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HomeMy WebLinkAbout10-5365A ?f 2; ?AM 17 fm I10t INTEGRITY BANK, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION CHRISTOPHER A. CHRONISTER, NO. JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN 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, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) ? f?-.o of d- C-t 61, a-y rd AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de a notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Code por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe antenormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reciamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Code sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE DUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS CUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS DUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) REAGER & ADLER, P.C. BY: THOMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 Email: Twilliams@ReagerAdlerPC.com BY: WAYNE S. MARTIN, ESQUIRE Attorney I.D. No. 208078 Email: Wmartinaa,ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER NO. JANE E.CHRONIS ER, PAUL E. KUHN, : 1 3 s G Ny and KATHRYN P. KUHN, Defendants COMPLAINT ACTION IN EJECTMENT 1. Plaintiff, Integrity Bank (hereinafter "Integrity"), is a Pennsylvania banking institution doing business at 3345 Camp Hill, Pennsylvania 17011. 2. Defendants Christopher A. Chronister and Jane E. Chronister (hereinafter, the "Chronisters") are adult individuals, husband and wife, currently residing at 1000 West Foxcroft Drive, Camp Hill, Pennsylvania 17011. 3. Defendants Paul E. Kuhn and Kathryn P. Kuhn (hereinafter, the "Kuhns"), are adult individuals, husband and wife, currently residing at 1000 West Foxcroft Drive, Camp Hill, Pennsylvania 17011. 4. This Court has jurisdiction and venue over this matter pursuant to Pa.R.C.P. 1051 because the land that is the subject of this lawsuit is located in Cumberland County, Pennsylvania. 5. On May 1, 2010, the Chronisters and the Kuhns executed a Deed in Lieu of Foreclosure to the real property located at 1000 West Foxcroft Drive, Camp Hill, Pennsylvania 17011 (hereinafter, the "Property"). The Property is more specifically described as tax parcel number 47-18-1302-057 and by the legal description contained in the Deed in Lieu of Foreclosure dated May 1, 2010 and recorded with the Cumberland County Recorder of Deeds on May 4, 2010, at instrument no. 201011260. A true and correct copy of the May 1, 2010 Deed in Lieu of Foreclosure is attached hereto and incorporated herein, as Exhibit "A". 6. Pursuant to Pa.R.C.P. 1054, the Abstract of the title upon which Integrity relies is as follows: Owners, September 15, 2005 to December 10, 2008: Christopher A. Chronister and Jane E. Chronister and Paul E. Kuhn and Kathryn P. Kuhn, conveyed by Jay A. Young, by Deed dated September 15, 2005, and recorded in Cumberland County Deed Book 271, Page 981. Owners, December 10, 2008 to July 10, 2009: Suntrust Mortgage, conveyed by R. Thomas Kline, Sheriff of Cumberland County, by Sheriff's Deed dated December 10, 2008, and recorded in Cumberland County Deed Book on December 29, 2008 at Instrument No. 200840575. Owners, July 10, 2009 to May 1, 2010: Christopher A. Chronister and Jane E. Chronister and Paul E. Kuhn and Kathryn P. Kuhn, conveyed by Suntrust Mortgage by Special Warranty Deed dated July 10, 2009, and recorded in Cumberland County Deed Book on July 31, 2009 at Instrument No. 200926723. Owners, May 1, 2010 to Present: Integrity Bank, conveyed by Christopher A. Chronister and Jane E. Chronister and Paul E. Kuhn and Kathryn P. Kuhn, by Deed in Lieu of Foreclosure dated May 1, 2010, and recorded in Cumberland County Deed Book on May 4, 2010 at Instrument No. 201011260. 7. The Chronisters and the Kuhns are the previous owners of the Property and continue to reside unlawfully at the Property. 