The URL can be used to link to this page

Home My WebLink About11-3224U FILED-OFFICE OF THE PROTHONOTARY 1011 MAR 23 PM 2: 39 IN THE COURT OF COMMON PL LANG COUNTY CUMBERLAND COUNTY, PENNSY SYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTOWN, PA 17072-1001 NO.: 0- 3,?u Ll Awl Plaintiff, NO.: 11-2769 MLD VS. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL #38-19-1610-041 TYPE OF PLEADING CIVIL ACTION - WRIT OF SCIRE FACIAS Defendant. FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff 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 E ERED AGAINST YOU. ATT E OR 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 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): 5 Poplar Drive Mechanicsburg, PA 17050 1A I ATT FOR PLAINTIFF JAMES, SMITH, DIETTERICK & CONNELLY, LLP pp ": // a-, '14/ # 1 ?. 6e' ('fir CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 5 Poplar , Mechanicsburg, PA 17050 ATTORN F LAINTIFF (/ x # G13,.W e, ! /', fk ,-/,ele IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: VS. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-19-1610-041 No.: 11-2769 MLD Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, VS. CIVIL DIVISION No.. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-19-1610-041 Defendant. No.: 11-2769 MLD 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 KINGSTON, PA 17072-1001 Plaintiff, No.: vs. JENNIFER L. SHATZER No.: 11-2769 MLD 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-19-1610-041 ; Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: A A A Scott A. WeNerick, 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 KINGSTON, PA 17072-1001 Plaintiff, No.: vs. JENNIFER L. SHATZER No.: 11-2769 MLD 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-19-1610-041 Defendant. TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: X /I N Scott A tDiditerick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 WRIT OF SURE FACIAS TO: JENNIFER L. SHATZER 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. 11-2769 MLD, for the sum of $4,284.63, 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 5 Poplar Drive, Mechanicsburg, Pennsylvania 17050, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 279, Page 2982, Tax Parcel #38-19-1610-041, 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. CG?st s b l1 66) _(SEAL) 31,W31il ` ONOT RY 66, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?Q?j?ty nt Carirrbrrf?? 0FFi E ...G N.t SFr T;EI?'ED-OFF! E PR0Tf10ti{c)T ,,t,,?,.,, 1J i 1 AP? f f PM 12: IF CUMBERLANC COMTY PEWisYLVA?INIA Silver Spring Township Authority vs. Jennifer L Shatzer Case Number 2011-3224 SHERIFF'S RETURN OF SERVICE 04/08/2011 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: Jennifer L. Shatzer, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Scire Facias as not found as to the defendant Jennifer L. Shatzer. Request for service at 5 Poplar Drive, Mechanicsburg, Pennsylvania 17050 is vacant. The Mechanicsburg Postmaster has confirmed, Jennifer L. Shatzer has moved and left no forwarding address. SHERIFF COST: $43.00 SO ANSWERS, April 08, 2011 RON R ANDERSON, SHERIFF ;c7 Goun' Suite Shenft Teieosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ? i ti 'rtSr ?'' OFFi.^_Er- F" „Sk4RIFF FILED-OFFICE OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 MAY 2S AM 8: 48 CUMBERLAND COUNTY PENNSYLVANIA Silver Spring Township Authority vs. Jennifer L Shatzer Case Number 2011-3224 SHERIFF'S RETURN OF SERVICE 05/10/2011 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: Jennifer L. Shatzer, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Scire Facias according to law. 05/18/2011 08:25 AM - Dauphin County Return: And now May 18, 2011 at 0825 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Jennifer L. Shatzer by making known unto Donald McKee, Husband of Defendant at 18502 Kay Street, Hamburg, Pennsylvania 17109 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 24, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF !ci GounfySuite Snenff Teteo.