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HomeMy WebLinkAbout12-1608IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. No. b I aq - 6D 501 STEPHEN M. KNIGHT & ; , ra ANNIE A KROL-KNIGHT and other 41; occupants of 71 Sherwood Circle M 1W Defendant =? ;:0 -<> w c c3 NOTICE m o You have been sued in Court. If you wish to defend against the claims set fortlVh tIR 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 you 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 clamed in the complaint of 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 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 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. Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 r? r- '? rn a , o? M Q??IO3.?SQcI aJ? Ck-hL l s ? 3 e4 afy-? a3ay IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. No. )P- I U CE C.Vil STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant COMPLAINT IN EJECTMENT 1. Plaintiff is CJD Group, LLC (hereinafter "Plaintiff") a Pennsylvania Limited Liability Company with an office at 1770 Oregon Pike, Lancaster, Lancaster County, Pennsylvania 17601. 2. Defendants STEPHEN M. KNIGHT & ANNIE M. KROL-KNIGHT and any other Occupants 71 Sherwood Circle, Enola, PA, County of Cumberland, Commonwealth of Pennsylvania (hereinafter "Defendants"). 3. The remaining Defendants are persons, names unknown to Plaintiff, who may be other persons occupying the property, whose claims of ownership are unknown to Plaintiff. 4. At all times relevant hereto, the property, which is the subject of this action, is 71 Sherwood Circle, Enola, PA, County of Cumberland, Commonwealth of Pennsylvania (Hereinafter "the property"). A copy of the last deed of record containing the legal description of the property is attached hereto as "Exhibit A". 5. Plaintiff is the equitable owner of record of the property through the purchase of the property at a Cumberland County Sheriffs sale. A copy of Plaintiffs receipts from the sale is attached hereto as "Exhibit B" 6. Defendants are the former owners of the property. A copy of Defendant's deed is set forth in "Exhibit A" 7. Plaintiff believes and therefore avers that it has good fee simple title to the property and that Defendants have no title. 8. Plaintiff believes and therefore avers that Defendants should be ejected from the property since they are still occupying the property. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a judgment in ejectment in its favor and against Defendants for possession of 71 Sherwood Circle, Enola, PA, County of Cumberland, Commonwealth of Pennsylvania together with such other relief as is just and appropriate. Respectfully Submitted, LAW OFFICE OF JEFFREY D. MOHLER Jeffrey D. Mohler, Esquire Attorney for Plaintiff 2938 Columbia Avenue, Suite 1402 Lancaster, PA 17603 (717) 291-6800 ID#69176 Dated: - 3 I ( Z , 2012 VERIFICATION I, JEREMY HESS, Member of CJD GROUP, LLC, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S.A. Sec. 4904 relating to unsworn falsification to authorizes. Dated: 92012 050 9 ?, PA 1909 Nk No. 134 ntNFM pbtjo2 Pt?cel 1D No. W15.17WI18 TAX glZbBgl.