Loading...
HomeMy WebLinkAbout11-5100McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 Attorneys for Plaintiff C H _ t J"O 41 JrJ14 21 AN If": 2 C.UMBr.R' AND G,`]U0 Y PENNSYI.VM IP; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, LLC Plaintiff, v. FRANK Z. AUNGST AKA FRANK D. AUNGST or Occupants 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 Defendants NO. I (- SI oU ci 0 I CIVIL ACTION - EJECTMENT NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. a,4* %R2.ad ? ab I C-l?- 0101Y 7 A0 F99 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 34 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las 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 propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 34 South Bedford Street Carlisle, PA 17013 (717) 249-3166 2 McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, LLC NO. Plaintiff, V. CIVIL ACTION - EJECTMENT FRANK Z. AUNGST AKA FRANK D. AUNGST or Occupants : 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 Defendants CIVIL ACTION - EJECTMENT Plaintiff, Sam Hill Properties, LLC, by and through its counsel, McCarthy Weisberg Cummings, P.C., hereby files the following Civil Action - Ejectment (hereinafter "Complaint") asserting a claim against the Defendants set forth herein, as follows: 1. Plaintiff Sam Hill Properties, LLC is a Pennsylvania limited liability company with a business address of 721 Sam Hill Lane, Dauphin, Dauphin County, Pennsylvania 17018. 2. Defendants are Frank Z. Aungst AKA Frank D. Aungst and/or Occupants currently residing at 1806 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff is the legal owner of the premises located at 1806 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011, a legal description of which is attached hereto and marked as "Exhibit A". 4. Plaintiff became the owner of said premises as a result of a sale by the Tax Claim Bureau of Cumberland County, Pennsylvania on September 16, 2010, as evidenced by the Tax Claim Bureau Deed dated November 19, 2010, and recorded November 19, 2010, in the Office of the Recorder of Deeds of Cumberland County as Instrument No. 201033973, a true and correct copy of which is attached hereto and marked as "Exhibit B". 5. Plaintiff, by virtue of the above, is the record owner of said premises, and is entitled to possession thereof. The Defendants are occupying said premises without right and so far as Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said Defendants, who have refused to deliver up possession of same. 2 WHEREFORE, Plaintiff Sam Hill Properties, LLC seeks to recover possession of said premises. Date Respectfully submitted, McCarthy Weisberg Cummings, P.C. Larry A. Weisberg, Esq. (PA ID 83410) Derrek W. Cummings, Esq. (PA ID 83286) 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 (717) 233-8133 (FAX) Attorneys for Plaintiff 3 E?Nlfy?? ?a Appendix "A" Tax Parcel No. 13-23-0547-210 Legal Description ALL that certain piece or parcel of land situated in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Westerly side of Letchworth Drive, fifty feet wide at the distance of nine hundred ninety-nine and forty-eight one hundredths feet, measured Nouthwardly Northeastwardly and EuN mdly along the Westerly Northwesterly Northerly and Easterly side of Letchworth Drive from the Southernmost terminus of a radial round comer to the Easterly side of Letchworth Drive with the Southeasterly side of Kent Drive fifty feet wide, said point of beginning also being a comer of Lots Nos 25 and 26 on Block "D" on the hereinafter mentioned Plan; thence extending Westwardly one hundred forty-four and thirty-eight one hundredths feet to a point; thence extending Northwardly sixty and four one hundredths feet to a point; thence extending Estwardly one hundred forty-four and twenty-one hundredths feet to the Westerly side of Letchworth Drive; thence extending Southwardly along the Westerly side of Letchworth Drive, sixty feet to the fust mentioned point and the place of BEGINNING, being Lot No. 26 in Block "D" on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registered Surveyor, dated May 4, 1950, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Plan Book 4, Page 100&c and having erected thereon buildings and improvements. BEING the same premises which Donald L. August and Joann H. August, his wife, conveyed to Frank Z. Aunust, by deed dated August 17, 2007 and recorded in the Cumberland County Recorder of Deeds Office as instrument number 200732498. ?i` 33973 UPSET PRICE SALE 13-073- C!s+i7-alC mill 0013YK Tax (flout Murratt %hiS PPBl} Made this ...............19 th.............. day of Na ram ber 20....... 