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HomeMy WebLinkAbout10-5838 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, CIVIL DIVISION NO.: 10 - 583$ flL ?.-n C CE I)TAPY -._ CUMBE-1. ?} {F UMY P?NVLVANA evil term NO.: (D- 5558 MU1, vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL # 38-19-1621-171 TYPE OF PLEADING CIVIL ACTION - WRIT OF SCIRE FACIAS Defendant. TO: DEFENDANT(S) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSr WITHIN TWENTY (20) DAYS FROM SHE OF OR A DEFAULT JUDGMENT MAY BE ED AINST YOU. FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 P.O. BOX 650 Hershey, PA 17033 (717) 533-3280 ATTURNEY"FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 31 E. Main Street, P.O. Box 1001 New Kingston, PA 17072-1001 AND THE DEFENDANT(S): JAMES, SMITH, DIETTERICK & CONNELLY, LLP 53 Warwick ' , Mechanicsburg, PA 17050 ATT FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATWFECTED BY THIS LIEN IS 53 Warwick Circ hanicsburz. PA 17050 A' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-19-1621-171 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD 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 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: VS. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-19-1621-171 Defendant. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-19-1621-171 Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY No.: 10 - 58,' 8 SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. 0 4,24.m Po A`n`y )4.0o CSF 4 8. oo PA PTT' 8 . oo Ste- flee a. oo Uue, Co alp 84aq I & ay8o88 Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 a-ri'ITerw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: VS. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL# 38-19-1621-171 Defendant. TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: Scott ie erick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 It, - 5838 CtyiiTeVV WRIT OF SCIRE FACIAS TO: ERIKA M. WARD WHEREAS, Silver Spring Township Authority, on August 25, 2010, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 10-5558 MLD, for the sum of $3,875.59, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Silver Spring Township Authority, said Claim filed against property owned by you in Silver Spring Township, located at 53 Warwick Circle, Mechanicsburg, Pennsylvania 17050, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 224, Page 107, Tax Parcel #38-19-1621-171, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof. ecws- 4 48.00 Po k7w $ . 00 5a-,+ fee i a . 00 LLW Gb . SEAL) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~e$~atr 0t ~Cur~6~r~~~d Jody S Smith ~, Chief Deputy ~~ "- f • ~~~ ,tar, Richard W Stewart ~ " SOiICItOf G~Ff~~E C - '..~ g..,ERtFF Silver Spring Township Authority vs. Erika M. Ward Case Number 2010-5838 SHERIFF'S RETURN OF SERVICE 09/23/2010 10:51 AM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on September 23, 2010 at 1051 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Erika M. Ward, by making known unto herself personally, at 53 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 27, 2010 RYAN BURGETT, SO ANSWERS, t: RON R ANDERSON, SHERIFF l ~ ~ `:'q ~ _~ ;.~ _ r~-r~N - ~~ r•Y'~_..s r3 s ..s ~ ~ r: s ~ ~ f~~ `s ~ c~ r. ~ -arr __.. ;~ c~ ~' ~° ® ° c- c ~? ~~ ~ ~ r~> ~ ~ _x,, ,. !cj CountySuite ShenfF, Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP CIVIL DIVISION AUTHORITY, 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTOWN, PA 17072-1001 No.: 10-5838 CIVIL TERM / No.: 10-5558 MLD vs. Plaintiff, TYPE OF PLEADING: ERIKA M. WARD, 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID#38-19-1621-171 Defendant. I Hereby certify that the last known address f Defendant(s) is/are: 53 Wa~ick it e 17050 ~- ,.:~ '. ~ -~ ('F'i ~WU r.'