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HomeMy WebLinkAbout11-0574 FILED-OFFICE OF THE PROTHONOTARY 2011 JAN 20 AM 11:28 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center CUBS COUNTY RIVA 701 Market Street Philadelphia, PA 19106 (215) 825-6314 Attornev for Plaintiff CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff VS. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY SANDRA K. FOOSE MARY A. MYERS CIVIL ACTION - LAW and OCCUPANTS 1008 Centerville Road ACTION OF EJECTMENT Newville, PA 17241 Defendants Term No. N d 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 the 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 claim in the Complaint of 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 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 4f wfi 9a .a od? WA'4, pzjt? Ss5?ia3 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT Plaintiff is CITIFINANCIAL INC, 6400 Las Colinas Blvd., Irving, TX 75039. 2. Defendants are SANDRA K. FOOSE, MARY A. MYERS, and OCCUPANTS. 3. Plaintiff is the owner of property located at 1008 Centerville Road, Newville, PA 17241, by virtue of a Deed from the Sheriff of Cumberland County to CITIFINANCIAL INC recorded on 10/12/2010 at Instrument # 201029005. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. By: GOLDBE MCCAFFERT MCKEEVER . ael cKeever Pa. ID 29 _?Gary Mc a 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff VERIFICATION )J ?Nal S ?'?'O1^? hereby states that he/she is the A-•V-F. of Plaintiff in this matter, CITIFINANCIAL INC, and that all of the facts set forth in the attached Plaintiff's Complaint are true and correct to the best of his/her information and belief. The undersigned understands that statements herein are made subject to the penalties of 18 P.S. §4904. CITIFINANCIAL INC By: *"`? Printed Name: Title: NANCY FILE#: 100363EJ REO ID#: PROPERTY: 1008 Centerville Road Newville PA 17241 ALL THAT CERTAIN lot or ground situate in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bowermaster, thence 75 feet In e Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direction along said Searvers land to a stake at the line of other land of the grantors; thence 75 feet in a Northerly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Placo of Beginning. BEING THE SAME PREMISES BY DEED FROM RUTH A. MYERS, A SINGLE PERSON DATED 04/07/00 AND RECORDED 04/18/00 IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVILLE PA 17241 TAX PARCEL NO: 31-29-2522-012 GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS & OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendant(s) ar: CTHDNOTAF 't 211ADIR21 1110:`9 C,"JMBERLAND COUNTY PENN5YLVANIA IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW EJECTMENT COMPLAINT Term No. 11-574-Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. y: OLDBECI CCAFFER & MCKEEVER Michae 6129 Gary McCafferty Pa. ID 42386er% Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ;& s(0a00 tgqd Q w-wr a4 c GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 vs. SANDRA K. FOOSE MARY A. MYERS & OCCUPANTS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Plaintiff CIVIL ACTION - LAW EJECTMENT COMPLAINT Term No. 11-574-Civil Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: C-) P-a r-' M rs C, V) .<-. N CJ r GOLDBECK;WCAFFER & MCKEEVER Michael McKee 6129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff Od'SIG o0 fly 9i/ CITIFINANCL4L INC 6400 Las Colinas Blvd. Irving, TX 75039 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. SANDRA K. FOOSE and MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 AND NOW, this olVd No. 11-574-Civil ORDER day of may 2011, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Ejectment upon Defendants by posting a copy of the Complaint upon the premises 1008 Centerville Road, Newville, PA, 17241, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 1008 Centerville Road, Newville, PA, 17241 and for Sandra K Foose at 505 South West Street, Apt A, Carlisle PA 17013, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Writ of Possession pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: J. Distribution list: Goldbeck, McCafferty & McKeever, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 SANDRA K. FOOSE, 1008 Centerville Road Newville, PA 17241, and 505 South West Street, Apt A, Carlisle PA 17013 MARY A. MYERS, 1008 Centerville Road Newville, PA 17241 supreme Cou=p-Of. Penns hania Co ftss fur Fi onotarr Use Only tr C County DocketNa a•i wr {r. purposes. This form does not The information collected on this form is used solely for court administration equi Su lement or replace the filing and service o leadin s or other papers as r iced law or rules o court. Commencement of Action: ? Petition ? Notice of Appeal X Complaint L] Writ of Summons E] Declaration of Taking E3 Transfer from another Jurisdiction ??ee ,?sntNSnc. Lead Plaintiff Name: MARY A. MYERS CITIF'INANC)<AL INC and Occupants ? Check here if you are a Self -Represented (Pro Se) Litigant cCAFFERTY M Name of Plaintiff/apPeu's Attorney: GOLD-BECK M & cKEEVER within arbitration limits A Dollar Amount Requested (Check one) X outside arbitration limits requested?: [3 Yes X No s Are money Damage I.,- Class Action Suit? ? Yes X NO i Is t a that the ONE case category of most accurately describes your g . to th :Ply ' the left Nature of more than one type of cl.. check the6 one that Y CASE ff you are making RTMAR :? P ou consider most unportant y ,. CML APPEAL TORT (do not include Mass Tort) CONTRACT ? Buyer Plaintiff Administrative Agencies ? Board of Assessment :fi t ? Intentional ? NLaiicious Prosecution ? Debt Collection: Credit Card bt Collection: Other ? D ? Board of Elections n ti ? Motor Vehicle e o ? Dept. of Transporta f N . ? Nuisance ? Premises Liability ? Zoning Board [3 Statutory Appeal: Other {. i t include ? Product Liability (does no ? Employment dispute' - - - mass tort) ? Slander/Libel Defamation Discrimination ? Employment Dispute: Other Judicial Appeals ? Other ? MDJ - Landlord/ Tenant ? MDJ - Money Judgment 't{ MASS TORT - ?_ Asbestos - ? Tobacco -DES ? Toxic Tort ? Toxic Tort - Implant ? Toxic Waste ? Other L,=J FPROF ESSIO NAL LL4BILITY Dental Legal Medical Other professional: i Pa.RC-P. 205.5 ? Other: ? Other REAL PROPERTY X Ejectment ? Eminent Domain/Condemnation ? Ground Rent ? Landlord/Tenant Dispute ? Mortgage Foreclosure ? Partition ? Quiet title MLSCELLANEOUS ? Common Law/Statutory Arbitration ? Declaratory Judgment ? Mandamus ? Non-Domestic Relations Restraining Order ? Quo Warranto ? Replevin ? Other ? Other 212, OF THE PROTHONOTARY GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 825-6314 1011 JAN 20 AM 11: is IS i 1?E? OR t?VZOPY OF A 1 INALILEd VE CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff VS. SANDRA K. FOOSE MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants NOTICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term N , ?.>y ?rvJ 1 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights -important to y-ou. _ _ _ _ _ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER ATONCE_ 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 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORRE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARI-0 QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO• PARR DEFENDE ? FORMA ESCRITA, EL PUNTO DE VISTA ABOGADO> REGISTRE CON LA CORTE DE LISTED Y CUALQUIER OBJECCION CONTRA LAS QUE3PiS EN SE ESTA TA DEMANDA. DE .. RECUERDE: SI USTEO IN SU PAR.I?Cg,ACION ?ENTDONCE5, LA COUTE PROSEGSIN CON EL PROC UEDE, NOTIFICARIO, DECIDIR A FAVOR pROVISIONES DME S ?D MANDAEPOR P SIN QUE LISTED CUMPLA CON TODAS LAS R.AZON DE ESA DECISION, ES POSSIBLE Q?USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS I1 OR LLEVE ESTA DEMANDA A UN ABOGADO IMATEDIATEAMENTE- SI NO CONOCE A UN ABOGADO>DE ABOG "OSR23gF6CE SERVICE" (SERVICIO DE REFEREN CUMBERLAND COUNTY BAR ASSOCIATION 2 LibertY Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 5 E' n.0 COMPLAINT IN EJECTMENT 1. Plaintiff is CITIFINANCIAL INC, 6400 Las Colinas Blvd., Irving, TX 75039. 2. Defendants are SANDRA K. FOOSE, MARY A. MYERS, and OCCUPANTS. 