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Home My WebLink About11-3226IN 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.. ROLLACE E. HEUSTESS BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 Defendants No.: 11-2767 MLD NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, No.: VS. ROLLACE E. HEUSTESS No.: 11-2767 MLD BARBARA A. HEUSTESS 78 W. MAIN STREET : NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 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 KINGSTON, PA 17072-1001 Plaintiff, No.: vs. ROLLACE E. HEUSTESS BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 TO: PROTHONOTARY No.: 11-2767 MLD Defendants. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By: I AN Scott A. Vor t ck, Esquire Attorney 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. ROLLACE E. HEUSTESS No.: 11-2767 MLD BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 : PARCEL ID #38-19-1621-004 Defendants. TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-cal2tioned Matter. By: q A N Scott A. i e 'dc, Esquire Attorney for intiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 WRIT OF SCIRE FACIAS TO: ROLLACE E. HEUSTESS and BARBARA A. HEUSTESS 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. 11-2767 MLD, for the sum of $4,441.73, 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 78 W. 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 274, Page 205, Tax Parcel #38-19-1621-004, 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. (?% : '11i ? 06 ®w po 4 d. 60 S64, [-& 0 4 k- GG (SEAL) OTHON TARY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Silver Spring Township Authority vs. Rollace E Heustess (et al.) FILED- OF THE P OTCHONOTAR t' 2011 MAR 29 PM 1: 02 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2011-3226 SHERIFF'S RETURN OF SERVICE 03/25/2011 08:20 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 25, 2011 at 2020 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Rollace E. Heustess, by making known unto himself personally, at 237 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGS T, DEPUTY 03/25/2011 08:20 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 25, 2011 at 2020 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Barbara A. Heustess, by making known unto Rollace E. Heustess, Husband of Defendant at 237 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGETT, DEPUTY SHERIFF COST: $54.00 March 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 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. rn Zm CIVIL DIVISIOf r- r+z v c-? No.: 11-3226 Cir t_.+ laa si? c G"7 c+ c? _4 O _r x -In cc)-n Z on r T, ROLLACE E. HEUSTESS No.: 11-2767 MLD BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 Defendants. PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment filed at the above-captioned term and number satisfied. Respectfully submitted: JAMES, SMITH, BY: & CONNELLY LLP Scott At erick, Esquire PA I.D. M6'5' 0 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 at&Vsg•°°1Aa C LI+ Rio pl?-o?V SO-9'6 C: Q IN THE COURT OF COMMON PLEAS OF r°W s,. CUMBERLAND COUNTY, PENNSYLVANIA G-') z? ?? SILVER SPRING TOWNSHIP AUTHORITY 31 E. MAIN STREET, P.O. BOX 1001 NEW KINGSTON, PA 17072-1001 Plaintiff, VS. ROLLACE E. HEUSTESS BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 Defendants. CIVIL DIVISIOD o ?c?z .. No.: 11-3226 Civi.4 cn No.: 11-2767 MLD PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: oc: SWMADAM: Please mark the Municipal Lien filed at the above - captioned term and number satisfied. By: Scott etterick, Esquire APA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 dk? c??oq 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. ROLLACE E. HEUSTESS BARBARA A. HEUSTESS 78 W. MAIN STREET NEW KINGSTOWN, PA 17072 PARCEL ID #38-19-1621-004 Defendants. CERTIFICATE OF SERVICE CIVIL DIVISION No.: 11-3226 Civil No.: 11-2767 MLD The undersigned hereby certifies that a true and correct copy of the Praecipe to Satisfy Municipal Lien was served on the following this I Oth day of August, 2011, via First Class U. S. Mail, Postage Pre-paid: Rollace E. Heustess Barbara A. Heustess 237 Ridge Hill Road Mechanicsburg, PA 17050 Respectfully Su tted. JAMES, S T TERICK & ONNELLY, LLP By: Scott A. k, squire Attorne Li 56 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor are t r: P 7. E S-ERIFF OF TH rARY E PRO °HONO 2011 AUG 23 qH g; 14 CUMBERLAND COUNTY PENS YLvANIA Silver Spring Township Authority Case Number vs. Rollace E Heustess (et al.) 2011-3226 SHERIFF'S RETURN OF SERVICE 06/28/2011 09:14 PM - Deputy Shawn Harrison, 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 ROLLACE HEUSTESS - HUSBAND, who accepted as "Adult Person in Charge" for Barbara A Heustess at 237 Ridge Hill Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 06/28/2011 09:14 PM - Deputy Shawn Harrison, 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: Rollace E Heustess at 237 Ridge Hill Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 06/29/2011 Michelle Gutshall, Deputy Sheriff, 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 78 W. Main Street, New Kingstown, PA 17072, Cumberland County. 