- ADDING lOt= C ? This Indenture, ,,.b a, /?' ,,,f d ebt ,2=, Between MIME A. KROL-KNIGHT varied the Ono=), of the one part, sm ANNIE A. 1' aid STlMIM AL 134GW Omm o for cried de Graft a), of the other part, Wflne&)Ctk dodo nid Grtator tw and io oomidnatiaa oat of aeoad kpa and adlet '* m fms wde uaao bmdmd cad vile of dw team of Zen Aid MW Dalian $AM) kv A mosey of the Unked Stain of Ameekk am her wan nd V* pdd by We said Onoook at or belle do ndbS and derivary hetaet, the teodpt vhetaof is bneby adwwbdpd, hn preeM 1 baepieed and add, nbwd aced oattH 1 i i, and by these pasma doer Part, I v I and nU, Mben and oaelitm aatb the odd Omawdlemw by die Barbary, Ihtbr udgm, the ao<vhw of them cad the smvhw't peraatd repsaeemdwa maid anipte then heba and ate, ALL THAT CZRrAIIY TRACT OR PAK= OF LAM AND PDMORZH, WMATR, LT MG AND MEND II(THR TOWMM Q OW ZApl' M400MD 1N Ti COUM OF CUMONSIAND AND CONWOKWULTH OF PIIM 6MWANKA, N ORR PARTD Q,Y D w IIM D DAM 71LY 27, 2!M IN BOOK = PAGE 2't<'I GRAMM AND DOWMfRD NY VMAAAU E. AROUGOOK AND NICOfd,E X ?O I Ot UNTO ANNM A. MMX- MOM, M M& DW9TWUAI.. MM DF Uff NQ a OF PffM SMPINON PLAN NO. 3 OF MW MW PARK AS 24 TER ADD DOtIl1'1'Y Dtm001?'e OMCE ON OL1+0 d„ lfr JN PLAN DOOR 94 PAGE d& U MIR AND $USMCT TO ACTS O!' ABORMY AND IOW MW ORDINAlM(i'S, DJQl1D OF PUKJC t)17U Y AND POMAC MMM OOSOM AW VXWf G MDTIP['llONls AND RARNNIMi3, VVNWi OR OF 1ROOlRa, TO TMs z3alN1' THAT ANY PM BONS OR MTQ1'1E8 RAVE ACQM LDGAL ISM T?OIl: %rY+A-1 Ae &,t. A i's geekle O w rrr r.- c N r- 40 .:+ ?. ca co zj- lzj -1; N ? RZ, z r•? c'? Co G r~; 0 booK 255 PAcE4564 ***M DMOUTU NAL P WOM ONLY*" The hetpweammt dlaaam bail btta?wo oat 710, ands Erie, PA 170M Together with aII ad aiaplar die buikbp and imp i m, mmgm. wq% atat, dioya, dd„awsn. paaapa, 'ON waaercae sm doS, mutm, Pme^ baadimmwft and OPWOMMOIS, wbobaa.ar otfo sr bwft smiad patina fit, or in aaywlae t4I i iand an eetveniooa and eaaaairdees, nett, iamaa, and poet d KOK and an do eahle, eight, dos, iataoeN, pay, (brim ad edmmd what mm of her. the acid gtmtor, U WA at lawn is etgeky, of, ln=d a dw ataoe. To have and to hold the tam IN or piece of VOW daacrgeed Am. vim do Ndmbtp ad hrpoe?aaeaat dtaaeea eeasetd, beeeditamaats ad prmsiam haaaby pertd, at seettiord neat iaarodad so a be, wA& *A apptterras, moo IM amid aaaaea, dear herm and ammo. to ad for the a* popr tae gad bdwdof the tam aealmos, am* hdin ad aaaipa, awerar. And die aid amaw. Ear honer( tad her min, atec? -, and admLiatralocs, does, by rhea pereetb, aoa<iot. iant tad ageae. e0 and wleb the aid avata, their heir and aaaysa, pat abe, the tam armor, ad ber bein, aU nd aiplar dta benditammt and pee dm i , is deaarl , 'and an wK a mlWWW =d 860 255 PACE4$95 boNA d so to be. Oft the appfKMNMa. MR the OW Gnam, weir hdm and mdpa, MOM ber, the said GUMW. and ber Mks. SW spieet aH aad every altar Pr, ad Pm? m bedidly chimiq# or to cbdm the acme a mfy Pat tbemof by. from or noder ban, her, it, or MW of OMM dM and will Warrant and Forever Defend. In Wlttcw Whereof, the perry of the drat pm ba beieaelo at bar hood and as mood the day and year am above v d"m Sealed and Delivered IN TMJRRUNCH. of us• , 'i ? ?iN?a ? {slst?I,} Com momma of Pamwmmia /? . Corey OR ? *e /4 dyr of -Ai!*+W"C ,2002. beffaee me, a Nohey PWAc for do C.ommommn of Pwmsylvasit, maidioI in dt Carney of Cusbwhak the mdamlped Omoar, pemooafgr sppnmd Anob A. Era 4w* . Imown to me (a addhemdly pvv* b be the petso?a whom amsaab wimedbed m do vviNfia i!MAM me, Ed arlmmdodped Wet ate =mad the erne ft ft puaPoaa aaeein co mAnd. ...-_ WEEti30F. I bteunso at my bod acad. +!L to* pdwc My? Mw ~ of the abwamaned Gnnmms Is: 'n atart -0 f:k* Brarerr At N0?' hd RombL PA 1 a Mwiaa?, a'? AwJEOIA On behalf the CkM Fib No. 024wnN11M BOOK 255 PAGE4566 row q AA -- UpwqLKxj NATIONAL HEADQUARTERS MACEMO lB, MOMA SCHEDULE A Condnaed Legal Description w LL Tint? QrXUM ~ or PI rod ybnd wdPwAw tAwA 6 ft oat &*f /. w. T y V= Peand e M AM Cmw 4f CambaW MW C.e+ MWft4* y ra.ry?aak?e.?Bp.rNedi.?ruaXd.s?+B?n+r: e6GlJ4,11if iltfi ?/taa r:.a1M Mtwwr iM.«±A«?p?hld F?aAMry3?.si Ckdta dithk rf.?t ridte?M L.a M.*. Qs e.d 3iar itJ?wr tretMtMMM?A o r,3? 