HomeMy WebLinkAbout13-1255 SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson c°L�D`0 F F I
Sheriff + $.::r;<
TA.
Jody S Smithati�r40 at t K''ar�b� � w,
Chief Deputy 2013 MAR 20 PM 3., 07
Richard W Stewart '
Solicitor OPME aF THE SgGRIFP CUMBERLAND COUNTY
PENNSYLVANIA
Lower Allen Township
vs. Case Number
Sun Yi Chon (et al.) 2013-1255
SHERIFF'S RETURN OF SERVICE
03/13/2013 02:32 PM-Deputy Valerie Weary, being duly sworn according to law, served the requested Writ of Scire
Facias by"personally"handing a true copy to a person representing themselves to be the Defendant, to
wit: Sun Yi Chon at 227 Ewe Rd., Lower Allen Twp., Mechanicsburg, PA 1 055.
VALERIE WEARY, DEPUTY
03/13/2013 02:32 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Writ of Scire
Facias by"personally" handing a true copy to a person representing themselves to be the Defend t, to
wit: Chang Mun Chon at 227 Ewe Rd., Lower Allen, Mechanicsburg, PA 1705 .
1.1111.VALERIE WEARY, DEPUTY
SHERIFF COST: $64.46 SO ANSWERS,
March 14, 2013 RON R ANDERSON, SHERIFF
c?CountySuite Sheriff,Teleosof Inc.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA , r
oo
LOWER ALLEN TOWNSHIP DOCKET NO. 13°'/ 5 rn
AUTHORITY �r_ -urn,
Plaintiff MUNICIPAL.LIEN DOCKEJ�- -4
13-893 MLD °`"
Vs. ,t ;1
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter default judgment pursuant to Pa.R.C.P. 1037(b) and (c) against Defendants,
Sun Yi and Chang Mun Chon on the issue of Plaintiff Lower Allen Township Authority's Writ
of Scire Facias Sur Claim for failure to file an affidavit of defense to Plaintiff's Claim within the
required time. A true and correct copy of Plaintiff's Notices of Intention to Enter Judgment by
Default as served upon Defendants, Sun Yi and Chang Mun Chon on April 25, 2013, pursuant to
Pa.R.C.P. 237.1 are attached collectively hereto and made part of this document as Exhibit"A
Damages are calculable as follows:
Funds owing from unpaid Liens $ 9,430.84
Attorneys' Fees and Costs $ t;6"
Servicing Expenses $ 168->�
Sub Total $ 12, psr'
Respectfully submitted,
DALEY ZUCKER
MEILTON & MINER, LLC
Dated:
s By:
Steven P4,Uner, Esquire
Attorney I.D.No. 389.01
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
16.,5ooa,494, (7.17) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
e
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255 CIVIL
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CAAIM
IMPORTANT NOTICE
rn r'n'
TO: Sun Yi
K=
4943 Gettysburg Road r.3 =4=
6
Mechanicsburg,PA 17055
(Defendant)
C")
5M
DATE OF NOTICE: April 25,2013
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. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION 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 MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Respectfully submitted,
DALEY ZUCKER
MEILTON"INER, LLC
Date: vjh'J 1, By:
Steven P.Miner,Esquire
Attorney ID#38901
635 N. 12'Street, Suite 101
Lemoyne,Pennsylvania 17043
(717) 724-9821
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255 CIVIL
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
CERTIFICATE OF SERVICE
1,Pamela S.Myers,Paralegal,hereby certify that on this '2013,1served
a true and correct copy of the foregoing Important Notice upon the following person(s)indicated below
by mailing a copy via the United States Mail,at Harrisburg,Pennsylvania and addressed as follows:
Sun Yi
4943 Gettysburg Road
Mechanicsburg,PA 17055
DALEYZUCKER
MEILT-ON&MINER,LLC
By: /�Vo)
Pamela S.Myers,Paralegal
635 N. 12" Street,Suite 101
Lemoyne,Pennsylvania 17043
(717)724-9821
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOWER ALLEN TOWNSHIP
DOCKET NO. 13-1255 CIVIL
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR JQLW c--
cw
IMPORTANT NOTICE
C6 , Za ,
TO: Chang Mun Chou Cnr-
_<.*. ?V
4943 Gettysburg Road r-Ze CA C)
Mechanicsburg,PA 17055
-
(Defendant) n
c-,
r"7
DATE OF NOTICE: April 25,2013
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. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION 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 MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717)249-3166
Respectfully submitted,
DALEY ZUCKER
MELTON& INER,LLC
Date: 7> 1 By:
StevenP* '
Miner Esquire
Attorney #38901
635 N. 12'Street, Suite 101
Lemoyne, Pennsylvania 17043
(717) 724-9821
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255 CIVIL
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
VS.
13-893 MLD
SUN YI and CHANG MUN CHON CIVIL DIVISION
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
CERTIFICATE OF SERVICE
I, Pamela S.Myers, Paralegal,hereby certify that on this r� {�� Y of da 2013,I served
r.
a true and correct copy of the foregoing Important Notice upon the following person(s)indicated below
by mailing a copy via the United States Mail,at Harrisburg,Pennsylvania and addressed as follows:
Chang Mun Chou
4943 Gettysburg Road
Mechanicsburg,PA 17055
DALEY ZUCKER
MEILTON&MINER, LLC
By:
Pamela S. Myers,Paralegal
635 N. 12'' Street, Suite 101
Lemoyne,Pennsylvania 17043
(717) 724-9821
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO.
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
CERTIFICATE OF SERVICE
I, Steven P. Miner, Esquire, hereby certify that on the date indicated below, I served a
true and correct copy of the foregoing Praecipe to Enter Default Judgment via United States,
First Class Mail, postage prepaid, upon the following:
Mr. Sun Yi
4943 Gettysburg Road
Mechanicsburg, PA 17055
Defendant
Ms..Chang Mun Chon
4943 Gettysburg Road
Mechanicsburg, PA 17055
Defendant
Dated: By:
Steven P Miner, squire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer@dzmmiaw.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Lower Allen Township Authority ❑Confessed Judgment
Plaintiff rj( Other
C w
vs. File No. 13-1255
Sun Yi and Chang Mun Chan Amount Due $9,430.84 ,
Defendant Interest $29.83 cs
Address: Atty's Comm $1,000.00 a ;
4943 Gettysburg Road Costs $1,545.00 =�
Mechanicsburg, PA 17055 :
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original
proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as
amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
County,for debt,interest and costs,upon the following described property of the defendant(s)
Real property located at 4943 Gettysburg Road, Lower Allen.Township,
Mechanicsburg,Pennsylvania 17055
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ ofattachnient to the Sheriff of County,for debt,interest
and costs,as above,directing attachment against the above-named garnishee(s)for the following property
(if real estate, supply,six copies of the description;`supply four copies of lengthy personalty list)
and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s).
