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Home My WebLink About12-35034 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BY: TERRENCE J. McCABE, ESQUIRE - ID •# 16496, 1jAlholrkeysi for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 I EDWARD D. CONWAY, ESQUIRE - ID # 34687 rte M?' ??' _J 0, MARGARET GAIRO, ESQUIRE - ID # 34419 ?' ?`r'!'1 ?? McCABE WEISBERG AND CONWAY P C Beneficial Consumer Discount Company V. Lonnie L Stazewski and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number - I/l I COMPLAINT IN EJECTMENT NOTICE You have been sued in court. If you wish to defend against the claims 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 DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en ]as paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a ]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 C) 9, ?Sl?ld 6 124? a-lc?tq? w rJ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company CUMBERLAND COUNTY 2929 Walden Avenue Depew, New York 14043 COURT OF COMMON PLEAS vs. Number Lonnie L Stazewski and Occupants 175 North Enola Road Enola, Pennsylvania 17025 COMPLAINT IN EJECTMENT Plaintiff is the owner of the premises known as 175 North Enola Road, Enola, Pennsylvania 17025, the legal description of which is set forth in the Sheriffs Deed which is attached hereto as Exhibit "A." 2. Plaintiff acquired title by reason of a Sheriffs Sale conducted by the Sheriff of Cumberland County on March 7, 2012, by reason of Writ of Execution issued out of Cumberland County Court of Common Pleas, Civil Term 2010 No. 6345 at the suit of Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania vs. Lonnie L Stazewski. Defendants Lonnie L Stazewski and Occupants are in possession of the foregoing described premises without title, color of title, or benefit of a lease from Plaintiff. 4. Defendants are wrongfully and unlawfully in possession of the premises. Defendants have no rights of possession to said premises. 6. By reason of the aforesaid Sheriff's sale, Plaintiff holds paramount title to the a premises but Defendants continue to unlawfully and willfully retain possession and keep Plaintiff out of possession thereof and refuse to vacate and deliver up the said premises to Plaintiff. 7. No landlord tenant relationship exists between Plaintiff and Defendants, either written or oral, express or implied, and no such relationship was created as a result of the mortgage foreclosure. 8. Because there is no landlord tenant relationship - this is an action in ejectment, not eviction - there is no requirement to give Defendants a notice to quit or vacate the premises. Further, the commencement of an action in foreclosure culminating in a sheriffs sale, followed by the filing of a complaint in ejectment should have put Defendants on notice that Plaintiff intends to recover full interest, title, and possession of the premises. 9. Notwithstanding the aforesaid, Defendants have willfully remained in possession of Plaintiff s property and refuse, and still refuse to vacate the premises and continue to occupy the same. WHEREFORE, Plaintiff demands a judgment be entered in its favor for possession of the property. McCABE, WEISBERG, AND CONWAY, P.C. BY: W .w Attorneys for Plaintiff _. TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE VERIFICATION The undersigned, Jarod Salas, hereby certifies that I work in the capacity of Assistant Vice President for the plaintiff in the within action, Beneficial Consumer Discount Company. I am authorized to make this verification, and that the forgoing facts are true and correct to the best of my knowledge, based on corporate records and documentation, information and belief, and further states that false statements herein are made subject to the penalties of 18 PA.C.S. § 4904 relating to unsworn falsifications to authorities. Jarod Salas - As ' tant Vice President Beneficial Consumer Discount Company v. Lonnie L Stazewski and Occupants ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201213207 Recorded On 5/4/2012 At 9:47:56 AM * Instrument Type - DEED-SHERIFF'S Invoice Number -107572 User ID - MSW * Grantor - STAZEWSKI, LONNIE L * Grantee - BENEFICIAL CONS DISC CO * Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 EAST PENNSBORO SCHOOL $0.00 DISTRICT EAST PENNSBORO TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA -/o RECORDER O * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 002MN3 Ili INII{I1 ? ?Ilil I I III Exhibit A i3a?? Tax Parcel No. 09-14-0832-274A Know all Men by these Presents 1111111111111 That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Beneficial Consumer Discount Company. 2010-6345 Civil Term Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania VS Lonnie L. Stazewski ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. The same having been sold by me to the said grantee on the 7th day of March, Anno Domini Two Thousand and Twelve (2012) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 17th of October Anno Domini 2011 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Ten (2010) Number 6345 at the suit of Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania VS Lonnie L. Stazewski. In Witness Whereof, I have hereunto affixed my signature this 2nd Anno Domini Two Thousand and Twelve (2012) Commonwealth of Pennsylvania, ss. County of Cumberland dayof April Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 2nd day of April Anno Domini Two Thousand and T ve (2012) o ary prothonotary, ed" county, C sk, ?A My Commission Expires the First -bars. 2011 _ t'= ?