HomeMy WebLinkAbout12-3061David J. Lenox, Esquire
I.D. No. 29078
3 N. Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
ERN EST I I. MARTINEZ and
TINA M. MARTINEZ,
Plaintiffs
V.
FRANK OROZCO and
AMY OROZCO,
Defendants
Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /JL - SCXW
CIVIL ACTION - LAW
PRAECIPE FOR WRIT OF SUMMONS
To the Prothonotary:
civil lei `4
cri
N)
Please issue a Writ of Summons on Frank Orozco and Amy Orozco, 6 Souder Court,
Mechanicsburg, PA 17050, in the above-captioned case.
-
BY:
- -
David J. " enox, Esquir
I.D. No. 29078
3 N. Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
Attorney for Plaintiffs
Dated: May 16, 2012
(3A
$ I o3."75 P D Ar^4
)(n.5o 11
JL 0. ds 10
C# l1(0?(0
a?Sa30
(f o(0
Commonwealth of Pennsylvania
County of Cumberland
WRIT OF SUMMONS
Court of Common Pleas
ERNEST H. MARTINEZ and
TINA M. MARTINEZ
Plaintiff
Vs. No. 12- 30(o l
FRANK OROZCO and
AMY OROZCO
6 Souder Court
Mechanicsburg, PA 17050
In CivilAction-Law
To: FRANK OROZCO and AMY OROZCO
You are hereby notified that the Plaintiff, E,RNEST H. MARTINEZ and TINA
M. MARTINEZ, 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.
(SEAL) David D. Buell, Prothonotary
Date 5/16/12
Deputy
Attorney: DAVID J. LENOX, ESQUIRE
Address: THE WILEY GROUP
3 N. BALTIMORE STREET
DILLSBURG, PA 17019
Attorney for: Plaintiff
Telephone: 717-432-9666
Supreme Court ID No. 29078
David J. Lenox, Esquire
I.D. No. 29078
3 N. Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
ERNEST N. MARTINEZ and
TINA M. MARTINEZ,
Plaintiffs
v.
FRANK OROZCO and
AMY OROZCO.
Defendants
Attorney for Plaintiffs
IN THE COURT OF COMMON PLEAS Of'
CUMBERLAND COUNTY, PENNSYLVANIA
NO. l)-,- 3661
CIVIL ACTION - LAW
PRAECIPE FOR LIS PENDENS
To the Prothonotary:
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".
1 hereby certify that this action affects an interest in the above-described real property.
BY: %y
David .1. Le ox, squire
I.D.. No. 29078
3 N. Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
Attorney for Plaintiffs
Dated: May 16, 2012
EXHIBIT ".A"
LP. ZIEGLER
,«-,tiRDEP, OF DEED`:
1006 SEP 8 PM 1 31
19biz 30jenture
Made the 31 S? day of _ t ?l?,S _, 2006,
?8et?een
Joseph Satdwein, single
-------- (hereinafter called the Grantor), of the ors; part, and
Amy L. Orozco, a married woman
(hereinafter called the Grantee), of the other part,
Vftneftttb, that the said Grantor for and In consideration of the sum of Five Hundred Sbay Thousand
And 00/100 Dollars ($60,000.00) lawful money of the United States of America, unto him well and truly
paid by the said Grantee, at or before the sealing and delivery hereof, the receipt whereof is hereby
acknowledged, has granted, bargained and sold, released and confirmed, and by them presents does grant,
bargain and sell, release and confirm In fee simple unto the said Grantee, her heirs and assigns,
ALL that certain lot of uaiimproved land situated in the Towuhip of Silver Spring. County of Cumberland and
Commonwealth of Pennsylvania, mono particularly bounded and described as follows:
BEGINNING at a point on the northern dedicated right-of-way line of Souder Court at the dividing line
between Lots Nos, 13 and 12 as shown on the hereinafter mentioned plan of lots; thence along said dividing
line between Tots Nos. 13 and 12, North 2 degrees 46 minutes Bast, a distance of 505.2 feet to a point at lands
now or formerly of Milton B. Humor; thence along said latter lands the following two courses and distances:
(a) South 85 degrees 22 minutes 45 seconds But, a distance of 141.45 feet to a point; and (b) South 41
minutes Bast, a dktanoa of 501.36 feet to a point on the dedicated right-of-way line of the curie-sac end of
Souder Court; thence along said dedicated right-of-way line, the following three courses and distances: (a) on
a curve to the left having a radius of 50 feet, an am distance of 142.59 feet to a point; (b) on a curve to the
right having a radius of 20 feet, an arc distance of 23.62 feet to a monument; and (c) North 87 degrees 14
minutes West, a distance of 54.46 feet to a point on the northern dedicated right-of-way line of Souder Court to
a point at the dividing line between Lots Nos. 13 and 12 as shown on the hereinafter mentioned plan of lots,
the place of beginning.