(Indicate)Inde this writ against the garnishee(s)as a lis pendens ag m t real estate of he
def da (s. s r`bed in the attached exhibit.
Date Signature:
Ip � j Print Name: Ste en . Miner, Esquire
Address: 635 N. I2th Street,Suite 101
Lemoyne, PA 17043
� S�
Attorney f6r: Plaintiff
& . 5D 'bue. Co Telephone: (717) 724-9821
3. 50 Supreme Court ID No: 88901
7q 'V
P141 W/7:7L
r
I
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being partly
in Upper Allen Township and partly in Lower Allen Township, Cumberland County,
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the center line of the legal right-of-way line of Gettysburg
Road, at the northeast comer of lands N/F Fleming Enterprises; THENCE along the center line
of the legal right-of-way line of Gettysburg Road, North 40 degrees 13 minutes 14 seconds East
a distance of 165.88 feet to a point being the northwest comer of Lot No. 1 of the hereinafter
referenced Preliminary/Final Subdivision Plan; THENCE along the western line of said Lot No.
1, South 49 degrees 46 minutes 46 seconds East a distance of 196.03 feet to a point; THENCE
along the same, North 58 degrees 30 minutes 30 seconds East a distance of 71.06 feet to a point;
THENCE along the same, South 53 degrees 49 minutes 11 seconds East a distance of 230.81 feet
to a point on the northern legal right-of-way line of Route 15 (S.R. 0015); THENCE along said
northern legal right-of-way line of Route 15, South 51 degrees 40 minutes 12 seconds West a
distance of 636.24 feet to a point on the eastern boundary line of land N/F Smith Land &
Improvement Company; THENCE along the eastern line of said Smith Land & Improvement
Company lands, North 49 degrees 46 minutes 46 seconds West a distance of 120.94 feet to an
existing iron pin along the southern line of the aforementioned Fleming Enterprises land;
THENCE along the southern line of said Fleming Enterprises land,North 41 degrees 33 minutes
14 seconds East a distance of 372.73 feet to a point at the southeast comer of said Fleming
Enterprises land; THENCE along the eastern line of said Fleming Enterprises land, North 49
degrees 24 minutes 46 seconds West a distance of 210.00 feet to a point, the point and place of
BEGINNING.
THE FOREGOING legal description is in conformance with the Preliminary/Final
Subdivision Plan for David L. and Jamie L. Hoffman, dated June 28, 2002, last revised October
15,2002,prepared by Hoover Engineering Services, Inc., File No. 201199,recorded in the
Office of the Recorder of Deeds of Cumberland County,Pennsylvania in Plan Book 86, Page 59.
BEING Lot No. 4 of the aforementioned Preliminary/Final Subdivision Plan.
BEING A PORTION of the same premises which Thomas W.E. Hoffman and Barbara A.
Hoffinan,husband and wife, and Helen F. Hoffinan, by David L. Hoffman her Attorney in Fact
by deed dated November 12, 1993 and recorded in the Office of the Recorder of Deeds of
Cumberland County, Pennsylvania in Deed Book R, Volume 36,Page 809, granted and
conveyed unto David L. Hoffinan and Jamie L. Hoffman.
UNDER AND SUBJECT to any and all conditions,restrictions, easements,rights-of-
way,agreements and covenants of record and that a physical inspection of the property would
disclose.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 2013-1255 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LOWER ALLEN TOWNSHIP AUTHORITY
Plaintiff(s)
From SUN YI AND CHANG MUN CHON
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $9,430.84 L.L.:$.50
Interest $29.83
Arty's Comm:$1,000.00 Due Prothy:$4.50
Atty Paid: $173.96 Other Costs: $1,545.00
Plaintiff Paid:
Date: 6/5/201'3
David D.Buell,Protho otary
(Seal) By.
Deputy
REQUESTING PARTY:
Name: STEVEN P..MINER, ESQ.
Address: 635 N. 12TH STREET,SUITE 101
LEMOYNE,PA 17043
Attorney for:PLAINTIFF
Telephone:717-724-9821
Supreme Court ID No.38901
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
AFFIDAVIT PURSUANT TO RULE 3129.1
Lower Allen Township Authority, Plaintiff in the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information concerning the real
property located at 4943 Gettysburg Road, Mechanicsburg, Pennsylvania 17055:
1. Name and address of owner(s) or reputed owner(s):
r"+
Sun Yi and Chang Mun Chon - s
4943 Gettysburg Road (business address) E6
Mechanicsburg, PA 17055 �= = �
r* CFA
227 Ewe Road (residence)
Mechanicsburg, PA 17055 =C
2. Name and address of Defendant(s) in judgment:
Sun Yi and Chang Mun Chon
4943 Gettysburg Road (business address)
Mechanicsburg, PA 17055
227 Ewe Road (residence)
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record or
lien on the real property to be sold:
Lower Allen Township Authority
120 Limekiln Road
New Cumberland, PA 17070
Pennsylvania Department of Revenue
Bureau of Compliance
Lien Section
P.O. Box 280948
Harrisburg, PA 17128-0948
Sysco Guest Supply, LLC
4301 US Highway
Monmouth Junction,NJ 08852-0910
County of Cumberland
Office of Solicitor
Cumberland County Courthouse
1 Courthouse Square, Room 208
Carlisle, PA 17013
Alpha Consulting Engineers, Inc.