/rte •,•• •- •aS.4' 3'?.l y'?\ ??: ! ?iI Ff1it? a I hereby certify that the residence And Post Office address of the Within Grantee is 2929 Walden Avenue Depew, NY 14043 Solicitor PEV-i83 EX (04-20) REALTY TRANSFER TAX RECORDER'S USE ONLY pennsylvania State Tax Paid ? DEPARTMENT OF REVENUE STATEMENT OF VALUE Book Number Bureau of Individual Taxes Page Number Po Box 280603 11b a 13 A Harrisburg, PA M28-o603 See reverse for instructions. Date Recorded 65141 Complete each section and file in duplicate with Recorder of Deeds when (1) the full value/consideration is not set forth in the deed, (2) the deed is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach additional sheets, A. CORRESPONDENT- All inquiries maybe directed to the following person: Name Telephone Number: Steven K. Eisenberg, Esq (215) 572-8111 Mailing Address City State ZIP Code 261 Old York Road, Ste. 410 Jenkintown PA 19046 B. TRANSFER DATA C. Date of Acceptance of Document Grantor(s)/Lessor(s) Grantee(s)/Lessee(s) Sheriff of Cumberland County Beneficial Consumer Discount Company Mailing Address Mailing Address One Courthouse Square, Room 303 2929 Walden Ave. City State ZIP Code City State ZIP Code Carlisle PA 117013 Depew NY 14043 D. REAL ESTATE LOCATION Street Address City, Township, Borough 175 North Enola Road _ Enola County School District Tax Parcel Number Cumberland East Pennsboro Area 14-0832-274A E. VALUATION DATA - WAS TRA NSACTION PART OF AN ASSIGNME NT OR RELOCATION? Y N 1. Actual Cash Consideration 2. Other Consideration 3. Total Consideration 1.00 +0.00 = 1.00 4. County Assessed Value S. Common Level Ratio Factor 6, Fair Market Value 98,600.00 x 1.00 = 98,600.00 la. Amount of Exemption Claimed 1b. Percentage of Grantor's Interest in Real Estate lc. Percentage of Grantor's Interest Conveyed 100.00 100 100 Check Appropriate Box Below for Exemption Claimed. ? Will or intestate succession. (Name of Decedent) (Estate File Number) ? Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ? Transfer from a trust. Date of transfer into the trust If trust was amended attach a copy of original and amended rust. ? Transfer between principal and agent/straw party. (Attach complete copy of agency/straw party agreement.) ? Transfers to the commonwealth, the U.S. and instrumentalities by gift, dedication, condemnation or in lieu of con- demnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of mortgage and note/assignment.) ? Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ? Statutory corporate consolidation, merger or division. (Attach copy of articles.) ? Other (Please explain exemption claimed.) Under penalties of taw, I declare that I have examined this statement, including accompanying information, and to the best of my knoWWge„and belief, it is true, correct and complete. Signature of Date 03/09/12 FAILURE?O COMPLETE THIS FORM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED. y, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Q7- Ronny R Anderson -4 Sheriff - , VON,,, of c"uigbrrlt'14 6r9T -- y, Jody S Smith k -? - CD Chief Deputy Richard W Stewart Solicitor OFFICEOF " Beneficial Consumer Discount Company Case Number VS. Lonnie L. Stazewski 2012-3503 SHERIFF'S RETURN OF SERVICE 06/07/2012 03:25 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2012 at 1525 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Lonnie L. Stazewski, by making known unto himself personally, at 175N. Enola Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY 06/08/2012 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: Occupant of 175 N. Enola Road, Enola, Pennsylvania 17025, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 175 N. Enola Road, Enola, Pennsylvania 17025 is only occuped by Lonnie L. Stazewski. SHERIFF COST: $64.45 June 08, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySuite Shenff. Teleosoft. Inc. 4 a McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company V. Lonnie L Stazewski and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-3503 Civil P R A E C I P E TO THE PROTHONOTARY: C"a r..a xm ? r- cnr` - ?' C7 3C AL_ c: t:. rU W Lr Kindly enter judgment for possession against the Defendants Lonnie L Stazewski and Oecupanta-in the above-captioned matter for failure to answer Complaint in twenty days as required by Pennsylvania Rules of Civil Procedure. Premises: 175 North Enola Road, Enola, Pennsylvania 17025 McCABE, WEISBERG, AND CONWAY, P BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE c? _+ 1(o . 50 a ATr/ e4l(Jq 8s ?, a led OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Curt Long Prothonotary Lonnie L Stazewski 175 North Enola Road Enola, Pennsylvania 17025 Beneficial Consumer Discount Company CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Lonnie L Stazewski and Occupants Number 12-3503 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in above proceeding as indicated below. 