8. On May 1, 2010, Integrity, the record owner of the Property, orally notified the Chronisters and the Kuhns that they had forty five (45) days to vacate the Property. 9. On July 13, 2010, Integrity provided notice to the Chronisters and the Kuhns that the forty five (45) day grace period to vacate the Property had elapsed. 10. The Chronisters and the Kuhns have failed and refused to vacate the Property. 11. Integrity claim title and right of possession of the Property, and are entitled to immediate possession of the Property. 12. The Chronisters and the Kuhns and all other occupants have unjustly and unlawfully detained possession of the Property from Integrity without right and claim of title. 13. Integrity has taken all actions and complied with all conditions precedent to the filing of this action. WHEREFORE, Plaintiff, Integrity Bank respectfully requests that this Honorable Court enter judgment in ejectment in its favor and against Defendants Christopher A. Chronister, Jane E. Chronister, Paul E. Kuhn, Kathryn P. Kuhn and all other occupants for possession of the Property. Respectfully submitted, REAGER & ADLER, P.C. Date: August 2010 /V/// Thomas . Williams, Esquire Attorney I.D. No. 67987 Email: Twilliams(&Re@gerAdlerPC.com Wayne S. Martin, Esquire Attorney I.D. No. 208078 Email: Wmartin(&Reai?erAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff Ing Prepared By: TURNER AND O'CONNELL 4701 North Front Street Harrisburg, PA 17110 (717) 232-4551 DEED IN LIEU OF FORECLOSURE Made this X day day ofd, 2010, between CHRIS A. CHRONISTER and JANE E. CHRONISTER, husband and wife, and PAUL E. KUHN and KATHRYN P. KUHN, husband and wife, of Cumberland County, Pennsylvania, parties of the first part, GRANTORS, A N D INTEGRITY BANK, a Pennsylvania banking institution, party of the second part, GRANTEE, WITNESSETH: that the Grantors, for and in consideration of the sum of ONE AND NO1100 ($1.00) DOLLAR, in hand paid, the receipt of which is hereby acknowledged, does grant and convey to the Grantee, it successors and assigns: ALL THAT CERTAIN lot of land situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Foxcroft Drive, said point being the northeastern corner of Lot No. 70, Section D of the hereinafter mentioned plan of lots; thence by the western side of Foxcroft Drive South 09 degrees 15 minutes 33 seconds East 92.16 feet to a point; thence by the same on a curve to the right having a radius of 10 feet, an arc distance of 13.29 feet to a point on the northern side of Echo Road; thence by the northern side of Echo Road South 60 degrees 54 minutes 27 seconds West 120.89 feet to a point; thence by the western line of Lot No. 70, Section D, North 09 degrees 15 minutes 33 seconds West 130.78 feet to a point; thence by the northern line of Lot No. 70, Section D, North 80 degrees 44 minutes 27 seconds East 125 feet to the place of BEGINNING. 9 q Tax Parcel No. 47-18-1302-057 BEING Lot No. 70, Section D, of the Plan of Lots of Riverview as recorded in Plan Book 11, page 9, Cumberland County Records and being SUBJECT to utility easements and building and use restrictions and conditions of record. BEING the same premises which SunTrust Mortgage, by deed dated July 10, 2009 and recorded in the Cumberland County Recorder of Deeds Office to Instrument No. 200926723 granted and conveyed unto Chris A. Chronister and Jane E. Chronister, husband and wife, and Paul E. Kuhn and Kathryn P. Kuhn, husband and wife. THE WITHIN TRANSFER is tax exempt pursuant to 72 P.S. §8102-C.3(16) of the Realty Transfer Tax Act, as amended. THIS DEED IS A CONVEYANCE FROM GRANTOR TO GRANTEE IN LIEU OF FORECLOSURE OF MORTGAGE GIVEN BY GRANTORS TO GRANTEE DATED JULY 15, 2009 AND RECORDED JULY 31, 2009 IN THE ORIGINAL AMOUNT OF $165,000.00 AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY TO INSTRUMENT NO. 200926724; AND IN LIEU OF FORECLOSURE OF THE MORTGAGE GIVEN BY GRANTORS TO GRANTEE DATED JULY 15, 2009 AND RECORDED AUGUST 14, 2009 IN THE ORIGINAL AMOUNT OF $43,873.55 AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY TO INSTRUMENT NO. 200928668. AND the said Grantors will SPECIALLY WARRANT AND FOREVER DEFEND the property hereby conveyed. IN WITNESS WHEREOF, the Grantors have set her hand and seal the day and year first written above. --(seal) Chris A. Chronister r.,•C? 