HomeMy WebLinkAbout12-2010David J. Lanza
I.D. No. 55782
2132 Market Street
Camp Hill, Pennsylvania 17011
(717) 730-3775
DENNIS COUCH AND LeANNE BEIL,
2bgai ??? pr; ?-?-
'n/1 eLL1 AH,«-??h+'?? Plaintiffs
V.
Attorney for Plaintiffs .
1
t"y`f
IN THE COURT OOMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2o?2-ao>lo CN(k
FRANK OROZCO and AMY OROZCO, CIVIL ACTION - LAW
Defendants
PRAECIPE FOR WRIT OF SUMMONS
To the Prothonotary:
Please issue a Writ of Summons on Frank Orozco and Amy Orozco, 6 Souder Court, Mechanicsburg,
PA 17050, in the above captioned case.
Date: March 28, 2012 y
By:
David J. Lanza
Attorney I.D. #55782
2132 Market Street
Camp Hill, PA 17011
(717) 730-3775
Attorney for Plaintiffs
Ct--W 1'7 S3
P-4-- a-? 31I 3
Commonwealth of Pennsylvania
County of Cumberland
WRIT OF SUMMONS
Court of Common Pleas
DENNIS COUCH AND LEANNE BEIL
Plaintiff
Vs. No. 2012-2010
FRANK OROZCO
And
AMY OROZCO
And
In CivilAction-Law
To: FRANK AND AMY OROZCO
You are hereby notified that the Plaintiff, DENNIS COUCH AND LEANNE
BEIL, has commenced an action in Civil Action-Law against you which you are required
to defend or a default judgment may be entered against you.
? - le'a (SEAL) David D. Buell, Prothonotary
Date 03/28,2012
Deputy
Attorney: DAVID J. LANZA, ESQUIRE
Address: 2132 MARKET STREET, CAMP HILL, PA 17011
Attorney for: Plaintiff
Telephone: 717-730-3775
Supreme Court ID No. 55782
or
f
David J. Lanza
I D. No. 55782
2132 Market Street
Camp Hill, Pennsylvania 17011
(717) 730-3775
DENNIS COUCH AND LeANNE BEIL,
Plaintiffs
V.
FRANK OROZCO and AMY OROZCO,
Defendants
PRAECIPE FOR LIS PENDENS
To the Prothonotary:
CIVIL ACTION - LAW
Please index the above action and judgment as a lis pendens against the following real property:
Tax parcel # 38130985119, situate in Silver Spring Township, Cumberland a/k/a 6
Souder Court, Mechanicsburg, PA 17050.
More fully described in the deed recorded at Book 276 Page 2813 in the office of
the Cumberland County Recorder of Deeds as more set forth in the attached
Exhibit "A".
I hereby certify that this action affects an interest in the above-described real property.
Date: March 28, 2012 G
By: Jr! /v 1
David J. Lanza
Attorney I.D. #55782
2132 Market Street
Camp Hill, PA 17011
(717) 730-3775
Attorney for Plaintiff
CVJ.? 6 1 . 56
['a
Ck? r? sY
Attorney for Plaintiff
?'11i'Ft' 28 PH 3:
E: 1.'I1BE l~i11 L'U'.j
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Do(D-Do 10 CAVil
.3 1--) Ct q(-)
?C
RrBERT P. ZIEGLER
ORDER OF DEEDS
"BFRLAND COUNT' - f' .