3W Prothonotary - Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call Christine L. Graham, Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Curt Long Prothonotary Occupants 175 North Enola Road Enola, Pennsylvania 17025 Beneficial Consumer Discount Company CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Lonnie L Stazewski and Occupants Number 12-3503 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been el in the above proceeding as indicated below. Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call Christine L. Graham, Esquire at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company v. Lonnie L Stazewski and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-3503 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law, deposes and says that Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1 as amended, and that the Defendants, Lonnie L Stazewski and Occupants , are over eighteen (? 8) years of age, and reside at 175 North Enola Road, Enola, Pennsylvania 17025. SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF 2012 NOTARY PUBLIC i /L/ TERRENCE J. McCABE, ES UIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff EA'_T CF PENNSYLVANIA SEAL "Nctdry Public is ;- ane '1ia County ?" XP,_Y , 2315 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: STAZEWSKI First Name: LONNIE L Active Duty Status As Of: Jul-10-2012 Results as of : Jul-10-12012 11.0254 SCRA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No Nq This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The. Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Data Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is th status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NCAA, Public Hea th, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly kn )wn as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that tie individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any amity member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitl d to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty -tatus date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 541 (c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual I ftActive Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report fo active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active serve authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization positi n in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the J.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who woul not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services eriods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this websit certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore. some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections oft e SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: AAIJ0009GM McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company V. Lonnie L Stazewski and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-3503 Civil CERTIFICATION The undersigned attorney for Plaintiff, being duly sworn according to law, deposes says that he deposited in the United States Mail letters notifying the Defendants that j would be entered against them within ten (10) days from the date of said letters in accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF X : -t .. .2012 TARY PUBLIC M f,,ry ?F n V NL ?'..vor FUt .c °' _' r'r!lads' is coi 'y 2,15 TERRENCE J. McCABE, ESQU RE MARC S. WEISBERG, ESQUI EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 David D. Buell Prothonotary June 28, 2012 Occupants 175 North Enola Road Enola, Pennsylvania 17025 Beneficial Consumer Discount Company CUMBERLAND COUNTY V. COURT OF COMMON PLEAS Lonnie L Stazewski and Occupants Number 12-3503 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE W 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 WITI IOUTA HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT Riot ITS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE, A LAWYER, THIS OFFICF.MAY BE ABLE TO PRO V I DE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO Dl RF.BELDIA POR NO HABER PRESENTADO UNA COMPARFCF.NCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RAD CADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFF.NSAS U OBJECT NES A LOS RF.CI.AMOS FORMULADOS EN CONTRA SUYO. AL NO OMAR LA ACC10N DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECF A DE ESTA NOTIFICACION, FL TRIBUNAL. PODRA, SIN NECE IDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUN , DICTAR SENTENCIA EN S U CONTRA Y USTED PODR I A PERDER B IF.N ;S O OTROS DI RF.CHOS. IMPORTANITS, USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGAD , VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMP AR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN BOGADO, F.STA OFICINA PUEDE SER CAPAZ DE PROPORCION RLO CON INFORMACIONACERCADELASAGENCIASQUEPUEDENOF ECERLOS SFRVICIOS LEGALES A PERSONAS ELEGIBI,FS FN UN H NORARIO REDUCIDO N] NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CONW//AY, P.C. BY: -?- Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE ANDREW L. MARKOWITZ, ESQUIR KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 David D. Buell Prothonotary June 28, 2012 Lonnie L Stazewski 17 5 North Enola Road Enola, Pennsylvania 17025 Beneficial Consumer Discount Company CUMBERLAND COUNTY V. COURT OF COMMON PLEAS Lonnie L Stazewski and Occupants Number 12-3503 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU LEAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS "LO THE CI.AIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELF.PI IONE THE OFFICE SEC FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLF, TO PROV IDE YOU WITH INFORMATION ABOUT AGENCIES TI IAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA FN ESTADO DE REBELDIA NOR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO I IABER RAD CADO POR FSCRITO CON ESTE TRIBUNAL SUS DF.FENSAS U OBJECT NES A LOS RECLAMOS FORMULADOS EN CON'T'RA SUMO. AL NO 'OMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECI A DE ESTA NOTIFICACION, EL TRIBUNAL. PODRA, SIN NECE'IDAD DE COMPARECER USTED EN CORTE U OIR PREUBA AL.GUN , DICTAR SENTENCIAENSUCONTRA YUSTEDPODRIAPERDERBIEN SUO'rROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGAD , VA A O TELEFONEA LA OFICINA EXPUSO ABA10. ESTA OFLCINA 1.0 PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DE EMPL :AR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN BOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORC[ON RLO CON INFORMATION ACERCA DE LAS AGENCIAS QUF PUEDEN OF ECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN H )NORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AIyI? C/ONWAY, P.t BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Lonnie L Stazewski and Occupants Number 12-3503 Civil AFFIDAVIT OF LAST-KNOWN ADDRESS OF DEFENDANTs I, the undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that to the best of my information, knowledge and belief, the last-known address of the Defendants are as follows: Lonnie L Stazewski and Occupants 175 North Enola Road, Enola, Pennsylvania 17025 SWORN AND SUBSCRIBED BEFORE ME THIS 1 DAY OF , 2012 OTARY PUBLIC TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff 711v1*NW7AL7H [F PENNSYLVANIA VERIFICATION The undersigned, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. McCABE, WEISBERG, AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company V. Lonnie L Stazewski and n s Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12-3503 Civil rrl M 2:::0 -c> ::z Y? Cz PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the above-captioned matter. 175 North Enola Road, Enola, Pennsylvania 17025 0 018.6o Po N-My &4. 45 W /03. 75 r' 110,50 0 aj3. c2C. PA A7ry 41.9-6- CL& D C? 1(09851 aV 9,55 C_ C r-- w -a 3 fN W Lei McCABE, WEISBERG, AND CONWAY, P.C. BY: / ' ?> r?(' ?! ?- ?/ I r: tits?`-`? Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE r= 6c cDI ; t..;9 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Beneficial Consumer Discount Company VS. Lonnie L Stazewski and Occupants 175 North Enola Road Enola, Pennsylvania 17025 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 12-3503 Civil WRIT OF POSSESSION Commonwealth of Pennsylvania } County of Cumberland } To the Sheriff of Cumberland County: (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to Beneficial Consumer Discount Company 175 North Enola Road, Enola, Pennsylvania 17025 (more fully described in legal description attached) ?osts : 0113 . A0 PD ATN ? ? ??? Q. a5 Due Co Prothonotary BY: DATE: ,.,,, 7J Y y Y ? r? nz ?d y?Z ??cm ??oy ? ??t?t??? V? °CA o ? ? t???A?v bd c? v?CC??;b C?J ?o?ddde ? 00 4k 4t 4t ?o p 4t w t04 d w A A J O O ti r w r? ? ? 1=J • CsJ . O o? r l N w 0 w C y l3d61 e-, Know all Men by these Presents Tax Parcel No. 09-14-0832-274A 11111111111 That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Beneficial Consumer Discount Company. 2010-6345 Civil Term Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania VS Lonnie L. Stazewski ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson S Smith ;f Deputy .tchard W Stewart Solicitor vayttn of clue r,rfi1140 OFFICE OF 7f4 Iz-ERIFF 22 PPS 12: 3) ,` PENNSYLVANIA Beneficial Consumer Discount Company Case Number vs. Lonnie L. Stazewski 2012-3503 SHERIFF'S RETURN OF SERVICE 08/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per request of plaintiffs attorney. 08/22/2012 Sheriff Ronny R. Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lonnie L. Stazewski, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Served" at 175 N Enola Road, Enola, PA 17025. 9 attempts at service were made; no one was home to receive the paperwork. SHERIFF COST: $77.21 SO ANSWERS, August 22, 2012 RON R ANDERSON, SHERIFF !C) OUntvSUlte Sheriff, Teleosoft. Inc .;onsumer Discount Company Case Number Stazewski 2012-3503 PERSONAL PROPERTY REQUEST LEDGER DATE CATEGORY MEMO CHK # DEBIT CREDIT 07/17/2012 Advance Fee Advance Fee 169852 $0.00 $125.00 07/17/2012 Docketing $18.00 $0.00 07/17/2012 Prothonotary 87991 $2.25 $0.00 07/17/2012 Surcharge $10.00 $0.00 08/22/2012 Postage $0.45 $0.00 08/22/2012 Service Mileage 9 attempts $45.00 $0.00 08/22/2012 Poundage $1.51 $0.00 08/22/2012 Refund 87992 $47.79 $0.00 $125.00 $125.00 TOTAL BALANCE: $0.00 Printed: 8/22/2012 10:11:49AM luu. ,yS. f, St,e,nif Te;:,csoq !n: Page 1 of 1