumberland county court house set forth in Mortgage Book and Page # 1614-602, and 687-1268. A certified copy of this Court Order shall be recorded of public record in the Cumberland County Recorder of Deed's Office under the name of the Defendant herein named. All filing and recording fees to record this Court Order shall be pai4?-? Plaintiffs. THE t1R't 6? J 8105 Irvine Center Dr Suite 350, Irvine CA 92618. D' tribution List U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 ,, l OWN PLANNER 44 Bethany Rd, Ephrata PA 17522 ??ITICORP NORTH AMERICA, INC ?( t-cc a/2lo. -?Zej ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 FEB 262010 THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff's ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL d No: 09-8649 M ? MM )jj ACTION TO QUIET TITLE .? co JUDGMENT AND?/O?RDE AND NOW, this day of P ` , 2010, it appearing that the following named Defendants have been duly served in accordance with the Rules of Civil Procedure governing Actions to Quiet Titles; have NOT filed an Answer, or otherwise pleaded to Plaintiffs Complaint within the time period required by the Rules of Civil Procedure, it is hereby ORDERED and DECREED that FINAL JUDGEMENT is entered against the following Defendants: CITICORP NORTH AMERICA, INC, The Recorder of Deeds is hereby ORDERED to satisfy or discharge any judgments or liens as herein described on the following properties, pursuant to PA R.C.P. No. 1066(b)(3). The real property included in this Order is as follows: s ALL THAT CERTAIN tract of ground, located at ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, described in a Deed among the land records of the county and state set forth above. The Mortgage to be satisfied by the Recorder of Deeds being more fully described in a Cumberland county court house set forth in Mortgage Book and Page # 1614-602, and 687-1268. A certified copy of this Court Order shall be recorded of public record in the Cumberland County Recorder of Deed's Office under the name of the Defendant herein named. All filing and recording fees to record this Court Order shall be paid by Plaintiffs. HE COURT J. Distribution List ,i U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 /SOWN PLANNER 44 Bethany Rd, Ephrata PA 17522 -,-ffTICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618. .. . ?s. Prepared by & Return to: Ab?ah Immanuel 6828 Torresdale Avenue, P Floor Philadelphia, PA 19135 Parcel # 13-23-0549-077 0/Tie ,4k 4/,,,d -? 4 a? C'W /Vo , 09 - g 647. Ac4,•cm fb l y E-k 4ILi' RELEASE OF JUDGMENT/ LIEN To all to whom these Presents shall come, sends Greeting: Whereas, KBL PETROLEUM INCORPORATED (Judgment/Lien Debtor), by Judgment/ Lien bearing recorded date on / /2008 in the Office of the Prothonotary in and for the County of CUMBERLAND, Pennsylvania in docket #2008-01642, granted and conveyed unto the U.S. TREASURY DEPARTMENT (Judgment/Lien Creditor) to secure the payment of a certain debt or principal sum of $85,000.00 lawful money, etc., with interest, as therein mentioned; Brief Property Description Parcel # 13-23-0549-077 DEED REFERENCE: 221-1128 LOWER ALLEN TOWNSHIP, COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA. Property Address: 2313 Gettysburg Rd, Camp Hill, PA 17011. Pursuant to the attached JUDGMENT AND ORDER, executed on MARCH 2°a, 2010, as a result of Case No. 09-8649 in the CUMBERLAND County Pennsylvania, Court of Common Pleas, the undersigned hereby certifies that the debt secured by the above-mentioned Judgment/Lien has been fully paid, or otherwise discharged and that upon that the recording hereof said Judgment/Lien shall be and is hereby fully and forever released, satisfied and discharged. The undersigned hereby authorizes and empowers the Prothonotary of CUMBERLAND County to enter this release of Judgment/ Lien, and to cause said Judgment/ Lien to be released of record. ? Q =r? z - r -D rn 7 l LD _ CC i?1 W r n - Witness the due execution hereof with the intent to be legally bound. On the day of j`1 A ro U . , 2010. WITNESS: Commonwealth of Pennsylvania County of Philadelphia ss ABI IMMANUEU AND NOW, this g day of M g ,, , , 2010, before me, the undersigned Notary Public, personally appeared A h , A in T,,,,,,,,,, iA ti L' known to me (or satisfactorily proven) to be the person whose name is (are) subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunder set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Roland V. Oris, Notary Public Notary Public City of Philadelphia, Philadelphia County My Commission Expires Sept. 30, 2012 My commission expires Member, Pennsylvania Association of Notaries ABIJAH IMMANUEL, Pro Se 6828 Torresdale Ave Philadelphia, PA 19135 (215)333-2233 FEB 262010, THIS IS NOT AN ARBITRATION CASE ABIJAH IMMANUEL PLAINTIFF VS. TOWN PLANNER U.S. TREASURY DEPARTMENT CITICORP NORTH AMERICA, INC and all other persons unknown claiming any right, title, estate, lien or interest in the real property described in the complaint adverse to plaintiff s ownership. DEFENDANT(S) CUMBERLAND COUNTY, PENNSYLVANIA. COURT OF COMMON PLEAS TRIAL DIVISION - CIVIL : No: 09-8649 ACTION TO QUIET TITLE JUDGMENT AND ORDER AND NOW, this ?'sk day of M &U'A , 2010 it appearing that the following named Defendants have been duly served in accordance with the Rules of Civil Procedure governing Actions to Quiet Titles; have NOT filed an Answer, or otherwise pleaded to Plaintiffs Complaint within the time period required by the Rules of Civil Procedure, it is hereby ORDERED and DECREED that FINAL JUDGEMENT is entered against the following Defendants: U.S. TREASURY DEPARTMENT, The Prothonotary is hereby ORDERED to satisfy or discharge any judgments or liens as herein described on the following properties, pursuant to PA R.C.P. No. 1066(b)(3). The real property included in this Order is as follows: tr f ALL THAT CERTAIN tract of ground, located at ALL THAT CERTAIN lot Folio Number: 13-23-0549-077, described in a Deed among the land records of the county and state set forth above. The Lien/ Judgment to be satisfied by the Recorder of Deeds being more fully described in a Cumberland county court house set forth in Docket # 2008-01642. A certified copy of this Court Order shall be recorded of public record in the Cumberland County Prothonotary's Office under the name of the Defendant herein named. All filing and recording fees to record this Court Order shall be paid by Plaintiffs. -? THE COURT J. Distribution List U.S. TREASURY DEPARTMENT 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand TOWN PLANNER and to "W of said Court at C.adtisle, Pa' TNs...L_.dayd ,20 16 44 Bethany Rd, Ephrata PA 17522 _ Prothonotary CIT ICORP NORTH AMERICA, INC 8105 Irvine Center Dr Suite 350, Irvine CA 92618.