3. Plaintiff is the owner of property located at 1008 Centerville Road, Newville, PA 17241, by virtue of a Deed from the Sheriff of Cumberland County to CITIFINANCIAL INC recorded on 10112/2010 at Instrument # 201029005. A true and correct copy of the legal description of the Property is attached to this Complaint. a 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, SANDRA. K. FOOSE, MARY A. MYERS and OCCUPANTS, are without right, and so far as the Plaintiff is informed, without occupying the Property claim of title. demanded possession of the Property from the Defendants and 6. Plaintiff has p ssession of the same. OCCUPANTS, who have refused to deliver up po WHEREFORE, plaintiff requests judgment for possession of the Property. By' MCKEEVER s: GOLDBE MCCAFFBR ael cKeever Pa. ID 29 Mc 42386 Gary Lisa Lee Pa- ID 78020 Kristin Murtha Pa. ID 61858 -- -- _------- David-Feint- D 826-28----- -- - - - - - - Thomas Puleo Pa. ID 27615 Say Kivitz Pa. ID 26769 Attorneys for Plaintiff I , I VERIFICATION u Na-? S, t-wKc-,l hereby states that he/she is the h-'V -P • of Plaintiff in this matter, CrrIFINANCIAL INC, and that all of the facts set forth in the attached Plaintiffs Complaint are true and correct to the best of his/her information and belief. The undersigned understands that statements herein are made subject to the penalties of 18 P.S. §4904. ALL THAT CERTAIN lot or ground situate in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bowermaster, thence 75 feet In a Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direction along said Searvers land to a stake at the line of other land of the grantors; thence 75 feet in a Northerly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Placo of Beginning. BEING THE SAME PREMISES BY DEED FROM RUTH A. MYERS, A SINGLE PERSON DATED 04/07/00 AND RECORDED 04/18/00 IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVILLE PA 17241 TAX PARCEL NO: 31-29-2522-012 RECEIPT FOR PAYMENT Cumberland Ccuntyy Prothonotary's Office Receipt Date 1/20/2011 Carlisle, Pa 17013 Receipt Time 11:42:44 Receipt No. 253963 CITIFINANCIAL INC (VS) FOOSE SANDRA K ET AL Case Number 2011-00574 Received of PD ATTY MCCAFFERTY MJM Total Non-Cash..... + 92.00 Check# 555903 Total Cash......... + .00 Change ............. - .00 Receipt total...... = $92.00 ------------------------ Distribution Of Payment Transaction Description Payment Amount COMPLAINT 55.00 CUMBERLAND CO GENERAL FUND TAX ON CMPLT .50 BUREAU OF RECEIPTS AND CONTROL SETTLEMENT 8.00 CUMBERLAND-CO GENERAL FUND AUTOMATION 5.00 CUMBERLAND CO AUTOMATION FUND JCP FEE 23.50 BUREAU OF RECEIPTS AND CONTROL $92.00 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 !-',,,.t i - ?A04t 03tteli CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Prothonotary Plaintiff vs. SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants N O T I C E Term No. 11-574-Civil Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: bd v : of d )3u.lell Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Goldbeck McCafferty & McKeever at the following telephone number: (215) 825-6319 5-60 (2) (Rev. 4/78)55 GOLDBECK MCCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 for Plaintiff CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff vs. SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants ;."? "? _LFILIED?-FF77 CJ11 J U L 22 A 11 '2 ` NENNSYLVANIA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 11-574-Civil PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, CITIFINANCIAL INC and against the Defendants SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237.1, written 10 day notice of Plaintiffs intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is CITIFINANCIAL INC, 6400 Las Colinas Blvd., Irving, TX 75039 and that the names and last known address of the Defendants are SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS 1008 Centerville Road, Newville, PA 17241. By: Jil G LD CK MCC FFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ?Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff vs. SANDRA K. FOOSE and MARY A. Nf ERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 11-574-Civil CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Valerie Merritt, an employee of Goldbeck McCafferty & McKeever, counsel for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: SANDRA K. FOOSE MARY A. MYERS OCCUPANTS 1008 Centerville Road Newville, PA 17241 DATED: J ?