10 between the TAX CLAIM BUREAU, of the County of Cumberland, Pennsylvania, as Trustee, San Hitl Properties LLC GRANTOR, and ........................................ ..................................................................... .................................................... Grantee A1fnais elh, that in consideration of ;...... !?..,, in hand paid, receipt whereof is hereby acknowledged, the said Grantor does hereby grant and convey unto the said Grantee, .....h° heirs and assigns, the certain premises situate in Cumberland County, Pennsylvania, as follows: Owner or reputed owner as returned to said Bureau Lower Allen Township 18% Letchworth Drive tax panel 813-23-0547-210 see Appendix A for Legal Description Frank Z. Anna AKA Frank D. Aungst 1806 Letchworth Drive Camp Hilt, PA 17011 the same having been sold by the Tax Claim Bureau to the said grantee, on the ............ 16-t. .................. day t of .......... .... g4.p.+110W................ Anno Domini two thousand and ...........2010 after due advertisement according to law, the period of redemption for the payment of tax claims having expired without the property having been redeemed, or any tax judgements heretofore having been entered against the described property having not been satisfied, or no agreement to stay the sale of the within described property having been entered into, or the within described real estate no longer remaining in possession of a sequestrator, by Upset Price Sale. under and by virtue of the Act of 1947 PL 1368 (Real Estate Tax Sale Law), (311 Xftt88 94trtd, said Grantor has hereunto caused this Deed to be executed by its Director the day and year first above written. Signed. Sealed and Delivered in the presence of: COWWONWEALTH OF PL•'NNSYI.VANIA COUNTY OF CUMBERLAND TAX CLAIM BUREAU OF CUMBERL TY, PENNSYLVANIA, R ST By ....... (SEAL) to ?ss On this, the ....... -1 ............ . day of before me. the Prothonotary of the County of Cumberland. the i ersigned officer, personally appeared Melissa F. Mixed "'"""*"'• °"' -•• •••• ••••••••••••••••• ............. Director of the Tax Claim Bureau of the Countv of Cumberland. Cot tipat"JI*?f Pennsylvania, known to me to be the person described in the foregoing instrument ant! is leaj?Ipt poses therein. t? t he executed the same in the capacity therein stated and for the pur- w rt 58. ''.have hereunto sin er hand and official seal. t,'? ` ; `?`(Certtftrttir of aesibrart hereby EerYiC_#at •tile- -.rO se residence of the grantee herein is as follows: ................. ............... Sam Hill! Proparrrdes 11?C.t, 721 Sam HiB Lane, Dauphin t PA 17018 _ ..... ................................................................................... ...... . . . .........Q ...... S phen D. Tiley Cumberland Cou ty, Assistant Solicitor Appendix "A" Tax Parcel No. 13-23-0547-210 Legal Description ALL that certain piece or parcel of land situated in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Westerly side of Letchworth Drive, fifty feet wide at the distance of nine hundred ninety-nine and forty-eight one hundredths feet, measured Northwardly Northeastwardly and Esswardly along the Westerly Northwesterly Northerly and Easterly side of Letchworth Drive from the Southernmost terminus of a radial round corner to the Easterly side of Letchworth Drive with the Southeasterly side of Kent Drive fifty feet wide, said point of beginning also being a comer of Lots Nos. 25 and 26 on Block "D" on the hereinafter mentioned Plan; thence extending Westwardly one hundred forty-four and thirty-eight one hundredths feet to a point; thence extending Northwardly sixty and four one hundredths feet to a point; thence extending Eastwatdly one hundred forty-four and twenty-one hundredths feet to the Westerly side of Letchworth Drive; thence extending Southwardly along the Westerly side of Letchworth Drive, sixty feet to the fast mentioned point and the place of BEGINNING, being Lot No. 26 in Block "D" on Plan No. 5 of Highland Estates Development, made by D.P. Rafl'ensperger, Registered Surveyor, dated May 4, 1950, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Plan Book 4, Page 100&c, and having erected thereon buildings and improvements. BEING the same premises which Donald L. Aungst and Joann H. Aungst, his wife, conveyed to Frank Z. Aungst, by deed dated August 17, 2007 and recorded in the Cumberland County Recorder of Deeds Office as instrument number 200732498. REV tea EX (ti.ocl 4W COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE StNtEAU OF e1DIVDUAL TAXES PO BOX 2tIM REALTY TRANSFER TAX STATEMENT OF VALUE See Reverse for Instructions RECORDER'S USE ONLY, State Tax Pad - - t / --- Book Number J /?