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HomeMy WebLinkAbout13-1877 Supreme Co nnsylvania Coo leas For iPl t Y t ' v i Docket No: C County The information collected on this form is used solely for court administration purposes. This form does not sup lement, or re place th e filing and service of pleadings or other papers as required bylaw or rules of court. Commencement of Action: 1l Complain 0 Writ of Summons 0 Petition Transfer from Another Jurisdiction Declaration of Taking Lead Plaintiff $ Name: Lead Defendant's Name: Mid Penn Bonk 827 W. Trindle Partners, Morton S opperman and G aff T Dollar Amount Requested: Elwithin arbitration limits Are money!, damages requested? Yes No (check one) ®outside arbitration limits `` 1 Is this a Cass Action Suit? 0 4es 13 No Is this an MDJAppear 0 Yes 1l No Name of Plaintiff /Appellant's Attorney: Marc A. Hess, Esquire Check here if you have no attorney (are a Self - Represented (Pro Sep Litigant) Nature : Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 13 Intentional ® Buyer Plaintiff Administrative Agencies Q Malicious Prosecution [3 Debt Collection: Credit Card 13 Board of Assessment [3 Motor Vehicle [3 Debt Collection: Other ® Board of Elections Nuisance ® Dept. of Transportation Premises Liability ® Statutory Appeal: Other S Product Liability (does not include [ 3 Employment Dispute: mass tort) Slande�/Libel/ Defamation Discrimination C E3 Other. 13 Employment Dispute: Other 13 Zoning Board ,.T, E3 other: 0 Other: © MASS TO T © Asbestos N 13 Tobago Toxic ort - DES 13 Toxic Tor - Implant REAL, PROPERTY MISCELLANEOUS Toxic �taste Other:'. 0 Ejectment [3 Common Law /Statutory Arbitration B Q Eminent Domain/Condemnation 13 Declaratory Judgment 0 Ground Rent Mandamus [3 Q Landlord/Tenant Dispute Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESS ONAL LIABLITY 13 Mortgage Foreclosure: Commercial 13 Quo Warranto 13 Denta 13 Partition 0 Replevin 0 Legal 13 Quiet Title 13 Other: [3 Medical ❑ Other: 0 Other Professional: Updated 1/1/2011 CT . HEIL ROOTNaNOTARY 2G 1 3 APR I I AH t 1: 23 CUMBERLAND COUNTY PENNSYLVANIA HENRY & BEAVER LLP By: Mac A. Hess Identification No. 55774 937 Willow Street P.O. B 1140 Lebano , PA 17042 -1140 (717) 2 4 -3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. I No.� c 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and GARY PA. KOPPERMAN, Defendants 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. P c l ����� YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT H #VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWY R. I( 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 or (800) 990 -9108 HENRY LP By: M RC ESS It PA I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042 -1140 (717) 274 -3644 Attorney for Plaintiff AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Lancaster County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator's Office at (717) 299 -8041. All arrange ents must be made at least 72 hours prior to any hearing or business before the Cou You must attend the scheduled conference or hearing. HENR & BEAVER LLP By: Mi rc A. Hess Identification No. 55774 937 Wi low Street P.O. B x 1140 Leban n PA 17042 -1140 (717) 2 4 -3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - - LAW vs. No. 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and GARY 10. KOPPERMAN, Defendants COMPLAINT IN EJECTMENT 1. The Plaintiff is Mid Penn Bank with an office located at 5500 Allentown Boulevard, Harrisburg, Pennsylvania 17112. 2. The Defendant 827 W. Trindle Partners is a Pennsylvania general partnership with an (office located at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. . The Defendant Morton S. Kopperman is an adult individual last known to reside at 981 Ridgebury Drive, South Park, Allegheny County, Pennsylvania 15129. 4. The Defendant Gary M. Kopperman is an adult individual last known to reside at 17 North 26th Street, Camp Hill, Cumberland County, Pennsylvania 17011 and 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. . The Plaintiff seeks possession to the exclusion of the Defendants and all others of the property commonly known and numbered as 827 West Trindle Road, Mecha icsburg, Cumberland County, Pennsylvania 17055, Parcel I.D.: 22 -24- 0783 -037, and as ( more particularly described in Exhibit "A" attached hereto and incorporated herein by reference (the "Real Property"). . The Defendants are the former owners of the Real Property having acquired their title in and to the same by Deed in conveyance from Keystone Financial Bank, N.A., formerly Financial Trust, a Pennsylvania banking corporation, dated July 12, 1999 and recorded July 22, 1999 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Record Book 204, Page 390. �. The interest of the Defendants in and to the said Real Property, as