`7 By: GOLDBECK MCCAFFERTY & MCKEEVER Valerie Merritt, Legal Assistant 215-825-6319 (Direct Phone) GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 MELLON INDEPENDENCE CFWrf:R 701 MARKET STREET PHnADELYHIA, PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL INC 6400 Las Colinas Blvd. Twin-g, `PX'75039------------- Plaintiff vs. SANDRA K. FOOSE, MARY A_ MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants DATE OF THIS NOTICE: July 8, 2011 TO: OCCUPANTS 1008 Centerville Road Newwille, PA 17241 IMPORTANT NOTICE ACTION OF EJECTMENT Term No. 11-574-Civil 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 WITH N 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 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 2 Liberty Avenue Carlisk, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 By: _ G DB K MCCAF ERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 -"Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CryIIL ACTION - LAW GOLDBECK MCCAFFERTY & McKEEVER SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARNET STREET PHILADELPHIA, PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL INC 6400--L-as-Colinas Blvd. Irving, TX 75039 Plaintiff VS. SANDRA K_ FOOSE, MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants DATE OF THIS NOTICE: July 8, 2011 TO: IN THE COURT OF COMMON PLEAS -- - -OF-Cumberland-COUN-TY -- ------- CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 11-574-Civil SA DRA K FOOSE 1008 Centerville Road Newville, PA 17241 IMPORTANT NOTICE 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 CLAIM'S SET FORTH AGAINST YOU. UNLESS YOU ACT ATTAIN 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 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. C[nvIBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 By: qq1LDFfCK MCCAFFERTY & MCKEEVER hael McKeever Pa. ID 56129 Gay McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa- ID 82628 omas Puleo Pa. ID 27615 lay Kivitz Pa- ID 26769 Attorneys for Plaintiff GOLDBECK McCAFFEWrY & McKEEVER SME 5000 MFLLON INDEPENDENCE CENTER 701 MARKET STREET PIIILADELPIIIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAIN IM CITIFINANCIAL INC --- Irving, TX 75039 Plaintiff vs. SANDRA K. FOOSE, MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 Defendants DATE OF THIS NOTICE. July 8, 2011 TO: MARY A. MYERS 1008 Centerville Road Newville, PA 17241 IMPORTANT NOTICE CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 11-574-Civil YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A MUFIEN 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 DARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 2 Liberty Avemw Carlisle, PA 17013 LEGAL SERVICES INC 8 bvwc Raw Carlisle, PA 17013 By: GI?DBfCK MCCAP ERTY & MCKEEVER Mi ael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa_ ID 82628 Thomas Puleo Pa. ID 27615 w/Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS - OF Cumberland-COUNTY----- - --- IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CITIFINANCIAL INC Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS NO. 11-574-Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with Goldbeck McCafferty & McKeever, as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, SANDRA K. FOOSE, has a last known residence of 1008 Centerville Road, Newville, PA 17241. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: 7/18/2011 By:_ (q?::?r G DBE K MCCAF ERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 1-.oOTay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CITIFINANCIAL INC Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS NO. 11-574-Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with Goldbeck McCafferty & McKeever, as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, MARY A. MYERS, has a last known residence of 1008 Centerville Road, Newville, PA 17241. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: 7/18/2011 By:_.. ??? G DB CK MCCA FERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gomall Pa. ID 92382 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jul-18-2011 13:25:50 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency FOOSE SANDRA K Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aby 14- DW?