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Home My WebLink About13-0855 Michael J. Pykosh, Esquire I D#58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 mp ► m Attomey for Defendant ROBERT KOMOLIBIO : COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COMITY, PENNSYLVANIA V. No: 13-855 WILLIAM R. FORD, CIVIL TERM Defendant NOTICE TO PLEAD _ To: Robert Komolibio 223 N. West Street, `, .' Carlisle, PA 17013 You are hereby notified to plead to the enclosed Preliminary Objections within twenty (20) days from the date of service hereof or a default judgment may be entered against you. Respectfully Sub ' d, Date: Michael J.Nkosh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant Michael J.Pykosh,Esquire ID#58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 m Mttomey for Defendant ROBERT KOMOLIBIO . COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No: 13-855 WILLIAM R. FORD, CIVIL TERM Defendant DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT IN EJECTMENT AND NOW, comes the Defendant, William R. Ford, by and through his attorneys Dethlefs-Pykosh Law Group, LLC, by Michael J. Pykosh, Esquire, who files his Preliminary Objections to the Plaintiff's Complaint in Ejectment, and avers as follows: 1. The Complaint in Ejectment was filed on February 15, 2013. First Preliminary Objection - Pa. R.C.P. 1028(a)(2) Failure to Conform to Law or Rule of Court 2. Plaintiff failed to attach a Notice to Defend to its Complaint in Ejectment pursuant to Pa. R.C.P. No. 1018.1(a). WHEREFORE, the Defendant respectfully requests that his Preliminary Objections be sustained, and that Plaintiff's Complaint in Ejectment be dismissed with prejudice. Respectfully Submitte Date: ...�, , Michael J. PylObsh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant Michael J. Pykosh,Esquire ID#58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)875-2309 movl shr$tdoWaw.com Attorney for Defendant ROBERT KOMOLISIO . COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No: 13-855 WILLIAM R. FORD, CIVIL TERM Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant's preliminary Objections to plaintiff's Complaint in Ejectment, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Robert Komolibio 223 N. West Street Carlisle, PA 17013 Respectfully Subm' Date: . f --- MichaekJ.Pykosh, Esquire I.D. # 58851 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant ROBERT KOMOLIBIO, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM R. FORD CIVIL TERM NO. 13-855 Defendant ACTION IN EJECTMENT NOTICE TO DEFEND 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,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMAITON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle,PA 17013 ROBERT KOMOLIBIO, IN THE COURT OF COMMON PLEAS _ Plaintiff OF CUMBERLAND COUNTY, G C= PENNSYLVANIA -v3 x =r. rn N� rV QC ? -4 WILLIAM R. FORD ° s* �-_ CIVIL TERM NO. 13-855 Defendant : ACTION IN EJECTMENT 5c = - " AMENDED COMPLAINT IN EJECTMENT Robert Komolibio,by and through his attorney,Joanne Marino McGreevy,Esq. , brings this complaint in ejectment against the above-captioned Defendant,William R. Ford,and avers the following: 1. Plaintiff,Robert Komolibio, is an individual residing at 223 N. West Street, Carlisle, Pennsylvania 17013. 2. Defendant,William R. Ford,is an individual residing at 418 Fourth Street, New Cumberland,Pennsylvania 17070("the premises") more fully described in the legal description attached as Exhibit"A" 3. Plaintiff is the record owner of the premises where defendant resides,having acquired title by a Tax Claim Deed on February 4,2013, pursuant to a `4 -se's sale held in Cumberland County,Pennsylvania,on December 13, h^" 2012. Theale was authorized under the terms of an Upset Tax p Sale held by the Cumberland County,Pennsylvania,Tax Claim Bureau on December 13,2012,filed in the Court of Common Pleas of Cumberland County,Pennsylvania,Civil Division,No.2012-7755 and confirmed on January 2,2013. 