HomeMy WebLinkAbout13-3821 Supreme Court of Pennsylvania
Co. om leas
C�'uer S t For Prothonotary Use Only:
C Ed.NI) County
Jx N
M vx a
Docket No:
r
F ,.
The information collected on this form is used solely for court administration purposes. This form does not supplement or
replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
❑x Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff s Name: Lead Defendant's Name:
C VRM (VENDOR RESOURCE MANAGEMENT), JAMES W. KAUTZ, JR or Occupants
T DULY AUTHORIZED AGENT FOR THE
I SECRETARY OF VETERANS AFFAIRS
O Name of Plaintiff/Appellant's Attorney: Phelan Hallinan, LLP
N
A El Check here if you have no attorney are a Self-Represented Pro Sel Litigant
Are money damages requested?: ❑ Yes 64 No Dollar Amount Requested: ❑ within arbitration limits
(Check one) ❑ outside arbitration limits
Is this a Class Action Suit? ❑ Yes §1 No Is this an MDJ Appeal? ❑ Yes ANo
Nature of the Case 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 CIVIL APPEALS
❑ Intentional Judgments) Administrative Agencies
❑ Malicious Prosecution ❑ Buyer Plaintiff ❑ Board of Assessment
• Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections
• Nuisance ❑ Debt Collection: Other ❑ Dept. of Transportation
• Premises Liability ❑ Statutory Appeal: Other
• Product Liability (does not
include mass tort)
• Slander/Libel/ Defamation ❑ Employment Dispute:
S ❑ Other: Discrimination ❑ Zoning Board
E ❑ Employment Dispute: Other ❑ Other:
C
T
I MASS TORT
O ❑ Asbestos ❑ Other:
N ❑ Tobacco
• Toxic Tort - DES
B ❑ Toxic Tort - Implant
• Toxic Waste REAL PROPERTY MISCELLANEOUS
• Other: Ejectment ❑ Common Law /Statutory Arbitration
❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure Residential Restraining Order
• Dental ❑ Mortgage Foreclosure Commercial ❑ Quo Warranto
• Legal ❑ Partition ❑ Replevin
• Medical ❑ Quiet Title ❑ Other:
• Other Professional: ❑ Other:
Pa.R.C.P. 205.5 Updated 1/1/2011
L" _e
OF Phelan Hallinan, LLP
By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff -ate w
1617 JFK Boulevard, Suite 1400 4,
One Penn Center Plaza
Philadelphia, PA 19103'
215 -563 -7000 ��, CD .� c:D °
a fi r
VRM (VENDOR RESOURCE Court of Common Pleas w `" y,4 r
MANAGEMENT), DULY AUTHORIZED
AGENT FOR THE SECRETARY OF Civil Division
VETERANS AFFAIRS
4100 INTERNATIONAL PKWY, SUITE 1000 CUMBERLAND County
CARROLLTON, TX 75007
13
Plaintiff No. U�
V.
JAMES W. KAUTZ, JR or Occupants
15 DEER DRIVE
NEWVILLE, PA 17241
Defendant
CIVIL ACTION — EJECTMENT
"This firm is a debt collector attempting to collect a debt and any information obtained will be used for
that purpose. If you have previously received a discharge in bankruptcy and this debt was not
reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but
only enforcement of a lien against property."
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 (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 and other claim or relief requested by the plaintiff. You may lose money or property
or other rights important to you.
You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford
one, go to or telephone the office set forth below to find out where you can get legal help. 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
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249 -3166
PHS # 322123
1. Plaintiff is VRM (VENDOR RESOURCE MANAGEMENT), DULY AUTHORIZED AGENT
FOR THE SECRETARY OF VETERANS AFFAIRS.
2. Defendant is JAMES W. KAUTZ, JR or Occupants.
3. Plaintiff is the record owner of premises located at 15 DEER DRIVE, NEWVILLE, PA 17241, a
legal description of which is attached.
4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the
Sheriff of CUMBERLAND County, on 5/01/2013, as evidenced by the Sheriffs deed recorded
06/19/2013 in the Office of the Recorder of CUMBERLAND County in Instrument 201320099.