/? } ?t0 G? ?f Pape Number '?o?rQ°"? 1 .1?-- Data RIWX ded _ _ Complete each section and fife in dupNcate with Recorder of Deeds when (1) the M vaiuefoonpderation is not set forth in the deed. (2) wren the deed is witlaut consideration, or by gift, or (3) a tax exemption is claimed. A Statement of Wlue is not required N the transfer is wholly exempt from tax based on: (1) family relationship or (2) public utility easement. If more space is needed, attach additional sheet(s). A, CORRESPCMIDEW - All in uirles m be directed Name to the foilotivin person: Melissa F. Mixell Telephone M-mb r tiw- d??ss c ry --V 7 ) 240-6366 One Courthouse Square Carlisle np code R_ TDAUCCeo r%Ava PA 7013 Grantw(syLe"or(s) Frank Z Aungst AKA Frank D Aungst StreetAdNress - -- 1806 Letchworth Drive Zip C Camp Hill [P-AiO6 7011 1. Actual cash Consideration $2,000.00 4. courny assessed Value - - $102,850.0 Street Address 1806 Letchworth Drive caaoy---.. ---. -- Cumberland County A VAS 1 uwi.a....... 1a. Ammord of Exemption Claimed 13_73..nA,A7_7An 2. Other consideration + 0.00 K common Level Repo Factor X 1.25 I b. Percentage of IrAereW Caweyed 3. Total Consideration = $2,000.00 6. Feir h%rRef value -- 2. Check Appropriate Box Below for Exemption Claimed ? Will or intestate succession _ (Name of Decedent) - -_ ? Transfer to Industrial Development Agency. (Estate File Number) ? Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ? Transfer between principal and agent. (Attach complete copy of agency/straw party agreement.) ? Transfers to the Commonwealth, the United States and Instrumentalitles by gift, dedication, condemnation or in lieu of condemnation. (If condemnation or In lieu of ?ndernnatlon, attach copy of resolution.) ? Transfer from mortgagor to a holder of a mortgage in default. Mortgage Book Number , Page Number ? Corrective or confimmatory deed. (Attach complete copy of the prior deed being corrected or confirmed.) ? Statutory corporate consolidation, merger or division. (Attach copy of articles.) ? Other (Please explain exemption claimed, if other than listed above.) ermm" III" nd I Signer of nderd or LU OMPLET THE RE Im-ro Q oee Grentee(syLsseee(s) ---- -- ----.••_••• Sam Hill Properties LLC Street Address -- 721 Sam Hill Lane city - -- S1 p Code - Dauphin IPA 17640 wry, 10'WrISMI), Borough _ Lower Allen Township -- Tax Pater u?.?r, West Shore that I have examined this Statement, Including accompanying InfiormnUon, and to the best it 1s vu% correct and complete. 70 F RM PROPERLY OR ATTACH APPLICABLE DOCUMENTATION MAY RESULT IN SAL RECORD THE DEED. ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201033973 Recorded On 11/19/2010 At 3:44:22 PM * Instrument Type - DEED Invoice Number - 77080 User ID - KW * Grantor - AUNGST, FRAM{ D *Grantee -SAM EM -1 PROPERTIES LLC * Customer - TAX CLAIM * FEES STATE TRANSFER TAX $1,285.63 STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 BEST SHORE SCHOOL $642.82 DISTRICT LONER ALLEN TOWNSHIP $642.81 TOTAL PAID $2,634.26 * Total Pages - 4 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER p " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. I VERIFICATION I, Michael David Morris, verify that I am president of Sam Hill Properties, LLC, the Plaintiff in the foregoing Complaint and that the facts set forth therein are true and correct to the best of my knowledge, information, and belief; and that this verification is subject to the penalties of 18 Pa.C.S. § 4904 relative to unsworn falsification to authorities. ?- ??. Dated. , 2011 ??"?? Michael David Morris 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?? ?-???