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HomeMy WebLinkAbout11-3217IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTOWN, PA 17072-1001 Plaintiff, vs. THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL #3 8-19-1621-090 & 3 8-19-1621-090./02 CIVIL DIVISION / ?1 ?! wI l NO.: ?? _ NO.: 11-2770 MLD Cl) 01 - zrn m- TYPE OF PLEADING Wr- r rn C5 C:)- n el) = ?>? N °rn CIVIL ACTION - WRIT N OF SCIRE FACIAS -' Defendants. TO: DEFENDANT(s) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE D AGAINST YOU. ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 31 E. Main Street, P.O. Box 1001 New Kingstown, PA 17072-1001 AND THE DEFENDANT(S): 2812 Meri Road, Camp Hill, PA 17011 ATT EY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 16 E. Main Street, New Kingstown, PA 17072 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 JAMES, SMITH, DIETTERICK & CONNELLY, LLP ) 7y C????r .may / G P6 t/& GU ,off .4 ATTO EY PLAINTIFF ?L' ? G' 3a3 TJ1,W a5U 9 7? 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: (I _ 3 ] 61"' VS. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: VS. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. 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 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: I 3 11 ?%`? ` vs. f No.: I1-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET : NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 : Defendants PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: V/1-J-1 ' -L k Scott AL DiV tericK, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: Scott A. VVI Esquire Attorney intiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 WRIT OF SCIRE FACIAS TO: THEODORE D. OPPERMAN and SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN WHEREAS, Silver Spring Township Authority, on March 7, 2011, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 11-2770 MLD, for the sum of $4,494.87, 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 16 E. Main Street, New Kingstown, Pennsylvania 17072, 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 P28, Page 464, Tax Parcel #38-19-1621-090 & 38-19-1621-090./02, 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. /O)ys ',Iq?00 &IJ 11 2- o' Z' 404THON?TARY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff 4?tat?' i uataGe ! THE Jody S Smith ?d 3: 11 Chief Deputy ZQ? 30 PM _?ELa?D?,.tr Richard W Stewart Solicitor ?5? ?.W a Silver Spring Township Authority Case Number vs. 2011-3217 Theodore D. Opperman (et al.) SHERIFF'S RETURN OF SERVICE 03/28/2011 07:55 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2011 at 1955 hours, she served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Susanna B. Potera now known as Susanna B. Opperman, by making known unto herself personally, at 2812 Merion Road, 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. ?? Vr, _' fld wk AMANDA COBAUGH, D UTY 03/29/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Theodore D. Opperman, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Scire Facias as not found as to the defendant Theodore D. Opperman. Request for service at 2812 Merion Road, Camp Hill, Pennsylvania 17011 the defendant was not found. Susanna Opperman advised Deputies, Theodore D. Opperman does not reside at this location or in the area. SHERIFF COST: $64.00 March 29, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF .C) Gou Swl Shen'.f.. Tell;-sott. Ire. SHERIFF'S OFFICE OF CUMBERLAND COUN, Ronny R Anderson / 4 Sheriff r. t Of Jody S Smith at?t,t Orr/r?lb r'+'1rr? ='U l'? Chief Deputy v4 Richard W Stewart Solicitor O?r RIFF Silver Spring Township Authority vs. Theodore D. Opperman (et al.) Case Number 2011-3217 SHERIFF'S RETURN OF SERVICE 05/25/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Theodore D. Opperman, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Northampton County, Pennsylvania to serve the within Writ of Scire Facias according to law. 05/31/2011 10:35 AM - Northampton County Return: And now May 31, 2011 at 1035 hours I, Randall P. Miller, Sheriff of Northampton County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Theodore D. Opperman by making known unto himself personally, at 962 Pennsylvania Avenue 127, Pen Agryl, Pennsylvania 18072 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, June 09, 2011 4RON R ANDERSON, SHERIFF - :-- iC i?gln'ty}tlifr. S!'E.rlf1. , e., ?. ,;5o`f. li•%. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY, 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTOWN, PA 17072-1001 CIVIL DIVISION No.: 11-3217 CIVIL TERM No.: 11-2770 MLD Plaintiff, vs. THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID#38-19-1621-090 & 38-19-1621-090./02 Defendants. I Hereby certify that the last known address of Defendant(s) is/are: Theodore D. Opperman 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 Susanna B. Potera a/k/a Susanna B. Opperman 2812 erMoad Cam17011 Attorney for Plaintiff TYPE OF PLEADING: rn ad ?-. M - -? ?' co ca , < o >q: ?M 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 aut a14.c6 pda 2 A,4Lgo8 ?V 0 hco Wcu l ed 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k!a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Theodore D. Opperman and Susanna B. Potera a/k/a Susanna B. Opperman, in the amount of $4,494.87, plus interest, penalties, and Quarterly bills after the 3`d Quarter 2011, and additional attorneys' fees and costs reasonable and actually incurred. JAMES, SMITH, I K & CONNELLY, L? By: Scott A. settrick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 Defendants are 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. 237A, aswicenced by the attached copies. Scott A. Dielerick, Esquire Sworn to and subscribed before me this 15th day of July, 2011. C,o u sfi ru, L Notary Public My Commission Expires: F OTARIAL SEAL TINE L SPURLOCK Notary Public N BORO, DAUPHIN COUNTY y ion 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: THEODORE D. OPPERMAN ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on v, L- i V9 '2011. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,494.87 plus interest, penalties, and Quarterly bills after the 3rd Quarter 2011, plus additional attorneys' fees and costs reasonable and actually incurred and for foreclosure and sale of the Premise Prothro f ?C. c= 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL VS. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. NOTICE OF ORDER DECREE OR JUDGMENT TO: SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on I 1% , 2011. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,494.87 plus interest, penalties, and Quarterly bills after the 3'd Quarter 2011, plus additional attorneys' fees and costs reasonable and actually incurred and for fa closure and sale of the Premis Prot SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ?> -` Chief Deputy Richard W Stewart Solicitor OFFICE 0, sKsaFF Silver Spring Township Authority vs. Theodore D. Opperman (et al.) Case Number 2011-3217 SHERIFF'S RETURN OF SERVICE 05/25/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Theodore D. Opperman, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Northampton County, Pennsylvania to serve the within Writ of Scire Facias according to law. 05/31/2011 10:35 AM - Northampton County Return: And now May 31, 2011 at 1035 hours I, Randall P. Miller, Sheriff of Northampton County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Theodore D. Opperman by making known unto himself personally, at 962 Pennsylvania Avenue 127, Pen Agryl, Pennsylvania 18072 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 09, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF i. c; Gcun?ySuite Sne;,..a. lelec;>o't. Ins. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith vQ??r?ts' °i Lctzratarj,????d Chief Deputy Richard W Stewart Solicitor Silver Spring Township Authority vs. Theodore D. Opperman (et al.) Case Number 2011-3217 SHERIFF'S RETURN OF SERVICE 03/28/2011 07:55 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2011 at 1955 hours, she served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Susanna B. Potera now known as Susanna B. Opperman, by making known unto herself personally, at 2812 Merion Road, 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. C1 AMANDA COBAUGH, D UTY 03/29/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Theodore D. Opperman, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Scire Facias as not found as to the defendant Theodore D. Opperman. Request for service at 2812 Merion Road, Camp Hill, Pennsylvania 17011 the defendant was not found. Susanna Opperman advised Deputies, Theodore D. Opperman does not reside at this location or in the area. SHERIFF COST: $64.00 March 29, 2011 SO ANSWERS, 6bN W?- R ANDERSON, SHERIFF !C? Goun*;'juilB ?^v':^.`L T2?c?C'oft InL 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 KINGSTOWN. PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL VS. THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 No.: 11-2770 MLD Defendants IMPORTANT NOTICE TO: SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2812 Merion Road Camp Hill, PA 17011 DATE OF NOTICE: June 21,2011 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 YOUR 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. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 &, 38-19-1621-090./02 No.: 11-2770 MLD Defendants AVISO IMPORTANTE A. Susanna B. Potera a/k/a Susanna B. Opperrrian FECHA DEL AVISO: June 21, 2011 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDF, PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIEN'TE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 JAMES SNIT DI TERICK & CONNELLY LLP DATE: June 21. 2011 BY: -° FIRST CLASS U.S. MAIL, POSTAGE PREPAID Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire PA I.D. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 1 1- 3217 CIVIL vs. : THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 &- )8-19-1621-090./02 Defendants. IMPORTANT NOTICE TO: THEODORE D. OPPERMAN 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 DATE OF NOTICE: June 21, 2011 No.: 11-2770 MLD 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 YOUR 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. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (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 KINGSTOWN. PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL Vs. THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN. PA 17072 PARCEL ID #38-19-1621-090 & )8-19-1621-090./02 Defendants. AVISO IMPORTANTE A. Theodore D. Opperman FECHA DEL AVISO: June 21, 2011 No.: 11-2770 MLD USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE LISTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR IJN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI LISTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR LINO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARR QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle. PA 17013 Phone (717) 249-3166 (800)990-9108 JAMES SMITH I TTERICK & CO ELLY LLP I DATE: June 21. 2011 BY: r Scott A: Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire PA I.D. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey. PA 17033 FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-3217 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY Plaintiff (s) From THEODORE D. OPPERMAN and SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN (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: $4,494.87 L.L.: $.50 Interest fro, 1 j1 S) I I +0 d#FL o'? SJ e Atty's Comm: % Due Prothy: $11.00 Atty Paid: $19450 Other Costs: Plaintiff Paid: Date: 7/18/11 David D. Buell, Prothonotary(Seal) Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP P.O. BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 IN THE COURT OF CM-UN PLEAS OF aMBER" COUWY, P006nVANIA Silver Spring Township Authority v (Plaintiff) CIVIL DIVISION . File No. 11-2770 MLD / 11-3217 Civil Term : Amount Due $ 4,494.87 . Interest from 7/15/11 to $ ?- . date of sale : Atty's Comm Theodore D. Opperman and Susanna B. Potera a/k/a Susanna B. Opperman ( Defendant (s ) TO THE PROTHONOTARY OF THE SAID COURT; The undersigned hereby certifies that the below does not arise out of a re l ° installment sale, contract, or account based on a confession of judgment, butte it,'LZoei ,", it-is based on the appropriate original proceeding filed pursuant to Act 7 of%36 ;R r amended; and for real property pursuant to Act 6 of 1974 as amended, ter-- rn -C3' C)o PRAECIPE FDR EXECUTION V O--nj Issue writ of execution in the above matter to the Sheriff of Cumberla o -1 M County, for debt, interest and costs upon the following described property of ttrie cn defendant(s) See Exhibit "A" attached. PRAECIPE FOR ARTACI MM EDaD ION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, 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 garnishee(s). (Indicate) Index this writ against the garnishee(s) a dens against real estate of the defendant(s) described in the attached exhibiM. DATE: July 15, 2011 b4.0o CM= 37.00 `• 0`2 9. 00 W, I0. t?bk?tt 1 U. C) C> l? ?.50 ?199r S? Costs Signature; Print Name; Address: James Smith Dietterick & Connelly LLP P 0 Box 650, Hershey PA 17033 Attorney for: SR. lb ? ? Telephone:- Supreme Court <U cLA: 79&? pAdli'i 909 Plaintiff (717) 533-3280 ID No.: 55650 l?lr?? ?F ?? ?'s?Pd LEGAL DESCRIPTION ALL that certain lot of ground situate in the village of New Kingstown, Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the East side of a public street 40 feet wide, thence along the curb line of the State Highway (formerly called the Harrisburg, Carlisle and Chambersburg Turnpike) North 73 degrees 30 minutes East, 50 feet to an iron pin; thence by other lands now or formerly of William R. Kline, South 16 degrees 30 minutes East 211 feet to an iron pin on the North side of a public alley; thence along said alley, South 73 degrees 30 minutes West 50 feet to an iron pin on