'F, l - (seal) Jmxrt. Chronister --'c" c&-l e. r-'. (seal) Paul E. Kuhn VAA DA (seal) KatUryn P. uhn Wi ss: State of Pennsylvania County of Cavr%f&ree-?,P On this the I' day of 2010, before me, the undersigned officer, personally appeared Chris A. Chronister, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that he executed same for the purposes therein contained. In witness whereof, I hereunto set my hand and notarial seal. 4 1 My Commission Expires: elq?'o40 No 'c NoWW S.w PWft 0 Ala 10-1 A Cot Cormi?brt 6pYa Jufw 29, Aenwvlvanls Asaooladori of C 0 W1 Be9tA,%-JP Olo ,?ve o b' ir' plan this the 50 day of U ch, 2010, before me, the undersigned officer, personally appeared Jane E. Chronister, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that she executed same for the purposes therein contained. In witness whereof, I hereunto set my hand and no 'a1 seal. 1 My Commission Expires: Notary Phkl)c TH OF PENNSYLVANIA NOINW feed D WW Dodk No" RM Camp HI8om%Cu *WW dCou* W ComrrB Wm Ej0w Jury 2 , 2D10 Member. Pennsylvanls AssodoWn of NoWW •aW 4V bo .. .t.f io?Y.. i '?/. • l?.??+y? l4 O N ¢y r.. ,5,1 t •p 141 % State of Pennsylvania County of 6 %, r7wy On this the 't day of Idi7ach, 2010, before me, the undersigned officer, personally appeared Paul E. Kuhn, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that he executed same for the purposes therein contained. In witness whereof, I hereunto set my hand and notari seal. q My Commission Expires: a-9 , ?l0 Notary'c r _eWU&W% UMAI Tu nc oeuuevR verorx NoWW 8w DMW Doric, No" PLd* CamplIBOI%OWhOWWft U00 ?" • e e r • ? Penn?ylvenb ly?• SG01? 0? ? -0,40 4, e ° e e srth4'" nnsvlvama ?r Via. t 41 °a•sodh'. ` On this the day of , 2010, before me, the undersigned officer, personally appeared Kathryn P. Kuhn, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that she executed same for the purposes therein contained. In witness whereof, I hereunto set my hand and notarial al. o ? ik--la?k a A -ADIO Notary Publi NoW,id eMl OmW Doti, N*O Pd* camp M Bolo, OWh WW Comely Nyc«rmron JtsM2%2MO Member, Pwns* b AaWWW & NMdit I hereby certify that the precise address of the within Grantee is ab " •43345 Market Street, Camp Hill, PA 1 t ;, Attorney r Grantee ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201011260 Recorded On 5/4/2010 At 9:41:37 AM * Instrument Type - DEED Invoice Number - 6490E User ID - AF * Grantor - CHRONISTER, CHRIS A * Grantee - INTEGRITY BANK * Customer - TURNER * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $13.00 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES,FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT NORMLEYSBURG BOROUGH $0.00 TOTAL PAID $63.50 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER OF DiL S * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. RIIIIAIIRNINI? 1 • VERIFICATION I, Gary G. Klick, hereby verify that I am the Vice President of Integrity Bank, and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authori- ties. INTEGRITY BANK Date: By; '?%,'Iq' (Uj Gary G. lick, Vice President SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~otr of `u~n6rr~$~~ C. ; ~.:;}~. .,,~. ~7FFiCE c ~ r~E ~aN~RIFF 7Ht P~ ~, ~, ~ .^~~TA~Y ~~ BUG ~ 1 AM 8~ 36 Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~i$`f t.