115 Limekiln Road
New Cumberland, PA 17070
4. Name and address of the last recorded holder of every mortgage of record:
Susquehanna Bancshares, Inc. (acquired from Graystone Tower Bank)
26 North Cedar Street
PO Box 1000
Lititz, PA 17543-7000
5. Name and address of every other person who has any record lien on the property:
N/A
t 4
6. Name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
Pennsylvania Department of Transportation
Keystone Building
400 North Street
Harrisburg, PA 17120
PPL Electric Utilities
827 Hausman Road
Allentown, PA 18104-9392
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
N/A
Respectfully submitted,
DALEY ZUCKER
MEILTON & MINER, LLC
Dated: `C I By:
St en . Miner, Esquire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
VERIFICATION
I, John J. Brossman, III, do hereby verify that I am an agent of Lower Allen Township
Authority, Plaintiff, and am authorized to make this verification on behalf of Plaintiff and that
the statements made in the foregoing Affidavit Pursuant to Rule 3129.1 are true and correct to
the best of my information, knowledge, and belief. I understand that false statements hereunder
are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
A rossman, III
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
c C=D V
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY '
Plaintiff MUNICIPAL LIEN DOCKET
13-893 MLD -�
C- -
. ,es .
VS. ac fir`
CIVIL DIVISION -.
SUN YI and CHANG MUN CHON G'
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
NOTICE OF SALE OF REAL PROPERTY
To: Sun Yi and Chang Mun Chon Sysco Guest Supply, LLC
4943 Gettysburg Road 4301 US Highway
Mechanicsburg, PA 17055 Monmouth,NJ 08852-0910
Lower Allen Township Authority PPL Electric Utilities
120 Limekiln Road 827 Hausman Road
New Cumberland, PA 17070 Allentown, PA 18104-9392
Pennsylvania Department of Revenue PA Dep. of Transportation
Bureau of Compliance Keystone Building
Lien Section 400 North Street
P.O. Box 280948 Harrisburg, PA 17120
Harrisburg,PA 17128-0948
County of Cumberland Alpha Consulting Engineers, Inc.
Office of Solicitor 115 Limekiln Road
Cumberlan d County Courthouse New Cumberland, PA 17070
1 Courthouse Square, Room 208
Carlisle, PA 17013
Susquehanna Bancshares, Inc.
26 North Cedar Street
P.O. Box 1;000
Lititz, PA 17543-7000
i
YOU ARE HEREBY NOTIFIED THAT the real estate located at 4943 Gettysburg Road,
Mechanicsburg, PA 17055, owned by Sun Yi and Chang Mun Chon, is scheduled to be sold at
the Sheriff.s Sale on September.4, 2013 at 10:00a.m. at the Cumberland County Courthouse to
enforce judgment of$9,430.84 obtained by Plaintiff against Sun Yi and Chang Mun Chon.
All parties in interest are hereby notified that a Schedule of Distribution will be filed by
the Sheriff on or before October 4, 2013, that distribution will be made in accordance with said
schedule unless exceptions are filed thereto within ten(10) days thereinafter.
Respectfully submitted,
DALEY ZUCKER
MEILTON & INER, LLC
Dated: By:
Steven Yminer, Esquire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
i
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being partly
in Upper Allen Township and partly in Lower Allen Township, Cumberland County,
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the center line of the legal right-of-way line of Gettysburg
Road, at the northeast corner of lands N/F Fleming Enterprises; THENCE along the center line
of the legal right-of-way line of Gettysburg Road, North 40 degrees. 13 minutes 14 seconds East
a distance of 165.88 feet to a point being the northwest corner of Lot No. 1 of the hereinafter
referenced Preliminary/Final Subdivision Plan; THENCE along the western line of said Lot No.
1, South 49 degrees 46 minutes 46 seconds East a distance of 196.03 feet to a point; THENCE
along the same, North 58 degrees 30 minutes 30 seconds East a distance of 71.06 feet to a point;
THENCE along the same, South 53 degrees 49 minutes l I seconds East a distance of 230.81 feet
to a point on the northern legal right-of-way line of Route 15 (S.R. 0015); THENCE along said
northern legal right-of-way line of Route 15, South 51 degrees 40 minutes 12 seconds West a
distance of 636.24 feet to a point on the eastern boundary line of land N/F Smith Land &
Improvement Company; THENCE along the eastern line of said Smith Land & Improvement
Company lands, North 49 degrees 46 minutes 46 seconds West a distance of 120.94 feet to an
existing iron pin along the southern line of the aforementioned Fleming Enterprises land;
THENCE along the southern line of said Fleming Enterprises land, North 41 degrees 33 minutes
14 seconds East a distance of 372.73 feet to a point at the southeast corner of said Fleming
Enterprises land; THENCE along the eastern line of said Fleming Enterprises land, North 49
degrees 24 minutes 46 seconds West a distance of 210.00 feet to a point, the point and place of
BEGINNING.
THE FOREGOING legal description is in conformance with the Preliminary/Final
Subdivision Plan for David L. and Jamie L. Hoffman, dated June 28, 2002, last revised October
15, 2002,prepared by Hoover Engineering Services, Inc.,File No.201199,recorded in the
Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Plan Book 86, Page 59.
BEING Lot No. 4 of the aforementioned Preliminary/Final Subdivision Plan.
BEING A PORTION of the same premises which Thomas W.E. Hoffman and Barbara A.
Hoffman,husband and wife, and Helen F. Hoffman,by David L. Hoffman her Attorney in Fact
by deed dated November 12, 1993 and recorded in the Office of the Recorder of Deeds of
Cumberland County, Pennsylvania in Deed Book R,Volume 36, Page 809, granted and
conveyed unto David L. Hoffman and Jamie L. Hoffman.
UNDER AND SUBJECT to any and all conditions, restrictions, easements,rights-of-
way, agreements and covenants of record and that a physical inspection of the property would
disclose.
r�.