.3 ~~ Gf! rt ~ n„~ ~„~ C'l AYE , ~~ - -t~, ,, ~: ~~ ~_ ~ p .r_-- ~- ~ PRAECIPE FOR DEFAULT JUDGMENT (Municipal Lien) FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: JAMES, SMITH, DIETTERICK & CONNELLY, LLP Pa. I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 10-5838 Civil Term vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1621--171 Defendant. No.: 10-5558 MLD PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Erika M. Ward, in the amount of $4,529.01, which is itemized as follows: Original Municipal Lien Amount $ 3,875.59 (Through 4th Quarter 2010) Arrears for 1St & 2nd Quarter 2011 $ 207.22 Penalties for 1St & 2nd Quarter 2011 $ 36.20 Title Cost $ 410.00 TOTAL CLAIM $ 4,529.01 plus interest, penalties, and Quarterly bills after the 2nd Quarter 2011, and additional attorneys' fees and costs reasonable and actually incurred. JAMES, Scott7~. `Y~ietterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ~ 1~•0o Po ATM c~ 85oi 7 ~,~ a503r/ 1 1~a-hee ~t~~ AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, ~,s-esc~denced by the attached copies. Sc~dtt ~,lBietterick, Esquire Sworn to and subscribed before me this 26~' day of October, 2010. ~~ Notary Public My Commission Expires: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Jun 23, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 10-5838 Civil Term vs. No.: 10-5558 MLD ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1621-171 Defendant. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Erika M. Ward ( )Plaintiff (X) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on (~(>al- n?8~' , 2010. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,529.01 plus interest, penalties, and Quarterly bills after the 2"d Quarter 2011, plus additional attorneys' fees and costs reasonable and actually incurred and for foreclosure and sale of the Premises. Pro onotary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Silver Spring Township Authority vs. Erika M. Ward ~43tt~tr ui ~tttr~$~rrr~il~ ~; _.- -- ,:,~-~~~ :~~ - : ; ~ ,. ~. r Case Number 2010-5838 SHERIFF'S RETURN OF SERVICE 09/23/2010 10:51 AM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on September 23, 2010 at 1051 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Erika M. Ward, by making known unto herself personally, at 53 Warwick Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DES TY SHERIFF COST: $37.00 September 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF !c CouniSuite Srenfl. Te!eose*t irc. IN THE OOiJRT OF ClQT'DN PTF.Afi OF C[lN)BERL.APID CO[JNi'Y, P~YLVABIIA Silver Spring Township CIVIL DMSICIn1 Authority File No.10-5558 MLD / 10-5838 Civil Term {Plaintiff) Amount Due $ 4,529.01 v Interest from 10/26/10 to S Erika M. Ward date of sa e : Atty's Comm Costs n ,,,~ o (Defendant(s) -~ -~ ~ -~ TO THE PROTHONCy2'ARY OF THE SAID COURT: ~~~ ~--.'~ ~~ The undersigned hereby certifies that the below does not arise out of a ~tai.l cam'-~'~;~ installment sale, contract, or account based an a confession of judgment, but,r~.~it doe~'o it-is based on the appropriate original proceeding filed pursuant to Act 7 of~~39~6 ~~ Q-~ amended; and for real property pursuant to Act 5 of 1974 as amended. ~ ~ cx~ o~ • - --t PRADCIPE FUR EXDCi]'I'IG~1 ;' Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Exhibit "A" attached. PRAFCIPE FDR ARTACFI~ENT E,~C[TrIO[~ Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as abbove, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) ' and all other property of the defendant(s) in the possession, custody or control of the said garnishes{s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached 'bit pA~; October 26, 