N SEP 8 PM 1 31
Tbfio 3nbenture
Made the 31 ?" day of AU-0 ks
Joseph Saftodln, stnglC ......... ....__..._. _........._?_.._.____....._..._ _
(hereinafter Called the Grantor), of the one part, and
Amy LI.Orsseo, a married woman ---- ---w.-.--.- _----._..._?._
--.------w.? _ __- Omwed tho Grantee), of the other part,
3PUM OUb, that the said Orsator for and is consideration of the arm of Five Huadnd Shy Thousand
And 00/100 Delh n ($60,000.00) lawful money of the United Stator of America, unto him well and truly
paid by the said Oraatee, at or before the waft and delivery hereof, the receipt whereof is hereby
acltnowledged, has granted, bargained ad sold, released and eoarnsd, and by thew presents does grant,
bargain and sell, release and confirm In fee simple unto the said G mtee, her heirs and assigns,
ALL that certain lot of umimpcoved land situated in to Township of Silver Spring, County of Cumberland and
CommonweaM of Pennsylvania, mote particularly-banded and described as follows:
BZGH4MG at a point on the northern dedicated right-of-way line of Souder Coact at the dividing line
between Lots Nos. 13 and 12 as shown on the hereinafter meuotioned plats of lob; thence along said dividing
limo between Lob Nos. 13 and 12, North 2 degrees 46 minutes But„ a distance of 505.2 feet to a point at lands
now or formerly of Mon B. Humer; thence alonug said latter lands the following two coursa and disbaces:
(a) South 83 degrees 22 minutes 45 seoomds Bast, a distame of 141.43 hot to a point; and (b) South 41
minutes Bast, a dispmn of 501,36 feet to a point on the dedicated right-of-way line of the culkie-sac and of
Souder Cant; dwoe along said dedicated right-of-way line, the following thm coma and distances: (a) on
a curve to the left having a radius of 50 feet, an am disdmce of 142.59 feet to a point; (b) on a curve to the
tight having a radius of 20 loot, an arc distance of 23.62 feet to a mommaent and (e) North 87 degrees 14
minuses West, a diitattt;e of 34.46 feet to a point on the northern dedicated right cf-way line of Souder Count to
a point at the dividing line between Lots Nos. 13 used 12 as shown on the hereinafter maudoned plan of lob,
the place of beginning.
BMG Lot No. 13 as shown on a certain; pins of lots eadded "Final Subdivision of Mmhaated Hills" se
recorded in the Office of dw Recorder of Deeds is and for Cumborfaad County, Pennsylvania in PLo Boole 76,
Page 37.
5Jvf 276 PAcr2813
THE ABOVE DRACRt8ED REAL EBTATE is the acme real estate which Greater Keystone Properdes, Inc.,
a Pennsylvania. bwiness corporation, by its deed dated May 31, 2005 and recorded Jima 6, 2005 In the Of&e
of the Recorder of Deeds of Cumberland County, Psunrylvanle in Deed Hook 269, Page 1157, cmnyed to
Joseph Kadwwn, of Ming heroin,
The above described lot is conveyed UNDER AND 8UBJECr, nevertbelew, to:
(1) The buildup eetrbacle lines and utility easeamAM and drainage eat, if any, as more
fatly shown, boated and defined on the above mentioned plan of Iota;
(2) The applicable restrictions, cor?anaats and conditions as more fully set fords on the above
mentioned plan of lots.
(3) Thos camunwi and rights-of-way berotaforo p ated to public utility aoupwli a for the use
of providing ettllity services to the subdivision shown on the above described plan of lots; and
(4) The restrictions, conditions and covenants as more fully set forth in a certain Amended
Declaration of Covenants and Reatrictions dated January 15, 1999 and recorded in the
Recorder's Olflce aforeaaid in Miscellaneous Record Book Volume 601, Page 770.
Thy - VM4igR Or Tffi8 1?iDE1VZ't1RE (David C. Cleaver, Empire) is in no way certifying to the
status of the We of dw above premises, and has not searched the records pertaining thereto.
Upon ttf(tb all and singular the buildings and improvements, ways, streets,
allays driveways,
pUWer, waters, walerLcourses, rights, liberties, prlvikges, hereditemm a and appurwunces, whatsoever
unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders,
runts, issues. and prolate thereof; and all the cote, right, title, interest, property, claim and demand
Whatsoever of him, the mid grantor, M well at law as in equity, of, in and to the sane.