_ 4"ir , Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL httn://www.defenselink.miUfag/vis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). Ifyou obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- https://www.dmdc.osd.mil/appj/scra/popreport.do 7/18/2011 Request for Military Status contact. Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. Report ID:921 JL24QOF https://www.dmdc.osd.mil/appj/scra/popreport.do 7/18/2011 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jul-18-2011 13:26:52 . Last Service Name First/Middle Begin Date Active Duty Status Active Duty End Date Agency MYERS MARY A Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of'Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL htti)://www.defenselink.mil/fag/t)is/PC09SLDR.htrnl. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. 'This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmde.osd.mil/appj/scra/popreport.do 7/18/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a iJniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic: and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to :rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted., but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:VJOEMIJJAC https://www.dmdc.osd.mil/appj/scra/popreport.do 7/18/2011 IN THE COMMON (PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA CITIFINANCIAL INC; et seq. ' CASE and/or DOCKET No.: 11-574-CIVIL Plaintiff (Petitioner) ` Sheriffs Sale Date: V. SANDRA K. FOOSE; et aL Defendant (Respondent) AFFIDAVIT OF SERVICE Complaint Summons J Other: PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT 1, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a parry to die action nor an employee nor relative of a party, and that I attempted to serve SANDRA K. FOOSE the above process on the 13 day of June, 2011, at 12:05 o'clock, PM, at 1008 Centerville Road Newville, PA 17241 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: J By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of SS: County of 114?t! ) Before me, the undersigned Mary public, this day, personally, appeared JFVAP Af&+kf to me known, who being duly sworn according law, deposes the following: I hereby swear or affirJ.". he facts set forth in the foregoing Affidavit of Service are true and correct. i Subscribed d sworn to before me (Si of Affiant) this 14 day of 0% 20 It File Number:] 00363EJ Notary Public COMMONWEALTH OF PENNSYLVANIA Notatal Swl Ertc M. Aftbxly NoWy ftft mwc"nWon , aerta county ?xpNea NOV. 13 2013 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA CITIMANCIAL INC; et seq. Plaintiff (Petitioner) V. SANDRA K. FOOSE; et al. Defendant (Respondent) AFFIDAVIT OF SERVICE Complaint Summons ? Other: PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party, and that I attempted to serve MARY A. MYERS the above process on the 13 day of June, 2011, at 12:05 o'clock, PM, at 1008 Centerville Road Newville, PA 17241 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: .r By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dateshimes: l) _ 2) 3) Commonwealth/State of IA SS: County of $-C .«l ) Before me, the undersigned n public, this day, personally, appeared j &6 Af *Arl to me known, who being duly sworn according t law, deposes the following: CASE and/or DOCKET No.: 11-574-CIVIL Sheriffs Sale Date: I hereby swear or affirm thn the facts set forth in the foregoing Affidavit of Service are true and correct. Subscribed an sworn to before me this /H day o n . , 20 n Notary Public File Number:100363FJ of Afliant) COMMONWEALTH OF PEhWSYLVANIA Notarial Seal Eric M. A1lkrbach, Notsy pWlC Wasdington Twp,, Berta tounly My or+ 13tptrec Nov. 18, 2013 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA CITIFINANCIAL INC; et seq. •, CASE and/or DOCKET No.: 11-574-CIVIL Plaintiff (Petitioner) Sheriffs Sale Date: V. SANDRA K. FOOSE; et al. Defendant (Respondent) AFFIDAVIT OF SERVICE Complaint Summons J Other: PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT I, RYAN MARKS, certify