~ANIAJ1~tiY Integrity Bank vs. Christopher A. Chronister (et al.) Case Number 2010-5365 SHERIFF'S RETURN OF SERVICE 08/18/2010 12:51 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1251 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Christopher A. Chronister, by making known unto Jane Chronister, Wife of defendant at 1000 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPUTY 08/18/2010 12:51 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1251 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Jane E. Chronister, by making known unto herself personally, at 1000 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. ~~~` RYAN BURGETT, DEPUTY 08/18/2010 12:51 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1251 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Paul E. Kuhn, by making known unto Jane Chronister, adult in charge at 1000 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. ~~ RYAN BURGETT, TY 08/18/2010 12:51 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1251 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Kathryn P. Kuhn, by making known unto Jane Chronister, adult in charge at 1000 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $89.50 August 26, 2010 RYAN BURGETT, D SO ANSWERS, ~ RON R ANDERSON, SHERIFF (c) CountySuite Shenif. Teleosoft, Inc. REAGER & ADLER, P.C. BY: THOMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 Email: TwilliamsARe@ZerAdlerPC.com BY: WAYNE S. MARTIN, ESQUIRE Attorney I.D. No. 208078 Email: Wmartin @Rea eg rAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 F ILEG-0Ft= 10 E i010 S1E t 110 r" ' II * 01 C1i ?IP3- R LAtl'D C0,UNT'-,' INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, NO. 10-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN, Defendants PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, Integrity Bank, and against Defendants, Christopher A. Chronister, Jane E. Chronister, Paul E. Kuhn and Kathryn P. Kuhn, for possession of the property located at 1000 West Foxcroft Drive, Camp Hill, Pennsylvania 17011. The undersigned hereby certifies that a 10-Day Notice of Plaintiff s intent to file the instant Praecipe for default judgment for failure to respond to Plaintiff s Complaint was mailed to Defendants. A true and correct copy of the aforementioned Important Notices are attached hereto as Exhibit A. Respectfully submitted, REAGER & ADLER, P.C. Date: September _k _, 2010 /Y.00 pd , ai 1;? 4413 Thomas O. Williams, Esquire Attorney I.D. No. 67987 Wayne S. Martin, Esquire Attorney I.D. No. 208078 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 ?Xh?, INTEGRITY BANK, : IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, NO. 2010-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN : IMPORTANT NOTICE TO: Christopher A. Chronister 1000 Foxcroft Drive Camp Hill, PA 17011 DATE OF NOTICE: September 15, 2010 YOU ARE IN DEFAULT BECAUSOYOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) Respectfully submitted, REAGER & ADLER, P.C. 11.10.11 / Wayn , Martin, Esquire Attorney I.D. No. 208078 Thomas 0. Williams, Esquire Attorney I.D No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 INTEGRITY BANK, : IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, : NO. 2010-5365 JANE E. CHRONISTER, PAUL E. KUHN, : and KATHRYN P. KUHN IMPORTANT NOTICE TO: Jane E. Chronister 1000 Foxcroft Drive Camp Hill, PA 17011 DATE OF NOTICE: September 15, 2010 YOU ARE IN DEFAULT BECAUSE?YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) Respectfully submitted, REAGER & ADLER, P.C. WaynerS, Martin, Esquire Attorney I.D. No. 208078 Thomas O. Williams, Esquire Attorney LD No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, : NO. 2010-5365 JANE E. CHRONISTER, PAUL E. KUHN, : and KATHRYN P. KUHN IMPORTANT NOTICE TO: Paul E. Kuhn 1000 West Foxeroft Drive Camp Hill, Pennsylvania 17011 DATE OF NOTICE: September 15, 2010 YOU ARE IN DEFAULT BECAUSE?YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) Respectfully submitted, REAG?ERR & ADLER, P.C. Wayn, Martin, Esquire Attorney I.D. No. 208078 Thomas O. Williams, Esquire Attorney I.D No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 INTEGRITY BANK, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION CHRISTOPHER