AGO We dttb to bOlb to said lot or piece of ground described above, with the buitdingtt and
improvenwo thereon and premises hereby granted, or mentioned and intended so to
be, with the appnroeaancea, into the said Gramm, her heirs and assigns, to and for the only proper use and
beboof of me said Grantee, her heirs and assigns, forever.
Stub the Said Grantor, for bkmlf and his heirs, executors and ad minbuators, does, by these presents,
covenant, grant and agree, to and with the said Grantee, her heirs and am*u, radar he, the said Grantor, and
his bears, all and singular the herCd waints and premises herein described and granted, or madded and
h flooded so to be, with the mss, unto the said Grantee, her hears and assigns, against him, the said
Clraaoor, and bis hears, and against all and every other person and pwmu whosoever lawltilly claiming or to
claim the same or my part thereof, by, fJrom or Under him, her, it, or any of them, shall and will
Opeciallp 30arraut m b loreber Metmb,
BOOK 276 PAGE28A
'Iri ?ffttm lvbt>L f, the patty of the ant part has hermto set his hand and real. Dated tie clay and
Year drat above wdttbea
*nub stab Atlibueb
IN THB PaBSBNCB OF US:
a- {SBALI
Jot h
Cosnmomwatlth of Pmwlvaaia
County of ?Iu m eA OLYl a
On this, the day of L?ak.S ?- , 2006, before me, a Nobmy Public, is and
for aid Co®monwaft and Comty, the ai wd Oftw. peaaaally app$UW Joseph , lmown to
me {or aaddhM* p mv* to be the person wbm acme is mbwAW to the within hwlxamemt, and
aclFri .1 ped that he examned the acme for Ow pmporer t meted.
IN WITNBSS WMWF, I hereunto set my hand sad offtW real.
COMMM&M OF PR" VA
Loeb E Tt f or, ?y Py? ??.
?Pds P•. Cw*oli ?d County
?N Comrni Mw Expos Om 18, 2M Public
AM?riUer, PMM1?AvaM& /le?o0M6pn of NoOuls
My commission expires 1 3
I Cc.Ii
714 ??(; _? . :, < <?
60th( PACE2,816
r
l
c
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
t 4v? F7rd
v _ 4
n
I I i
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2 APR -5 P
Dennis Couch (et al.)
vs.
Frank Orozco (et al.)
SHERIFF'S RETURN OF SERVICE
Case Number
2012-2010
04/02/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 2, 2012, he was
unable to serve a true copy of the within Writ of Summons and Praecipe for Lis Pendens, upon the within
named defendant, to wit: Amy L. Orozco. Steve Brickford advised Deputies he would not accept service
on behalf of the Defendant since there was not a contract with his office and the Defendant.
04/04/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 2, 2012, he was
unable to serve a true copy of the within Writ of Summons and Praecipe for Lis Pendens, upon the within
named defendant, to wit: Frank Orozco. Steve Brickford advised Deputies he would not accept service on
behalf of the Defendant since there was not a contract with his office and the Defendant.
SHERIFF COST: $59.45 SO ANSWERS,
",0,2
(;" N - ???
April 04, 2012 RONKfY R ANDERSON, SHERIFF
SHERIFF'S OFFICE OF CUMBERLAND COUNTY -=
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
= c
Solicitors
Dennis Couch (et al.)
Vs. Case Number
Frank Orozco (et al.) 2012-2010
SHERIFF'S RETURN OF SERVICE
04/13/2012 On this date Ronny R. Anderson, Sheriff mailed the within Writ of Summons and Praecipe for Lis Pendens
by certified mail, return receipt requested to Frank Orozco.
04/13/2012 On this date Ronny R. Anderson, Sheriff mailed the within Writ of Summons and Praecipe for Lis Pendens
by certified mail, return receipt requested to Amy L. Orozco.