60Jirr a aroits d4tosc rla?rBJd r?ytw. ? M Aa r?M ? a nBXae ?f il60)Ies??irr?6?rce ?/?t +L?3i?et ea.? elwtsesewi ?rirwerlj,eiaeier Sanwwdi ?seea te:liReR rr.rr tr7aw ai.Nia yl.?tJbr. a+wt.f last b•,4./LB. Xr I3lduTftete..Pa? raredl of d?.es?IS t wMk* "w'v'w* ew 4w -,W- MAww .$ Wfty& q1l?.s+ w.b 4f Goad W • dfiMwnr ?17.t, JMt to sfflBwi,• I oe a" do . ?+a t3 eeiawes N i«owlb +wBr b r?elwe y MMew L.w+rr I far. ss,awr de.r,?Ye. !?. etftaBr. ?b«r.se y?3ar0,/iare ?b.,e?r.wdrae6 yua . 1'FJMG Lot Na, dd y1%e! irt.w Plop Na 3 oJS?ewew Perot rrosr?d In 40 t.0460ow d co" Am*, &,* 0jw oK osr«wr I. /DN in Plan awk X~ d3 I Certify this to be recorded In Cumberland County PA >i= Recorder of I-)n ..cds ***FOR EMRMATIONAL PURPOSES ONLY*** The improvements thereon being known as: 71 Sherwood Circle Enoh4 PA 17025 9oo!(255 PACE4567 Sdwdate A - Prue 2 Caa mkmant No. 02447M M IK farrier b lra l wim Ihr i.e?..ro. am rdadri/r A art Bar aMarJ - Mar. 8. 2012 3:29PM Cumberland County Sherrif SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 0 al Cufnb"f.. Sheriff Jody S Smith Chief Deputy GuPe GiSNj4rFi No.0096 P. 2/2 Richard W SleWart Solicitor r Plaintiff BAG Home Loans Senncing, L.P. Va. L Attorney for the Plaintiff' Daniel G Schmieg One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 Location of the real estate: 71 Sherwood Circle, Enols, PA 17025 Sheriff Costs Docketing Postage Levy Posting Handbills Service Mime Auctioneer Poundage Acknowledging Deed Legal $eareb Sheriffs Deed Distribution of Proceada Surcharge Adver0sln0 Cumberland Law Journal Patriot News Prothonolary Other Out of County Municipal Costs Municipal Lien Judgment Costs Defendant Stephen M. Knight Annie A. Krol-Knight J Sheriff's Safe Dale: Wednesday, MarCh 7, 2012 Writ of EKeCutlon No.: 2009-2218 Advance Sheriff Costs: 1,500.00 30.00 0.44 15.00 15.00 15.00 10,00 22,96 46.00 300,00 .. .... ...... 63.00 25.00 30.00 15.00 355.00 215.24 ... 2.50 9.00 Total Sheriff Costa 1,171.14 1,332.70 Total Municipal Coats 1,332-70 Real Debt 2911257.74 Intereal 37,325.82 .... . .. .... .... .... ..... ... .... .... Attorney 'Paid 208.92 Total Judgment Coate 2419,790.49 Additional Costs Grand Total! 271,194.32 Lien Search $300.00 Bid Price $166,700,00 Poundage $3,334.00 Less Deposit 16,670.00 Local Transfer Tax 6,361,00 Plus Additnfrl 10,356.00 State Transfer Tax $3,361.00 Costs Total $10,356,00 $160,386 Balance Due by 3/23/2012 at 12:00 boon 4 ?t Sheriff's poundage coal Will be calculated according to the current law and added to the Sheriffs' costa after the sale. Cumberland County Sher1H. Carllsls, Pennsylvania, 17013, (717) 240-6390, (717) 240.6397 (fax) fC1 ca+•urd 'lo sr Vro TCVA'rti'C lri. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff °tv Jody S Smith Chief Deputy ! r pa ,f I ?: i., Richard W Stewart Solicitor r 4 '? y CJD Group, LLC vs. Case Number Stephen M. Knight (et al.) 2012-1608 SHERIFF'S RETURN OF SERVICE 03/19/2012 12:00 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2012 at 1200 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Annie A. Krol Knight, by making known unto herself personally, at 71 Sherwood Circle, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. AMA kylamdaDA COBAUGH, DEP 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stephen M. Knight, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Stephen M. Knight. Deputies were advised, the Defendant is deceased. SHERIFF COST: $64.00 SO ANSWERS, March 21, 2012 RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CTATTY A Crr1nXT T A III CJD GROUP, LLC Plaintiff v. No. 2012-1608 STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTRY: f T-j r-!7 C-0 Plaintiff, CJD Group, LLC, kindly requests that Judgment be entered against Stephen M. Knight and Annie A Krol-Knight, for failure to respond to the complaint. A notice of intention to take default judgment was sent to Defendant Stephen M. Knight and Annie A. Krol-Knight on April 12, 2012. No response has been forthcoming from anyone. Enter judgment against Stephen M. Knight and Annie A. Krol-Knight in ejectment for premises 71 Sherwood Circle, Enola Pennsylvania, County of Cumberland, Commonwealth of Pennsylvania 17025 LAW OFFICE OF JEFFREY D. MOHLER Je rey D. "Mohler, Esq. Attorney for Plaintiff 2938 Columbia Avenue, Suite 1402 Lancaster, PA 17603 717-291-6800 ID#69176 Dated: , 2012 QWA-'a) U-561 61? Ck- 14 95X PO a'74314 1\IAtp (\A-a.: ItCA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. No. 2012-1608 STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant AFFIDAVIT OF NON-MILITARY SERVICE Before me, the undersigned authority, personally appeared Jeffrey D. Mohler, Esq. who being duly sworn according to law, doth depose and say that Annie A. Krol-Knight, the Defendant is not in the Military or Naval Service, based on the following facts: Age of Plaintiff: Unknown Present Place of Employment: Unknown Present Place of Residence: 71 Sherwood Circle, Enola PA 17025 (-J" Jeffrey D. Mohler, Esquire Sworn and subscribed Before me this Zlo??` Day of ?? . 2012 mcuus,) `9- Q'Q_0j4'p Notary Public NOTARIAL SEAL MARIA L CLARK LANCASTER ""CITy CftgM Coati b0 ft Jul 18, U10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. No. 2012-1608 STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant Pursuant to requirements of Pennsylvania Civil Procedural Rule #236, you are notified that there was entered in this office today, in the above-captioned case - • Judgment for Plaintiff and against Defendants. • Judgment for Plaintiff and against Defendant for Ejectment from Premises at 71 Sherwood Circle, Enola, Pennsylvania, County of Cumberland, Commonwealth of Pennsylvania 17025 • Order or Decree in favor of Plaintiff Date: {-?? 2012 3q q6 PROTHONOTARY -- To: Annie A Krol-Knight 71 Sherwood Circle Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. No. 2012-1608 STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant Pursuant to requirements of Pennsylvania Civil Procedural Rule #236, you are notified that there was entered in this office today, in the above-captioned case - • Judgment for Plaintiff and against Defendants. • Judgment for Plaintiff and against Defendant for Ejectment from Premises at 71 Sherwood Circle, Enola, Pennsylvania, County of Cumberland, Commonwealth of Pennsylvania 17025 • Order or Decree in favor of Plaintiff Date: ?J,(? 2012 PROTHONOTARY To: CJD Group, LLC 1770 Oregon Pike Lancaster, PA 17601 . 0?5 _ _-g LAWN AVENUE SUITE 200 FNe No. 024H71NFM NORRISTOWN, PA 19403 IMred ID No. 9915.1788-118 TAX EXEMPT: ADDING SPOUSE C?J6 jt-j3$? This Indenture, made / day of ,* ,. , Between ANNIE A. KROL-KNIGHT (hereinafter called the Grantor), of me one part, and ANNIE A. SROI.-lam GHr and STZpmcN M. mewr (hareimfter called the Grantees), of the other part. Witnesseth, mat the said Grantor for and in comwersom out of wtural love and affection from wife unto husband and wife of the sum of zwo Am 8@/100 Ddim (3.00) lawiW money of the ummd States of America, unto bar well and tridy paid by the sold Gramm, at or before do sealing and delivery hereof, the receipt whereof is hereby aclatowledged, has granted, bargakW and sold. rslmsed and confirmed, and by these presents does gruel, bargain and sell, release and confirm am me soil