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HomeMy WebLinkAbout13-4435 Supreme Cote e ,, i 0, 0 , Cou ftCOIriIQO Pleas For Prothonotary Use Only: CI b 'sheet Docket No: W5 11 j CUM>RLQNb = ;�` County 3 `. 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 ruler of court. Commencement of Action: S El Complaint E3 Writ of Summons Petition Transfer from Another Jurisdiction [3 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: PNC Bank, National Association Robert E. Swavola T Dollar Amount Requested: ® within arbitration limits I Are money damages requested? M Yes 0 No (check one) outside arbitration limits O N Is this a Class Action Suit? Q Yes F1 No Is this an MDJ Appeal? 0 Yes FE No A Name of Plaintiff/Appellant's Attorney: Louis P. Vitti, Esquire PAID #01072 i Check here if you have no attorney (are aSelf- Represented [Pro SeJ Litigant) 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 Judgments) CIVIL APPEALS E3 Intentional [I Buyer Plaintiff Administrative Agencies Malicious Prosecution [3 Debt Collection: Credit Card Board of Assessment Motor Vehicle Debt Collection: Other Board of Elections Nuisance Dept. of Transportation S � Premises Liability [3 Statutory Appeal: Other Product Liability (does not include Employment Dispute: E mass tort) Slander/Libel/ Defamation Discrimination C [3 Other: Employment Dispute: Other [3 Zoning Board T 0 Other: I Other: O MASS TORT Asbestos N [3 Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste ®x Ejectment 13 ® ��_ Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation [3 Declaratory Judgment 0 Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LL&BLITY 1! Mortgage Foreclosure: Commercial Quo Warranto El Dental n Partition El Replevin 0 Legal E] Quiet Title El Other: ® Medical Other: Q Other Professional: Updated 1/1/2011 C� f CT i cn, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION NO. 13- 1!/ ,�- `� 7 c,�S Plaintiff, COMPLAINT IN EJECTMENT vs. Code: EJECTMENT Filed on behalf of Plaintiff ROBERT E. SWAVOLA and/or TENANT /OCCUPANT, Counsel of record for this PAY: Louis P: Vitti, Esquire Defendants. Supreme Court #01072 Vitti & Vitti & Associates, P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281 -1725 � - s� COMPLAINT IN EJECTMENT NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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 ON 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 1- 800 - 990 -9108 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, NO. Plaintiff, VS. Robert E. Swavola and/or Tenant/Occupant, Defendants. COMPLAINT IN EJECTMENT NOW, comes the above - captioned Plaintiff, by and through its counsel, Vitti & Vitti & Associates, P.C. and Louis P. Vitti, Esquire, who files this Complaint in Ejectment as follows: 1. The Plaintiff is a corporation having a principal place of business located at 3232 Newmark Drive, Miamisburg, OH 45342. 2. The Defendant is an individual, sui juris, whose last known address was 2 Johns Drive, Mechanicsburg, PA 17050. It is unknown whether the subject property of 18 Jane Lane, Carlisle, PA 17013 is otherwise occupied. 3. Plaintiffs Counsel sent a ninety (90) days Tenant Right Letter on April 16, 2013 by ordinary and certified mail to 18 Jane Lane, Carlisle, PA 17013. 4. On April 23, 2009, the Plaintiff or its predecessor in title lent to Defendants and/or their predecessors in title, the sum of One Hundred Eighty Two Thousand, Six Hundred Ninety Two and 00 /100 ($182,692.00) Dollars, and in consideration thereof, the Defendants and /or their predecessors in title, executed a mortgage which was recorded on May 28, 2009, in the Office of the Recorder of Deeds of Cumberland County at Instrument No. .200917557. 5. The premises secured by the mortgage (hereinafter "the Property") are described in the document that is attached hereto, made a part hereof, and called Exhibit "A ". 6. The mortgage provides that, in the event of default, the holder thereof has the rights, inter alia, to take possession of the Property and to foreclose the mortgage. 