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Home My WebLink About11-8630IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 NO.: 11-7964 MLD Plaintiff, vs. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL #01-21-0271-405 Defendant. TO: DEFENDANT(S) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM S+VICE H OF OR A DEFAULT JUDGMENT MAY BE jjNTEREj5,AGAR,16T YOU. A I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 2145 Walnut Street Camp Hill, PA 17011 AND THE DEFENDANT(S): 15 Cumberland Road Lemoyne PA 43 ATTO E FOR AINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 2026 M ke tr et, Camp Hill, PA 17011 A EY O PL IN F NO.. 1 t_ ?p ?G TYPE OF PLEADING: CIVIL ACTION - WRIT OF SCIRE FACIAS FILED ON BEHALF OF: Camp Hill Borough, 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 01Xk %--&0uw 0 CC LL Ct'w 0".1 (P ?-i? aL? 340 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 _ Plaintiff, No.: 11-7964 MLD vs. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7964 MLD VS. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 ; Plaintiff, No.: 11-7964 MLD vs. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. Writ of Scire Facias in the amount of $6,449.24 /1 By: ___LV 1--' Scott A. Dietterick, 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 vs. Plaintiff, No.: 11-7964 MLD FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. : TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the By: ;/ \ [`? k , Scott A. DiZtterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 WRIT OF SCIRE FACIAS TO: FRED W. ZEPLIN WHEREAS, Camp Hill Borough, on October 19, 2011, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 11-7964 MLD, for the sum of $6,449.24, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Camp Hill Borough, said Claim filed against property owned by you in Camp Hill Borough located at 2026 Market Street, Camp Hill, PA 17011, 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 Book 35-Z Page 1120 Tax Parcel #01-21-0271-405, 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. (SEAL) a ` <R-, w %cL fi e- a-. 6V rte &, Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLANRgQ TY I'JOY 28 AM B: 42 CTIBERLANB CBU?,1 V, T PENNSYLVANIA Camp Hill Borough vs. Case Number Fred W. Zeplin 2011-8630 SHERIFF'S RETURN OF SERVICE 11/17/2011 08:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2011 at 2002 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Fred W. Zeplin, by making known unto himself personally, at 15 Cumberland Road, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $44.00 November 18, 2011 DENIMS FRY, DEPtOY SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 VS. Plaintiff, FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID#01-21-0271-405 Defendant. CIVIL DIVISION No.: 11-8630 CIVIL TERM No.: 11-7964 MLD TYPE OF PLEADING: C") ra ?' ao =M M = M- x' r -ors r CD CD zr ? <ca C-n >C:: c-n PRAECIPE FOR DEFAULT JUDGMENT (Municipal Lien) FILED ON BEHALF OF: Camp Hill Borough, Plaintiff I Hereby certify that the last known address of Defen t(s) is/are: 15 Cum r1a Ro d Lemo l 1704 ,Of 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 414.0o Pb Arry e* I o13'7 OpC20asy &ee "awl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff,, No.: 11-7964 MLD VS. No.: 11-8630 Civil FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. 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, Fred W. Zeplin, in the amount of $6,449.24, plus interest, penalties, and Quarterly bills after the 1" Quarter 2012, and additional attorneys' fees and costs reasonable and actually incurred. JAMES,_..S?M H, T?ERICK & CONNELL By: V Sco A. 'ettenc c, 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 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, a?denced by the attached copies. Scott A. Sworn to and subscribed before me this 28"' day of December, 2011. . S V?pC- NotaryPublic My Commission Expires: NOTARIAL SEA 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7964 MLD vs. No.: 11-8630 Civil FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: FRED W. ZEPLIN ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on -L?0-0- 30 12011. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $6,449.24 plus interest, penalties, and Quarterly bills after the 1St Quarter 2012, plus additional attorneys' fees and costs reasonable and actually incurred and fore osure sale of the P ises. onotary ???_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 CIVIL DIVISION Plaintiff, No.: 11-7964 MLD vs. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. IMPORTANT NOTICE TO: Fred W. Zeplin 15 Cumberland Road Lemoyne, PA 17043 DATE OF NOTICE: December 8, 2011 No.: I1-8630 Civil YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7964 MLD vs. No.: 11-8630 Civil FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. AVISO IMPORTANTE A. Fred W. Zeplin FECHA DEL AVISO: December 8, 2011 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENDS 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 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 DATE: December 8, 2011 JAMES SMITH D)NTTF%QK & CONNELLY LLP BY: FIRST CLASS U.S. MAIL, POSTAGE PREPAID Sco ie ei`i`ck, Esquire PA 1.0-455650 Kimberly A. Bonner, Esquire PA I.D. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?o?ytir ci' ?arrrt?irrd??rb Jody S Smith Chief Deputy Richard W Stewart Solicitor OFI tCE w)z Tt-, = ERIFF Camp Hill Borough Case Number vs. Fred W. Zeplin 2011-8630 SHERIFF'S RETURN OF SERVICE 11/17/2011 08:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2011 at 2002 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Fred W. Zeplin, by making known unto himself personally, at 15 Cumberland Road, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $44.00 November 18, 2011 DENT IS FRY, DEP Y SO ANSWERS, RON R ANDERSON, SHERIFF rc Cou"Suite Shenff. Teteasoft Irc. IN THE OOURr OF CO DN PLEAS OF CLMBERI.AND COUNTY, PENNSYLVANIA Camp Hill Borough CIVIL DIVISION z File No. 11-7964 MLD / 11-8630 Civil Term (Plaintiff) . Amount Due $ 6,449.24 v . Interest from 12-29-2011 to $ Fred W. Zeplin : pate I sf aCom Y (Defendant(s) TO THE PROTHONOTARY OF THE SAID COURT. . Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXEC[TIZON 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 L$e q defendant(s) RM See Exhibit "A" attached. :e =---o n;r= Vl• O PRAE7CIPE FOR ATTAC4MEW E BC SON Issue writ of attachment to the Sheriff of Cumberland County< fret debt interest and costs, as above, directing attachment against the above-named garnishee(s"f, 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) real estate of the defendant(s) described in the attached exh# DATE: December 28, 2011 O $d q. 00 p o ATTy 1q. 0o C5F 4?• 00 o1q . 00 " N.oo " A.5o It $13A.-p - Pb AYN X8.00 Sa+ Feel #4.oo Que Co 60 LL Signature: Print Name: lis pendens against Address: James Smith Dietterick & Connelly LLP P O Box 650, Hershey PA 17033 Attorney for: Telephone: Plaintiff (717) 533-3280 Supreme Court ID No.: 55650 ?# acs any ?E Gt?'`i*f-JI r LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the curb line of Market Street, which said point is references South Eighty-Seven (87) degrees Ten (10) minutes East, a distance of Twenty-Two and Seventy- Five One Hundredths (22.75) feet measured along the curb line of Market Street from the northeast corner of Market and North 21" Street; thence North Two (2) degrees Fifty (50) minutes East, in part along and through a partition wall between the property hereby conveyed and property known as 2028 Market Street, and also continuing along a wire fence at the rear of said property, a distance of One Hundred Twenty-Four (124) feet to a point on the southern side of a row of garages; thence along said garages, North Eighty-Four (84) degrees Twenty-Three (23) minutes Forty (40) seconds East, a distance of Three and Twenty-Five One Hundredths (3.25) feet to a point; thence North Six (6) degrees Fifty-Six (56) minutes West, through the partition or dividing line between the said garages, a distance of Twenty-Seven (27) feet to a point on the southern line of a Twelve (12) feet wide alley; thence along the southern line of said alley, North Eighty (80) degrees Nine (9) minutes East, a distance of Twenty-Six (26) feet to a point; thence along lands now or formerly of Harry Fry, known as 2024 Market Street, South Two (2) degrees Fifty (50) minutes West, a distance of One Hundred Fifty-Six and Eighty One Hundredths (156.80) feet to a point on the curb line of Market Street; and thence along the curb line of Market Street, North Eighty-Seven (87) degrees Ten (10) minutes West, a distance of Twenty-Four (24) feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known and numbered as 2026 Market Street, Camp Hill, Pennsylvania. BEING the same premises which Fred W. Zeplin and Elizabeth Sheely Zeplin, Husband and Wife, by Deed dated November 2, 1992, and recorded on November 25, 1992 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 35-Z, Page 1120, granted and conveyed unto Fred W. Zeplin. Parcel No.: 01-21-0271-405 Exhibit "A" --^ +. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7964 MLD vs. c°s N a ?i No.: 11-8630 CiV4 -+ FRED W. ZEPLIN zm rn - 2026 MARKET STREET am CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 <c7 -? Defendant. z4 -, 1 AFFIDAVIT PURSUANT TO RULE 3129 ° . . ? Camp Hill Borough, 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 2026 Market Street, Camp Hill, Pennsylvania 17011: 1. Name and Address of Owner(s) or Reputed Owner(s): FRED W. ZEPLIN 15 Cumberland Road Lemoyne, PA 17043 Name and Address of Defendant(s) in the Judgment: 2. FRED W. ZEPLIN 15 Cumberland Road Lemoyne, PA 17043 Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: 3. CAMP HILL BOROUGH FIA CARD SERVICES, N.A. 2145 Walnut Street Camp Hill, PA 17011 Apothaker & Associates, PC 520 Fellowship Road, C-306 Mt Laurel, NJ 08054 Name and Address of the last record holder of every mortgage of record: 4. 