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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA '
CAMP HILL BOROUGH CIVIL DIVISION ' ?
2145 WALNUT STREET
CAMP HILL, PA 17011 NO.: 11-7968 MLD `n
Plaintiff NO _
?'
7rD --T
, .
VS. y .,
FRED W. ZEPLIN TYPE OF PLEADING:
2028 MARKET STREET & 7 N. 21ST STREET CIVIL ACTION - WRIT
CAMP HILL, PA 17011 OF SCIRE FACIAS
PARCEL #01-21-0271-404
Defendant.
FILED ON BEHALF OF:
TO: DEFENDANT(s)
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED WRIT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT
MAY BE RED ST YOU.
ATTORf4 EY R PLAINT F
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
2145 Walnut Street
Camp Hill, PA 17011
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
AND THE DEFENDANT(S):
15 Cumberland Road
Lemoyne, #A 1;743
ATTORNf rff)"LAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
2028 Mar t re 7 N. 21" Street, Camp Hill, PA 17011
ATTO PLA
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 sT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
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
2028 Market Street a/k/a 7 N. 21St 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
2. Name and Address of Defendant(s) in the Judgment:
FRED W. ZEPLIN 15 Cumberland Road
Lemoyne, PA 17043
3. Name and Address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
CAMP HILL BOROUGH 2145 Walnut Street
Camp Hill, PA 17011
FIA CARD SERVICES, N.A. Apothaker & Associates, PC
520 Fellowship Road, C-306
Mt Laurel, NJ 08054
4. Name and Address of the last record holder of every mortgage of record:
5.
6.
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
CURRENT OCCUPANTS/TENANTS
UNKNOWN SPOUSE OF FRED W. ZEPLIN
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
2028 Market Street
Camp Hill, PA 17011
7 N. 21St Street
Camp Hill, PA 17011
15 Cumberland Road
Lemoyne, PA 17043
7. Name and Address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities.
DATED: December 28.2011
JAMES, SMI'
& CONNELL
BY: _ - k' z z:, r- -
Scott A. D'' erI , Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
• V
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011 :
Plaintiff, No.: 11-7968 MLD
vs.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 ST STREET
CAMP HILL, PA 17011 :
PARCEL ID #01-21-0271-404
Defendant.
NOTICE OF SHERIFF'S SALE
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:
2028 Market Street
a/k/a 7 N. 21St Street
Camp Hill, Pennsylvania 17011
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8631 Civil Term No. 11-7968 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.
DATED: December 28, 2011
JAMES, SMITH, D
& CONNELLY, LI,
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, County
of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to
wit:
BEGINNING at a point on the northern line of Northern line of Market Street which
point is in the line which is a division in the northerly direction of the partition wall of Nos. 2026
and 2028 Market Street, Camp Hill; thence North 7 degrees 58 minutes East by the partition wall
between the aforesaid two houses and by a fence in the rear of the said two houses 115.66 feet to
the southerly side of a row of garages; thence North 86 degrees 56 minutes East a distance of
3.25 feet to the dividing line between the most easterly garage of the said row of garages and the
garage adjoining it immediately to the west; thence North 1 degree 22 minutes West and by the
dividing line between the aforesaid two garages a distance of 29.41 feet to the southerly line of a
public alley; thence South 83 degrees 48 minutes West and along the southern line of a public
alley 55.20 feet to a point on the eastern line of North 21 St Street; thence South 6 degrees 0
minutes East and along the eastern line of North 21St Street 135.39 feet to a point the northern
line of Market Street; thence South 81 degrees 14 minutes East and along the Northern line of
Market Street a distance of 22.71 feet to a point, the place of BEGINNING.
HAVING thereon erected a two and one-half story frame dwelling known as and
numbered as 2028 Market Street a/k/a 7 N. 21 St Street, Camp Hill, a one story brick and frame
building and frame garages on the rear of said premises.
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 1116,
granted and conveyed unto Fred W. Zeplin.
Parcel No.: 01-21-0271-404
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8631 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: $6,630.84 L.L.: $.50
Interest from 12/29/11 to date of sale
Atty's Comm: % Due Prothy: $4.00
Atty Paid: $132.50 Other Costs: Satisfaction Fee - $8.00
Plaintiff Paid:
Date: 11230/11.