the East side of said public street; thence along said public street, North 16 degrees 30 minutes West 211 feet to an iron pin, the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 16 E. Main Street, New Kingstown, Pennsylvania 17072. BEING the same premises which Ray D. McCoy and Esther I. McCoy, Husband and Wife, by Deed dated August 17, 1979, and recorded on August 17, 1979 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book P28, Page 464, granted and conveyed unto Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/k,/a Susanna B. Opperman, Joint Tenants with Right of Survivorship. Parcel No.: 38-19-1621-090 & 38-19-1621-090./02 Exhibit "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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL VS. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN no cz? _= ..q 16 E. MAIN STREET co zrn c_ -ter M , NEW KINGSTOWN, PA 17072 : z? C PARCEL ID #38-19-1621-090 & <> 38-19-1621-090./02 <o `? Defendants. z? z A.? w orn AFFIDAVIT PURSUANT TO RULE 3129.1 w' 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 16 E. Main Street, New Kingstown, Pennsylvania 17072: 1. Name and Address of Owner(s) or Reputed Owner(s): THEODORE D. OPPERMAN A/K/A D. THEODORE OPPERMAN SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 2812 Merion Road Camp Hill, PA 17011 Name and Address of Defendant(s) in the Judgment: THEODORE D. OPPERMAN 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2812 Merion Road Camp Hill, PA 17011 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 4. 5. 6. BOROUGH OF CAMP HILL 2145 Walnut Street Camp Hill, PA 17011 Name and Address of the last record holder of every mortgage of record: COUNTRYWIDE HOME LOANS, INC. 4500 Park Granada Calabasas, CA 91302-1613 Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM Cumberland County Courthouse BUREAU One Courthouse Square Carlisle, PA 17013 Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: DEPARTMENT OF REVENUE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PA CURRENT OCCUPANTS/TENANTS UNKNOWN SPOUSE OF THEODORE D. OPPERMAN UNKNOWN SPOUSE OF SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 16 E. Main Street New Kingstown, PA 17072 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 2812 Merton Road Camp Hill, PA 17011 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of 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 authorities. JAMES, SMITH, DW'TIARICK & CONNELLY, LLP DATED: July 15, 2011 BY: Scott A. Dl?tterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. : THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 No.: 11-2770 MLD2 mcr) x M zm c r r=- -a D rn c) r- -+o a s x,c ?q am ? Defendants. =s? NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2812 Merion Road Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 7, 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: 16 E. Main Street New Kingstown, Pennsylvania 17072 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-3217 Civil Term No. 11-2770 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/k/a Susanna B. Opperman 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 may be 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, D RICK & CONNELLYI"1. DATED: July 15, 2011 BY: Scott A. iette ck, 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 VIA PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL that certain lot of ground situate in the village of New Kingstown, Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the East side of a public street 40 feet wide, thence along the curb line of the State Highway (formerly called the Harrisburg, Carlisle and Chambersburg Turnpike} North 73 degrees 30 minutes East, 50 feet to an iron pin; thence by other lands now or formerly of William R. Kline, South 16 degrees 30 minutes East 211 feet to an iron pin on the North side of a public alley; thence along said alley, South 73 degrees 30 minutes West 50 feet to an iron pin on the East side of said public street; thence along said public street, North 16 degrees 30 minutes West 211 feet to an iron pin, the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 16 E. Main Street, New Kingstown, Pennsylvania 17072. BEING the same premises which Ray D. McCoy and Esther 1. McCoy, Husband and Wife, by Deed dated August 17, 1979, and recorded on August 17, 1979 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book P28, Page 464, granted and conveyed unto Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a /k/a Susanna B. Oppermai:, Joint Tenants with Right of Survivorship. Parcel No.: ':)8-19-1621-090&38-19-1621-090./0') Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor v4??ott4? of ?.otaut,i?.f??t? ..K F _ ., ?1n-TFi(}t G it LaP'1 ` Pp, jr CUUM3ERLAti!0 C0 Ukj,f. a. PEWPISYLV, NIA Silver Spring Township Authority vs. Theodore D. Opperman (et al.) Case Number 2011-3217 SHERIFF'S RETURN OF SERVICE 09/29/2011 08:17 PM - Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Susanna B. Potera at 2812 Merion Road, Camp Hill, Cumberland County. 