BRING Lot No. 13 as shown on a certain plan of lots entitled "Final Subdivision of Enchanted Mile" as
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 76,
Page 37.
8WO 276 FAct2813
THE ABOVE DEStCREM REAL ESTATE is the same real estate which Greater Keystone Properties, Inc.,
a Pennsylvania business corporation, by its deed dated May 31, 2005 and recorded June 6, 2003 in the Office
of the Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 269, Page 1137, conveyed to
Joseph Kadmin, Grantor herein.
The above described lot is conveyed UNDER AND SUBJECT, nevertheless, to:
(1) The building set back lines and utility easements and drainage easements, if any, as more
fully shown, located and defined on the above mentioned plan of lots;
(2) The applicable restrictions, covenants and conditions as more fully set forth on the above
mentioned plan of lots.
(3) The easements and rights-of-way beratoforo granted to public utility companies for the use
of providing utility services to the subdivision shown on the above desenlvd plan of lots; and
(4) The restrictions, conditions and covenants as more fully Be forth in a certain Amended
Declaration of Covenants and Restrictions dated January 15, 1999 and recorded in the
Recorder's Office aforesaid in Miscellaneous Record Book Volume 601, Page 770.
THE SCRIVENER OF THIS INDENT'1.J E (David C. Cleaver, Eagnfre) is in no way certifying to the
status of the title of the above premises, and has not searched the records pertaining thereto,
Ugetber With all and singular the buildings and imwovements, ways, streets, alleys, driveways,
passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever
unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders,
rants, issuers, and profits thereof; and all the estate, right, title, interest, property, claim and demand
whatsoever of him, the said grantor, as well at law as in equity, of, in and to the same.
Iro babe anb to bOlb the said lot or piece of ground described above, with the buildings and
improvements thereon erected, hereditaments and premises hereby granted, or mentioned and intended so to
be, with the appurtenances, unto the said Grantee, her heirs and assigns, to and for the only proper use and
behoof of the said Grantee, her heirs and aesigna, forever.
S(nb the said Grantor, for himself and his heirs, executars and administrators, does, by these presents,
covenant, grant and agree, to and with the said Grantee, her heirs and assigns, that be, the said Grantor, and
his heirs, all and singular the hereditaments and premises herein described and granted, or mentioned and
Intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, against him, the said
Chntor, and his heirs, and against all and every other person and persons whosoever lawfully claiming or to
claim the same or any part thereof, by, from or under him, her, it, or any of them, shall and will
bpettallp Warrant anb joreber Metenb,
BOOK 276 FnE28A
"n W'bMgg Wbtt"f, the party of the first part has hereunto set his hand and seal. Dated the day and
year first above written,
OWO =b atItbereb
IN THE PRESENCE OF US:
{SEAL}
J h
Commonwealth of Peaaaylvania
ss
County0f???JeX?0.r1C?
On this, the 3? S?- day of k-S- , 2006, before me, a Notary Public, in and
for said Commonwealth and County, dw u aimed Officer, personally appeared Joseph Satkocbt, known to
me (or satidwWrily proven) to be the peraon whose name is subscribed to the within imU merit, and
acknowk;dpd that he executed the wane for ttze purposes therein contained.
IN WrMM WHEREOF, I hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
Notarbl Seal
LOOD E TaYIK Notary Public
Hampden 11wp., Cumberland County
MY Commissbn Expires Dec. 13, 2009
r 16rn - PS-ftft& a Ar dodon or Notarlea
S?v 276 FACE28if;
Pablic
my commission expires i 3
I <<i