5. Plaintiff, by virtue of the above, is the record owner of said premises, and is entitled to possession
thereof. The defendant is occupying the said premises without right and so far as the plaintiff is
informed, without claim of title.
6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to
deliver up possession of same.
WHEREFORE, Plaintiff seeks to recover possession of the Premises.
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
Phelan Hallinan, LLP
' Legal Description
ALL THAT CERTAIN tract of land situate in Cooke Township, Cumberland County,
Pennsylvania, bounded and described in accordance with Final Subdivision Plan of Pinebrook,
prepared by William B. Whittock, Registered Professional Engineer, dated October 19, 1977,
consisting of two pages, recorded in the hereinafter named Recorder's Office in Plan Book 42,
Page 146, and incorporated herein by reference, as follows:
BEGINNING at a point in the center of Deer Drive cul -de -sac, which has a radius of 50 feet at
corner common to Lot Nos. 14, 15, 16 and 17; thence from said point at the place of beginning,
along the dividing line between said Lot Nos. 15 and 16, South 64 degrees 26 minutes 44
seconds East, a distance of 248.62 feet to a point in line of land now or formerly of
Commonwealth of Pennsylvania; thence along line of said land now or formerly of
Commonwealth of Pennsylvania, South 44 degrees 30 minutes 00 seconds West, a distance of
308.88 feet to a point at the dividing line between Lot Nos. 11 and 15; thence along the dividing
line between Lot Nos. 11 and 15, North 62 degrees 59 minutes 20 seconds West, a distance of
78.14 feet to a point at the dividing line between Lot Nos. 14 and 15; thence along said dividing
line between Lot Nos. 14 and 15, North 11 degrees 56 minutes 56 seconds East, a distance of
298.54 feet to a point in the center of said Deer Drive cul -de -sac at the place of BEGINNING.
The above described tract of land contains a net area of 1.054 acres exclusive of the dedicated
right of way of Deer Drive cul -de -sac, and is all of Lot No. 15 as shown on said Final
Subdivision Plan of Pinebrook, recorded as aforesaid.
So much of the above described tract of land as lies with 50 feet of the center of Deer Drive cul-
de -sac has been dedicated as a portion of the right of way of said Deer Drive cul -de -sac as shown
on said Final Subdivision Plan of Pinebrook, recorded as aforesaid.
UNDER AND SUBJECT, NEVERTHELESS, to the following building and use restrictions
which shall be binding on the within described tract of land only and shall not be binding on
other land of the Pine Brook Corporation, with which building and use restrictions the within
Grantees, their heirs and assigns, by the acceptance of this deed, agrees to comply:
1. This tract of land shall be used for residential purposes only. No business, commercial or
industrial uses whatsoever shall be permitted on this tract of land.
2. Only one single - family residence and accessory buildings may be erected on this tract of
land.
3. No building or any part or projection thereof shall be erected or maintained within 25 feet
to any side or rear property line.
4. No wall of any building shall be erected nearer than 40 feet to the legal right of way line
of any public street or road abutting the within described tract of land.
5. No trailer, mobile home, or similar structure may be located on this tract of land
temporarily or permanently, for any use whatsoever.
6. No basement, tent, shack, garage, barn or structure may be located on this tract of land
temporarily or permanently, for any use whatsoever.
e .� 7. No cesspool shall be permitted on this tract of land. The disposal of sewage shall be
accomplished by use of a septic tank system or such other disposal system as shall comply with
the requirements of local and state health authorities. No outside privy shall be permitted.
8. No advertising or display sign shall be erected or maintained on this tract of land other
than customary 'For Rent' and 'For Sale' signs when the same pertain to the premises on which
they are located.
9. Nothing shall be done on this tract of land which may be or become an annoyance or
nuisances to the neighborhood.
10. The within described tract of land shall not be subdivided.
11. No tree shall be felled on this tract of land except in accordance with good forestry
practices or as may be necessary for the convenient locating of improvements.