10/07/2011 Michelle Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 16 East Main Street, New Kingstown, Cumberland County. (2 Tracts) 10/07/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Theodore D. Opperman, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Northampton County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 10/07/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Northampton County upon Theodore D. Opperman, personally, at 962 Pennsylvania Ave, # 127, Pen Argyl, PA 18072. So Answers: Randall P.Miller, Sheriff. 12/01/2011 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/7/2012 03/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. Plaintiff received $5,137.75 to cancel sale. SHERIFF COST: $926.61 March 21, 2012 SO ANSWERS, "- 6Z RON R ANDERSON, SHERIFF tlo f,t . Ce,. . SZ' L.L.- rol - . ; i.9u?lf Suite SN r t Ei s0{t. Ii?J. 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 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 16 E. Main Street, New Kingstown, Pennsylvania 17072: 1. Name and Address of Owner(s) or Reputed Owner(s): 2. 3 THEODORE D. OPPERMAN A/K/A 962 Pennsylvania Avenue 127 D. THEODORE OPPERMAN Pen Argyl, PA 18072 SUSANNA B. POTERA A/K/A 2812 Merion Road SUSANNA B. OPPERMAN Camp Hill, PA 17011 Name and Address of Defendant(s) in the Judgment: THEODORE D. OPPERMAN 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2812 Merion Road Camp Hill, PA 17011 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 r? 4 5. 6. 7 BOROUGH OF CAMP HILL 2145 Walnut Street Camp Hill, PA 17011 Name and Address of the last record holder of every mortgage of record: COUNTRYWIDE HOME LOANS, INC. 4500 Park Granada Calabasas, CA 91302-1613 Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM Cumberland County Courthouse BUREAU One Courthouse Square Carlisle, PA 17013 Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: DEPARTMENT OF REVENUE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PA CURRENT OCCUPANTS/TENANTS UNKNOWN SPOUSE OF THEODORE D. OPPERMAN UNKNOWN SPOUSE OF SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 16 E. Main Street New Kingstown, PA 17072 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 2812 Merion Road Camp Hill, PA 17011 Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of 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 authorities. JAMES, SMITH, DMVT*UCK & CONNELLY, LLP DATED: July 15, 2011 BY: Scott A. Dj, tterick. Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 THEODORE D. OPPERMAN 962 Pennsylvania Avenue 127 Pen Argyl, PA 18072 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 7, 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: 16 E. Main Street New Kingstown, Pennsylvania 17072 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-3217 Civil Term No. 11-2770 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/k/a Susanna B. Opperman 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 may be 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 DIE RICK & CONNELLY, L DATED: July 15, 2011 BY: / 11-' Scott A. Diet ri-c c, squire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED and VIA PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL that certain lot of ground situate in the village of New Kingstown, Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the East side of a public street 40 feet wide, thence along the curb line of the State Highway (formerly called the Harrisburg, Carlisle and Chambersburg Turnpike) North 73 degrees 30 minutes East, 50 feet to an iron pin; thence by other lands now or formerly of William R. Kline, South 16 degrees 30 minutes East 211 feet to an iron pin on the North side of a public alley; thence along said alley, South 73 degrees 30 minutes West 50 feet to an iron pin on the East side of said public street; thence along said public street, North 16 degrees 30 minutes West 211 feet to an iron pin, the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 16 E. Main Street, New Kingstown, Pennsylvania 17072. BEING the same premises which Ray D. McCoy and Esther 1. McCoy, Husband and Wife, by Deed dated August 17, 1979, and recorded on August 17, 1979 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book P28, Page 464, granted and conveyed