well as any right to occupy the same, was extinguished and divested when the Plaintiff conducted a foreclosure through judicial sale of the Real Property on February 6, 2013 in an action captioned: Mid Penn Bank vs. 827 W. Trindle Partners, Morton S. Kopo and Ga M. Kopperman Cumberland County No. 08 -6339. �. The Defendants received notice of the foreclosure sale prior thereto as required by the Pennsylvania Rules of Civil Procedure. �. The Plaintiff is the owner of the above- referenced Real Property having receiv I d ownership of the same by virtue of the Sheriffs Sale on the Writ of Execution to Action No. 08 -6339 in the Court of Common Pleas of Cumberland County, Pennsylvania conducted February 6, 2013. The Sheriff's Deed was recorded on March 28, 2013 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument No. 20130968, Exhibit "B" attached hereto. 0. The Defendants have no valid, legal or equitable right to possession of the Real P I operty. 1. As a result of the Sheriffs Sale, the Plaintiff has full legal, equitable, complete, and marketable title to the subject Real Property. 12. The Plaintiff claims a right to possession of the Real Property to the exclusion of the [defendants. 13. The Plaintiff demands that the Defendants remove themselves and anyone claiming to or through them from the subject Real Property. h 4. To the best of the undersigned's knowledge and belief the Defendants are not in the military service. WHEREFORE, the Plaintiff, Mid Penn Bank, prays that your Honorable Court enter judgment in ejectment in favor of the Plaintiff, Mid Penn Bank, and against the Defendants, 827 W. Trindle Partners, Morton S. Kopperman, and Gary M. Kopperman, and anyone else claiming by or through them and for possession of the Real Property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County,, Pennsylvania 17055. HE7 EF LLP By: Z7 ARC . H SS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042 -1140 (717) 274 -3644 Attorney for Plaintiff MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 827 TRINDLE PARTNERS, MOR ON S. KOPPERMAN and GAR M. KOPPERMAN, Defendants VERIFICATION I, Amy Custer, being duly affirmed according to law, depose and say that I am a Vice President, Asset Recovery Manager of Mid Penn Bank, and that I am authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint in Eje�tment are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. Section 4904 relating to unsworn falsification to authorities. MID NN BANK Date: By: y us Vice nt Asset Recovery Manager ALL THOSE two (2) certain adjoining pieces or parcels of land situated in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: PARCEL NO. 1: BEGINNING at a point in the center of the Trindle Road, at the corner of prop arty formerly of C. Irvin Horrocks, Jr. and wife, now or formerly of Thomas W. Cawth rn and wife, thence along the lone of said property now or formerly of Thomas W. Cav ithern and wife, South twenty (20) degrees thirty (30) minutes East, a distance of one hu idred seventy (170) feet to a point on the line of a proposed eighteen (18) foot alley; tt ence along the line of said alley; South sixty-nine (69) degrees thirty (30) minutes West, a distance of one hundred thirty (130) feet to a point of Parcel No. 2 herein law; thence along the line of Parcel No. 2 hereinbelow, North twenty (20) degree thirty (30) minutes West, a distance of one hundred seventy (170) feet to a point in the center line of said Trindle Road, aforesaid; thence along the center Fine of said Trindle Road, North sixty -nine (69) degrees thirty (30) minutes East, a distance of one hu dred thirty (130) feet to a point, the place of BEGINNING. HAVING erected thereon a masonry commercial building known and numbered as 827 West Trindle Road, Mechanicsburg, Pennsylvania 17055. PARCEL NO. 2: BEGINNING at a point in the center line of the Trindle Road at the northw astern comer of Parcel No. 1 described hereinabove; thence in a southerly direction along the western line of said Parcel No. 1 hereinabove, a distance of one hundred seventy (170) feet, more or less, to a point on a proposed eighteen (18) foot alley; thence in a westerly direction along the northern line of said alley, a distance of twenty-five (25) feet, more or less, to a point on the eastern line of Wertz Avenue as shown on a Plan of lots known as "Revised Plan of Trindle Spring Manor ", which said Plan oi lots is recorded in the Cumberland County Recorder's Office in Plan Book 10, Page 6; thence northwardly along the eastern line of said Wertz Avenue as shown on the aforementioned Plan, a distance of one hundred seventy (170) feet, more or less, to a point in the center line of the Trindle Road; thence eastwardly along the center line of the Tri dl Road, a distance of twenty -five (25) feet, more or less, to