David D. Buell, Prothonota!y
('peal)
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
IN THE COURT OF CCmoN PLEAS OF C'LMIiau Am cawry, PBWMVANIA
CIVIL DIVISION
Camp Hill Borough
File No. 11-7968 MLD / 11-8631 Civil Term
(Plaintiff) Amount Due 6,630.84
v : Interest from 12-29-2011 to
r
$
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Fred W. Zeplin : At ty' s = --4
Costs =m M rn -,,r-
(Defendant(s)
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TO THE PROTHONOTARY OF THE SAID COURT: <>
rU CMO C)
3> c-) :X
The undersigned hereby certifies that the below does not arise out of a ai?y X-
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installment sale, contract, or account based on a confession of judgment, but' i?do,
it-is based on the appropriate original proceeding filed pursuant to Act 7 of I?166cas -:?D
-
amended; and for real property pursuant to Act 6 of 1974 as amended. <
PRAECIPE FOR EXECUTION
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.
PRAE7CIPE FOR ATTACHMENT LION
Issue writ of attachment to the Sheriff of Cumberland County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishees as a lis pendens against
real, estate of the defendant(s) described in the attached 3.t.
DATF, December 28, 2011 Signature:
r- Print Name, Scott A. Dietterick, Esquire
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Address: James Smith Dietterick & Connelly LLP
P O Box 650, Hershey PA 17033
Attorney for:
48 co = FM Telephone :
Plaintiff
(717) 533-3280
It. 50 LL Supreme Court ID No. 55650
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LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Borough of Camp Hill, County
of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to
wit:
BEGINNING at a point on the northern line of Northern line of Market Street which
point is in the line which is a division in the northerly direction of the partition wall of Nos. 2026
and 2028 Market Street, Camp Hill; thence North 7 degrees 58 minutes East by the partition wall
between the aforesaid two houses and by a fence in the rear of the said two houses 115.66 feet to
the southerly side of a row of garages; thence North 86 degrees 56 minutes East a distance of
3.25 feet to the dividing line between the most easterly garage of the said row of garages and the
garage adjoining it immediately to the west; thence North 1 degree 22 minutes West and by the
dividing line between the aforesaid two garages a distance of 29.41 feet to the southerly line of a
public alley; thence South 83 degrees 48 minutes West and along the southern line of a public
alley 55.20 feet to a point on the eastern line of North 21St Street; thence South 6 degrees 0
minutes East and along the eastern line of North 21St Street 135.39 feet to a point the northern
line of Market Street; thence South 81 degrees 14 minutes East and along the Northern line of
Market Street a distance of 22.71 feet to a point, the place of BEGINNING.
HAVING thereon erected a two and one-half story frame dwelling known as and
numbered as 2028 Market Street a/k/a 7 N. 21St Street, Camp Hill, a one story brick and frame
building and frame garages on the rear of said premises.
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 1116,
granted and conveyed unto Fred W. Zeplin.
Parcel No.: 01-21-0271-404
Exhibit "A"
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.: 11-8631 CIVIL TERM
No.: 11-7968 MLD
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TYPE OF PLEADING:
FRED W. ZEPLIN
2028 MARKET STREET &
7 N. 21 ST STREET
CAMP HILL, PA 17011
PARCEL ID#O l -21-0271-404
Defendant.
I Hereby certify that the last known
address of Defendant(s) is/are:
15 Cumberland Road
Lemoyne, V11?Q43
PRAECIPE FOR DEFAULT JUDGMENT
(Municipal Lien)
FILED ON BEHALF OF:
Camp Hill Borough,
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
414.OD PO A17Y
C*-ID 13`{
a&9a4q
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff,
VS.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21sT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant.
No.: 11-7968 MLD
No.: 11-8631 Civil
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 $6,630.84, plus interest, penalties, and
Quarterly bills after the 1St Quarter 2012, and additional attorneys' fees and costs reasonable and
actually incurred.
JAMES, SMITH, DIETTERICK &
CONNELLY, L
By:
Scott A. Diettenck, squir
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. 27.1, as evidenced by the attached copies.
Scott A. D*tterick, Esquire
Sworn to and subscribed before me
this 281h day of December, 2011.