unto Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/k/a Susanna B. Oppe-nan. Joint Tenants with Right of Survivorship. Parcel No.: 38-19-1621-090 & 38-19-1621-090./02 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTOWN, PA 17072-1001 Plaintiff, vs. CIVIL DIVISION : No.: 11-3217 CIVIL No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID 438-19-1621-090 & 38-19-1621-090./02 Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN 2812 Merion Road Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, December 7, 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: 16 E. Main Street New Kingstown, Pennsylvania 17072 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-3217 Civil Term No. 11-2770 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/k/a Susanna B. Opperman 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 may be 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, D & CONNELLYW DATED: July 15, 2011 BY: Scott A. iett ck, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Her PA 17033 (717) 533-3280 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED and VIA PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL that certain lot of ground situate in the village of New Kingstown, Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the East side of a public street 40 feet wide, thence along the curb line of the State Highway (formerly called the Harrisburg, Carlisle and Chambersburg Turnpike) North 73 degrees 30 minutes East, 50 feet to an iron pin; thence by other lands now or formerly of William R. Kline, South 16 degrees 30 minutes East 211 feet to an iron pin on the North side of a public alley; thence along said alley, South 73 degrees 30 minutes West 50 feet to an iron pin on the East side of said public street; thence along said public street, North 16 degrees 30 minutes West 211 feet to an iron pin, the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 16 E. Main Street, New Kingstown, Pennsylvania 17072. BEING the same premises which Ray D. McCoy and Esther I. McCoy, Husband and Wife, by Deed dated August 17, 1979, and recorded on August 17, 1979 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book P28, Page 464, granted and conveyed unto Theodore D. Opperman a/k/a D. Theodore Opperman and Susanna B. Potera a/kla Susanna B. Opperman, Joint Tenants with Right of Survivorship. Parcel No.: 38-19-1621-090&38-19-1621-090./02 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT CbMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3217 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 THEODORE D. OPPERMAN and SUSANNA B. POTERA A/K/A SUSANNA B. OPPERMAN (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: $4,494.87 L.L.: $.50 Interest ?ro v. 7 Ps-i 11 'to ? e of sra?e Atty's Comm: % Due Prothy: $9.00 Atty Paid: $119.50 Other Costs: Plaintiff Paid: Date: 7/18/11 David D. Bu 11, Prothonot ?$ id D Q5 ? (Seal) Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP P.O. BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the, steal of said =at l, ;; Thlsday of Pro20 thonotary `' a kAoLvi Iq On August 23, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Silver Springs Township, Cumberland County, PA, Known and numbered as, 16 East Main Street, New Kingstown, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 23, 2011 By: Real Estate Coordinator .i A ? 1 , i Ir.... IN THE COURT OF COMMON PLEAS OF !} k CUMBERLAND COUNTY, PENNSYLVANIA P19 3:4-1 .XIBERL ANA coU TV' SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION PENNS YL-VANIA 31 E. MAIN STREET, P.O. BOX 1001 ; NEW KINGSTOWN, PA 17072-1001 Plaintiff, No.: 11-3217 CIVIL vs. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 ; PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: SIR/MADAM: Please mark the Municipal Lien filed at the above - captioned term and number satisfied. 01%N % q.-SD PA 61 ?? aboY Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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 KINGSTOWN, PA 17072-1001 ; Plaintiff, No.: 11-3217 CIVIL VS. No.: 11-2770 MLD THEODORE D. OPPERMAN SUSANNA B. POTERA a/k/a SUSANNA B. OPPERMAN 16 E. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-090 & 38-19-1621-090./02 Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy ' Jung, Municipal Lien was served on the following this O day of Mm-eh, 2012, via First Class U. S. Mail, Postage Pre-paid: Susanna B. Potera a/k/a Susanna B. Opperman 2812 Merion Road Camp Hill, PA 17011 Theodore D. Opperman 962 Pennsylvania Avenue #127 Pen Argyl, PA 18072 Respectfully JAMES, ST By: '3c0tt . OTMerick, Esquire Attorny I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY, LLP