- ?O?.NO????,? ????tu ?t?rari6crf? Jody S Smith Chief Deputy 2011 JUN 24 AM 9; 21 Richard W Stewart Solicitor OFF CUMBERLAND COUNTY PENNSYLVANIA Sam Hill Properties, LLC Case Number vs. Frank D Aungst 2011-5100 SHERIFF'S RETURN OF SERVICE 06/23/2011 07:01 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2011 at 1901 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Frank D. Aungst, by making known unto himself personally, at 1806 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. A T ALL, DlEkZY, SHERIFF COST: $43.44 June 27, 2011 SO ANSWERS, RON + R ANDERSON, SHERIFF .?; CounigS!aite Sheri?7. ie?ecsoff_ 0?r.. THE PROTH qlo , f Counsel for the Plaintiff McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 P i AUG -4 AH ! I : UMBE??LAf?1tJ ?;?f?l?!» ?? PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, I.LC Plaintiff, v. FRANK Z. AUNGST AKA FRANK D. AUNGST or Occupants 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 Defendants NO. 11-5100 Civil CIVIL ACTION - EJECTMENT PRAECIPE FOR ENTRY OF JUDGMENT OF DEFA ULT To the Prothonotary: Please enter a judgment of default in favor of Plaintiff and against Defendant Frank Z. Aungst AKA Frank. D. Aungst or Occupants for Defendant's failure to plead to the complaint in this action within the required time. The complaint contained a notice to defend within 20 days from the date of service thereof. Defendant was served with the complaint on June 23, 2011, and Defendant's answer was due to be filed on July 13, 2011. Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File a Praecipe for Entry of Default Judgment, which I certify was mailed to the Defendant by First Class Mail ?w ?iy,oof?l a4 I??hce dV1a?IP? Counsel for the Plaintiff McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 at his last known address on July 14, 2011, which is at least 10 days prior to the filing of this Praecipe. Defendant Frank Z. Aungst AKA Frank D. Aungst does not have an attorney of record in this matter. Date Respectfully submitted, McCARTHY WEISBERG CUMMINGS, P.C. By: Larry A. Weisberg, Esquire Sup. Ct. I.D. #83410 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 Counsel for the Plaintiff McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Praecipe for Entry of Judgment of Default upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, first-class postage prepaid, addressed as follows: FRANK Z. AUNGST AKA FRANK D. AUNGST or Occupants 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 pro se Defendant Date McCarthy Weisberg Cummings, P.C. Larry A. Weisberg, Esq. Sup. Ct. I.D. #83410 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 (717) 233-8133 (FAX) Attorney for Plaintiff Counsel for the Plaintiff McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, LLC NO. 11-5100 Civil Plaintiff, V. FRANK Z. AUNGST AKA FRANK D. AUNGST or Occupants 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 Defendants CIVIL ACTION - EJECTMENT IMPORTANT NOTICE To: Frank Z. Aungst AKA Frank D. Aungst or Occupants 1806 Letchworth Drive Camp Hill, PA 17011 Date of Notice: July 14, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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. ?"/, H(6)-? A Counsel for the Plaintiff McCarthy Weisberg Cummings, P.C. 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 34 South Bedford Street Carlisle, PA 17013 (717) 249-3166 i'- H:1) By; Date Larry A. Weisberg, Esquire Sup. Ct. I.D. #83410 2041 Herr Street Harrisburg, PA 17103-1624 (717) 238-5707 (717) 233-8133 (FAX) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Sam Hill Properties, LLC File No. 11-5100 Civil COSTS (to be completed by Prothonotary) Pltf. Paid Deft. Paid Vs. Frank Z. Aungst AKA Frank D. Aungst or Due Prothonotary Occupants Other Costs -ox = ---q - =M z c? r M y CD PRAECIPE FOR WRIT OF POSSESSION -<X =° TO THE PROTHONOTARY OF SAID COURT: =p S - ? (Check appropriate block) ?c l ® Issue writ of possession in the above captioned case and direct Sheriff to deliver possession of the following property to the plaintiff(s). ? To satisfy the costs against the defendant(s), direct Sheriff to levy upon the interest of the defendants(s) in the following described property and to sell the same: ? Personal Property as follows: ® Real Estate as per attached description Date: 08/0412011 X?4 say. ao ?d c 4 3.yy CAF qa. oo it I l 4. oo U if 1-03.41 P1 Q•1? Signature: Print Name: Address Attorney for: Telephone: zoz?? Larry A. Weisberg 2041 Herr St., Harrisburg, PA 17103 Plaintiff Sam Hill Properties, LLC 17) 238-5707 Supreme Court ID No. 83410 ?a.00 lbte & WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO THE SHERIFF OF SAID COUNTY: ® To satisfy the judgment for pas ession in the above plaintiff(s) possession of the abovecribed property. ® To satisfy the costs against the defen nt(s), defendant(s) and sell the defendant(s)' inte st t Date ,,*%:)y.t° Pd aol cj:, IL 14 83 V. V* Flo IJITK case, you are directed to deliver the directed to levy upon any property of the Deputy Prothon. - 30 (8-97) Appendix "A" Tax Parcel No. 13-23-0547-2I0 Legal Description ALL that certain piece or parcel of land situated in the Township o4Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described !as follows, to wit: BEGINNING at a point on the Westerly side of Letchworth Drive, fifty feet wide at the distance of nine hundred ninety-nine and forty-eight one hundredths f?t, measured Northwardly Nordwastwardly and Estwardly along the Westerly Northwesterly Northerly and Easterly side of Letchworth Drive ftom the Soil 9nentmoat terminus of a radial round comer to the Easterly side of Letchworth Drive with the Southeasterly side of Kent Drive fifty feet wide, said point of beginning also being a comer of Lots Nos. 25 and 26 on Block `D" on the hereinafter mentioned Plan; thence extending Westwardly one hundred forty-four and thirty-eight one hundredths feet to a point; thence extending Northwardly sixty and four one hundredths feet to a point; thence extending Eastaardly one hundred forty-four and twenty-one hundredths feet to the Westerly side of Letchworth Drive; thence extending Southwardly along the Westerly side of Letchworth Drive, sixty feet to the fiist mentioned point and the place of BEGINNING, being Lot No. 26 in Block `D" on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registcred Surveyor, dated May 4, 1950, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Plan Book 4, Page 100&c, and having erected thereon buildings and improvements. BEING the same premises which Donald L. Aungst and Joann H. Aungst, his wife, conveyed to Frank Z. Aungst, by deed dated August 17, 2007 and recorded in the Cumberland County Recorder of Deeds Office as instrument number 200732498. 6,\I- w16) Y "' A ,. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, LLC VS. No. 11-5100 Civil Term- FRANK Z. AUNGST AKA FRANK D. AUNGST OR OCCUPANTS 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 Costs Attorney's $ 173.44 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (I) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) SAM HILL PROPERTIES, LLC being: (Premises as follows): 1806 LETCHWORTH DRIVE, CAMP HILL, PA 17011 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA Date AUGUST 4.2011 (Seal) 2 of 2 No 11-5100 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAM HILL PROPERTIES, LLC VS. FRANK Z. AUNGST AKA FRANK D. AUNGST OR OCCUPANTS 1806 LETCHWORTH DRIVE CAMP HILL, PA 17011 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 173.44 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: LARRY A. WEISBERG, ESQUIRE 2041 HERR STREET HARRISBURG, PA 17103 717-238-5707 ID # 83410 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of I caused the within named to have possession of the premises described with the appurtenances, and So Answers, Sworn and subscribed to before me this Day of , Prothonotary Sheriff By Deputy SHERIFF'S OFFFCE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff C Z -, Jody S Smith a t Chief Deputy Richard W Stewart ° Solicitor c,Fs s t3 C--; Sam Hill Properties, LLC Case Number vs. Frank Z Aungst 2011-5100 SHERIFF'S RETURN OF SERVICE 08/16/2011 07:51 PM - Deputy Michael Barrick, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Frank Z Aungst at 1806 Letchworth Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 08/16/2011 07:51 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that he served a true copy of the within Writ of Possession, upon the within named defendant, to wit: Occupant, by making known unto Frank Aungst, adult in charge, at 1806 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09/08/2011 By virtue of this writ, on the 7th day of September, 2011, Sheriff Ronny R. Anderson caused the within named Sam Hill Properties, LLC, to have possession of the premises described as 1806 Letchworth Drive, Camp Hill, PA 17011. SHERIFF COST: $100.00 September 08, 2011 SO ANSWERS, RON ' R ANDERSON, SHERIFF C Gow ,-ySlite Shentf. I.,,ieaso'1. I,1;;.