4. The Tax Claim Bureau Deed conveying the premises to Plaintiff was acknowledged by Melissa E. Mixell, Director of the Tax Claim Bureau of the County of Cumberland,Commonwealth of Pennsylvania,on February 4, 2013,was delivered to the Plaintiff on February 4,2013,and was duly recorded in the office for the recording of deeds of Cumberland County on February 5,2013,as Instrument Number 201303852. 5. Defendant has no valid legal right to possession of the premises. 6. Plaintiff claims the right to possession of the premises to the exclusion of the defendant. WHEREFORE,Plaintiff seeks judgment for possession of the aforesaid premises. IP h'Vw,.,r•� AV Joanne Marino McGreevy Attorney for the Plaintiff S. Ct. No.47612 137 S. West Street Carlisle,Pennsylvania 17013 717-243-0092 w��+A3M71ithu..=cF.y.2.wrC'wirbxN`=.t:,sr..,..w,.s.a.w..t.»s�+,�4era..4v.'4«:f:5su.�iWA4+r+.Syr:y111rwr.:.uxisMM��Fii�V�W+++.srl�IMiiF HI, 3 l Wum dw 19}� day at StptCmbt r , in tba yea Wbdmn bwa"and Slow (1940) BBTW=N tfU& M 1. Nib and 1R.'t m M. I=* Lis sue. Grantors and parties of the first part► AND Nvum ti.•rt' ' of Use Gmmberlad. Cumberland qty. Pamasylvania. Grantee ad Plilm 0 sA _! gut .. _ �V of the massed gft%%TrNEitrS7;i'1.1hat add pct Sao of dM set pmt,for end in aomdandn of do mm of One (pi.tNi) � DoWk lawtat sooty of do tbked Stsho of Answioa,wail and b*rg by do Ley of do a.ommi pwt fe dw+aid pet Sae o(Go Sat W%at and bafom the m"S asd of&m prmaafy the"odpt wt vwf 6 bu*admwwlsdpd, pushed,bmp bm4 aald,.ti*4 eafeoiad, . and aooitm4 sad by dun"to do r>4 bolo* w%ab%aef*A rdmm,convey ad omdbm sate dw acid poste of the mooed W% his hdta and m 4* ALL tbat aertaia pieta or parcel of "m sit"" is ties),cough of New emobarlad, dmbarlmd tlownty, Pmmsylvamla, bounded and dsrmibad in a000cdmee with a *arm and plain tbsrmof wade by Inset J. italkwo Professional ttiwaart dated Harsh 7, 1974, as, followst ' aaGttat=at a point on the Seat side of Pomrtb ftraatt said point bNnS one. ` hrardrad aim-fiw (183) feet ia►th of tLa 000001at earner of AM*and Patrth " .t stratum tbmta.dlomt promise known oa 10. 414 Wowrth street south 66 daarses I( 30 minutes Vast one btmdred forty (140) fist to a pain an the hest side of Roby Lvenuef tbaaee a2oop the asst south 23 Asposs 30 simstaa Went 20 feat to a career of promisoo'Ynom as No-.420 Panrth atsesti themes alms said promises r !butt►66 charm 39 R mstos west one ummared forty (140) feet to a point oath. l Salt side of lowth street aforsesidi theses sue$ the "no#Forth 23 descent 30 ulmtes Seat 20 fast to the point and plans of tSCTNMr. . #AT= dwrom created a to and one-bait story frame dtnilbg..k awe as lb. 41s Wanrth accost. Safi the am& Premier which Rubsoll L. Martin and sluing W. Marna, hie wife by dead doted assambw 21, 1477, and rocordd in die item wUmd County amorderts ottiao is dead book 'b", volume, 27. pap 809, Scanted and conveyed nsto Willman a. lord and tli3ra M. Word, Grantors bomda. RtstsiIRID at THE kEWCU1NB"D 60029 LSE &W 03/2112013 4:08:11 PM CUMBERLAND COUNTY fnst.s 198002547-Pape 1 at 4 TOCBTHRR vA&aU and sbtgdar the tesroment, hmaftmeats and appmtmasoam to the aama be• lm ft or in anywbe appirtaiotnp,and the mvadm and mvwA sm,remdWw and vwmWdw% no% Imes and proDts th mi; ANA ALSO aU the estat%r1864 two,intact,property,Balm aed damaod .. wbatsonw both!o law mod equity,of the nW pram ias of tae fint•part,of,b.to or ost of the aid pre• mism and away part aad parcel thavd. . I TO HAVE AND 110 HOLD the sdd premier,with alt and AgWw the appmtemenow,emto the aid poly of the second part, his hdn and adyw6 to and for*the only proper we and s beboaf of said pars 7 of the wowtd par4 his babe and aadgna(Drava. i AND the MW parties of the first part', for themselves for their hairs hft wevatoa,and adadduratav6 do by tbata pmm*awasant.Brent and apea to and wRh the aid party of the,cooed pact. his hdn mod a dpk that the said rrr parties of the first part. for themselves, for their t r r b*4 all and dVdw the haedttaments sad I bards above desatbad and Bathed,at stastbmsd ad b mmtdad so to be.with the apportmanow crate the aaW party of she seamed park iris f Ida a".aalgor,aptbttt the aid part I" of the Bat part and their hd%and apdemt aU sad ovary other person,or penanr whommover,lawf&y elatmtog or to eldm the am or any part thereof, *4 sad wA by tba o punt%WAWWa AND FORWIR DIIFEND. ! IN WrrNESS WHEREOF,the meld parties of the fink part have beratmto at their heads. ad meal s ,the day.and year But wdttm above. >�RAtie eats ssurgasP w am A os 1 ./ C -I ,(. ......