the point and place of BE tNNING. BEING the same property conveyed by the Sheriff of Cumberland County to Mid Penn Bank by Deed dated February 28, 2013, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on March 28, 2013 at Instrument No. 20 309868. KNOWN AS 827 W. Trindle Road, Mechanicsburg, Pennsylvania PARCEL NO. 22 -24 -0783 -037 EXHIBIT "A" 00 WRC Tax Parcel No. 22 -24- 0783 -037 Know', all Men by these Presents 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 Mid Penn Bank Writ No. 2008 -6339 Civil Term Mid Penn Bank Vs 827 W. Trindle Partners Morton S. Kopperman Gary M. Kopperman ALL THOSE two (2) certain adjoining pieces or parcels of land situated in the Township of Monroe, County of Cumberland and Commor wealth of Pennsylvania, more particularly bounded and described as follows: PARCEL NO. 1: BEGINNING at a point in the center of the Trindle Road, at the comer of property formerly of C. Irvin Horrock , Jr. and wife, now or formerly of Thomas W. Cawthem and wife, thence along the lone of said property now or formerly of Thomas W. Cawthem and wife, South twenty (20) degrees thirty (30) minutes East, a distance of one hundred seventy 170) feet to a point on the line of a proposed eighteen (18) foot alley; thence along the line of said alley; South sixty - nine (69 ) degrees thirty (30) minutes West, a distance of one hundred thirty (130) feet to a point of Parcel No. 2 hereinbelow; thence al Dng the line of Parcel No. 2 hereinbelow, North twenty (20) degrees thirty (30) minutes West, a distance of one hundred seventy (170) feet to a point in the center line of said Trindle Road, aforesaid; thence along the center line of said Trindle Road, North siN ty -nine (69) degrees thirty (30) minutes East, a distance of one hundred thirty (130) feet to a point, the place of BEGINNING. HAVING erected thereon a masonry commercial building known and numbered as 827 West Trindle Road, Mechanicsburg, Pennsylvania 17055. PARCEL NO. 2: BEGINNING at a point in the center line of the Trindle Road at the northwestern comer of Parcel No. 1 describec hereinabove; thence in a southerly direction along the western line of said Parcel No. 1 hereinabove, a distance of one hundred seventy (170) feet, more or less, to a point on a proposed eighteen (18) foot alley; thence in a westerly direction along the northern line of said alley, a distance of twenty -five (25) feet, more or less, to a point on the eastern line of Wertz Avenue as shown or a Plan of lots known as "Revised Plan of Trindle Spring Manor ", which said Plan of lots is recorded in the Cumberland County R ecorder's Office in Plan Book 10, Page 36; thence northwardly along the eastern line of said Wertz Avenue as shown on the aforementioned Plan, a distance of one hundred seventy (170) feet, more or less, to a point in the center line of the Trindle Road; tht rice eastwardly along the center line of the Trindle Road, a distance of twenty -five (25) feet, more or less, to the point and place of BEGINNING. BEING the same property conveyed by Keystone Financial Bank, NA., formerly Financial Trust, a Pennsylvania banking corporation, to 827 W. Trindle Partners by Deed dated July 12, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on July 22, 1999 at Record Book 204, Page 390. KNOWN AS 827 W. Trindle Road, Mechanicsburg, Pennsylvania PARCEL NO. 22-24-0783-037 The same having been sold by me to the said grantee on the 6th day of February Anno bomini Two Thousand and Twelve (2013) after due advertisement according to law, utider and by Virtue of a Writ of Execution issued on the 31st of August Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as Y Y of Civ�l Term, Two Thousand and Eight (2008) Number 6339 at the suit of Mid Penn Bank —vs- 827 W. Trindle Partners, Morton S. Kopperman and Gary M. Kopperman i i In Witness Whereof, I have hereunto affixed my signature this 28th day of February Anno Domini Two Thousand and Thirteen (2013) Ronn . Anderson, Sheriff Com onwealth of Pennsylvania, ss. Coun of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sher* 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 4ed might be recorded. Witness my hand and seal of said Court, this 2 8 th day of �e br u a r y Anno Domini Two Thousand and Thirteen (2013 ) f1 otho • I . , e . u �' .. f �,'' • p,�,,,�,,,, Alp Cwff"M EVkU ffN� of Jm. 2014 I hereby certify that the residence And Post Office address of the Within Grantee is ,•;'f� 5500 Allentown Boulevard '! {ft�ttll +���� Harrisburg, PA 17112 e. Richard W. Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717- 240 -6370 t Instrument Number - 201309868 Record On 3/28/2013 At 10:34:28 AM * Total Pages - 5 • Instrument Type - DEED - SHERIFF'S Invoice Number - 132722 User 11) - SW • Grantor 827 WEST TRINDLE PARTNERS • Grantee M PENN BANK • Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE IT TAX $0.50 Certification Page STATE CS /ACCESS TO $23.50 JUSTIC DO NOT DETACH RECORD NG FEES — $12.50 RECORD R OF DEEDS This page 1S DOW art PARCEL,CERTIFICATION $10.00 p g P FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT MONROE TOWNSHIP $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA RECORDER OF DDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 002VMC NN 111111 1111111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c }'E Sheriff i " R0Z'H01'10 t.t � Jody S Smith ' � t013 MAY } 3 All I0* 37 Chief Deputy � � Richard W Stewart ' - Solicitor M TfA.SV RIP: P E N K S Y LVA11'31 A Mid Penn Bank Case Number vs. 827 West Trindle Partners(et al.) 2013-1877 SHERIFF'S RETURN OF SERVICE 04/11/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Morton S Kopperman, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint& Notice according to law. 04/15/2013 04:31 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Gary M Kopperman at 827 W Trindle Road, Monroe Township, Mechanicsburg PEA 17✓055. DEN,NKFRY, DEPU 04/15/2013 04:31 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Gary Kopperman owner, who accepted as"Adult Person in Charge"for 827 West Trindle Partners at 827 West Trindle Road, Monroe Township, Mechanicsburg, PA 17055. DENMfS FRY, D TY 05/03/2013 03:25 PM-The requested Complaint& Notice served by the Sheriff of Allegheny County upon Morton S Kopperman, personally, at 981 Ridgebury Drive, South Park, PA 15129. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $94.00 SO ANSWERS, May 03, 2013 RONW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. r�oAn)d SHERIF FS OFFICE OF CUMBERLAND CO TY Onny rSOn �1u o4 wiorybrr f itb Sheriff _'Jody S Smith ""-'x Richard W Stewart Chief Deputy OFFICE OF THE SftERIFF Solicitor Mid Penn Bank Case Number vs. 827 West Trindle Partners(et al.) 2013-1877 0 SERVICE COVER SHEET N c Service Deals: i 7777, o Category: jClvil Action -Complaint& Notice Zone: wCharg Manner: Adult in e ,Expires: 05/10/2013 Warrant: Notes: N LO Q a Y Serve,To: �� nt Final Service: �. Q Name: Morton S Kopperman Served: rson Adult In Charge • Posted • Other a = Primary 981 Ridgebury Drive Adult In Address: South Park, PA 15129 Charge: Phone: DOB: Relation: Alternate Date: 1 3 Time: ' 2 >- Address : V w Phone: Deputy: Mileage- 0 Attorney/Originator 'i- 00 Name: Henry&Beaver LLP Phone: 717-274-3644 Service Attempts: Date: ti T%mss: Aj Go M Mileage: Deputy. Glc 2 2 3 4 5 5 C"I Notes/Special Instructions ':_` � ' ._ _ '�' `` (,C CO MONW AL '0 PENNSYLVANIA.'`> U) Notarial Seal Z "'�co x/,3 , EEda n Woodward,Not ary Public 0 n lttsburgh,Allegheny county mission @xplres May 28,2016 0 MEMBER,PENNSyWANiA ASSOCIATION OF NOTARIES M...... ... z No r 1 13 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to Q execu a sear a of the documents herewith and make return thereof according to law. aReturn To: Cumberland County Sheriffs Office Y One Courthouse Square C` Carlisle, PA 17013 Ronny R Anderson, Sheriff (c)CountySuite Sheriff Teleosoft,Inc T . Q to F, C"ARE Rs YLD COUNTY VA NIA HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT AS TO DEFENDANTS 927 W. TRINDLE PARTNERS AND GARY M. KOPPERMAN TO THE PROTHONOTARY: Please enter judgment by default in favor of Plaintiff, Mid Penn Bank, and against Defendants, 827 W. Trindle Partners and Gary M. Kopperman, for its/his failure to plead to the Complaint in this action within the time required. The Complaint contains a Notice to Defend within twenty (20) days from the date of service thereof. Defendants 827 W. Trindle Partners and Gary M. Kopperman were served with the Complaint on April 15, 2013, and its/his answer was due to be filed on May 6, 2013. ,,,k <sa�A of rll)?l 2A4- aC?a 6��U %ate Attached as Exhibits "A" and "B", respectively, are copies of Plaintiffs written Notices of Intention to File Praecipe for Entry of Default Judgment which I certify were given to Defendants 827 W. Trindle Partners and Gary M. Kopperman in accordance with Pa.R.C.P. 237.1 by regular mail to the Defendants at its/his last known addresses on May 7, 2013, which is at least ten (10) days prior to the filing of this Praecipe. To the best of the undersigned's knowledge and belief Defendants 827 W. Trindle Partners and Gary M. Kopperman are not represented by counsel of record in the within matter. WHEREFORE, Plaintiff requests that judgment in ejectment in favor of Plaintiff, Mid Penn Bank, and against Defendants 827 W. Trindle Partners and Gary M. Kopperman and anyone else claiming by or through them and for possession of the real property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. HENRY V LP By: AR H SS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff - 2 - HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: 827 