=,oft. In t ? r (ptfirt Jack Duignan Chief Deputy William. T. Tully Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SILVER SPRING TOWNSHIP AUTHORITY VS County of Dauphin JENNIFER L SHATZER Sheriff s Return No. 2011-T-2268 OTHER COUNTY NO. 20113224 And now: MAY 18, 2011 at 8:25:00 AM served the within WRIT OF SCIRE FACIAS upon JENNIFER L SHATZER by personally handing to DONALD MCKEE 1 true attested copy of the original WRIT OF SCIRE FACIAS and making known to him/her the contents thereof at 1502 KAY STREET HARRISBURG PA 17109 SPOUSE Sworn and subscribed to before me this 19TH day of May, 2011 -)P*2 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, lel"?2°1c- Sheriff of Dau?ty, Rv Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 5/16/2011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3224 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 JENNIFER L. SHATZER (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: $4,284.63 L.L.: $.50 Interest Atty's Comm: % Due Prothy: $4A0 Atty Paid: $ 1 V Y. 5'0 Other Costs:'r$, QO sQ}' FQe e Plaintiff Paid: Date: 7/14/11 David D. Buell, • thonotary (Seal) n / By: Dep 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 i IN THE OOM OF M44:)N PLEAS OF aPMERU ND Ca NrY, PF *6nVANIA Silver Spring Township CIVIL DIVISION Authority . File No. 11-2769 MLD / 11-3224 Civil Term (Plaintiff) . Amount Due $ 4,284.63 v . Interest from 7/12/11 to $ date of sale Jennifer L. Shatzer . Atty's Comm N C) Costs rn - (Defendant (s ) Mrn r- r- rn TO THE PROTHONOTARY OF THE SAID COURT: CA,D ?C7 The undersigned hereby certifies that the below does not arise out of a ULlo installment sale, contract, or account based on a confession of judgment, butzt=rdoer3F it- is based on the appropriate original proceeding filed pursuant to Act 7 of)*V6 as amended; and for real property pursuant to Act 6 of 1974 as amended. -?+ try PRAECIPE FOR EX LMION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) See Exhibit "A" attached. PRAECIFE FOR ATTACHMENr MCttrlON 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). I (Indicate) Index this writ against the garnishee( real estate of the defendant(s) described in the attached exr DATE : July 12, 2011 C? CN\ ay.o° t? a * Li OCS CR.? I ?1 l l 460 1c) . 60 " " 1 N, 0 0 Signature: Print Name: pendens against Address: James Smith Dietterick & Connelly LLP P 0 Box 650, Hershey PA 17033 Attorney for: - Telephone:_ SO-00 QiSuprerre Court '&. W1.4- fit, ? ?03 V-? d4i%ao Plaintiff (717) 533-3280 ID No.: 55650 1?1 ?- a? ?? LSsue? LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Poplar Street, which point is 225.47 feet west of the southwest corner of the intersection of said Poplar Street and Maple Drive; thence along the southern line of Poplar Street, North 65 degrees 27 minutes East, a distance of 18.57 feet to a point; thence continuing along the southern line of said Poplar Street by a curve to the right having a radius of 387.64 feet, a distance of 41.5 feet to a point at the western line of Lot No. 39 on the hereinafter mentioned Plan of Lots; thence along the western line of Lot No. 39, South 24 degrees 33 minutes East, a distance of 117.79 feet to a point at the intersection of the northern line of Lots Nos. 41 and 42; thence along the northern line of Lot No. 42, South 65 degrees 27 minutes West, a distance of 60 feet to a point in the eastern line of Lot No. 37; thence along the eastern line of Lot No. 37, North 24 degrees 33 minutes West, a distance of 120 feet to a point, the place of BEGINNING. BEING Lot No. 38 on Plan of Lots of Silver Spring Development Company which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 4. HAVING thereon erected a dwelling house being known and numbered as 5 Poplar Drive, Mechanicsburg, Pennsylvania 17050. BEING the same premises which David M. Shatzer and Jennifer L. Shatzer, Husband and Wife, by Deed dated April 11, 2007, and recorded on April 16, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 279, Page 2982, granted and conveyed unto Jennifer L. Shatzer. Parcel No.: 38-19-1610-041 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 KINGSTON, PA 17072-1001 Plaintiff, No.: 11-3224 Civil Term VS. No.: 11-2769 MLD c JENNIFER L. SHATZER -OZ = --? 