�..................... u.:...G.r......+tlG k:�l.:t.......... "...... . r�_... } 3 LVIU X. ream I ". .........................................._..."....... ................................»..................................."" ...._......". (meat.) _.................................................._......................... ...................................................................._.................... (WA+•) C ►TE OF xcsmmm i 1,ha aW amity that tba pmedme redaa m of the S=tee 418 Youth attest, Now Ci mberland, PA 1 0 _.. C014MCKWAAtrrr or Pnamrtattaa SSr } Canty of »._. l oo tbl.t>- / 7. der of 19 60,before me I the anderdrad oNOe.pamoodly appeared ELVIIA!I. FORD !mown to sa(or sdidaetodU proves)to be the pass who i4f_%LUy'�!2.�suWQlbed tq the wkLls i mtmment sad aelmowWSed that she t�c ppp thaNn I oontdsed IN WITNESS WHEREOF,I bare harmato set my hwd FL �•s�m t r Wam-b"bon 29IACf 6'91 .........."....rYG0110 ►ErCMes �1�148t......_.. .._" _. 03/21/2013 4:06:11 PM CUMBERLAND COUNTY InstJ 196002847-Page 2 of 4 ...cr2w+dr++::rta.iiaal.d..4....aw:..�snr....-.:h•.:en..y�.ry:+y7i�.a W�i��+i«c�.w�...�i.+axi.:.c:a.dh.ri:..rAAiariYiui;Jwti+'II+ItA.ING'. .. . t RIIItsS=Lvmzi cmq 1 of Dmw fitt j on sk the !9H' aay ae Sao�a„�6r- 1pao i .befaa me tba mdta omd 06104 pa=*appaarad WMI/IB 1t. r= kaowa ro aw(or 'Pweo)b be the panos wbaeo rime is ,.sabam W to tbo wlt k bwb-amok.md admwaW d tb,* he .R.o..e.d tf.....4oc.airw�Mtpoq tents i ��ses�swyww 1,�� •�' ''1AS '� ►�� 'K�aMM AEC ovi'j 11Nw wV®W sd my bead and Of tic ��t�1vr,!�•�dr� r��I i wz Ito- side of cowdyd -• { on tblr.�a ah ;1 6"A to=b(or mttehkdl7 p ov to bear ptaaa wbw to tba wltbbt f lnbumeK sod oclmotried=sd'Nnt ..=MAW the am far do porpoao dads D.t WMM WBm=y.1 hmra banNmto at my had asd ..._....................._......__ _... _..... _... .. • � i t! r i I r4 r i a + i r Zvi far R-W ft4f DOW4 eta,fs and for odid � •J. :-e Deed Book Ne Val I� 7•Q , \ WrM=my band and affim aal Ord WA:129 Pa 02 - 03/21/2013 4:08:11 PM CUMBERLAND COUNTY Inst.0 198=547-Pape 3 of 4 ROBERT KOMOLIBIO, : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V• : CIVIL TERM NO. 13-855 WILLIAM R. FORD, ; Defendant : ACTION IN EJECTMENT VERIFICATION I verify that the statements made in this Complaint in Ejectment are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§ 4904,relating to unsworn falsification to authorities. DATE ROBERT KOMOLIBIO PLAINTIFF ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 WILLIAM R. FORD, ; Defendant : ACTION IN EJECTMENT CERTIFICATE OF R V I F 1,Robert Komolibio,hereby certify that on the date indicated below,I did serve by first class mail,prepaid, a true and correct copy of the AMENDED COMPLAINT IN EJECTMENT to: Michael J. Pykosh Attorney at Law Dethlefs-Pykosh Law Group,LLC 2132 Market Street Camp Hill,PA 17011 DATE: �� r Robert Komolibio 223 N. West Street Carlisle,PA 17013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff _ Jody S Smith v ��tr ci+t umbrr;j k t HE PRO 1 I I Chief Deputy. 2013 KIIR 25 PPS 2: 26 Richard W Stewart � - CUMBERLAND Solicitor � €CE OF TI-E i - CfJW W," PENNSYLVANIA Robert Komolibio vs. Case Number William R. Ford 2013-855 SHERIFF'S RETURN OF SERVICE 03/22/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states this Complaint in Ejectment upon defendant William R. Ford is returned not served per request from attorney Joanne McGreevy. SO ANSWERS, 1�z � ate— ' – March 25, 2013 RON R ANDERSON, SHERIFF (ci CountySUite SherS,Teleoso(t Irc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;: { Sheriff 1 L I._.J- Jody S Smith ;. Chief Deputy k ? 