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Home My WebLink About01-0865DARRAINE R. JONES and ZXYBRYUL WADDELL, Plaintiffs CHARLES L. BEISTLINE, SYLVIA D. BEISTLINE and BERYL BEISTLINE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- ~.~ CIVIL TERM CIVIL ACTION o LAW ACTION IN EJECTMENT NOTICE 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DARRAINE R. JONES and ZXYBRYUL WADDELL, Plaintiffs CHARLES L. BEISTLINE, SYLVIA D. BEISTLINE and BERYL BEISTLINE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- ~ CIVIL TERM CIVIL ACTION - LAW ACTION IN EJECTMENT COMPLAINT AND NOW, this day of February, 2001, come Plaintiffs, Darraine R. Jones and Zxybryul Waddell, by and through their counsel, Law Offices of Craig A. Diehl, and file the within Complaint, and in support thereof state the following: 1, Plaintiff, Darraine R. Jones, is an adult individual residing at 641 South 29th Street, Harrisburg, Dauphin County, Pennsylvania, 1711 I. 2. Plaintiff, Zxybryul Waddell, is an adult individual residing at 1212 Penn Street, Harrisburg, Dauphin County, Pennsylvania, 17102. 3. Defendants, Charles L. Beistline and Sylvia D. Beistline, husband and wife, are adult individuals residing at 511 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 4. Defendant, Beryl Beistline, is the mother of Charles L. Beistline and resides at 20 East Green Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 5. Defendants were the prior owners of a certain premises situate in Mechanicsburg Borough, Cumberland County, Pennsylvania, known as 20 East Green Street, Mechanicsburg, Pennsylvania, 17055. 6. On or about October 26, 2000, Plaintiffs purchased the said premises at the Cumberland County Tax Upset Sale. 7. The period of redemption for the payment of tax claims having expired, no payment being made on the tax judgments entered against the premises, and no agreement to stay the sale having occurred, legal title vested to Plaintiffs on or about December 15, 2000 when the Tax Claim Bureau conveyed a deed to Plaintiffs. 8. Plaintiffs are currently legal owner of the subject premises described as follows: ALL THAT CERTAIN house and lot of ground situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on Green Street; thence Southward along the line of lot now or formerly of Nellie W. Myers, one hundred sixty (160) feet to an alley; thence along said alley, Westwardly, thirty-two (32) feet to lot now or formerly of Ella R. McGuire and George K. McGuire, her husband; thence along said lot, Northwardly, one hundred sixty-two (162) feet to Green Street; thence along Green Street, Eastwardly, thirty-two (32) feet to the place of BEGINNING. HAVING THEREON ERECTED a two and one-half story frame dwelling numbered 18 and 20 East Green Street, Mechanicsburg, Permsylvania. 9. The abstract of the title on which Plaintiffs rely is as follows: Subject premises was vested in John H. Beistline and Beryl Beistline, his wife; the said John H. Beistline died October 16, 1989, whereupon sole title vested in his wife, the said Beryl Beistline by right of survivorship granted and conveyed unto 2 real property. WHEREFORE, Charles L. Beistline and Sylvia D. Beistline, his wife, by deed dated November 13, 1989 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book G, Vol. 34, Page 861. I 0. As of February 2, 2001, Defendants or their tenant(s) have continued in possession of the subject real property, and have at all times subsequent thereto withheld, and still do withhold, the possession thereof from Plaintiffs. I 1. Due to Defendants' continued possession of the above-described real property since December 15, 2000, Plaintiffs have suffered damages approximating Two Thousand Dollars ($2,000.00) as follows: No rent payments for their use or tenant(s) use; Nonpayment of real estate taxes; Nonpayment of water, sewer, and refuse charges; Inability of Plaintiffs to sell or rent the premises; and Court costs, service costs, and legal fees to obtain possession of the Plaintiffs pray that this Honorable Court enter judgment against Defendants restoring Plaintiffs to the possession of the above-described real property, for damages accrued, costs, and such further relief as may be just. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL By: Craig ,lt. Diehl, Esquire Attorney ID No. 52801 3464 Trindle Road Camp Hill, PA 17011-4436 (717) 763-7613 Counsel for Plaintiffs 4 DARRAINE R. JONES and ZXYBRYUL WADDELL, Plaintiffs CHARLES L. BEISTLINE, SYLVIA Do BEISTLINE and BERYL BEISTLINE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- CIVIL TERM CIVIL ACTION - LAW ACTION IN EJECTMENT VERIFICATION WE, DARRAINE R. JONES and ZXYBRYUL WADDELL, VERIFY that the statements set forth in the foregoing COMPLAINT are true and correct to the best of our knowledge, information and belief. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Dated: Darraine R. Jones Dated: b~ul ~ddell ZXYBRYUL WADDELL, .................... '"P l~'i~f~'~'~ ........ the C~rt oE Comm~a l~e~ o; Cambedami Cou=~, No .... Qi~A~ ................ CNiL ~9 CHARLES Lo BEISTLINE, CIVIL ACTION - LAW SYLVIA D. BEISTLINE and BERYL ACTION IN EJECTMENT BEISTLINE, Defendants . s&~ ....................................................................................... Enter my appearance for Bmryl Beistline, defendant in the above captioned action. To _ .C.u.T.t.J-.s. ~ °--n.,% ........................ Prothonotary ~ohn M. Eak~n ?O6351 ' '~--~.'~'TJF~. '- Mechanicsburg, PA 17055 766-3172 01 I,??, t 3 Pr; 3: ! 7 COUNTY PENNSYLVANIA Xo ....................... Term, I9 ...... PRAEClPE Fi,led ........................... 19 .................................. , ., SHERIFF'S RETURN - CASE NO: 2001-00865 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARP~AINE R ET AL VS BEISTLINE CHARLES L ET AL REGULAR SHAWN HARRISON Cumberland County,Pennsylvania, says, the within COMPLAINT - EJECTMENT BEISTLINE CHARLES L DEFENDANT , at 0018:15 HOURS, on the at 5211 EAST TRINDLE RD 1 R MECHANICSBURG, PA 17055 SYLVIA BEISTLINE (WIFE) a true and attested copy of COMPLAINT NOTICE 9th day of March Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 2001 by handing to - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.82 Affidavit .00 Surcharge 10.00 .00 34.82 Sworn and Subscribed to before me this /L~ day of ' ' Prothonotary' So Answers: R. Thomas Kline 03/12/2001 ~ ~ CRAIG A. DIE7 /~ Sherift , SHERIFF'S RETURN - REGULAR CASE NO: 2001-00865 P COMMONWEALTH OP PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARP~AINE R ET AL VS BEISTLINE CHARLES L ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT BEISTLINE SYLVIA D DEFENDANT at 0018:15 HOURS, on the at 5211 EAST TRINDLE RD MECHANICSBURG, PA 17055 SYLVIA BEISTLINE a true and attested copy of COMPLAINT - NOTICE was served upon 9th day of March the 2001 by handing to EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /L~--- day of ~ o2~! A.D. &!' onotary / So Answers: R. Thomas Kline CRAIG A. DIE By: d/D~uty ~h~'ri f f , SHERIFF'S RETURN - CASE NO: 2001-00865 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES DARRAINE R ET AL VS BEISTLINE CHARLES L ET AL REGULAR SHAWN HARRISON , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT BEISTLINE BERYL DEFENDANT at 0013:50 HOURS, at 20 EAST GREEN ST MECHAlqlCSBURG, PA 17055 BERYL BEISTLINE a true and attested copy of COMPLAINT NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 26th day of February , 2001 by handing to - EJECTMENT together with and at the same time directing _Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 6.82 Affidavit .00 Surcharge 10.00 .00 22.82 Sworn and Subscribed to before me this /4 ~- day of thonotary So Answers: R. Thomas Kline 03/12/2oo [