OrmsemTeaants by the Entirety, dleir assign, do sucvhw of them sad the survivor's perswal repro and au*m their heirs and ALL THAT CERTAM TRACT OR PARCER. OF LAND AND PREMSE'S, SITUATE, LYING AND BEING IN THE TOWN OF EAST McMONO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DXBCYJM IN DEED DATED JULY 37, 2000 IN BOOK 225 PAGE 367 GRANTED AND CONVEYED BY MUM[ E. BIROUGHM AND NICOLLE M, BROUGEOM UNTO ANNIE A. KROL- KNWvHT, SINGLE IImIVMAL. BEING IN LOT NO 66 OF FINAL SUBDIVISION PLAN NO. 3 OF SBBRWOOD PARK AS RECORDED IN THE CUM ERI AND COUNTY RECORDERS OFFICE ON OCTOBER 4, 1908 IN PLAN BOOK 56, PAGE 63. UNDER AND SUBJECT TO ACTS OF ASSXhMY AND TOWNMP ORDRMNCES, RHOM OF PUffiJC UTHM AND PUBLIC SERVICE COMPANIES, ZXW04G .my.. CrIOO!? AND LMEMENTS, VISMX OR OF RECORD, TO THE E%TENr THAT ANY PERSONS OR ENTMARS HAVE ACQUIRED LEGAL RIGHTS THEREOF. 7r-'On-5 ?r &'e. h 4WA ?'S A'V-aste' +y e-Aep v f-, 0 w W M b. ©: . ? "I r v ? ? r 7 a.. ?•T c`? -r fi r o 0 900U 255 FACE4564 ***FOR INFORMATIONAL PUAPOM ONLY*** imp e"aw as &aaan belts known as: 71 Rserweed Clrrle ),cola, PA 170M Together with alt and singular the buiftp and improvesaerrts, ways, streets, alleys, driveways. Pte, walm. WMPVOWM, tights, liberties, privileges, bereditamenm and appartaamtxs, wbapoaver undo the husky gmmed pte num ba m*Wg, or ht anywise apperWniog, and ft mveraiaos and taatainders, teats. issues, and profits dendf, and ap the esate, right, title, interest, p %WW, cisim ad demand whatsoever of bar, the add grantor, as well at taw as in ophy, of, in and to the some. To have and to hold the said lot or piece of ground desmgmd atwve, with the buildbW and improvamean fereoa erected, hettaiitamama ad premises bareby granted, or mentioned sad intended so to be, with the q puttemm m, undo fa add Grantees, tbeir haia and asolgm, to and for the only proper use and beW of fe said Grantees, fair heirs and assigns, fonwa. And the said Grantor, for herself and her heirs, emeeutors and admhdsrlatora, does, by these prtwenta, oovanant, grant and agree. to and with the said Gramees, 6* hW" sad assigns, hart she, the said Grantor, and her hairs, all and singular the hereditaments and premises berWn deserted and granted, or mentioned and 8* 255 PACE4565 intended so to be. with the apputtemntxs, unto the acid Gm*", their heirs and assigns, against her, the said G actor, and her heirs, ad apmt all and every other p mon and persona whosoever lawfully ehm" or to eWm the acme or say part thereof, by, kom or under him, her, it, or any of them, shall and will Warrant and Forever Defend. In Witness Whereof, the party of the first part Im hereunto set her hand and seal.Mted the day and year first above written. Sealed and Delivered IN THE RESENCe OF US. MMM A. IMOI Commem "Ith of Penmylvania County of Q mberland ; ss On this the /faddy of ?t M . bd= me, a Notary Public far the Comas wcmth of Pemt ylvama, rtliag in the Cowtty of Cumberland, the tmdenigaed of m, Family appeared ArA& A. Kroll, mown to me (or t a9ly pawn) to be the person whose nemeis subscribed to the within msd sclmowledW that she enculed the same fff the pmpoeea dmrm oadmined. WHEREOF. I herataw set ray head an =/s/eal? NMIFy Pof& My commission ettpfres The a MM of the above-mined Grantees Is: 71 good Cline PA 17825 On behalf the Gmy ttaa?aetoe ty Noww SW t 66 Publk MNaon,gas?w ?.2003 antot„pa File No. WAK71NFM aooK 255 PAGE4566 Lawye mlffie N n6w e Oo p ora 0 on NATIONAL HEADQUARTERS ar?ororo?, vrn,orrw? SCHEDULE A Continued Legal Description w U rJU7 Cl.It15 M traa ar ,Perot! a(&W ondp+r ibm A two. aft and belt In rho T ??nsAip gr ?r PepasbKo M tAe Coan{r of C?trnbalend and Ceannarteal?A Qj Pe?raxyiMmrf4arorepartiattm? dtrc?l8od etfoJloti+t: N 6G1,W,WG of Mp polor of latenreeriah berwnra rl o irorrher?y +^9? 