C �-
IN THE COURT OF COMMON PLEAS
ca
OF CUMBERLAND COUNTY, PENNSYLVANIA 5—;
LOWER ALLEN TOWNSHIP DOC T NO. 13-1255, v
AUTHORITY ,c-, c
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD �.t +
VS. ,
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
AFFIDAVIT OF SERVICE
Steven P. Miner, Esquire, being duly sworn according to law, deposes and says that he is
an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on
the 6' day of June, 2013, he did serve upon Sysco Guest Supply, LLC, Lower Allen Township
Authority, PPL Electric Utilities, Pennsylvania Department of Revenue, Pennsylvania Department
of Transportation, County of Cumberland, Alpha Consulting Engineers, Inc. and Susquehanna
Bancshares, Inc., all parties in interest in the foregoing case, a true and correct copy of the Notice
of Sale of Real Property by sending it to them via Certified Mail, Return Receipt Requested. The
signed green cards accepting said Notice of Sale of Real Property are attached collectively as
Exhibit"A".
DALEY ZUCKER
MEILTON & MINER, LLC
Dated: / By: _
Stever P. Miner, Esquire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
EXHIBIT "A"
Postal
CERTIFIED MAIL,, RECEIPT
Ln
co N
(Domestic Only;
0^
r-�
7E, our
E f,. L U
Cr M PoG
rq certified o s3.10 u l -
r3 Retum Recelpt Fee 1•1 $2.S5 Q P e P
(Endorsement Required) p(. SS �'^� 1) l
f-3 Restricted Delivery Fee
tr (Endorsement Required $0.00
co
fU Total Postage&Fees $ (2)•If $6.11 a 3
3 Sent o�1 V U t
`43oi us H.orPO�rNo. ( qh ---------------------------
PS Form 3800,June 2002 See Reverse for Instructions
SECTION COMPLETE THIS . .
SENDER: COMPLETE THIS SECTION
• Complete items 1,2,and 3.Also complete A. Signature
Item 4 if Restricted Delivery is desired. X ❑Agent
• Print your name and address on the reverse ❑Add ee
so that we can return the card to you. g ed Dat o ry
• Attach this card to the back of the mailpiece,
or on the front If space permits.
D. Is delivery address different from Item 1? ❑
1. Article Addressed to: If YES,enter delivery address below: ❑No
sysC., Gam} su?pky,W-( .
�ySo l US 4iitc )wCLy
h on f`�X�O% `Nz �$ ^491 3. ice Type
�f Certified Mall 13 Express Mail
istered ❑Return Receipt for Merchandise
❑Insured Mail ❑C.O.D.
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number 7pO4 289 0001 3910 9852
(rmnsfer from service la►Y
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 j
Postal
CERTIFIED MAIL,. RECEIPT
,a
(Domestic Only;
Cr
For delivery information visit our website at www.usps.comlo
D' W.46 UL111
M Postage $ L16 07
CerBfied Fee 3.16
na Return Receipt Fee 17.55
(Endorsement Required) 01-557 �)
O Restricted Delivery Fae
U'
(Endorsement Required) ivy
ru Total Postage&Fees $Cp. b• Q5
O Sent o ,,pp
O To,
W��Of� TbW(1 re � `
-- - - °--------------- --
orPO8oxNo. as GMe.K% c�aad
----------------------------------------------------------- ---•---
ciry,Srare.ZJP,.New cum\ P CI 4 A 17 0 _p
PS ForYI13800,June 2002 See Reverse for Instructions
COMPLETE SENDER: COMPLETE THIS SECTION
■ Complete items 1,2,and 3.Also complete A. Si nature
Item 4 If Restricted Delivery is desired. X 1:1 Agent
Print your name and address on the reverse ❑Addressee
so that we can return the card to you. B. Regeived by(Printed Ngme) C. DaT of gelivery
• Attach this card to the back of the mailpiece,
or on the front If space permits.
D. Is delivery address different from item 1? Yes
1. Article Addressed to: If YES,enter delivery address below: ❑No
Lowcf- A16o `i"owwst ►P "
I aD Lir'neKk Road
New C"Pe-I Cv d PA 1'70'70 3. ice Type
Kegistered ertified Mail ❑Express Mail
❑Return Receipt for Merchandise
❑Insured Mall ❑C.O.D.
4. Restricted Delivery!(Extra Fee) ❑Yes
.2. Article Number 7004- 2890 0001 3910 9821
(transfer from servioe raw
PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540
Postal
o CERTIFIED MAIL-,. RECEIPT
q"D (Domestic Only;
Q^
p^ 1.11 U r
M Postage $ . 14 G
�
Certified Fee �j. G ;•10 �� Gd '
POSE"
O Retum Receipt Fee ^ #2.55
C3 (EndorsementRequired) A. S �,.6tvr4.' r PAS
C3 Restdcted Delivery Fee
Q' (Endorsement Required) �7��
co 06/�
nu Total Postage&Fees Is C.. I I
S
C3 Sent ro PPS. r-1eC.+•i �}�'t�i�1e5
C3 ` rz------------------------------------------------------- --—-
N Street,Apf No.;
orPOBoxNo. Sa� Na� a� Rood
---------------------- --- ----------isl oy- 3�'
�te,ZI A�j�fia�►n PA of
PS Form 3800,June .r
SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
• Complete items 1,2,and 3.Also complete A. Signa re
Item 4 N Restricted Delivery Is desired. ❑Agent
• Print your name and address on the reverse Addressee
so that we can return the card to you. B. Received by( nted Name) C. Date of elivery
11111111 Attach this card to the back of the mailpiece, 'I t 3
or on the front If space permits.
D. Is del"address different from item 1? Yes
1. Artic�' ddressed to: If YES,enter delivery address below: ❑ No
`ba? A ausry^an R c,8
Ier;+Owr� PP '�I Cjy— 9- 3. Service Type
1 r 11
XCertified Mail ❑Express Mall
❑'Registered ❑Return Receipt for Merchandise
❑Insured Mail ❑C.O.D.
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number -- 7004 2890 0001 3910 9760
Marmfer(mm serrrfce habeq
PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540
Postal
CERTIFIED MAIL,, RECEIPT
N (Domestic Mail Only, .•.
For delivery information visit our website at
° � L U8� �
Er
M Postage $
C3Certified Fee 3 l f7 $3.14
C3 Return Receipt Fee $2.55 P
(Endorsement Required) a• s _ C11 l
O Restricted Delivery Fee �� �� ! GjQ
Q" (Endorsement Required) �- J
co
fU Total Postage&Fees $ �O. (� X6.11 17
C3 SentTo
P� .Oe.?............. e� �e---............................