2010 Signature: o't~: oo P ~ A`~ Print Name : Scott A . Dietterick, Esctuire ~a .oo CBF 37. oo A 014. oo ~~ 1.00 a. so " Id5.50 - P a Am • 50 l.l. ~8.0o SAT F+~ iwE, Address: James Smith Dietterick & Connelly LLP P ~ Box 550, Hershey PA 17033 Attorney for: Plaintiff Telephone: (717} 533-3280 ~*85018 016037 ) RJELL1rii-~US~u~ Supreme Court ID No.: 55650 r' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1621-171 Defendant. CIVIL DIVISION No.: 1.0-5838 Civil Term : No.: 10-5558 MLD AFFIDAVIT PURSUANT. TO RULE 3129.1 ~ ~~ ra-~ m ~~ ~~ ~~ . -~ :-- ~-_, ,~;. c-~ <_ Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 53 Warwick Circle, Mechanicsburg, Pennsylvania 17050: 1. Name and Address of Owner(s) or Reputed Owner(s): ERIKA M. WARD 53 Warwick Circle Mechanicsburg, PA 17050 2. Name and Address of Defendant(s) in the Judgment: ERIKA M. WARD 53 Warwick Circle Mechanicsburg, PA 17050 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: SILVER SPRING TOWNSHIP AUTHORITY Plaintiff ERIE INSURANCE EXCHANGE c/o John Ninosky, Esquire P.O. Box 109 Lemoyne, PA 17043 4. Name and Address of the last record holder of every mortgage of record: UNITED STATES OF AMERICA Department of Agriculture P.O. Box 66889 St. Louis, MO 63168 N C.'] c~ r~ --~ t'-..3 ~:.,.~ ~. c ,~ ca z~ rn -- ~ r- ~rn ,_ , Q ~~, , ~.. ; k~ ~_ -~, u -~ c~ -i ~ -< t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1621-171 Defendant. No.: 10-5838 Civil Term No.: 10-5558 MLD NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 TAKE NOTICE: n -b ~ rn .: -.~~ s~ : r- '~: .,-- c~ ~_ ~ N a --~ -~ ~..~ -~ r .r- ~- That the Sheriffs Sale of Real Property (Real Estate) will beheld at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, March 2, 2011, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 0 x-~ m ~,, ~.`• -~ a ..._ -~, ~~ c~ -r ;c> -< 53 Warwick Circle Mechanicsburg, Pennsylvania 17050 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 10-5838 Civil Term No. 10-5558 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Erika M. Ward A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DIETTERICK & CONNEt.LY~I.bJ' DATED: October 26, 2010 BY: ~~ ~ ~~ Sco ietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL -RETURN RECEIPT REQUESTED AND PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right of way line of Warwick Circle at the common front property corners of Lot Nos. 6-C and 6-D as shown on the hereinafter mentioned Plan of Lots; thence along Warwick Circle, South O1 degrees 54 minutes O1 seconds West, 20 feet to a point at the dividing line between Lot Nos. 6-D and 6-E; thence along said line, North 88 degrees OS minutes 59 seconds West, 124 feet to a point at land now or late of I.B.M.; thence North Ol degrees 54 minutes O1 seconds East, 20 feet to a point at the dividing line between Lot Nos. 6-C and 6-D; thence South 88 degrees OS minutes 59 seconds East, 124 feet to a point, the place of BEGINNING. CONTAINING 2,400.00 square feet. BEING Lot No. 6-D, Final Subdivision Plan of Southfield Crossing (Phase Two), prepared by Harhnan and Associates, Inc., Engineers and Surveyors, and recorded September 24, 1993 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 66, Pages 131-A through 131-F. UNDER AND SUBJECT to restrictions in Misc. Book 481, Page 1063. UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and right of way of record. HAVING thereon erected a dwelling house being known and numbered as 53 Warwick Circle, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Tanya L. Nicholas f/k/a Tanya L. Milliron, Single, by Deed dated June 23, 2000, and recorded on June 27, 2000 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 224, Page 107, granted and conveyed unto Erika M. Ward, Single Woman. Parcel No.: 38-19-1621-171 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5838 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY, Plaintiff (s) From ERIKA M. WARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,529.01 Interest from 10/26/10 to Date of Sale Atty's Comm Atty Paid $125.50 Plaintiff Paid Date: 10/28/10 L.L.