W. Trindle Partners 827 West Trindle Road Mechanicsburg, PA 17055 Date of Notice: May 7, 2013 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU V -r 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 or (800) 990-9108 HENRY B R,L By: MARC HESS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff _ 2 _ UN nW STATES POSTAL SERVICE® v ay fee,afro stamps or C! ailin rpostage here. Thls Certificate of Mailing provides evitlence th r» This fo be used fordome 'c end interns ion Sz in r AWOM�w� From: _ �- '."'PITNEY BOWES q t,QQ61�6 02 1P $ 001.20° 76012 MAY 07 2013 MAILED FROM ZIPCODE 17046 Ot`1 PA To: all PS Form 381.7,April 2007 PSN 7530-02-000-9065 OL oc\da HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: Mr. Gary M. Kopperman 17 North 26th Street Camp Hill, PA 17011 Mr. Gary M. Kopperman 827 West Trindle Road Mechanicsburg, PA 17055 Date of Notice: May 7, 2013 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 (10) 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 or (800) 990-9108 HENRY B R LL By: MA SS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff - 2 - 0 UN17EDSTATES POSTAL SERVICE® spay fee,affa stamps or O ailin postage here. This Certificate of Meiling'providesevidence m t m - rn S I This form' e.used for domesti and iMem lido y' ^ �- From: PITNEY 130WES � �� r 02 1P $ 001.200 76012 MAY 07 2013 I7 .MAILED FROM ZIPCODE 17046 To: Postrner �PNON PA 1 u l,v 1 2013 PS Form 3817,April 2007 PSN 7530-02-000-9065 USPS 11N/rEpSTUES -. POSTd ® E prq(iPSES P This Certificate of Meiling proNdes.e'denoe th �4T°�Illn "�? ay fee,aft stamps or This form m- d for domesti - - r postage here. From: dintem tk U Qp IN q_- r` � PIT BOWES °2 'P 001,200 6012 2013 Una MAILED FROM Z P CODE 1 7046 To: NON PA 1 rk Here v — unv 7 2013 PS Form 3817,April 2007 PSN 7530-02-000-9065 USPS HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: Mr. Gary M. Kopperman 17 North 26th Street Camp Hill, PA 17011 Mr. Gary M. Kopperman 827 West Trindle Road Mechanicsburg, PA 17055 NOTICE OF ENTRY OF JUDGMENT IN EJECTMENT Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by default in ejectment and for possession of the real property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 was entered against you and anyone else claiming by and through you on 2013, in the above proceeding. A copy of the Praecipe for Entry of Judgment by Default is attached hereto. PROTHONOTA Y Date: 12013 By: Depu �. ., ,. HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: 827 W. Trindle,Partners 827 West Trindle Road Mechanicsburg, PA 17055 NOTICE OF ENTRY OF JUDGMENT IN EJECTMENT Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by default in ejectment and for possession of the real property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 was entered against you and anyone else claiming by and through you on 1 , 2013, in the above proceeding. A copy of the Praecipe for Entry of Judgment by Default is attached hereto. PROTHON ARY Date: , 2013 By: `? Depu y i t 2013 Jum'. —5 CUMBERLAND C0UH*Ty HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT AS TO DEFENDANT MORTON S. KOPPERMAN TO THE PROTHONOTARY: Please enter judgment by default in favor of Plaintiff, Mid Penn Bank, and against Defendant, Morton S. Kopperman, for his failure to plead to the Complaint in this action within the time required. The Complaint contains a Notice to Defend within twenty (20) days from the date of service thereof. Morton S. Kopperman was served with the Complaint on May 3, 2013, and his answer was due to be filed on May 23, 2013. Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment which I certify was given to Defendant Morton S. kt>(6.5 a c - - 7119� aC1 ql Y JVV b c'k /Y1a.i le j Kopperman in accordance with Pa.R.C.P. 237.1 by regular mail to the Defendant at his last known address on May 24, 2013, which is at least ten (10) days prior to the filing of this Praecipe. To the best of the undersigned's knowledge and belief Defendant Morton S. Kopperman is not represented by counsel of record in the within matter. WHEREFORE, Plaintiff requests that judgment in ejectment in favor of Plaintiff, Mid Penn Bank, and against Defendant Morton S. Kopperman and anyone else claiming by or through him and for possession of the real property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. HENRY LL By: ARC A. HESS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff 2 - i HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: Morton S. Kopperman 981 Ridgebury Drive South Park, PA 15129 Date of Notice: May 24, 2013 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 (10) 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 or (800) 990-9108 HENRY LP By: M RC A. H SS I.D. #55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff Y UNITEDSTATES 90 P aMSTdL SERVICE® , pay