�;�r ;(?o.. &ox a�doq MS
------------------------------------------------------- -
=------------------------------
SYara.� Nc.�cr,sbu� A ►7(a�-oay 8
1�PS Form 3800,June 2002 See Reverse for Instructions
SENDER: SECTION . .
• Complete Items 1,2,and 3.Also complete A n u r
Item 4 if Restricted Delivery is desired. ❑Agent
• Print your name and address on the reverse ❑Addressee
so that we can return the card to you. e. ce ed b n d Na C. Date of Delivery
• Attach this card to the back of the mailpiece, U N
or on the front If space permits.
1. Article Addressed to: . is del ery address different from Item 1? ❑Yes
If YES,enter delivery address below: ❑No
PA OeP. oV R cvenu t-
�j t+f^fr°4 V D� Gor►PI I can Lc
L; en Sec-++r'0. 1 3. Service Type
R Certified M
all ❑Express Mail
egisteted [3 Return Receipt for Merchandise
❑Insured Mail ❑C.O.D.N 0.r^r S'oU!1J t ?A I 71a��—M 1B
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number 7004 2 8 9 0 0001 3 910 9 7 91
(rrwn*r from servfoe labeo
ipt 102595-02-M-1540
r`
U.S. Postal Service,.
0 CERTIFIED MAIL. RECEIPT
CO (Domestic Mail Only;No Insurance Coverage Provided)
Er
r-q 0117171 Er 7" -°E 77
M Postage $ 4G $0.46 001.
a 63 � '' �'
C3 ceroeed Fee 3-�Q #3.10
C3
Return Receipt Fee Postm
(Endorsement Roulred) or. 155- $2.55
� ResMcted Delivery Fee �, J
Q^ (Endors Deliequlre a \
fU Total Postege&Fees $
p nt o
C3 VA pep of 'j'cuns�ot--f��,�
N 3nosL Ap£No-------------------------------------
--- ---
orPOS�r,vo. �QO Noon S�-
cua state,27P+4 .............................•---•-------
Hacr bu� ---...
,S A PQ 0
SECTION LPS Fcrm 3800.June 2002 See Reverse for Instructions
SENDER: COMPLETE THIS SECTION COMPLETE THIS . .
• Complete items 1,2,and 3.Also complete A. Signature
item 4 if Restricted Delivery Is desired. ❑Agent
• Print your name and address on the reverse X ❑Addressee
so that we can return the card to you. B. Received by(Prin, Name) C e of Delivery
• Attach this card to the back of the maiipiece, U�Q o 7 2013
or on the front if space permits.
D. Is del"address different from Item 1? ❑Yes
1. Article Addressed to: If YES,enter delivery address below: ❑No
PA pep o `rrcknsP,ac+a+,on
14P-1S C'r) gu►ldf
y ob /�6c+h s-�-��
3. Service Type
4 Cr/sb urS i PA 171 a 0 Certified Mail ❑Express Mall
Registered ❑Retum Receipt for Merchandise
❑Insured Mail ❑C.O.D.
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article ansferuam 7004 2.890 0001, 3910 9807 -
(Trartsfi3r fiom service labep
PS Form 3811,February 2004 Domestic Return Receipt 102595-o2-M-1540
i
Postal
CERTIFIED MAIL. RECEIPT
ca�.
(Domestic
For delivery tr
information
UO visit our website at www.usps.com�o
L U S �
Ir
m Postage $ . Co $x.46
Certified Fee
C3
Q
Return ipt .
(Endo rsemerdRequiRece 55
red) .C✓Fee �� {J
O RestrictedDelivery Fee Z� t co
Er (Endorsemerrt Required) Co.
CID
ru Total Postage&Fees $ C It b6.11 1111
o em o Coun+t O�T: CAt40v-1 0.n a
orPOBoxN0.
City,state:ZJP+a Gcc 1 A 17013
PS Form 3800,June 2002 'See Reverse for Instructions—,
SECTION SENDER: COMPLETE THIS SECTION COMPLETE THIS . .
• Complete items 1,2,and 3.Also complete A. Sign
Item 4 if Restricted Delivery is desired. ` em
• Print your name and address on the reverse ❑Addressee
so that we can return the card to you. B. R ceiv y(.ifnted Name) C.Pa of 'v
• Attach this card to the back of the mailpiece, I�_l
or on the front if space permits. "'
D. Is delivery d from item 1? Fo
1. Article Addressed to: If YES,enter delivery address below:
Coc>� a3 Curyll\: )4nC�
0 ��►C.e Gy Sol.6+o<'
CU/m6{4C,00 Cax- y cbt,r+6t,5
CO(>t�`70Ucj� �}1f 0.re- 1n�,�n 3. Wice Type
Certified Mall ❑Eupress Mail
C Q�I rS�P1 PA 17 13 �]RegLstered 13 Return Receipt for Merchandise
❑Insured Mail ❑C.O.D.
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number 1
7004 2890 0001 3910 9814
{transferfromservicelabeo —
PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540
Postal Service,.
m
M ',
(Domestic Mail Only;No Insurance Coverage Provided)
U
For delivery information visit our website at
C3 �r L U .
m y C £13.46 001
Postage $ , (�
C Certified Fee 3./o 0
0 1-' al
C3 3 Retum Reoelpt Fes 2.5`i No jj
(Endorsement Required} (9.,5 5 11,
C3 Restricted Delivery Fee 01 \"fi7i,
0" (Endorsement Required) $0.00
Cc
Total Postage&Fees $ G.�( $6.11 1?0 dl�
C3 sent
C3 oAlp�G- GG(1SU� C`1 �hIf�C
Sveei ilpi T7o.; -. ... -- - ------------------>...-
ii t
or PO Box No. 1 I t t'+j"}e- go C •
City SYatB ZIRr4 ----°°• -••••-------Curnl�prlana A l�o"�a
PS Form :»» June 2002
SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTiON ON
• Complete Items 1,2,and 3.Also complete A. Si nature
item 4 if Restricted Delivery Is desired. 13 Agent
• X
Print your name and address on the reverse 0 Addressee
so that we can return the card to you. g, c Ived by(P fed ame) C. Date of DeP ery
• Attach this card to the back of the mailpiece,
or on the front If space permits.