5 6 7 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 FRED W. ZEPLIN Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 2026 Market Street Camp Hill, PA 17011 15 Cumberland Road Lemoyne, PA 17043 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 unworn falsification to authorities. DATED: December 28, 2011 JAMES, SMITH, DIET E & CONNELLY, L BY: c I-- I Scott A. Dietterick, Esq ire 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 CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET : CAMP HILL, PA 17011 : Plaintiff, No.: 11-7964 MLD VS. No.: 11-8630 Civil FRED W. ZEPLIN .. 2026 MARKET STREET rnC0 m v rn =-,; CAMP HILL, PA 17011 x c -) -am PARCEL ID #01-21-0271-405 <T W C) Defendant. r- =--n y,c °`-? NOTICE OF SHERIFF'S SALE -< C> = OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Fred W. Zeplin 15 Cumberland Road Lemoyne, PA 17043 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, June 6, 2012, 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: 2026 Market Street Camp Hill, Pennsylvania 17011 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8630 Civil Term No. 11-7964 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Fred W. Zeplin 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 & COIN DATED: December 28, 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 lot or tract of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the curb line of Market Street, which said point is references South Eighty-Seven (87) degrees Ten (10) minutes East, a distance of Twenty-Two and Seventy- Five One Hundredths (22.75) feet measured along the curb line of Market Street from the northeast corner of Market and North 21" Street; thence North Two (2) degrees Fifty (50) minutes East, in part along and through a partition wall between the property hereby conveyed and property known as 2028 Market Street, and also continuing along a wire fence at the rear of said property, a distance of One Hundred Twenty-Four (124) feet to a point on the southern side of a row of garages; thence along said garages, North Eighty-Four (84) degrees Twenty-Three (23) minutes Forty (40) seconds East, a distance of Three and Twenty-Five One Hundredths (3.25) feet to a point; thence North Six (6) degrees Fifty-Six (56) minutes West, through the partition or dividing line between the said garages, a distance of Twenty-Seven (;27) feet to a point on the southern line of a Twelve (12) feet wide alley; thence along the southern line of said alley, North Eighty (80) degrees Nine (9) minutes East, a distance of Twenty-Six (26) feet to a point; thence along lands now or formerly of Harry Fry, known as 2024 Market Street, South Two (2) degrees Fifty (50) minutes West, a distance of One Hundred Fifty-Six and Eighty One Hundredths (156.80) feet to a point on the curb line of Market Street; and thence along the curb line of Market Street, North Eighty-Seven (87) degrees Ten (10) minutes West, a distance of Twenty-Four (24) feet to a point, the place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known and numbered as 2026 Market Street, Camp Hill, Pennsylvania. BEING the same premises which Fred W. Zeplin and Elizabeth SheelyZeplin, Husband and Wife, by Deed dated November 2, 1992, and recorded on November 25, 1992 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 35-Z, Page 1120, granted and conveyed unto Fred W. Zeplin. Parcel No.: 01-21-0271-405 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8630 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAMP HILL BOROUGH, Plaintiff (s) From FRED W. ZEPLIN (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: $6,449.24 Interest from 12/29/11 to date of sale Atty's Comm: % Atty Paid: $132.50 Plaintiff Paid: Date: 12/30/11 (Seal) L.L.: $.50 Due Prothy: $4.00 Other Costs: $8.00 Satisfaction Fee David . uell, ;Prot By: Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP PO BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 CD c j- .• f - V7 ^- C7 -TI IN THE COURT OF COMMON PLEAS OF r,' CUMBERLAND COUNTY, PENNSYLVANIA r CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, : No.: 11-7964 MLD VS. : No.: 11-8630 Civil FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Defendant. PRAECIPE TO SATISFY MUNICIPAL LIEN TO THE PROTHONOTARY: SWMADAM: Please mark the Municipal Lien filed at the above - captioned term and number satisfied. By: ?Vot iett , Esquire Atto ey for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 anll? ?q.Sapd ct IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 vs. FRED W. ZEPLIN 2026 MARKET STREET CAMP HILL, PA 17011 PARCEL ID #01-21-0271-405 Plaintiff, No.: 11-7964 MLD No.: 11-8630 Civil 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 16`h day of February, 2012, via First Class U. S. Mail, Postage Pre-paid: Fred W. Zeplin 15 Cumberland Road Lemoyne, PA 17043 Respectfully Submitted: JAMES, SMITO, I)t By: Sc t Die 'crf Esquire tto y I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY, LLP