06/11/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ
of Summons and Praecipe for Lis Pendens upon the within named defendant, Amy L. Orozco, in the
following manner: On April 13, 2012 the Sheriff mailed by certified mail, return receipt requested a true
and correct copy of the within Writ of Summons and Praecipe for Lis Pendens to the defendant's last
known address of 8168 Via Bella Notte, Orlando, Florida 32836. The certified mail return receipt card was
returned to the Cumberland County Sheriff's Office as Return to Sender, Unclaimed, Unable to Forward
on June 11, 2012.
06/11/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ
of Summons and Praecipe for Lis Pendens upon the within named defendant, Frank Orozco, in the
following manner: On April 13, 2012 the Sheriff mailed by certified mail, return receipt requested a true
and correct copy of the within Writ of Summons and Praecipe for Lis Pendens to the defendant's last
known address of 8168 Via Bella Notte, Orlando, Florida 32836. The certified mail return receipt card was
returned to the Cumberland County Sheriff's Office as Return to Sender, Unclaimed, Unable to Forward
on June 11, 2012.
SHERIFF COST: $66.35
June 12, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
c, Cowls as to Sheri. T7eie soft. b?C
20 t Z ZO 10
W eOe^^ N
O
m N
r
Z ? O [7
0 d
LU IXi
eF
Q C`t O cfl
O
® N NO
Q'
fU
Ir
co
-- rl
co
co
f`-
O
.? O
C3
0
r-q
_ CD
0
?.?.0
0
0
f`-
0 y. O M
m
W .C
Cu
CD C
U F' to c
LL 4. (1)
OO:a
t d 0 m
Z jE ? .?
U00 U U
4t?i
(ri
fnt
iJ
rr,{'
ld:
Sid
4
LU
'S ?^ N
LO O
m N
}
Z
,/?
LO
I L L
?
.? 0 11 ?
L
ui 64
.
Q CO 00
?
s
Q F?
a 6
O
s.7
l
O
N
O
O
r
}
?
f L'! I d?
?
r 1
::'I
.j
Q) U-i
m
+
O M j
I
_ Q
Z OC) J rl
...
ri N
_Q M
c
o N
aJ
co 0
m LL
ij
? L
?
C) d
M II e't
C3 Y C
c 00 erg's
C J
0 s0 ?O ?
p L -
LL
'
O 4
xt
rO hGt
E:3
`0
O tLl
,
C3 tai
0 C`7
O
Z '~ Ce)
O
/?
1j
J
r
9. ? ?
/
Z
(v
W
y
N a
in
0 ('o >
C ? 5,
U?..U) c
U- C:
O p j 0
L >- n
d o
-
Z .v
y
O O U
U
r
Y
f?
{:?
?G!
(yLl
-tiJ
i1".!
try
tsl?
?i
1
v 0 0 0
CD ? Z
T c ,
CD 0
CCD
c C
v
2 m y 00
o r
?. D
? l
)
CA)
w C) Z
C
0Lo >
-I rn 3
00 -<
Q < 0
O O
(T W n
O
-J
0
Q
Ir
L - ?
O - ?
C3
C3 r. _._
C3
C3 ? -
0
03
n
-0
ni
a
r r?,
O O N
ONCn
W v (T
m w !? D
OD Ao
)D. m
?Iv
Xo
z
m
N W co
O 0
N p m
.e
L?1?
t??
i?ty
•hu
t},l O 00 -n
?1 tL 00 D
n C
-n CO O
ro N
w O
% N
00 Z
w O
O\ ^*+
rD
C7 0 C7
O
m Er
O
? N ? O
c ? C
7 (D y CO
C) D
?w•wz
woyp
CA)
-i
O
C3
Q"
O ? ? •
w
6-' ?. ?
O
C
O
C
C3
-0
w
cr
opN C
o r');6
n
o ? C l)
w? O
Vi
W
rn o 1)
OD w D
A
co
'? ? I ffl
?oI
w m
,A <
N
O ?w I :E
N O m