$.50 Due Prothy $4.00 Other Costs: $8.00 Satisfaction Fee Due David D. Buell, Prothonotary (Seal) REQUESTING PARTY: By: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP PO BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff . ' Jody S Smith Chief Deputy Richard W Stewart Solicitor 4, 't14 Ott s 11. I+ iC TIC u?. ?.IFF F THE PROTHONOTARY 2010 NOY 22 PM 4: 19 CUMBERLAND COUNTY PENNSYLVANIA Silver Spring Township Authority vs. Erika M. Ward Case Number 2010-5838 SHERIFF'S RETURN OF SERVICE 11/22/2010 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Scott Dietterick on 11/12/10. SHERIFF COST: $86.64 SO ANSWERS, November 22, 2010 RON R ANDERSON, SHERIFF .504 LC- Pd a # `2? ?a 'P'te ?z S /S- 3 ? ;c GounfySuite Sheriff. Teleosuft. In- NOV-12-2010 09:25 November 12, 2010 Via Facsimile 240-6397 Cumberland County Sheriff Attn: Real Estate Dept. Fax: 717.5332795 RE: Silver Spring Township Authority VS. Erika M. Ward Docket No. 10-5838 Civil Term /ll? MLD Sheriff Sale Date: March 29 2011 Property: 53 Warwick Circle, Mechanicsburg, PA 17050 Ounr File No. 102411 Dear Sir or Madam: Please consider this correspondence a formal request to stay the sheriff sale scheduled for March 2, 2011 in the above-referenced matter. Plaintiff received no money. Please refund any excess from our advance or bill our office for additional funds due. Should you have any questions, please do not hesitate to contact the undersigned. & CONNELLY LLP P. 02 P0. Box 650 HERSHEY, PA 17033 Ocwrier Address: 134 SIPS AVENUE HUMMELSTOWN, PA 17036 TEL, 717.533.3280 W Ww.J5DC.CDM GARY L. JAMES MAX J. SMRH, in. JOHN J. CONNELLY, JR. SCOTT A. DIETT mire JAMES F. SPADE MATTHEW CHABAL. III NEIL W. YAHN EDWAND P. SEEKER RONALD T. TOMASKO SUSAN M.KADEL JAW W. MANDELMAN COURTNEV K. POWELL KimemV A. BONNER KAREN N. UwNeLLY JOHN M. HYAMS CHRISTINE T. BMW JES84A E. LOWS SEAN M. CDNOANNON GAMM A. KOGuT, JA. TrioMAS J. CAA OF COUNSEL: GREGORY K. RICHARDS BENaw o A. RYAN, JR. TnTAI P Aa WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) • COUNTY OF CUMBERLAND) NO 10-5838 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY, Plaintiff (s) From ERIKA M. WARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,529.01 Interest from 10/26/10 to Date of Sale Atty's Comm % Atty Paid $125.50 Plaintiff Paid Date: 10/28/10 (Seal) REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE L.L.$.50 Due Prothy $4.00 Other Costs: $8.00 Satisfaction Fee Due David D. Buellkrothonotary By: Address: JAMES SMITH DIETTERICK & CONNELLY LLP PO BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 Deputy TRUE COPY FROM RECORD in Temnony wt?anof. I hwe unto ad my hand and of aid Coat at CW26b, Pa. Tridayd 2010 . 7*-)Ak) - 40S IN THE COURT OF COMMON PLEAS OF 3 p? _ CUMBERLAND COUNTY, PENNSYLVANIA i PUMBERLAND SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISI(gNNSYLVANI'A 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 10-5838 Civil Term f vs. : No.: 10-5558 MLD ERIKA M. WARD 53 WARWICK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1621-171 : Defendant. PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment filed at the above-captioned term and number satisfied. Respectfully submitted: JAMES, SMITH IAIETTMCK & CONNELLY LLP Date: 1' BY: Sc . Dietterick, Esquire PA 1.6. #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 r9. a v/ aC -4r' cklk Z7 4.0? 9135-6 ?