12. All plans and specifications for any proposed building must be submitted to the President
of Pine Brook Corp., or his nominee, for approval as to size, style of architecture and materials to
be used, and no construction shall begin until approval had been given, which approval will not
be unreasonably withheld and will be based in part on the conformity of any proposed building
with the size and style of existing buildings in the area, general character of the area, and
commonly accepted building standards and practices. Approval or disapproval shall be given in
writing within 30 days from the date of submission of plans.
13. Lot Nos. 1, 6, 7, 10, 11, 15 and 16 are subject to a 15 foot wide fire lane as shown on said
Final Subdivision Plan of Pinebrook, recorded as aforesaid.
BEING THE SAME PREMISES which Daniel E. Kauffman, single man, Jeffrey S. Kauffman
and Peggy L. Kauffman, husband and wife, and George N. Grove and Gladys M. Grove,
husband and wife, by Deed dated August 3, 1995 and recorded August 4, 1995 in the Office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 126, Page
260, granted and conveyed unto James C. McCombs, III and Melody R. McCombs, husband and
wife, Grantors herein.
Premises: 15 DEER DRIVE
VERIFICATION
hereby states he /she is P yY � Q. ch Ob fo �&O ab'r
(nnme) OQ/VS CV.QAdOCQ- t?S0(-LfCA ff`Q'�Ckqg,T"1 (title) �
of V)\ �`1 ow�� - 11 o ri � C\ Q) r�" servicing agent for VKM (Vendor Resource
Management), as duly authorized property management contractor as referenced in the signatory
line below, in this matter, that he /she is authorized to make this Verification, and that the
statements made in the foregoing Civil Action in Ejectment are true and correct to the best of
his/her knowledge, information and belief. The undersigned understands that this statement is
made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
VRM (VENDOR RESOURCE
MANAGEMENT), DULY AUTHORIZED
q T FORETA OF RANS AFF
j s* tore
DATE:
PHS #: PHS # 322123
Return to: Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Attn: Eviction Department
PHS # 322123
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,fir:
Sheriff r� T j
Jti%p elth- p',
N1dL "r
1� i a�
Jody S Smith r � � b
Chief Deputy AM 9: 50
Richard W Stewart w"` CUMBERLAND COUIN_•Y
Solicitor OFFICE OrTIiF,
PEMNSYLVANIA
VRM Vendor Resource Managment, Duly Authorized Agent for the Secretary Case Number
vs.
James W Kautz 2013-3821
SHERIFF'S RETURN OF SERVICE
07/09/2013 04:20 PM-Sergeant Jason Vioral served the requested Complaint in Ejectment by"personally" handing
a true copy to a person representing themselves to be the Defendant, to wit: James W Kautz at the
Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013.
JASO IOR L, DEPUTY
SHERIFF COST: $50.60 A ERS,
July 10, 2013 RON R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,Inc.
Phelan Hallinan, LLP
Jonathan Lobb,Esq.,Id. No.312174
1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff
One Penn Center Plaza
Fn
Philadelphia, PA 19103
215-563-7000
VRM (VENDO R RESOURCE C)C)
MANAGEMENT), DULY AUTHORIZED 1< C)--ri
AGENT FOR THE SECRETARY OF
VETERANS AFFAIRS p -77
Plaintiff COURT OF COMMON PLEAS
CIVIL DIVISION
vs No. 13-3821 CIVIL
JAMES W. KAUTZ, JR Or occupants
15 DEER DRIVE CUMBERLAND County
NEWVILLE, PA 17241
Defendant
PRAECIPE FOR JUDGMENT IN EJECTMENT
TO THE PROTHONOTARY:
Kindly enter Judgment in Ejectment in favor of Plaintiff, VkM(VENDOR RESOURCE
MANAGEMENT), DULY AUTHORIZED AGENT FOR THE SECRETARY OF VETERANS
AFFAIRS and against the Defendant(s)JAMES W. KAUTZ JRand Or occupants for possession of
.premises 15 DEER DRIVE;NEWILLE, PA 17241 for failure to file an Answer within twenty (20)
days of service.
I hereby:certify that according to Rule 237.1, written )0-day notice of Plaintiffs intention to file
4 praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which
is attached hereto.
liar
Jfathan,Cobb, Esq., Id. N0.312174
Attorney for Plaintiff
Phelan Hallinan, LLP
Default Judgment entered as indicated above.