that I am eighteen years of age or older and that 1 am not a party to the action nor an employee nor relative of a party, and that I attempted to serve OCCUPANTS the above process on the 13 day of June, 2011, at 12:05 o'clock, PM, at 1008 Centerville Road Newville, PA 17241 ; County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: If By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: l) _ 2) 3)- Commonwealth/State of SS: County of >scitl ) Before me, the undersigned otary public, this day, personally, appeared Q?.? *W r r _ to me known, who being duly sworn according law, deposes the following: I I hereby swear or aff n4 the facts set forth in the foregoing Affidavit of Service are true and correct. Subscribed and om to before me this 114 day of 20__&_, Notary Public COMMONWEALTH OF peaSYLYANIA Natar1a15a?1 Eric M' A?rba<;fi, Pubik Washln4oon 71vp., earls County MY Conxnlssiun Ekes tbv. 18, 2013 File Number:100363EJ or Arriant) Form 3877 Page: 1 Mailer's Name and Address: Permit Number- MA Cert. er. Num. Goldbeck McCafferty & McKeever 969005937 SendSuite - MAC v6.25.6.25.L 701 Market Street Sequence Number: PHILADELPHIA, PA 19106 0001186 Pc ID #1 Addressee Name Postage ES ES Insured Due Total Article # Delivery Address Type Fee Value Sender Charge 100363EJ-MM MYERS, MARY A. 0.640 C 02.850 0.00 4 640 9171082133393932086062 1008 Centerville Road ERR 01.150 - Newville, PA 17241 100363EJ-00 OCCUPANTS 0.640 C 02-850 0.00 4 640 9171082133393932086086 1008 Centerville Road ERR 01.150 . Newville, PA 17241 100363EJ-SF FOOSE, SANDRA K. 0.640 C 02.850 0.00 4 640 9171082133393932086055 1008 Centerville Road ERR 111.150 . Newville, PA 17241 100363EJ-SF.2 FOOSE, SANDRA K. 0.640 C 02.850 0.00 4 640 9171082133393932086079 505 South West Street Apt A ERR 01.150 . Carlise, PA 17013 101117EJ-IC 0.640 C 02 850 0 00 9171082133393929302953 i I a 24 N . ERR 111.150 . 4.640 ia, A 1 1 hi 101117EJ00 O 0.640 C -'2 850 0 00 9171082133393929302960 5 224 &An" . ERR 01.150 . 4.640 P a i 102362EJ-TAWANDA.2 E E , DERRICK J. 0.640 C u2.850 0 00 9171082133393929302922 6 t v ERR 01.150 . 4.640 t h 18 103190EJ-IM 0.640 C 02.850 0.00 4 640 9171082133393929302977 out 1st t ERR 01.150 . i delphia, PA 143 103190EJ-00 0.640 C 02.850 0 00 9171082133393929302984 ERR [11.150 . 4.640 3 103590EJ-JS A 0.640 C 112.850 0.00 4 640 9171082133393929302991 2e ERR 01.150 . 103590EJ-00 A 0.640 C 02.850 .850 O DO 9171082133393929303004 W e h4 ERR 111.150 . 4.640 j 9 105358EJ-00 0.640 C 02850 0.00 4 640 9171082133393932086024 ERR 1-11.150 . h1 1 19 105358EJ-WR E S 1 0 640 C 02 850 9171082133393932086017 . e ia, A 9 . ERR 01.150 0.00 4.640 9 98693EJ-CL 9171082133393929302939 98693EJ-000NG 9171082133393929302946 G 19148 :: ` /r ` .f 6treet 48 C 02.850 0.00 4.640 ERR 51.150 C 02.850 0.00 4.640 ERR 01.150 Page Totals: 15 9.600 60.000 69.600 Cum Totals: 17 10.880 68.000 78.880 Form 3877 (Facsimile) SendSuite - MAC v6.25.6.25.1- D o cn 0 0 rn o ? W D m 02 4 -n -n Q c att cr m lm?1 RD N 0 ?? Sll N D O (D D c ? o `G N m ., cn m CD 0 0 3 v Q ?c v m 7 x 0 m I 0 (D m'o l 07 V Ut .A W N W:Eocoz i i O a." j or -?r3 y3 ..p>Cht1l , S c+m;v oma m.o Nr7Ccony -om ?n Z ' x -i D $ co D (N A r CD D m CD ?yri Z c m -{ a °-' 3 m m z Q= w 3 v vR 0 v n N y 3 Z°80 oC? ncnT ?O z8 m a Z ?-n m ° 0 C1 0 CD m 3 D SD 0 ?m - cn m j In , ?n0C)0 a ?m z p D?> -0, K > ?, (n D $ c X z'o?? o CD (D Z D?. z Z ny 2 3 m N N (D D N CD .U Z m. 0 fl, o wcnD ?? 1aa7D m Om CD T? ' d N CD _ CL m a OL SR o ` D 0 3 D ???? (D N m a, c ? 1p n v (N n m n n m n n 0 O 3 o m 3 o m o n o m v ?