1y Hirt q/'Sbse+rvod [ irele ands" flab vfar#eir V iawaar Lott Pray. 6s errd 6d on rbe kerrlarylPer wew/eaN rlap a Plot!; lamer aortA 09 dlirm I! mbrwer 00jeeardt east Jy taid otb4 wa . fw a dimmev orM Wfb& ra a po6tr; rhtncorlonjtaW r0"fiwayasa awwto she ofSkwfth a memo d?raer lB arbraYes Sd raa?aads J 900/rerfers Avaece of 27, IJ JW ro a p4kc rAeneerow k it am by At Mw 4Wj*ptder bw men Lou /Vein of sad d7 oo dw plan of ZeuJbr 0 Arrowee of 13 63jbw so o polar; dwer"Wh OD et?rtn dS a+fiarres 00seaoadt wstt by loads bowl er f wm" 4rJq- t Chun A grGedafrWolafor a dfamee gfDT dJbrr M a pWW. tMeace aarb 40 a e8ren IS ndntrht 00 jetomb war by rke Ike efa4ainsfi rbenreoa lab Nat. 65 end dd an 'the P Van of Lon o dlttaade of J94g0 fear io rho paint and place 4r=0 46W . 1'FJMG Lot No. 6d of Final SabdWon Plat+ N& J of Sb rrwaed Fart at marled In the VNwrbetldw d Ceringr ilerad&* QJW on October A. /Did in Plow Nook.M Fate 63 I Certify this to be recorded In Cumberland C:o«nty PA Recorder of DIc eds ***FOR INFORMATIONAL PURPOSES ONLY*** The improvements thereon being known as: 71 Sherwood Circle Enola, PA 17025 soox 255 PAGE4567 SrheMe A - Pap 2 Commitment No. 02447INF'M TWA eama.- b iavali 1 ad= do ta&Mod= Sbw and ScbodAw A nd 5 are apaebed COPY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CJD GROUP, LLC Plaintiff V. STEPHEN M. KNIGHT & ANNIE A KROL-KNIGHT and other occupants of 71 Sherwood Circle Defendant TO: Annie A Krol-Knight Date of Notice: April 11, 2012 No. 2012-1608 IMPORTANT NOTICE 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 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 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 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. Lawyer Referral Service 100 West Airy Street (Rear) Norristown, Pennsylvania 19404-0268 (610) 279-9660, Extension 201 h Respectfully Submitted, LAW OFFICE OF JEFFREY D. MOHLER Jeffrey D. Mohler, Esquire Attorney for Plaintiff 2938 Columbia Avenue, Suite 1402 Lancaster, PA 17603 (717) 291-6800 I.D. 69176 0 C3 M co -0 C3 Certified Fee W ES 6ro oo 0003848 10 APR 12 2012 M ZIPCODE 17601 C3 Postmark C3 Retum Receipt Fee Here C3 (Endorsement Required) M Restricted Delivery Fee (Endorsement Required) O r%- L171 Tbtal Postage & Fees Sent T PO Box N ? 1 Y 1?Y V.3 S0? 5 L ?? ?? -- -- Crfy, State, ZIP+4 ? -`----------- ` - = E I PS Form :3800 August \ ??ic?as See Reverse for Instructions 2006 , 10f 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CJD GROUP, LLC VS. No. 2012-1608 Civil Term_ STEPHEN M. KNIGHT and ANNIE A. KNOL-KNIGHT AND OTHER OCCUPANTS Costs Attorney's $ 212.75 Plaintiff's $ Prothonotary $ 2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) CJD GROUP, LLC being: (Premises as follows): 71 SHERWOOD CIRCLE, ENOLA, PA 17025 (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 6/22/12 (Seal) 2 of 2 No 12-1608 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CJD GROUP, LLC vs. STEPHEN M. KNIGHT and ANNIE A. KNOL-KNIGHT AND OTHER OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 212.75 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: JEFFREY D. MOHLER, ESQUIRE 2938 Columbia Avenue, Suite 1402 Lancaster, PA 17603 717-291-6800 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 Sheriff By Prothonotary Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA A CJD GROUP, LLC 'Plaintif a r CERLAAD COUIliT V. No. 2012-1608 r 'SYL+I STEPHEN M. KNIGHT and ANNIE A. KNOL-KNIGHT and other occupants of 71 Sherwood Circle