DATE:-
AA 9 41s9s
Li
Phelan Hallinan,LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza,
Philadelphia, PA 19103
215-563-7000
VRM (VENDOR RESOURCE MANAGEMENT), DULY Court of Common Pleas
AUTHORIZED AGENT FOR THE SECRETARY OF
VETERANS AFFAIRS
. Plaintiff Civil Division
VS
No. 13-3821 CIVIL
JAMES W. KAUTZ,JR or Occupants
Defendant CUMBERLAND COUNTY
TO: JAMES W. KAUTZ,JR or Occupants
15 DEER DRIVE
NEWVILLE, PA 17241
DATE OF NOTICE: July 30, 2013
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT
REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO
BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST
PROPERTY.
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 of 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 notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Office of the Prothonotary Cumberland County Bar Association
Cumberland County Courthouse 32 South Bedford Street
I Courthouse Square Carlisle,PA 17013
Carlisle, PA 17013 (717)249-3166
(717)240-6195
By: 't, v
Adam H. Davis,Esq., Id. No.203034
Attorney for Plaintiff
Phelan Hallinan,LLP
PH# 815881
a Phelan Hallinan,LLP
Jo0athan Lobb,Esq., Id.No.312174
1617 HK Boulevard, Suite 1400 Attorney for.Plaintiff
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
VRM (VENDOR RESOURCE MANAGEMENT),
DULY AUTHORIZED AGENT FOR THE
SECRETARY OF VETERANS AFFAIRS
Plaintiff_ COURT OF COMMON PLEAS
CIVIL DIVISION
vs No. 13-3821 CIVIL
JAMES W. KAUTZ, JR Or occupants
15 DEER DRIVE CUMBERLAND County
NEWVILLE, PA 17241
Defendant
VERIFICATION OF NON-MILITARY SERVICE
I hereby verify that. I am the Attorney for Plaintiff in the above captioned matter, and that on
information and belief, I have knowledge of the following facts, to wit:
(a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the'Servicemembers Civil Relief Act of
Congress of 1940, as amended.
(b) That defendant JAMES W. KAUTZ, JR Or occupants, is over 18 years of age, and resides at
15 DEER DRIVE,NEWVILLE, PA 17241.
(c) It is unknown whether any other occupants are in the military or are over 18 years of age.
This statement is made subject to penalties of 18 PA. C.S. §4904 relating to unsworn
falsification to authorities.
Date: August 16, 2013
J athan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
Phelan Hallinan, LLP
PH # 815881
PRAECIPE FOR WRIT OF POSSESSION _
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
VRM (VENDOR RESOURCE C-- �,�--
MANAGEMENT), DULY AUTHORIZED '
AGENT FOR THE SECRETARY OF c�
VETERANS AFFAIRS <'z=:1
Plaintiff COURT OF COMMON PLEAS -
CIVIL DIVISION
vs No. 13-3821 CIVIL c�
JAMES W. KAUTZ, JR Or occupants
15 DEER DRIVE CUMBERLAND County
NEWVILLE, PA 17241
Defendant
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Issue Writ of Possession in the above matter for possession of:
15 DEER DRIVE,NEWVILLE, PA 17241
"PLEASE SEE THE ATTACHED LEGAL DESCRIPTION"
Being Known as No. 15 DEER DRIVE -11k,
�Jo than Lobb, Esq., Id. No.312174
:Attorney for Plaintiff,
Phelan Hallinan, LLP
ao
D TE:
S
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1ag.75 c<
ILI ,sV �� u
S ?d aff 8,-
Legal Description
ALL THAT CERTAIN tract of land situate in Cooke Township, Cumberland County,
Pennsylvania, bounded and described in accordance with Final Subdivision Plan of Pinebrook,
prepared by William B. Whittock, Registered Professional Engineer, dated October 19, 1977,
consisting of two pages, recorded in the hereinafter named Recorder's Office in Plan Book 42, Page
146, and incorporated herein by reference, as follows:
BEGINNING at a point in the center of Deer Drive cul-de-sac, which has a radius of 50 feet at
comer common to Lot Nos. 14, 15, 16 and 17; thence from said point at the place of beginning,
along the dividing line between said Lot Nos. 15 and 16, South 64 degrees 26 minutes 44 seconds
East, a distance of 248.62 feet to a point in line of land now or formerly of Commonwealth of
Pennsylvania; thence along line of said land now or formerly of Commonwealth of Pennsylvania,
South 44 degrees 30 minutes 00 seconds West, a distance of 308.88 feet to a point at the dividing
line between Lot Nos. I I and 15; thence along the dividing line between Lot Nos. 11 and 15, North
62 degrees 59 minutes 20 seconds West, a distance of 78.14 feet to a point at the dividing line
between Lot Nos. 14 and 15; thence along said dividing line between Lot Nos. 14 and 15,North I I
degrees 56 minutes 56 seconds East, a distance of 298.54 feet to a point in the center of said Deer
Drive cul-de-sac at the place of BEGINNING.