3 � s Richard W Stewart Solicitor 0MCG OP TkE SHERIFP CUMBERLAND GU;,NI ,,. PENNSYLVANIA i Robert Komolibio vs. Case Number William R. Ford 2013-855 SHERIFF'S RETURN OF SERVICE 04/05/2013 09:02 PM-Deputy Shawn Gutshall, being duly swom according to law, served the requested Amended Complaint in Ejectment by handing a true copy to a person representing themselves to be Christine Ford, daughter of defendant,who accepted as"Adult Person in Charge"for William . Ford at 418 4th Street, New Cumberland Borough, New Cumberland, PA 17070. TSHALL, EPUTY SO ANSWERS, April 08, 2013 RON R ANDERSON, SHERIFF (c).,ours;;wto Sheriff, eleosott.h7r,. ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 c.� WILLIAM R. FORD, n CIVIL ACTION-LAW „03 w i; -r, Defendant : IN EJECTMENT Mrn ro i`- -ts =r N � F C7� 4 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT CD rn co TO: WILLIAM R. FORD T' 3' DATE OF NOTICE: April 26,201.3 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,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THE OFFICE CAN PROVIDE 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 S.Bedford Street Carlisle,PA 17013 717-249-3166 C Attorney for Plaintiff TAY3- 'q o ?. - Telephone Number ROBERT KOMOLIBIO : IN THE COURT OF COMMON PCF-AS Plaintiff OF CUMBERLAND COUNTY, -x _ PENNSYLVANIA ter' v. : CIVIL TERM: NO. 13-855 t-- � 0% a+ WILLIAM R. FORD, 5-6 CIVIL ACTION-LAW -' ' Defendant : IN EJECTMENT en CERTIFICATE OF SERVICE I, Joanne Marino McGreevy, attorney for Plaintiff, Robert Komolibio„ hereby certify that on the date indicated below,I did serve by first class mail, a true and correct copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT to: Defendant, William R. Ford 418 4" Street New Cumberland, Pennsylvania 17070 and to: Michael J. Pykosh Attorney at Law Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, P 17011 DATE: JoAme Marino McGreevy, Esq. Attorney for Plaintiff, Robert Komolibio 137 S. West Street Carlisle, PA 17013 717-243-0092 ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, Cl) PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 z WILLIAM R. FORD, x> CIVIL ACTION-LAW Defendant : IN EJECTMENT PRAECIPE TO ENTER DEFAULT JUDGMENT - C) To the Prothonotary: AND NOW,this r day of May,2013,comes the above-named Plaintiff,through his attorney,Joanne Marino McGreevy,and files this Praecipe for Entry of Default Judgment for Failure to Plead as follows: Defendant has failed to plead an Answer to Plaintiff's Amended Complaint,containing a Notice to Plead,for ejectment and possession of the premises at 418 Fourth Street,New Cumberland,title to which Plaintiff acquired on February 4,2013 from the Tax Claim Bureau of Cumberland County. Said deed was recorded as 2013-03852. Upon Defendant's failure to timely answer the Amended Complaint,written Notice of Intention to File this Praecipe was mailed to (1) the Defendant and (2) to Defendant's attorney of record on April 26,2013,by first class mail,postage prepaid; the Certificate of Service is attached hereto. As of the date of the filing of this Praecipe, 201.3,there has been no Answer filed. Pennsylvania Rule of Procedure 237.1 allows Plaintiff to file for Judgment by Default for Failure to Plead within ten days of the mailing of the Notice of Intent to File a Praecipe. An Affidavit of Non-Military Service as required by the Soldiers' and Sailors' Civil Relief Act of 2003 is attached hereto. Please issue a judgment by Default in favor of Plaintiff,Robert Komolibio,for ejectment of Defendant,and for possession of the premises at 41.8 Fourth Street,New Cumberland, PA, 1707)0 by Plaintiff,rightful owner herein. -1j7 !13 7)-u....a �'1.e Date J anne Marino McGreevy Attorney for Plaintiff ENTRY OF JUDGMENT r1 �J� AND