Defendant Address: 71 Sherwood Circle Enola, PA 17025 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOATRY: (1) Issue a writ of possession in the above matter, directed to the Sheriff of Cumberland County, against Stephen M. Knight and Annie A. Krol-Knight the unknown occupants of 71 Sherwood Circle, Enola, PA 17025 Defendant, (2) and direct Sheriff to eject to Defendant from the premises at 71 Sherwood Circle, Enola, County of Cumberland Pennsylvania 17025. °iN`t UL 4, 00 UP l C) S )s (fit Clio DsL?? al Dated: ?0 ` -w I Iz Amount Due........... $ Interests From ......$ Plus Costs Attorney for Plaintiff (1) to adapt for mortgage foreclosure, strike out the next nine words (Pa. R.C.P. 3256) and change "Money judgment" to "Mortgage Foreclosure" under center heading (2) Wording for garnishment or special indexing (on money judgment execution) is prescribed by Pa. R.C.P. 3104 as follows: (a) If garnishment is desired insert here. "and against [stating garnishee's name and address], garnishee". (b) If indexing in judgment index of issuing county is desired, insert here. "and index this writ against [name Defendant]". (c) If real property of Defendant in the name of the garnishee is attached, and indexing as lis pendens is desired, insert here (or combine with any indexing instructions under (b), above. "and index this writ against....., Garnishee, as a lis pendens against real property of the defendant, in the name of garnishee, as follows: [specifically describing estate]". (3) List property to be levied on, with location/s (if different from defendant's address in caption). For levy on real estate, furnish ten copies of description. If this is soley an attachment, delete this line. c? d xl ri LL Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ", E PR0??Fr44ONOTAR`T CJD Group, LLC vs. Stephen M. Knight (et al.) ?4?tkL19` at Ctt[21'7GT?./,Yft? OFgC€ C?F Thy 4<ERIFF 2012 JUL 10 AM 8: 09 ;U PtNNS LVANIA TY Case Number 2012-1608 SHERIFF'S RETURN OF SERVICE 07/06/2012 08:10 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent seprcF and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant iM hi: bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 71 Sherwood Circle, Enola, PA 17025. No one resides at the residence other than Annie Krol-Knight. 07/06/2012 08:10 PM - Deputy Amanda Cobaugh, 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 bye the Defendant, to wit: Annie A. Krol Knight at 71 Sherwood Circle, East Pennsboro Township, Enola, PA 17025, Cumberland County, informed Defendant of contents of same. July 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ic;. CountySuite Sheriff. Te eosott lilt-. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,my R Anderson ,heriff ..FE;i.Ef;.F -r E IrIERIFF flhzi Jody S Smith Chief Deputy Richard W Stewart Solicitor 2 12AUG -3 PM I2: 40 CUMBERLAND COLI ',, PENNSYLVANIA CJD Group, LLC I Case Number vs. 2012-1608 Stephen M. Knight (et al.) SHERIFF'S RETURN OF SERVICE 07/06/2012 08:10 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 71 Sherwood Circle, Enola, PA 17025. No one resides at the residence other than Annie Krol-Knight. 07/06/2012 08:10 PM - Deputy Amanda Cobaugh, 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: Annie A. Krol Knight at 71 Sherwood Circle, East Pennsboro Township, Enola, PA 17025, Cumberland County, informed Defendant of contents of same. 08/03/2012 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 71 Sherwood Circle, Enola, PA 17025. SHERIFF COST: $118.01 August 03, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF a as-fir e ? Ay* ?-7 ic? Coun ySuite Sheriff, Teleosoft.. Inc.