5 POPLAR DRIVE xr" C= rn- MECHANICSBURG, PA 17050 cn r- M rn PARCEL ID# 38-19-1610-041 °' . Q Defendant. D h -v Q -q z° zF5 5;c: 77 im' AFFIDAVIT PURSUANT TO RULE 3129.1 v 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 5 Poplar Drive, Mechanicsburg, Pennsylvania 17050: 1. Name and Address of Owner(s) or Reputed Owner(s): JENNIFER L. SHATZER 18502 Kay Street Harrisburg, PA 17109 2. Name and Address of Defendant(s) in the Judgment: JENNIFER L. SHATZER 18502 Kay Street Harrisburg, PA 17109 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. Name and Address of the last record holder of every mortgage of record: WELLS FARGO FINANCIAL PA, INC. 4830 Carlisle Pike E3 Mechanicsburg, PA 17050 5. 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 6. 7 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 COMMONWEALTH OF PA CURRENT OCCUPANTS/TENANTS UNKNOWN SPOUSE OF JENNIFER L. SHATZER PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 5 Poplar Drive Mechanicsburg, PA 17050 18502 Kay Street Harrisburg, PA 17109 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, DATED: June 23, 2011 BY: Scott A. ck, Esquire Pa. I.D. 55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY, LLP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1610-041 Defendant. CIVIL DIVISION No.: 11-3224 CivilgerM: ._? rnM No 1-2769 Ml : 11-2769M§'*' M- M . C-) 6-n =C) is r? ?M NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 JENNIFER L. SHATZER 5 Poplar Drive Mechanicsburg, PA 17050 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: 5 Poplar Drive Mechanicsburg, Pennsylvania 17050 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-3224 Civil Term No. 11-2769 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jennifer L. Shatzer 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, DIETTERICK & COI` DATED: June 23, 2011 BY: Scott A 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 piece or parcel of land situate in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Poplar Street, which point is 225.47 feet =pest of the southwest corner of the intersection of said Poplar Street and Maple Drive; thence along the southern line of Poplar Street, North 65 degrees 27 minutes East, a distance of 18.57 feet to a point; thence continuing along the southern line of said Poplar Street by a curve to the right having a radius of 387.64 feet, a distance of 41.5 feet to a point at the western line of Lot No. 39 on the hereinafter mentioned Plan of Lots; thence along the western line of Lot No. 39, South 24 degrees 33 minutes East, a distance of 117.79 feet to a point at the intersection of the northern line of Lots Nos. 41 and 42; thence along the northern line of Lot No. 42, South 65 degrees 27 minutes West, a distance of 60 feet to a point in the eastern line of Lot No. 37; thence along the eastern line of Lot No. 37, North 24 degrees 33 minutes West, a distance of 120 feet to a point, the place of BEGINNING. BEING Lot No. 38 on Plan of Lots of Silver Spring Development Company which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 4. HAVING thereon erected a dwelling house being known and numbered as 5 Poplar Drive, Mechanicsburg, Pennsylvania 17050. BEING the same premises which David M. Shatzer and Jennifer L. Shatzer, Husband and Wife, by Deed dated April 11, 2007, and recorded on April 16, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 279, Page 2982, granted and conveyed unto Jennifer L. Shatzer. Parcel No.: 38-19-1610-041 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 CIVIL DIVISION No.: 11-3224 CIVIL TERM No.: 11-2769 MLD Plaintiff, vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID#38-19-1610-041 Defendant. I Hereby certify that the last known address of Defendant(s is/are: 18502 Kayeet Harrisbur. A 10A Attorney TYPE OF PLEADING: C-) o C) "'7 r- rnr- z? r -- ? o Z ? o 20 -v ca-n C) r+n 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 am+ %AIq.w pd alt.. ?t 77oa. .* 11 ,u19 ?'? Ct ?Ulouled IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 11-3224 Civil Term Vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1610-041 Defendant. No.: 11-2769 MLD PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Jennifer L. Shatzer, in the amount of $4,284.63, plus interest, penalties, and Quarterly bills after the 3'd Quarter 2011, and additional attorneys' fees and costs reasonable and actually incurred. JAMES, SMI' CONNELLY, By: Scott A. r ' tte Attorney for Pla tii 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 Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as a den ed by the attached copies. Scott A? Die*rick, Esquire Sworn to and subscribed before me this 23`d day of June, 2011. 