The above described tract of land contains a net area of 1.054 acres exclusive of the dedicated right
of way of Deer Drive cul-de-sac, and is all of Lot No. 15 as shown on said Final Subdivision Plan
of Pinebrook, recorded as aforesaid.
So much of the above described tract of land as lies with 50 feet of the center of Deer Drive cul-de-
sac has been dedicated as a portion of the right of way of said Deer Drive cul-de-sac as shown on
said Final Subdivision Plan of Pinebrook, recorded as aforesaid.
UNDER AND SUBJECT,NEVERTHELESS, to the following building and use restrictions which
shall be binding on the within described tract of land only and shall not be binding on other land of
the Pine Brook Corporation, with which building and use restrictions the within Grantees, their
heirs and assigns, by the acceptance of this deed, agrees to comply:
1. This tract of land shall be used for residential purposes only. No business, commercial or
industrial uses whatsoever shall be permitted on this tract of land.
2. Only one single-family residence and accessory buildings may be erected on this tract of
land.
3. No building or any part or projection thereof shall be erected or maintained within 25 feet to
any side or rear property line.
4. No wall of any building shall be erected nearer than 40 feet to the legal right of way line of
any public street or road abutting the within described tract of land.
5. No trailer, mobile home, or similar structure may be located on this tract of land temporarily
or permanently, for any use whatsoever.
6. No basement, tent, shack, garage, barn or structure may be located on this tract of land
temporarily or permanently, for any use whatsoever.
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VRM(VENDOR RESOURCE MANAGEMENT),DULY AUTHORIZED AGENT FOR THE
SECRETARY OF VETERANS AFFAIRS
VS. No. 13-3t.)-i Civil Term_
JAMES W. KAUTZ, JR OR OCCUPANTS
15 DEER DRIVE
NEWVILLE, PA 17241
Costs
Attorney's $ 19 q•IS
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))
VRM(VENDOR RESOURCE MANAGEMENT), DULY AUTHORIZED AGENT FOR THE
SECRETARY OF VETERANS AFFAIRS
being: (Premises as follows):
15 DEER DRIVE,NEWVILLE,PA 17241
(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.
David D.Buell,Prothonotary,
Common Pleas Court of Cumberland County, PA
Date 8/19/13
(Seal) .
2of2
No 13-3821 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
VRM(VENDOR RESOURCE MANAGEMENT),DULY AUTHORIZED AGENT
FOR THE SECRETARY OF VETERANS AFFAIRS
VS.
JAMES W.KAUTZ,JR OR OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 9q.3s
Plff(s) $
Prothy $ 2.25
Sheriff $
Plaintiff(s)attorney name and address:
JONATHAN LOBB, ESQUIRE - ID 4312174
1617 JFK BLVD., SUITE 1400, ONE PENN CENTER PLAZA
PHILADELPHIA,PA 19103
215-563-7000
Attorney for Plaintiff(s)
Where papers may be served
By virtue of this writ,on the day of I caused the within
named ,
appurtenances, and to have possession of the premises described with the
So Answers,
Sworn and subscribed to before me this
Day of ,
Sheriff
By
Prothonotary Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson E ;,*-
Sheriff ` ;l .,OFF 1 �'.