fee,afro stamps or .C.e O` ailin 69rpostegehere. This Cwtifloate Of Mailing provides,61dence that. r This fo m aybe used fordomeshc end'tematio Z From: ' '�PITNEY BOWES 02 1 P $ 001.20° VVO 6012 MAY 24 2013 MAILED FROM ZIP CODE 1 7046 To: ryf q M Postmark Here�4� A MAY242013 I _I PS Form 3817,April 2007 PSN 7530-02-000-9065 �� HENRY & BEAVER LLP By: Marc A. Hess Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS, MORTON S. KOPPERMAN and IN EJECTMENT GARY M. KOPPERMAN, Defendants To: Morton S. Kopperman 981 Ridgebury Drive South Park, PA 15129 NOTICE OF ENTRY OF JUDGMENT IN EJECTMENT Pursuant to Pa.R.C.P. Rule 236 please be advised that judgment by default in ejectment and for possession of the real property and improvements situate at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 was entered against you and anyone else claiming by and through you on ')UYI S , 2013, in the above proceeding. A copy of the Praecipe for Entry of Judgment by Default is attached hereto. PROTHONOT RY Date: Y1L> S 2013 Bye. Deputy _ 1 C :X CD .. HENRY & BEAVER LLP - _ ' ✓ C= By: Marc A. Hess '# Identification No. 55774 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 CIS Q � MID PENN BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 13-1877 Civil 827 W. TRINDLE PARTNERS," MORTON S. KOPPERMAN� IN EJECTMENT GARY M. KOPPERMAN,-=- 17 N. c*)LA 04. gal WTrIrvile 'Pd Defendants 69mP 0;11, PA 17DII �(fZt-OA)i CSWrg. PA OMS PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a Writ of Possession in the above matter in favor of Plaintiff, Mid Penn Bank. HENR V LL *aB.5a Pty ATTY B �5 c'11 y to 3. M RC A. HES 1(p. 50 " I.D. #55774 )(0.50 it 937 Willow Street b14 -PD Am/ P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorney for Plaintiff r c� 71198 �+ op ALL THOSE two (2) certain adjoining pieces or parcels of land situated in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: PARCEL NO. 1: BEGINNING at a point in the center of the Trindle Road, at the corner of property formerly of C. Irvin Horrocks, Jr. and wife, now or formerly of Thomas W. Cawthern and wife, thence along the lone of said property now or formerly of Thomas W. Cawthern and wife, South twenty (20) degrees thirty (30) minutes East, a distance of one hundred seventy (170) feet to a point on the line of a proposed eighteen (18) foot alley; thence along the line of said alley; South sixty-nine (69) degrees thirty (30) minutes West, a distance of one hundred thirty (130) feet to a point of Parcel No. 2 hereinbelow; thence along the line of Parcel No. 2 hereinbelow, North twenty (20) degrees thirty (30) minutes West, a distance of one hundred seventy (170) feet to a point in the center line of said Trindle Road, aforesaid; thence along the center line of said Trindle Road, North sixty-nine (69) degrees thirty (30) minutes East, a distance of one hundred thirty (130) feet to a point, the place of BEGINNING. HAVING erected thereon a masonry commercial building known and numbered as 827 West Trindle Road, Mechanicsburg, Pennsylvania 17055. PARCEL NO. 2: BEGINNING at a point in the center line of the Trindle Road at the northwestern corner of Parcel No. 1 described hereinabove; thence in a southerly direction along the western line of said Parcel No. 1 hereinabove, a distance of one hundred seventy (170) feet, more or less, to a point on a proposed eighteen (18) foot alley; thence in a westerly direction along the northern line of said alley, a distance of twenty-five (25) feet, more or less, to a point on the eastern line of Wertz Avenue as shown on a Plan of lots known as "Revised Plan of Trindle Spring Manor", which said Plan of lots is recorded in the Cumberland County Recorder's Office in Plan Book 10, Page 36; thence northwardly along the eastern line of said Wertz Avenue as shown on the aforementioned Plan, a distance of one hundred seventy (170) feet, more or less, to a point in the center line of the Trindle Road; thence eastwardly along the center line of the Trindle Road, a distance of twenty-five (25) feet, more or less, to the point and place of BEGINNING. BEING the same property conveyed by Keystone Financial Bank, N.A., formerly Financial Trust, a Pennsylvania banking corporation, to 827 W. Trindle Partners by Deed dated July 12, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on July 22, 1999 at Record Book 204, Page 390. KNOWN AS 827W, . Trindle Road, Mechanicsburg, Pennsylvania PARCEL NO. 22-24-0783-037 EXHIBIT "A" a W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MID PENN BANK VS. No. 13-1877 Civil Term_ 827 W. TRINDLE PARTNERS 827 W. Trindle Rd Mechanicsburg,PA 17055 MORTON S.KOPPERMAN 981 Ridgebury Drive Southpark, PA 15129 GARY M.KOPPERMAN 17 N. 26`h Street Camp Hill, PA 17011 Costs Attorney's $ 262.25 Plaintiff's $ Prothonotary $2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County,Pennsylvania (1)To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff(s)) MID PENN BANK being: (Premises as follows): 827 WEST TRINDLE ROAD,MECHANICSBURG, PA 17055 ***********SEE ATTACHED EXHIBIT (2)To satisfy the costs against the defendant(s)you are directed to levy upon any property of the defendant(s) and sell his/her(or their)interest therein. ue11,Pror notary, Common Pleas Court of Cumberland County, PA Date 6/6/13 (Seal) 2of2 No 13-1877 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MID PENN BANK VS. 827 W.TRINDLE PARTNERS, MORTON S.KOPPERMAN and GARY M.KOPPERMAN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 262.25 Plff(sj $ Prothy $ 2.25 Sheriff $ Plaintiff(s) attorney name and address: MARC A.HESS,ESQUIRE - ID#55774 HENRY&BEAVER LLP 937 WILLOW STREET/PO BOX 1140 LEBANON,PA 17042-1140 717-274-3644 Attorney for Plaintiff(s) Where papers may be served By virtue of this writ,on the day of I caused the within named ,to have possession of the premises described with the appurtenances,and So Answers, Sworn and subscribed to before me this Day of Sheriff By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c Sheriff rrl Jody S Smith Chief Deputy t Ci)L N c-D Richard W Stewart , C7 "{ Solicitor t-. Sa !"y1 Mid Penn Bank vs. Case Number 827 West Trindle Partners (et al.) 2013-1877 SHERIFF'S RETURN OF SERVICE 06/12/2013 11:45 AM- Deputy Noah Cline, 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: Gary M Kopperman at 827 W Trindle Road, Monroe Township, Mechanicsburg, PA 17055, Cumberland County, and informed Defendant of contents of same. 06/12/2013 11:45 AM - Deputy Noah Cline, 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 Gary Kopperman, adult in charge for the Defendant, to wit: 827 West Trindle Partners at 827 W Trindle Road, Monroe Township, Mechanicsburg, PA 17055, Cumberland County, and informed Mr. Kopperman of the contents of same. 06/18/2013 10:25 AM-ALLEGHENY COUNTY RETURN-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: Morton S. Kopperman at 98 Ridgebury Drive, South Park, PA 15129, and informed Defendant of contents of same. SO ANSWERS, June 25, 2013 RONNY R ANDERSON, SHERIFF .Chan';i.r€ieOSQf. n. SHERIFF'S OFFICE OF CUMBERLAND C NTY R 74111.)onny .Ide�son ,.,,,„,, ,,i t:.ae i,b,,,,,„„ / Sheriff t�// Jody S Smith 1 Richard W Stewart Chief Deputy 6ftve, 3.r =g,, Solicitor Mid Penn Bank vs. Case Number 827 West Trindle Partners (et al.) 2013-1877 z SERVICE COVER SHEET ga .Service Details: , - - ti:.;,.,41.1*- n' a x Category: Personal Property -Possession Zone: w p Manner: Deputize Expires: Warrant: z Notes: Deputize Allegheny County Sheriffs Office to serve defendant or adult in charge with writ of possession. N g- y. ADVISE THAT DEFENDANT HAS 7_ DAYS TO VACATE THE PREMISES AT 827 W TRINDLE ROAD, v7 MECHANICSBURG, PA. ibt( ) a - Serve To: ,, ? Final4Seruicef pa: Name: Morton S Kopperman Served: Personal Adult In Charge • Posted • Other ~,, Primary 981 Ridgebury Drive Adult In n Address: South Park, PA 15129 Charge: co ui Phone: DOB: Relation: >- Alternate Date: (f i 3 1 to Time: (alas la Address: t .. "!\ re w Phone: Deputy —...._ Mileage: 2 Attorney/,Dngln for <,_i-w--74--- _ _ . t. 7,a, f ' 'Y i ,_:_ o Name: Henry& Beaver LLP Phone: 717-274-3644 Service Attempts: s s �m II¢ b , Date: Time: IIII1 I i 1 11 i i i i ! Co Mileage: [ Itilll '. [1:11E11E7:11 M o Deputy: N Notes l Spee14141si`t`uct1ons: - r . . , ti: EiWiti OF ”:'` O Calk d ,g- c e Notarial Seal Public t2 A /�,� �J�� Eda lean Woodward,Notary Z I gllegheny County �u'bLC� !l U(; , p(�� City of Pittsburgh, 28,2016 ° 1/ My Commission @xplres May O 1 , ' MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES Q Now, t pJN y 3 AAd Owl I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff g of A.i f eii e,v y County to execute service of the documents herewith and make return thereof according to law. w Return To: a0 Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F+LE 0-0Fr ICE Sheriff OF THE PRO HONOTAW ���,��xtro of+"arrn✓'+r�^���r Jody S Smith ., 2013 JUL _2 PM 2 Chief Deputy Richard W Stewart ' CU118ERLANU COUNTY Solicitor 0M CE F THE VERIFP PENNSYLVANIA Mid Penn Bank vs. Case Number 827 West Trindle Partners(et al.) 2013-1877 SHERIFF'S RETURN OF SERVICE 06/12/2013 11:45 AM-Deputy Noah Cline, 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: Gary M Kopperman at 827 W Trindle Road, Monroe Township, Mechanicsburg, PA 17055, Cumberland County, and informed Defendant of contents of same. 06/12/2013 11:45 AM- Deputy Noah Cline, 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 Gary Kopperman, adult in charge for the Defendant, to wit: 827 West Trindle Partners at 827 W Trindle Road, Monroe Township, Mechanicsburg, PA 17055, Cumberland County, and informed Mr. Kopperman of the contents of same. 06/18/2013 10:25 AM-ALLEGHENY COUNTY RETURN -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: Morton S. Kopperman at 98 Ridgebury Drive, South Park, PA 15129, and informed Defendant of contents of same. 07/01/2013 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 827 West Trindle Road, Monroe Township, Mechanicsburg, PA 17055. SHERIFF COST: $105.47 SO ANSWERS, July 02, 2013 RONIV R ANDERSON, SHERIFF pt (c)CounlySuite Sheriff,Teleosoft,Inc. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MID PENN BANK VS. No. 13-1877 Civil Term_ 827 W. TRINDLE PARTNERS 827 W. Trindle Rd Mechanicsburg,PA 17055 MORTON S.KOPPERMAN 981 Ridgebury Drive Southpark,PA 15129 GARY M. KOPPERMAN 17 N. 26`h Street Camp Hill, PA 17011 Costs Attorney's $262.25 Plaintiff's $ Prothonotary $2.25 COMMONWEALTH OF PENNSYLVANIA: , COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County,Pennsylvania (1)To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff(s)) MID PENN BANK being: (Premises as follows): 827 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 ***********SEE ATTACHED EXHIBIT (2)To satisfy the costs against the defendant(s)you are directed to levy upon any property of the defendant(s)and sell his/her(or their) interest therein. TRUE COPY FROM RECORD D.Buell,Prothono ary, In Testimony whereof,i here unto set my hand tThts the.seal of said at Cadis{20 L A } -d Of prothonotary Common Pleas Court of Cumberland County, PA Date 6/6/13 (Seal) 2of2 No 13-1877 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MID PENN BANK VS. 827 W.TRINDLE PARTNERS, MORTON S.KOPPERMAN and GARY M.KOPPERMAN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 262.25 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: MARC A. HESS, ESQUIRE - ID#55774 HENRY&BEAVER LLP 937 WILLOW STREET/PO BOX 1140 LEBANON, PA 17042-1140 717-274-3644 Attorney for Plaintiff(s) Where papers may be served By virtue of this writ, on the day of I caused the within named ,to have possession of the premises described with the appurtenances,and So Answers, Sworn and subscribed to before me this Day of , Sheriff By Prothonotary Deputy ALL THOSE two (2) certain adjoining pieces or parcels of eland situated in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: PARCEL NO. 1: 'BEGINNING at a point in the center of the Trindle Road, at the corner of property formerly of C. Irvin Horrocks, Jr. and wife, now or formerly of Thomas W. Cawthem and wife, thence along the lone of said property now or formerly of Thomas W. Cawthern and wife, South twenty (20) degrees thirty (30) minutes East, a distance of one hundred seventy (170) feet to a point on the line of a proposed eighteen (18) foot alley; thence along the,line of said alley; South sixty-nine (69) degrees thirty (30) minutes West, a distance of one hundred thirty (130) feet to a point of Parcel No. 2 hereinbelow; thence along the line of Parcel No. 2 hereinbelow, North twenty (20) degrees thirty (30) minutes West, a distance of one hundred seventy (170) feet to a point in the center line of said Trindle Road, aforesaid; thence along the center line of said Trindle Road, North sixty-nine (69) degrees thirty (30) minutes East, a distance of one hundred thirty (130)feet to a point, the place of BEGINNING. HAVING erected thereon a masonry commercial building known and numbered as 827 West Trindle Road, Mechanicsburg, Pennsylvania 17055. PARCEL NO. 2: BEGINNING at a point in the center line of the Trindle Road at the northwestern corner of Parcel No. 1 -described.hereinabove; thence in a southerly direction along the western line of said Parcel No. 1 hereinabove, a distance of one hundred seventy (170)feet, more or less, to a point.on a proposed eighteen (18) foot alley; thence in a westerly direction along the northern line of said alley, a distance of twenty-five (25) feet, more or less, to a point on the eastern line of Wertz Avenue as shown on a Plan of lots Known as "Revised Plan of Trindle Spring Manor", which said Plan of lots is recorded in the Cumberland County Recorder's Office in Plan Book 10, Page 36; thence northwardly along the eastern line of said Wertz Avenue as shown on the aforementioned Plan, a distance of one hundred seventy (170) feet, more or less, to a point in the center line of the Trindle Road; thence eastwardly along the center line of the Trindle Road, a distance of twenty-five (25)feet, more or less, to the point and place of BEGINNING. BEING the same property conveyed by Keystone Financial Bank, N.A., formerly Financial Trust, a Pennsylvania banking corporation, to 827 W. Trindle Partners by Deed dated July 12; 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on July 22, 1999 at Record Book 204, Page 390. KNOWN AS 827W_ Trindle Road, Mechanicsburg, Pennsylvania PARCEL NO. 22-24-0783-037 EXHIBIT "A"