04.Aj <?I? (?? C - () i A t a--x- Notary Public My Commission Expires: NOTARIAL AL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Jun 23, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 11-3224 Civil Term vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1610-041 : No.: 11-2769 MLD Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: JENNIFER L. SHATZER ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on 2011. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,284.63 plus interest, penalties, and Quarterly bills after the 3rd Quarter 2011, plus additional attorneys' fees and costs reasonable and actually incurred and for f closu and f the Premi f Pro ary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID 438-19-1610-041 Defendant. IMPORTANT NOTICE TO: JENNIFER L. SHATZER 18502 Kay Street Harrisburg, PA 17109 DATE OF NOTICE: June 8, 2011 CIVIL DIVISION No.: 11-3224 Civil No.: 11-2769 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 KINGSTON, PA 17072-1001 Plaintiff, No.: 11-3224 Civil vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID #38-19-1610-041 No.: 11-2769 MLD Defendant. AVISO IMPORTANTTE A. Jennifer L. Shatzer FECHA DEL AVISO: June 8, 2011 USTED 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 SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE 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 i JAMES S T D & CONNELLY LLP 11 BY: DATE: June 8. 20 ?Sco erick, 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith :?.. Chief Deputy Richard W Stewart Solicitor 'OFFICE OF THE &t"ERIFF Silver Spring Township Authority vs. Jennifer L Shatzer Case Number 2011-3224 SHERIFF'S RETURN OF SERVICE 05/10/2011 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: Jennifer L. Shatzer, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Scire Facias according to law. 05/18/2011 08:25 AM - Dauphin County Return: And now May 18, 2011 at 0825 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Jennifer L. Shatzer by making known unto Donald McKee, Husband of Defendant at 18502 Kay Street, Harriburg, Pennsylvania 17109 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 24, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (Cl Coun+,Suite Sheriff. Teieosoit. In,C. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 4'???ttt, 4f "L'einGrP(Y ?b I a I- _r; THE n rT ?? i s i . .. d ?a y1 Lij 2 JAS 12 3 }; l E: ? -13 Richard W Stewart Solicitor Silver Spring Township Authority vs. Jennifer L Shatzer 11 --c _?FPIFF C,UMBERLAiE?U ECG`U NT ?' FEMN S `'!.?6 W Case Number 2011-3224 SHERIFF'S RETURN OF SERVICE 10/07/2011 Michelle Gutshall, Deputy, 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 5 Poplar Drive, Mechanicsburg, Cumberland County. 10/07/2011 Ron Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jennifer L. Shatzer, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin 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 Dauphin County upon Theresa Stoner, Adult in Charge, who accepted for Jennifer L. Shatzer, at 1502 Ka} Street, Harrisburg, PA 17109 on 10/3/11 at 0859 a.m. So Answers: W. Conway, Deputy, Sheriff. 12/02/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $814.80 SO ANSWERS, January 20, 2012 RON R ANDERSON, SHERIFF 5j, cep ,4- . ? . 