D. is delivery address different from Item 1? [3 Yes
1. Article Addressed to: If YES,enter delivery address below: O No
A(pbcL CansuI4:,nol �Enolneets
IDA
New C.,v A Pr Jct rv-A I n 1�d/(5 3. Servfce Type
Certified Mail 0 Express Mail,
Registered 0 Return Receipt for Merchandise
❑insured Mail O C.O.D.
4. Restricted Delivery?(Extra Fee) 13 Yes
2. Article Number — — -- —---. _
(rraWwfrom service Labe¢ 7004 2890 0001 3910 9838
PS Form 3811,February 2004 Domestic Return Receipt 102595-o2-M-1540
-Postal
ut CERTIFIED MAIL, RECEIPT
CD (Domestic Mail Only;No Insurance Coverage Provided)
Q"
For delivery information visit our website at wimW.usps.cornt
a
m �3.4 t70]1
Postage $ 'y E ,,q 11115A
Q Certified Fee 3 .fib X3.10 J 1 os4na
O Return Receipt Fee $2
(Endorsement Required) o'�, 55
O
Er Delivery Fee �{].tlQ 0
� (Endorsement nt Required)quired)
co ru Total Postage rf Fees rp. fit;•1 n
LISPS
O Sent TO
C3 St�quc�4nnc,. �}Qr�c. Q�G ,. nc,
or PO Box No.eXG N• C dear . Q ( * 1066
'L1...,...�--------------- -' --- - ------ -
�in,state z� .* 17 5 3 yCob
COMPLETE SENDER: COMPLETE THIS SECTION
■ Complete items 1,2,and 3.Also complete AM���j Sit
Item 4 If Restricted Delivery is desired. '
■ Print your name and address on the reverse Agent
so that we can return the card to you. Addressee
■ Attach this card to the back of the mailpiece, C Date of Delivery
Or on the front if space permits.
1. Article Addressed to: D. Is delivery address different from Item 1? 13 Yes
SUIf YES,enter delivery address below: Q$'No
'CtUe gQC�cS�arcgi
dG Nxr+�n Cedar Sire_,+
R0 &x ! D66
L I 1+z, � i�5y 2 7 DQ C) T4Rastdrtd Service Ty7Mall press Mail
-1 J CertifieO 6c❑Regis ter ❑Retum Receipt for Merchandise
❑Insured ❑C.O.D.
Delivery?(Extra Fee) 13 Yes
z. Article Number
(b 7004 2 8 9 0 0 0 01 3 910 9 8 4 5
ansli3r from service lsbeQ -,
PS Form 3811,February 2004 Domestic Return Receipt
102595-02-M-1540 r
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
CERTIFICATE OF SERVICE
I, Steven P. Miner, Esquire, hereby certify that on the date indicated below, I served a
true and correct copy of the foregoing Affidavit of Service via United States, First Class Mail,
postage prepaid, upon the following:
Mr. Sun Yi
4943 Gettysburg Road
Mechanicsburg, PA 17055
Defendant
Ms. Chang Mun Chon
4943 Gettysburg Road
Mechanicsburg, PA 17055
Defendant
Dated: k C By:
Steven P. finer, squire
Attorney I.D. No. 38901
635 N: 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
A SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson ; - _ :Il,G'.
' ��-
Sheriff fib I I`R0 T rH0N0 1,P%Y
Jody S Smith
Chief Deputy 2013 SEP 10 AM 10: 1
K.;
Richard W Stewart
Solicitor OF�cecFTPEs�.E IFS CUMBERLAND COUNTY
PENNSYLVANIA
Lower Allen Township
Case Number
vs.
Sun Yi Chon (et al.) 2013-1255
SHERIFF'S RETURN OF SERVICE
06/25/2013 05:38 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be Chang Mon Chon -
Husband, who accepted as"Adult Person in Charge"for Sun Yi Chon at 227 Ewe Rd., Lower Allen Twp.,
Mechanicsburg, PA 17055, Cumberland County.
06/25/2013 05:38 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Chang Mun Chon at 227 Ewe Rd., Lower Allen, Mechanicsburg, PA 17055, Cumberland County.
06/25/2013 05:59 PM -Deputy Jason Vioral, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 4943 Gettysburg Road, Lower Allen -Township,
Mechanicsburg, PA 17055, Cumberland County.
08/06/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1,500.00 SO ANSWERS,
September 06, 2013 RbNW R ANDERSON, SHERIFF
o
.2 75 ;Z;�
(c)CountySuite Sheriff,TeleosoR,Inc.
a
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
AFFIDAVIT PURSUANT TO RULE 3129.1
Lower Allen Township Authority, Plaintiff in the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information concerning the real
property located at 4943 Gettysburg Road, Mechanicsburg, Pennsylvania 17055:
1. Name and address of owner(s) or reputed owner(s):
Sun Yi and Chang Mun Chon
4943 Gettysburg Road (business address)
Mechanicsburg, PA 17055
227 Ewe Road (residence)
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in judgment:
Sun Yi and Chang Mun Chon
4943 Gettysburg Road (business address)
Mechanicsburg, PA 17055
227 Ewe Road (residence)
Mechanicsburg, PA 17055
s
3. Name and last known address of every judgment creditor whose judgment is a record or
lien on the real property to be sold:
Lower Allen Township Authority
120 Limekiln Road
New Cumberland, PA 17070
Pennsylvania Department of Revenue
Bureau of Compliance
Lien Section
P.O. Box 280948
Harrisburg, PA 17128-0948
Sysco Guest Supply, LLC
4301 US Highway
Monmouth Junction,NJ 08852-0910
County of Cumberland
Office of Solicitor
Cumberland County Courthouse
1 Courthouse Square, Room 208
Carlisle, PA 17013
Alpha Consulting Engineers, Inc.