A. CHRONISTER, : NO. 2010-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN IMPORTANT NOTICE TO: Kathryn P. Kuhn 1000 West Foxcroft Drive Camp Hill, Pennsylvania 17011 DATE OF NOTICE: September 15, 2010 YOU ARE IN DEFAULT BECAUSO'YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) Respectfully submitted, REAGER & ADLER, P.C. Wayne , Martin, Esquire Attorney I.D. No. 208078 Thomas O. Williams, Esquire Attorney I.D No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT $ 2 PROVIDE FOR INSURANCE-POSTMASTER c d d N N '-WXGER & ADLER, P a One piece of ordinary mail addressed to: ' ?jt °O re V n 9 U?rlsta 1 phf'i' C?II L _ N •?I Q p C -amp /4:111 -DL _U 0 a m PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MP4 MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N PROVIDE FOR INSURANCE-POSTMASTER o N o O Received From: O M REAGER A. ADLER, PC 2331 ivLAMET STREET PA i "t i N One piece of ordinal mail addressed to: c 9?7 9 rip I v/ 3 + Z?p atClf 1 tJ'1 N ? I tic N PS Form 3817, January 2001 PROVIDE FOR INSURANCE-POSTMASttx c N o O ?d "XGER & ADLER, PC one piece of ordinary mail addressed to: j ? CD C? v) n c 9? 1 y U ? ' ??? ?It?• ui?s?"o U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT c C PROVIDE FOR INSURANCE-POSTMASTER o° u eg' A&R & ADLER, PC" R , A..._,•< One piece of ordinary mail addressed toS `. Ot-? d '?i) <A ?aU f C?th \? F • 1 ? •??? N? O 'V Gam) O ? m PS Form 3817, January 2uu1 INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, NO. 10-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN, Defendants NOTICE OF DEFAULT JUDGMENT TO: Christopher A. Chronister Jane E. Chronister Paul E. Kuhn Kathryn P. Kuhn You are hereby notified that on September 30, 2010, judgment by default was entered against you for ejectment from the property of 1000 West Foxcroft Drive, Camp Hill, Pennsylvania 17011, in the above-captioned case. Date: 9 `--V -/h s?? h. i2jiga bw& _ Prothonotary 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 32 South Bedford Street Carlisle, PA 17013 (717-249-3166) I hereby certify that the following is the last known address of the Defendants: Christopher A. Chronister Jane E. Chronister Paul E. Kuhn Kathryn P. Kuhn 1000 West Foxcroft Drive Camp Hill, PA 17011 WAYNE . MARTIN, ESQUIRE Attorney for Plaintiff REAGER & ADLER, P.C. BY: THOMAS 0. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 Email: Twilliams@,ReagerAdlerPC.com BY: WAYNE S. MARTIN, ESQUIRE Attorney I.D. No. 208078 Email: Wmartin(a)ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 FIL'r- " F1;;- ' ;: p O"+OTA7 ,Z31a SE? 30 '?}1 ?I?( Ctj1`?iJt_R ?'?r D COiS?t ;? P i;ER:ltsic 1 _?. za INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CHRISTOPHER A. CHRONISTER, NO. 10-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN, Defendants AFFIDAVIT OF NON-MILITARY SERVICE Commonwealth of Pennsylvania ) ) ss: County of Cumberland ) The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended: '0? //? [ Wayne S. Martin, Esquire Sworn to and subscribed Before me this )day of 2010. otary Public COMMONWEALTH OF PENNSYLVANIA Notanal sea, Linda H. Millar, Notary Public Camp Hill eoro, Cumberland County my ca mm"on $xpirss May 9, 2013 McMb@t', P@AASy VSAiS Aftocaatnn of Rotaries _ ~ iL~~ ~~~ ICC +,. s 4..1r" ~ ~~T~~~.i~~~~+~~ t. REAGER & ADLER, P.C. BY: THOMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 Email: Twilliamsna4ReagerAdlerPC.com BY: WAYNE S. MARTIN, ESQUIRE Attorney I.D. No. 208078 Email: Wmartin~a ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 ~~ID~~~T 13 ~~ l~ ~8 X49 ;~ s.~..,, ~ 5.t~ hid n ~ i ,-~:. ~ INTEGRITY BANK, IN THE COURT OF COMMON PLEAS, Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION CHRISTOPHER A. CHRONISTER, : NO. 10-5365 JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN, Defendants PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a writ of possession in the above matter. da` ~p° ~ ~'`~ ~' ~ ~O~`CVT~~T ~n-v~Q,~tz'l(, ~~ Respect y ed Date ctober l3 , 2010 s 84. 