571 LZ 1d I 7 0146 ;c) CeWTYSkl trn hey `t, Te eoso`t. W- 2011.3224 Chid Term Silver Spring Township Authority Vs JennHer L Shatzer Atty: Scott A Dietterlck ALL THAT CERTAIN piece or parcel of kv ad situate in the Township of Silver Spri.lg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Poplar Street, which point is 225.47 feet west of the southwest comer of the intersection of said Poplar Street and Maple Drive; thence along the southern line of Poplar Street, North 65 degrees 27 minutes East, a distance of 18.57 feet to a point; thence continuing along the southern line of said Poplar Street by a curve to the right having a radius of 387.64 feet, a distance of 41.5 feet to a point at the western line of Lot No. 39 on.the hereinafter mentioned Plan of Lots; thence along the western line of Lot No. 39, South 24 degrees 33 minutes East, a distance of 117.79 feet to a point at the intersection of the northern line of Lots Nos. 41 and 42: thence along the northern line of Lot No. 42, South 65 degrees 27 minutes West, a distance of 60 feet to a point in the eastern line of Lot No. 37; thence along the eastern line of Lot No. 37, North 24 degrees 33 minutes West, a distance of 120 feet to a point, the place of BEGINNING. BEING Lot No. 38 on Plan of Lots of Silver Spring Development Company which Plan is recorded in the Cumberland county Recorders Office in Plan Book 6, Page 4. HAVINUthereon erected a dwelling house being known and numbered ai 5 Poplar Drive, iMechattictburg, Pennsylvania 17050. BEING the same premises i3ich ISavid M. $1 1#1'„p;p[oehdifer L. Shatzer, Husband and by Deed dated April 11, 2007, and r ". on April„16, 2007 in,' Office uhhe Recorder of Deeds in and for Cumberland County, in;Aeed Book 279, Page 2982, granted and conveyed unto Jennifer L. ?hatwr. Parcel No.: 28-19-1610-041 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. i? Llva Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this da of November, 2011 Notary F OTARIAL SEAL ORAH A COLLINS Notary Public UGH, CUMBERLAND COUNTY ion Expires Apr 28, 2014 ?'..; .?? The Patrio°:-News Co. 2020 Technology Pkwy Sultc, 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERt.AND CO. SHERIFFS OFFICE CUMBEF`_AND COUNTY COURT HOUSE Z4 e Patti* ot News Now you know CARLISL PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, Counbf of Dauphin} ss Holly Blain. beira duly sworn according to law, deposes and says: That she is a St iff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Penrsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, :-ounty of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspape -s of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid, that The Patri:)t-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all hav been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday! Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patrioi-News Co. aforesaid by virtue and pursuant to a resoiutiun unanimously passed and adopted severally by the stockholders and board :)f directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/21111 10/28/11 11/04111 Sworn to 4nd subscribed before e thify16 day of November, 2311 A.D. Notary Public COMMONWI; TH OF PENNSYLVANIA Notarial Seel Sherrie E. Owens, Notary Public Lower Parton 1'wp., Dauphin County MY Commissbn Expires Ncv. 26, 2015 MEMBER, PENNSYLVANIA ASSo(7AIION OF NOTARIES a eh a PatriotAms Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriff's Office Cumberland County Court House Carlislf; PA 17013 ACCT. # 2260 DUPLICATE BILL Date D--?scription Sale # Size Rate Net Cost w Of Ad 10/21/11 Sheriff .;ale 3224 8.22 $12.00 S 08.64 10/28/11 Sheriff -3aie 3224 8.22 $12.00 3 98.64 11/04/11 Sheriff :;ale 3224 8.22 $12.00 6 98.64 Notary -ee i 4 $500 TOTAL DUE FOR THIS SALE: $ 300.92 JLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, vs. JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1610-041 Defendant. CIVIL DIVISION : No.: 11-3224 Civil Term No.: 11-2769 MLD . ? as -Y•, - M f rE 9 ' <[D PRAECIPE TO SATISFY MUNICIPAL LIEN -`' - d r. TO THE PROTHONOTARY: SIR/MADAM: Please mark the Municipal Lien filed at the above - captioned term and number satisfied. By: Scott X erick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 } *q•,jo po A77-f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: 11-3224 Civil Term vs. No.: 11-2769 MLD JENNIFER L. SHATZER 5 POPLAR DRIVE MECHANICSBURG, PA 17050 PARCEL ID# 38-19-1610-041 Defendant. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy Municipal Lien was served on the following this 2"a day of December, 2011, via First Class U. S. Mail, Postage Pre-paid: Jennifer L. Shatzer 1502 Kay Street Harrisburg, PA 17109 Respectfully Su tted- JAMES, SMI ETT RICK & CONNELLY, LLP By: _br Scott A. ck, Esquire Attorney I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280