115 Limekiln Road
New Cumberland, PA 17070
4. Name and address of the last recorded holder of every mortgage of record:
Susquehanna Bancshares, Inc. (acquired from Graystone Tower Bank)
26 North Cedar Street
PO Box 1000
Lititz, PA 17543-7000
5. Name and address of every other person who has any record lien on the property:
N/A
S `
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Pennsylvania Department of Transportation
Keystone Building
400 North Street
Harrisburg,PA 17120
PPL Electric Utilities
827 Hausman Road
Allentown, PA 18104-9392
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
N/A
Respectfully submitted,
DALEY ZUCKER
MEILTON & MINER, LLC
t / J
Dated: `C By:
St en . Miner, Esquire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
VERIFICATION
I, John J. Brossman, III, do hereby verify that I am an agent of Lower Allen Township
Authority, Plaintiff, and am authorized to make this verification on behalf of Plaintiff and that
the statements made in the foregoing Affidavit Pursuant to Rule 3129.1 are true and correct to
the best of my information, knowledge, and belief. I understand that false statements hereunder
are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
ohn J. rossman, III
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
NOTICE OF SALE OF REAL PROPERTY
To: Sun Yi and Chang Mun Chon Sysco Guest Supply, LLC
4943 Gettysburg Road 4301 US Highway
Mechanicsburg, PA 17055 Monmouth,NJ 08852-0910
Lower Allen Township Authority PPL Electric Utilities
120 Limekiln Road 827 Hausman Road
New Cumberland, PA 17070 Allentown, PA 18104-9392
Pennsylvania Department of Revenue PA Dep. of Transportation
Bureau of Compliance Keystone Building
Lien Section 400 North Street
P.O. Box 280948 Harrisburg, PA 17120
Harrisburg, PA 17128-0948
..County of Cumberland Alpha Consulting Engineers, Inc.
Office of Solicitor 115 Limekiln Road
Cumberland County Courthouse New Cumberland, PA 17070
1 Courthouse Square, Room 208
Carlisle,PA 17013
Susquehanna Bancshares, Inc.
26 North Cedar Street
P.O. Box 1000
Lititz, PA 17543-7000
YOU ARE HEREBY NOTIFIED THAT the real estate located at 4943 Gettysburg Road,
Mechanicsburg, PA 17055, owned by Sun Yi and Chang Mun Chon, is scheduled to be sold at
the Sheriff's Sale on September 4, 2013 at 10:00a.m. at the Cumberland County Courthouse to
enforce judgment of$9,430.84 obtained by Plaintiff against Sun Yi and Chang Mun Chon.
All parties in interest are hereby notified that a Schedule of Distribution will be filed by
the Sheriff on or before October 4, 2013, that distribution will be made in accordance with said
schedule unless exceptions are filed thereto within ten (10) days thereinafter.
Respectfully submitted,
DALEY ZUCKER
MEILTON & INER, LLC
Dated: L By:
Steven yMiner, Esquire
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being partly
in Upper Allen Township and partly in Lower Allen Township, Cumberland County,
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the center line of the legal right-of-way line of Gettysburg
Road, at the northeast corner of lands N/F Fleming Enterprises; THENCE along the center line
of the legal right-of-way line of Gettysburg Road, North 40 degrees 13 minutes 14 seconds East
a distance of 165.88 feet to a point being the northwest corner of Lot No. 1 of the hereinafter
referenced Preliminary/Final Subdivision Plan; THENCE along the western line of said Lot No.
1, South 49 degrees 46 minutes 46 seconds East a distance of 196.03 feet to a point; THENCE
along the same, North 58 degrees 30 minutes 30 seconds East a distance of 71.06 feet to a point;
THENCE along the same, South 53 degrees 49 minutes 11 seconds East a distance of 230.81 feet
to a point on the northern legal right-of-way line of Route 15 (S.R. 0015); THENCE along said
northern legal right-of-way line of Route 15, South 51 degrees 40 minutes 12 seconds West a
distance of 636.24 feet to a point on the eastern boundary line of land N/F Smith Land &
Improvement Company; THENCE along the eastern line of said Smith Land & Improvement
Company lands, North 49 degrees 46 minutes 46 seconds West a distance of 120.94 feet to an
existing iron pin along the southern line of the aforementioned, Fleming Enterprises land;
THENCE along the southern line of said Fleming Enterprises land,North 41 degrees 33 minutes
14 seconds East a distance of 372.73 feet to a point at the southeast corner of said Fleming
Enterprises land; THENCE along the eastern line of said Fleming Enterprises land, North 49
degrees 24 minutes 46 seconds West a distance of 210.00 feet to a point, the point and place of
BEGINNING.
THE FOREGOING legal description is in conformance with the Preliminary/Final
Subdivision Plan for David L. and Jamie L. Hoffman, dated June 28, 2002, last revised October
15, 2002,prepared by Hoover Engineering Services, Inc., File No. 201199, recorded in the
Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Plan Book 86, Page 59.
BEING Lot No. 4 of the aforementioned Preliminary/Final Subdivision Plan.
BEING A PORTION of the same premises which Thomas W.E. Hoffman and Barbara A.
Hoffman,husband and wife, and Helen F. Hoffman,by David L. Hoffman her Attorney in Fact
by deed dated November 12, 1993 and recorded in the Office of the Recorder of Deeds of
Cumberland County, Pennsylvania in Deed Book R, Volume 36, Page 809, granted and
conveyed Lento David L. Hoffman and Jamie L. Hoffman.
UNDER AND SUBJECT to any and all conditions, restrictions, easements,rights-of-
way, agreements and covenants of record and that a physical inspection of the property would
disclose.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 2013-1255 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LOWER ALLEN TOWNSHIP AUTHORITY
Plaintiff(s)
From SUN YI AND CHANG MUN CHON
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $9,430.84 L.L,:$.50
Interest $29.83
Arty's Conun:$1,000.00 Due Prothy:$4.50
Atty Paid: $173.96 Other Costs: $1,545.00
Plaintiff Paid:
Date:6/5/2013
David,D.Buell,*Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: STEVEN P. MINER,ESQ.