08/13/2011 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: $1,018.02 August 22, 2011 SO ANSWERS, RbNWY- R ANDERSON, SHERIFF • SV tom. "Oed ' 6_1 3 61 {ci GountySuite Sheritt le!eosoft_ Inc. CUMBERLAND LAW JOURNAL Writ No. 2011-3226 Civil Silver Spring Township Authority vs. Rollace E. Heustess Barbara A. Heustess Atty.: Scott A. Dietterick ALL THAT CERTAIN lot of land and the improvements thereon erected, situate in the Village of New Kingstown, Silver Spring Township, Cumberland County, Pennsylvania, bounded and described in a survey by Ernest J. Walker, P.E., dated Sep- tember 26, 1979, as follows, to wit: BEGINNING at a point on the north side of U. S. Route 11 and lands now or formerly of Potteiger, said point being 40 feet West of an x-out in concrete on U.S. Route 11 and a right-of-way for drainage; thence South 85 degrees 52 minutes West (incorrectly referred to as South 65 degrees 52 minutes West in previous instruments of record), a distance of 40 feet to a point on U.S. Route 11 and lands now or formerly of Frank Potteiger; thence along lands of said Potteiger, North 04 degrees 08 min- utes West, a distance of 160.20 feet to a wall of a frame garage; thence along said wall and lands of said Potteiger, South 85 degrees 52 minutes West 2.2 feet to a point; thence through a partition wall, North 03 degrees 30 minutes 20 seconds West, a distance of 29.79 feet to an iron pin at an un- named alley; thence along said alley and rear of garage, North 85 degrees 52 minutes East, a distance of 30.5 feet to an x-out in concrete at other lands now or formerly of said Pot- teiger, thence along said lands now or formerly of Potteiger and through a partition wall, South 02 degrees 55 minutes 45 seconds East, a dis- tance of 29.79 feet to a point; thence along said garage, North 85 degrees 52 minutes East, a distance of 12 feet to a point at other lands now or formerly of said Potteiger, thence along other lands now or formerly of 35 said Potteiger; South 04 degrees 08 minutes East, a distance of 160.20 feet to the north side of U.S. Route 11, the place of BEGINNING. BEING known as No. 78 West Main Street, formerly No. 78 West Carlisle Pike, New Kingstown, Penn- sylvania 17072. BEING the same premises which Anna Thompson, as Executrix of the Estate of Thomas Edward Thomp- son, Deceased, by Deed dated April 13, 2006, and recorded on April 18, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 274, Page 205, granted and conveyed unto Rollace E. Heustess and Barbara A. Heustess, Husband and Wife. Parcel No.: 38-19-1621-004. 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: July 15, July 22 and July 29, 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. isa Marie Coy q1 Editor SWORN TO AND SUBSCRIBED before me this C da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE t Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have 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 Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of 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: Sworn day of August, 2011 A. D. le? ry P COMMONWEALTH OF Sherrie LN?al Seal Lower Paxton T 'Notary Public MY Commissl '' Dauphin County I Member, Pennsylvania Assoctatlor of Notaries 07/15/11 07/22/11 07/29/11 2011-3225 Civil TQrr^ Silver Spring Township Authority Vs Rollace E Heustesa+ Barbara A Heustesa Atty: Scott A Dietterick ALL TI i CF. RFMN Ln of an,, and the imptovements thcr.on ercc[e 1, s,tuate in the Village of Now Kingstown, Silver Spring Township. Cumberland G aunty Pennsylvania, bounded and dcsca ibed in a survey by Ernest ].Walker, PE dated September 26, 1979, as follows, t. l wit: BEGINNING at a point on the north side of U.S. Route it and lands row or formerly of Potteiger, said point being 40 feet West of an x-out in concrete on U.S. Route 11 and a right-of-way for drainage; thence South 85 degrees 52 minutes West (incorrectly referred to as South 65 degrees 52 minutes West in previous instruments of record), a distance of 40 feet to a point on U.S. Route I I and lands now m formerly of Frank Potteiger; thence along lands of said Potteiger, North 04 degrees 08 minutes West a distance of 160.20 feet to a wall of a frame garage; thence along said wall and lands of said Potteiger, South 85 degrees 52 minutes West 2.2 feet to a point; thence through a partition wall, North 03 degrees 30 minutes 0 seconds west, a distance of 29.79 feet to an iron pin at an unnamed alley; thence along said alley and rear of garage, North 85 degrees 52 minutes East, a distance of 30.5 feet to an x-out in concrete at other lands now or formerly of said Potteiger, thence along said lands now or formerly of Potteiger and through a partition wall, South 02 degrees 55 minutes 45 seconds East, a distance of 29.79 feet to a point; thence along said garage, North 85 degrees 52 minutes East, a distance of 12 feet to a point at other lands now or formerly of said Potteiger, thence along other lands now or formerly of said Potteiger; South 04 degrees 08 minutes East, a distance of 160.20 feet to the north side of U.S. Route 11, the place Of BEGINNING. BEING known as No. 78 West Main Street, formerly No. 78 West Carlisle Pike, New Kingstown, Pennsylvania 17072. BEING the same premises which Attna Thompson, as Executrix of the Estate of Thomas Edward Thompson, Deceased, by Deed d? red April 13, 2006, and recorded on April 18, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 274, Page 205, granted and conveyed unto Rollace E. Heustess and Barbara A. Heustess, Husband and Wife. Parcel No.: 38-19-1621-104