Jody S Smith
I.,r THE r�0- H0N IA
Chief Deputy „ 2013 AUG 30 PM 2: 42
Richard W Stewart
Solicitor QFFi EOFTHESHERIFP CUMBERLAND COUNTY
PENNSYLVANIA .
VRM Vendor Resource Managment, Duly Authorized Agent for the Secretary Case Number
vs.
James W Kautz 2013-3821
SHERIFF'S RETURN OF SERVICE
08/29/2013 10:11 AM- Deputy Gerald Worthington went to the property; reports that the property appears to be
vacant. There is a realtor lockbox on the front door.
08/30/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states that on August 29, 2013 at
1010 hours a true copy of the within writ of possession was attempted to be served upon the defendant,
to wit: James W. Kautz Jr., or Occupants, of 15 Deer Drive, Newville, Cumberland County, Pennsylvania
17241. The property appeared to be vacant. Therefore, the within Writ of Possession is being returned
with no service as the defendant, James W. Kautz Jr., or Occupants was NOT FOUND.
SHERIFF COST: $44.68 SO ANSWERS,
August 30, 2013 RbNW R ANDERSON, SHERIFF
'Co
z 9;�L-7?!P
(c)CountySuite Sheriff,Teleosoft.Inc.
"VRM Vendor Resource Managment, Duly Authorized Agent for the Secretary
vs. Case Number
James W Kautz 2013-3821
PERSONAL PROPERTY REQUEST LEDGER
DATE CATEGORY MEMO CHK# DEBIT CREDIT
08/23/2013 Advance Fee Advance Fee 001337757 $0.00 $200.00
08/23/2013 Docketing
$18.00 $0.00
08/23/2013 Surcharge $10.00 $0.00
08/23/2013 Prothonotary 92779 $2.25 $0.00
08/30/2013 Service Mileage $13.56 $0.00
08/30/2013 Poundage $0.87 $0.00
08/30/2013 Refund 92780 $155.32 $0.00
$200.00 $200.00
TOTAL BALANCE: $0.00
Printed: 8/30/2013 12:30:14PM (c)countySuiw Sheriff,Teleosofi.inc. Page 1 of 1
Gf=' MME I ROT�'��'��_l
HOMOTARy
Phelan Hallinan,LLP 33 EP _ Attorney For Plaintiff
1617 JFK Boulevard,Suite1�40�
S ' : .
One Penn Center Plaza CU
PIBRLAij COUNTY
Philadelphia,PA 19103 PFt�N$YLV/�N(A
215-563-7000
VRM (VENDOR RESOURCE Court of Common Pleas
MANAGEMENT), DULY AUTHORIZED
AGENT FOR THE SECRETARY OF Civil Division
VETERANS AFFAIRS
Plaintiff CUMBERLAND County
vs No. 13-3821 CIVIL
JAMES W.KAUTZ,JR
MELISSA L. KAUTZ
Or Occupants
Defendant
TO THE PROTHONOTARY: PRAECIPE
❑Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑ Please mark the above referenced case Settled, Discontinued and Ended.
❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
®Please mark the judgment Satisfied and the action Discontinued and Ended.
❑Please Vacate the Judgment entered.
Date:
PHELAN 7HA�LLINAN,LLLP/
BY:
Adam H.Davis,Esq.,Id.No.203034
PH#815881 Attorney for Plaintiff
pd-
Cq
Phelan Hallman, LLP Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
VRM (VENDOR RESOURCE MANAGEMENT), Court of Common Pleas
DULY AUTHORIZED AGENT FOR THE
SECRETARY OF VETERANS AFFAIRS
Plaintiff Civil Division
V. CUMBERLAND County
JAMES W. KAUTZ,JR No. 13-3821 CIVIL
MELISSA L. KAUTZ
Or Occupants
Defendant PH#815881
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
JAMES W. KAUTZ,JR
MELISSA L. KAUTZ
Or Occupants
15 DEER DRIVE
NEWVILLE,PA 17241
Date: PHELAN HALLINAN,LLP
By:—
Adam H.Davis,Esq., Id.No.203034
Attorney for Plaintiff