NOW,this � t day of May,2013,Judgment is entered in favor of Plaintiff and against Defendant for ctme of De dant and for 'very of Possession of above-noted premises to Plaintif Pr otary S M1 { ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM:NO. 13-855 WILLIAM R. FORD, CIVIL ACTION-LAW Defendant : IN EJECTMENT CERTIFICATE OF SERVICE I, Joanne Marino McGreevy, attorney for Plaintiff, Robert Komolibio„ hereby certify that on the date indicated below, I did serve by first class mail, a true and correct copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT to: Defendant, William R. Ford ; 418 4t" Street c �` New Cumberland, Pennsylvania 17070 -c7 =!-n MCC :z - and to: u,.r- w sx• c5 Michael J. Pykosh y Attorney at Law c a Dethlefs-Pykosh Law Group, LLC .,� CA 2132 Market Street Camp Hill, P 17011 DATE: Joanne Marino McGreevy, Esq. Attorney for Plaintiff, Robert Komolibio 137 S. West Street Carlisle, PA 17013 717-243-0092 Joanne Marino McGreevy,Esq. Attorney for the Plaintiff 137 S. West Street Carlisle,PA 17013 717-243-0092 ROBERT KOMOLIBIO, COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL TERM: 13-855 WILLIAM R. FORD, :CIVIL ACTION-LAW Defendant : IN EJECTMENT AFFIDAVIT OF NON-MILITARY SERVICE a) 1, Joanne Marino McGreevy,Attorney for Plaintiff,verify that the Defendant WILLIAM R. FORD,is over 18 years of age;that the Defendant presently resides at 418 Fourth Street,New Cumberland,PA 17070,and that his employer,Harrisburg Auto Auction,verified that his occupation is that of driver for that employer. b) I further verify that an on-line search revealed that defendant is 73 years old, and that there are court records,to be found at Cumberland County Court of Common Pleas,Civil Docket Number 4416-2012,filed on July 16,2012,that Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Service Members' Civil Relief Act of 2003, c) I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date �7 r --a JOANNE MARINO MC GREEVY Attorney for Plaintiff ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 WILLIAM R. FORD, CIVIL ACTION-LAW Defendant : IN EJECTMENT TO; WILLIAM R. FORD You are hereby notified that on Z ,2013,the following default judgment was entered against you in the above-captioned case. Judgment has been entered for ejectment of the Defendant from and for delivery of possession of the premises at 418 Fourth Street, ew C erla , to the P ff Date �asr onotary I hereby certify that the name and address of the proper person to receive this notice is: William R. Ford 418 Fourth Street New Cumberland, PA 17070 Michael J. Pykosh,Atty-at-Law Dethlefs-Pykosh Law Group,LLC 2132 Market Street Camp Hill,PA 17011 `_'- 64 Date: v— Jo nne Marino McGreevy Attorney for Plaintiff ROBERT KOMOLIBIO IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL TERM:NO. 13-855 WILLIAM R. FORD, CIVIL ACTION-LAW Defendant IN EJECTMENT CERTIFICATE OF SERVICE 1, Joanne Marino McGreevy, attorney for Plaintiff, Robert Komolibio,hereby certify that on the date indicated below, I did serve by first class mail,postage prepaid, a true and correct copy of the PRAECIPE TO ENTER DEFAULT JUDGMENT, ENTRY OF JUDGMENT, AFFIDAVIT OF NON-MILITARY SERVICE, NOTICE OF DEFAULT JUDGMENT, PRAECIPE FOR WRIT OF POSSESSION, WRIT OF POSSESSION to: Michael J. Pykosh, Attorney-at-Law Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA, 17011 Attorney for William R. Ford 418 4' Street New Cumberland, Pennsylvania 17070. xl� DATE: Joavnne Marino McGreevy,Atty. for PlaintiW 137 S. West Street Carlisle, PA 17013 717-243-0092 ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 WILLIAM R. FORD, : CIVIL ACTION-LAW Defendant : IN EJECTMENT CERTIFICATE OF SERVICE 1, Joanne Marino McGreevy, attorney for Plaintiff, Robert Komolibio, hereby certify that on the date indicated below, I did serve by first class mail, postage prepaid, a true and correct copy of the NOTICE OF DEFAULT JUDGMENT to: William R. Ford 418 4" Street New Cumberland, Pennsylvania 