? rU S L. i
Notary Public
My Commission Expires:
F OTARIAL SEAL
TINE L SPURLOCK
Notary Public
N BORO, DAUPHIN COUNTY
ion 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.: 11-7968 MLD
VS.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21sT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
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 ?)PC. 30'x' 92011.
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $6,630.84
plus interest, penalties, and Quarterly bills after the 1St Quarter 2012, plus additional attorneys'
fees and costs reasonable and actually incurred and for oreclosure and sale of the Pr es.
t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 ST STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant.
IMPORTANT NOTICE
TO: Fred W. Zeplin
15 Cumberland Road
Lemoyne, PA 17043
DATE OF NOTICE: December 8, 2011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 ST STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
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 MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED 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 [j
JAMESrN,SNVTH PIETTE RICK & CONNELLY LLP
DATE: December 8, 2011 BY: _
co A. Dietterick, Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
01 ClIft 1017 1116
OFFiC= iF'. _ RIFF
Camp Hill Borough
vs. Case Number
.
Fred W. Zeplin 2011-8631
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 Complaint and Notice, 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.
DENNI FRY, DEPUTY
SHERIFF COST: $44.00
November 18, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
IC '.CIIIfifSJllC.Sner,ff, TeIeCSO`(. I;::.
. S
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 IT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
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.: 11-7968 MLD
vs.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21" STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
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
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LISTED 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
t '.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 ST STREET :
CAMP HILL, PA 17011 ;
PARCEL ID #01-21-0271-404
Defendant.
PRAECIPE TO ISSUE
WRIT OF SCIRE FACIAS
TO: PROTHONOTARY
SIR/MADAM: Please issue a Writ of Scire Facias in thf
Writ of Scire Facias in the amount of $6,630.
By:
Scott A. Dlb-hwiGk-,?E
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
i l
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILI, BOROUGH CIVIL DIVISION
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
VS.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 ST STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant. :
TO: PROTHONOTARY
SIR/MADAM: Please issue a Writ of Scire Facias in the abovacaptionW Matter.
By: J \1<?t`
ScottA. Di'dtterick, Esquire
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
l .
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. 11-7968 MLD, for the sum of
$6,630.84, 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 2028 Market Street & 7 N. 21St 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 1116 Tax Parcel
#01-21-0271-404, 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)
1-
&D Sad- /tee
a. a z.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY-,-
Ronny -?'FF'?C?:.
R Anderson
Sheriffrtti, oC ?an?urr-?
Jody S Smith NOV 28 414 oo.- t I
Chief Deputy CUPMF-Rr At4D Cou 7 ",.
Richard W Stewart PERUCYLVANIA
Solicitor
Camp Hill Borough Case Number
vs.
Fred W. Zeplin 2011-8631
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 Complaint and Notice, 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.
DENNI FRY, DEPUTY
SHERIFF COST: $44.00
November 18, 2011
SO ANSWERS,
RON ? R ANDERSON, SHERIFF
ic!
.. 0-
IN THE COURT OF COMMON PLEAS OF 2012 FER 17 FM 2:50
CUMBERLAND COUNTY, PENNSYLVANIA l'MBERLAND COUNTY
CAMP HILL BOROUGH CIVIL DIVN `?
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff, No.: 11-7968 MLD
vs.
No.: 11-8631 Civil
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21sT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant.
PRAECIPE TO SATISFY MUNICIPAL LIEN
TO THE PROTHONOTARY:
S"ADAM: Please mark the Municipal Lien filed at the above - captioned term and number
satisfied.
By:
Scott. Dietterick, Esquire
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
avxk 4.qsod
??? IOsC1
.•
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAMP HILL, BOROUGH
2145 WALNUT STREET
CAMP HILL, PA 17011
Plaintiff,
vs.
FRED W. ZEPLIN
2028 MARKET STREET & 7 N. 21 IT STREET
CAMP HILL, PA 17011
PARCEL ID #01-21-0271-404
Defendant.
CIVIL DIVISION
No.: 11-7968 MLD
No.: 11-8631 Civil
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 16th day of February, 2012, via First Class U. S.
Mail, Postage Pre-paid:
Fred W. Zeplin
15 Cumberland Road
Lemoyne, PA 17043
Respectfully S
JAMES,
By:
Attorney I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
CK & CONNELLY, LLP