Address:635 N. 12TH STREET,'SUITE 101
LEMOYNE,PA 17043
Attorney for: PLAINTIFF TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
Telephone: 717-724-9821 and the seal of said Court at Carlisle,Pa,
Supreme Court ID No.38901 This 5* day of ,20
Prothonotary
C
On June 11, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA,
Known and numbered as, 4943 Gettysburg Road,
Mechanicsburg, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
Date: June 11, 2013
L_
" By:
I-j
Real Estate Coordinator
LL-
U_ '
r�
LXII 30 CUMBERLAND LAW JOURNAL 07/26/13
2013-1255 Civil Term Fleming Enterprises land, North 41
degrees 33 minutes 14 seconds East
LOWER ALLEN TOWNSHIP a distance of 372.73 feet to a point
at the southeast comer of said Flem-
vs. ing Enterprises land;THENCE along
SUN YI CHON,Chang Mun Chon the eastern line of said Fleming En-
Atty.: Steven P. Miner terprises land, North 49 degrees 24
ALL THAT CERTAIN tract or minutes 46 seconds West a distance
of 210.00 feet to a point, the point
parcel of land and premises situate,
and place of BEGINNING.
1 Y mg and bein g partly in Upper Allen
THE FOREGOING legal descrip-
Township and partly in Lower Allen tion is in conformance with the
Township, Cumberland County, Preliminary/Final Subdivision Plan
Pennsylvania, more particularly de- for David L. and Jamie L. Hoffman,
scribed as follows: dated June 28,2002,last revised Oc-
BEGINNING at a point on the cen- tober 15, 2002,prepared by Hoover
ter line of the legal right-of-way line Engineering Services, Inc., File No.
of Gettysburg Road,at the northeast 201199,recorded in the Office of the
corner of lands N/F Fleming Enter- Recorder of Deeds of Cumberland
prises;THENCE along the center line County, Pennsylvania in Plan Book
of the legal right-of-way line of Get- 86,Page 59. BEING Lot No. 4 of the
tysburg Road, North 40 degrees 13 aforementioned Preliminary/Final
minutes 14 seconds East a distance Subdivision Plan.
of 165.88 feet to a point being the BEING A PORTION of the same
northwest corner of Lot No. 1 of the premises which Thomas W.E. Hoff-
hereinafter referenced Preliminary/ man and Barbara A. Hoffman,han,
Final Subdivision Plan; THENCE band vidL.Hand Helen A F.Hoffman,
along he western line of said Lot No. by David L.Hoffman her Attorney in
g Fact by deed dated November 12,
1, South 49 degrees 46 minutes 46 1993 and recorded in the Office of
seconds East a distance of 196.03 the Recorder of Deeds of Cumberland
feet to a point; THENCE along the County, Pennsylvania in Deed Book
same, North 58 degrees 30 minutes R,Volume 36,Page 809,granted and
30 seconds East a distance of 71.06 conveyed unto David L.Hoffman and
feet to a point; THENCE along the Jamie L. Hoffman.
same, South 53 degrees 49 minutes UNDER AND SUBJECT to any
11 seconds East a distance of 230.81 and all conditions,restrictions,ease-
feet to a point on the northern legal ments, rights-of- way, agreements
right-of-way line of Route 15 (SR. and covenants of record and that a
0015);THENCE along said northern physical inspection of the property
legal right-of-way line of Route 15, "Would disclose.
South 51 degrees 40 minutes 12
seconds West a distance of 636.24
feet to a point on the eastern bound-
ary line of land N/F Smith Land &
Improvement Company; THENCE
along the eastern line of said Smith
Land & Improvement Company
lands,North 49 degrees 46 minutes
46 seconds West a distance of 120.94
feet to an existing iron pin along the
southern line of the aforementioned
Fleming Enterprises land; THENCE
along the southern line of said
36
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 26, August 2 and August 9, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Lisa Marie Coy+, Editor
SWORN TO AND SUBSCRIBED before me this
da of August, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.
K _ 1900 Patriot Drive
Mechanicsburg, PA 17050
Inquiries - 717-255-8213 Now you know
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael J. Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of
Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday .
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since-,
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
07/28/13
2013-1255 Civil Tenn 08/04/13
LO R ALLEN TOWNS P
vs. 08/11113
SUN YI CMON
Chang Mun Chon
AW. Steven R Miner
ALL THAT CERTAIN tract or parcel of j
land and premises situate,lying and being I
partly in Upper Allen Township and partly in Sworn to d subscribed be e this 23 day of August, 2013 A.D.
Lower Allen Township,Cumberland County,
Pennsylvania,more particularly described as
follows: A I a4
BEGINNING at a point on the center line
of the legal right-of-way line of Gettysburg 0 ary Public
Road,at the northeast corner of lands N/F
Fleming Enterprises; THENCE along the I
center line of the legal right-of-way line i
of Gettysburg Road, North 40 degrees t
13 minutes seconds East a distance I COMMONWEALTH OF PENNSYLVANIA
165.88 feet to o a point being the northwest st I
comer of Lot No. 1 of mom--ter Notarial Seat
referenced Preliminary/Final Subdivision Holly Lynn Warfel,Notary Public
Plan;THENCE along the western line of , Washington TWA.,Dauphin County
My Commission Expires Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
IN THE COURT OF COMMON'PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned matter SATISFIED of record and
DISCONTINUE and END the above-captioned case. s
r ;;
3>n'
5-
Respectfully submitted, cn '
DALEY ZUCKER
MEILTON & MINER, LLC
Dated: By:
Steven mer, Esquire
Attorn y I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com
Attorney for Plaintiff
#4.50 P o AYtJ
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOWER ALLEN TOWNSHIP DOCKET NO. 13-1255
AUTHORITY
Plaintiff MUNICIPAL LIEN DOCKET:
13-893 MLD
VS.
CIVIL DIVISION
SUN YI and CHANG MUN CHON
Defendants WRIT OF SCIRE FACIAS SUR CLAIM
CERTIFICATE OF SERVICE
I, Steven P. Miner, Esquire, hereby certify that on the date indicated below, I served a
true and correct copy of the foregoing Praecipe for Satisfaction of Judgment via United States,
First Class Mail, postage prepaid, upon the following:
William Grubb, Esquire
3803 Old Gettysburg Road
Camp Hill, PA 17011
Counsel for Defendants
Sun Yi Chon
Chang Mun Chon
4943 Gettysburg Road
Mechanicsburg, PA 17055
Defendants
Dated: y By:
Steve P.Miner,Esquire
Attorney I.D.No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer @dzmmlaw.com