5o CgF 9a. oo I~ . oo ~~ ~ d i4. so - P-d. R~ a .oo ~.x.t+~.~-o Thomras O. Williams Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Plaintiff cam- ~L59 ~~~Qs~ ~rit~ Pow ~~o< .DQ, /~ y ~. ,. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INTEGRITY BANK VS. No. 10-5365 Civil Term CHRISTOPHER A. CHRONISTER, JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN Costs Attorney's $ 219.50 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) INTEGRITY BANK being: (Premises as follows): 1000 WEST FOXCROFT DRNE, CAMP HILL, PA (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their} interest therein. David D. Buell, Prothono , Common Pleas Court of C berland County, PA Date 1010/13/10/10 (Seal} 2of2 No 10-5365 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INTEGRITY BANK VS. CHRISTOPHER A. CHRONISTER, JANE E. CHRONISTER, PAUL E. KUHN, and KATHRYN P. KUHN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 219.50 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: THOMAS O.WILLIAM5, ESQUIRE - ID#67987 2331 MARKET STREET CAMP HILL, PA 17011 717-763-1383 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~4,~k~tp 4t ~au~bcrl,~~~ Jody S Smith Ch' f D t ~" ~- -~ "~` -e epu y ^~Y ~•+~ ~ Richard W Stewart ` ~ .~'~ ~' "' r ~._ s4r FF -a, Solicitor c~'c;: ~ .. ~ ~ ~ ~ -~-- rn c-~ ~ ~~ ~~ sU -~C ~ ~~ ~ N t Integrity Bank ~ C un~r ~ YC "` 1 vs. ~53aaC~t ~ ~~.: ~ - Christopher A. Chronister (et al.) • . ~,. ~ - ~: : SHERIFF'S RETURN OF SERVICE ~ _, 10/21/2010 06:57 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Christopher A. Chronister, by making known unto Jane Chronister, Adult in Charge and wife of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2010 06:57 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Jane E. Chronister, by making known unto Jane Chronister, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21!2010 06:57 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Paul E. Kuhn, by making known unto Jane Chronister, Adult in Charge and daughter of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2010 06:57 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Kathryn P. Kuhn, by making known unto Jane Chronister, Adult in Charge and daughter of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SO ANSWERS, M October 22, 2010 RON R ANDERSON, SHERIFF ;c CountySuite Sher,Tf, Teseosoft, Hic. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY QFFI CE OFT' : S4ERiFF Integrity Bank vs. Christopher A. Chronister (et al.) SHERIFF'S RETURN OF SERVICE fl:!f- 12 NA 2 jjj? Case Number 2010-5365 10/21/2010 06:57 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Christopher A. Chronister, by making known unto Jane Chronister, Adult in Charge and wife of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2010 06:57 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Jane E. Chronister, by making known unto Jane Chronister, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2010 06:57 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on Octobei 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Paul E. Kuhn, by making known unto Jane Chronister, Adult in Charge and daughter of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2010 06:57 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on Octobei 21, 2010 at 1857 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Kathryn P. Kuhn, by making known unto Jane Chronister, Adult in Charge and daughter of defendant, at 1000 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 11/10/2010 By virtue of this writ, on the 10th day of November, 2010, Sheriff Ronny R. Anderson caused the within named Integrity Bank, to have possession of the premises described as 1000 West Foxcroft Drive, Camp Hill, PA 17011. SHERIFF COST: $119.79 SO ANSWERS, November 12, 2010 RON R ANDERSON, SHERIFF f3 Sharon R. Lantz ? a S?a3 9 {C; CountySuite SFenf. Te eoso`T_ Inc.