17070. DATE: �u-�� c✓/ � Joa e Marino McGreevy, Atty. for Plaintiff 137 S. West Street Carlisle, PA 17013 717-243-0092 ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 WILLIAM R. FORD, CIVIL ACTION-LAW Defendant : IN EJECTMENT C"*) PRAECIPE FOR WRIT OF POSSESSION rn 3M- rn TO THE PROTHONOTARY:. Issue writ of possession in the above captioned matter. a ,:T =C) + �_ CD Joanne Marino McGreevy S.Ct. No.47612 137 S. West Street Carlisle,PA 17013 Attorney for Plaintiff,Robert Komolibio ROBERT KOMOLIBIO : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL TERM: NO. 13-855 WILLIAM R. FORD, CIVIL ACTION-LAW Defendant : IN EJECTMENT WRIT OF POSSESSION Commonwealth of Pennsylvania County of Cumberland To the Sheriff of Cumberland County (1) To satisfy the judgment for ejectment of Defendant and for delivery of possession to Plaintiff,Robert Komolibio,in the above matter,you are directed to eject the defendant and deliver possession to Plaintiff of the following property located at 418 Fourth Street,New Cumberland,Pennsylvania 17070,as described on the attached Legal Description. Prothonotary Seal,of the Court Deputy Appendix"A" Tax Parcel No. 25-25-0006-048 Legal Description ALL that certain tract of land situated in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated March 7, 1974, as follows,to wit: BEGINNING at a point on the East side of Fourth Street; said point being one hundred eighty-five (185) feet South of the southeast corner of Reno and Fourth Streets; thence along premises known as No. 416 Fourth Street South 66 degrees 30 minutes East one hundred forty (140) feet to a point on the West side of Ruby Avenue; thence along the same South 23 degrees 30 minutes West 20 feet to a corner of premises known as No. 420 Fourth Street; thence along said premises North 66 degrees 30 minutes West one hundred forty (140) feet to a point on the East side of Fourth Street aforesaid; thence along the same North 23 degrees 30 minutes East 20 feet to the point and place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling known as No. 418 Fourth Street. AND BEING Lot No. 12, Block "G" in Plan No. 3 of Ridley Park, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 14, page 22. BEING the same premises which William R. Ford and Elvira M. Ford conveyed to William R. Ford, by deed dated September 19, 1980 and recorded in the Cumberland County Recorder of Deeds Office in Book C29, Page 690. of 1 3/21/13 5:08 PM SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,01 clouti"tt OF THE Pi?0TH0N1G'jA--. Jody S Smith , x Chief Deputy .° 2013 MAY 1-5 t Richard W Stewart Solicitor C,,xrVi.YFTF, Sf.=RIFP CUMBERLAND COUNTY PENNSYLVANIA Robert Komolibio Case Number vs. William R. Ford 2013-855 SHERIFF'S RETURN OF SERVICE 05/15/2013 11:10 AM-Deputy Jason Vioral, 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:William R. Ford at his place of employment, Harrisburg Auto Auction, 1110 S York Street, Mechanicsburg, Cumberland County, PA, and informed Defendant of contents of same. JAS L, DEPUTY f SHERIFF COST: $0.00 S SWERS,� May 15, 2013 RbNW R ANDERSON, SHERIFF tc)CountySuiie Sheriff,Tefeosotf.Inc. r SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c - Sheriff Jody S Smithk rrt Chief Deputy Richard W Stewart `" °� rQ Solicitor OMCE OF THE SwERIFF Z�- � E Robert Komolibio Case Npfnbe4- vs. 2013-855 William R. Ford SHERIFF'S RETURN OF SERVICE 05/15/2013 11:10 AM - Deputy Jason Vioral, 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: William R. Ford at his place of employment, Harrisburg Auto Auction, 1110 S York Street, Mechanicsburg, Cumberland County, PA, and informed Defendant of contents of same. 05/24/2013 By virtue of this writ, Sheriff Ronny R. Anderson, caused the within named Plaintiff to have possession of the premises described as 418 4th Street, New Cumberland, PA 17070. SHERIFF COST: $0.00 SO ANSWERS, x 2x May 24, 2013 RbNW R ANDERSON, SHERIFF (c)County5uite Sheriff,Toleosofi.Inc.