\ la v J 4 D D, 0 _ y \ 4 T (D y y; (^, N x o ? ? m w a E N ( D ? ( co FRO. 3 S, ' 3 CL gi o. v m (D (D m m ? n 0 cn - m 3 A 3 r ` N Q I Q m < OD o ? ?? -7 m G ) ; m a L p Z .? m a? D N w/ ? Cc (A c„ o I ? O C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 SANDRA K. FOOSE MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff vs. Defendants OF Cumberland COUNTY PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: 11-574-Civil ;2=rri C rri }? r.. l <A N rr l Ms- CD -,n - 77" Issue the Writ of Possession in the above matter, for possession of 1008 Centerville Road Newville PA 17241 (describe property) SEE ATTACHED LEGAL DESCRIPTION Ejectment Quiet Title A. 5 116 (Rev. 10/76) By: G%DgECK MCCAFFERTY & MCKEEVER -Michael McKeever Pa. ID 56129 -Gary McCafferty Pa. ID 42386 -Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 -David Fein Pa. ID 82628 -Thomas Puleo Pa. ID 27615 _?Jay E. Kivitz Pa. ID 26769 -Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff '-D U-vo 0 ` /q- Op WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160-3165) CITIFINANCIAL INC 6400 Las Colinas Blvd. Irving, TX 75039 Plaintiff vs. SANDRA K. FOOSE and MARY A. MYERS and OCCUPANTS 1008 Centerville Road Newville, PA 17241 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland To the Sheriff of Cumberland County, Pennsylvania. COURT OF COMMON PLEAS Term No. 11-574-Civil WRIT OF POSSESSION (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to CITIFINANCIAL INC, Plaintiff, being: (Premises as follows): 1008 Centerville Road Newville, PA 17241 (2) To satisfy the costs against the defendants you are directed to levy upon any property of the defendants and sell his., her or their interest therein. /I U Prot o Court of Common Pleas Cumberland County By: Dated: Deputy c-)Qp Vd rod. d? a-oo Qtv CU v F" o z con Q W a a ?z 00 UV ?To -a O ? O ? U U W H z 0-4 U U d U cl? W Q QZa'? U 2 p?U? o? w ? o Z 0 Q z z 0 rW? vr?1 V1 In 1 w 0 h 0 U W W W ? U Q) U ? o ? M W o ?a"v? U ? a W o0 Q tr) o? --- ----- ---- - ALL THAT CERTAIN lot or ground situate in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bowermaster, thence 75 feet In e Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direction along said Searvers land to a stake at the line of other land of the grantors; thence 75 feet in a Northerly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Placo of Beginning. BEING THE SAME PREMISES BY DEED FROM RUTH A_ MYERS, A SINGLE PERSON DATED 04/07/00 AND RECORDED 04/18/00 IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVILLE PA 17241 TAX PARCEL NO: 31-29-2522-012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff F {LSD-CIF F Xl,?.. Jody S Smith Chief Deputy I I AUG _8 APB 8: Richard W Stewart Solicitors . ;UMSERL.3 PENNSY124WNI,i? Citifinancial, Inc. vs Case Number . Sandra K. Foose (et al.) 2011-574 SHERIFF'S RETURN OF SERVICE 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupant(s), by posting purusant to court order, one true and attested copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Sandra K. Foose, by posting pursuant to court order, one true and attestec copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Mary A. Myers, by posting pursuant to court order, one true and attested copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. SHERIFF COST: $80.00 August 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 11426e? h utshall, Deputy !o1 Geu^`-St. to enlf. 7e': osom In; SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???+at? Ct CGUinbrfy;??? OFF.=_EV 3"ERIFF i._ TOP TH !T t11 i AUG 15 PPl b: 04 r'UMBERLAt?D CGUN `'a' PEMSYLYAMA Jody S Smith Chief Deputy Richard W Stewart Solicitor Citifinancial, Inc. vs. Sandra K. Foose (et al.) Case Number 2011-574 SHERIFF'S RETURN OF SERVICE 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupant(s), by posting purusant to court order, one true and attested copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Sandra K. Foose, by posting pursuant to court order, one true and attester copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. 07/28/2011 07:31 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on March 16, 2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Mary A. Myers, by posting pursuant to court order, one true and attested copy of the within Writ of Possession at 1008 Centerville Road, Newville, PA 17241. 08/12/2011 By virtue of this writ, Ronny R. Anderson, Sheriff caused the within named Plaintiff to have possession of the premises described as 1008 Centerville Road, Newville, PA 17241. Possession give to Plaintiff's representative; Ronald R. Clever, Smart Choice Realty. SHERIFF COST: $122.00 August 12, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF G' i G pd . c _ 3? tc CcunrySuite Sheriff, Teleoso t. Inc.