7. Since July 1, 2011, the mortgage has been in default by reason of the failure of the mortgagors to make appropriate payments. 8. An action in mortgage foreclosure was instituted in the Court of Common Pleas of Cumberland County at No. 12 -4519 Civil, and ultimately a sheriff s sale of the Property -- at which Plaintiff or its predecessor in title was the successful bidder -- occurred on March 6, 2013. 9. By deed dated April 9,-2013 and recorded May 8, 2013 in the Recorder's Office of Cumberland County at Instrument No. 201315012, the sheriff conveyed the property to Plaintiff PNC Bank, National Association. 10. Plaintiff, PNC Bank, National Association, has the right to immediate possession of the Property. 11. Defendants and/or all other occupants continue to occupy the Property. 12. Any alleged claim of Defendants to possession of the Property is as or through the owners /mortgagors described in Paragraph 3 hereof. WHEREFORE, Plaintiff prays Your Honorable Court enter Judgment in favor of the Plaintiff, PNC Bank, National Association, for sole possession of the Property and vesting the title of said premises in the Plaintiff. Respectfully submitted, VITTI & I TI & ASSOCIATES, P.C. By: L 1s P. Vitti, Esquire Attorney for Plaintiff EXHIBIT "A" LEGAL DESCRIPTION 'l *i certain tw or p cool of lend and prcntisos, situate, lying and being in the Township of North Middleton in the County o cvnlbL-riand And commonvvewth orpennaylwarzia. more particularly dcstribed As (allows: Being t.ot Nd. 3 an the Plan or.S=Uon 9 ni :4oll Mnuor as rccoyded in the OfTice of t!he keoovAar of Duads tar Cumberland Coun(y in Plan l ooL 24, Pap 104, containing 85 feet along Jane lane, hr4n a depth along tho Smth of 125 I'w along Lot 144, 4 Dn said Man, having a witfth in the soar along the Lost of 85 fit and having a depth aiorT, she Noah along Lot No. 2 on said Plan of 125 fe4t. Bein1; the carne prerni= which Gary 8_ Davis widower, conveyed unto. Robert .E. -Svmvole mid Joyce /L S war ola,,, husband emd wife, by deed dated January 15, '1 and recorded January 17, 1992 in the Office of the Rewdcr or Deeds .in and for Cumberland County, Pennsy *lv=ia in Book WS, Page 212. 1+arccl hlo: �fi -1 brl tl4G• ® ?4 Commonly knawrr As: 1 g June Lane, Carlisle. PA 1170113 VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint in Ejectment are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. A ouisp. Dated: 7/23/2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smiths' r�} 3 s � '" �� Chief Deputy W Stewart UMBERLAND CWJNTY' Solicitor csr.rICEOFTXM IERIrr PENNSYLVANIA PNC Bank National Association Case Number vs. Robert E. Swavola 2013-4435 SHERIFF'S RETURN OF SERVICE 08/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert E. Swavola, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 18 Jane Lane, North Middleton Township, Carlisle, PA 17013. Residence is vacant. 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert E. Swavola, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 2 Johns Drive, Silver Spring Township, Mechanicsburg, PA 17050. Several attempts at service were made but deputies were unable to make contact with anyone at the residence, the Complaint has since expired. SHERIFF COST: $100.00 SO ANSWERS, 6z August 27, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosott.!nc. + f { f f Of 0t '.,, zG 3 pj j ry(''�f! 4 `..Uf"hi.J R'lAt'D CVUtj I i" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, VS. Robert E. Swavola and/or Tenant/Occupant, Defendants. PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly reinstate the complaint in the above-captioned case. Respectfully submitted, VITTI &.XITTI &ASSOCIATES, P.C. By: P. Vitti, Esquire Attorney for Plaintiff Date: 10/30/2013 J a�� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION, CIVIL DIVISION NO. 13-4435-Civil Plaintiff, PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT vs. Code: EJECTMENT Filed on behalf of ROBERT E. SWAVOLA and/or Plaintiff TENANT/OCCUPANT, Counsel of record for this party: Defendants. Louis P. Vitti, Esquire Supreme Court#01072 Vitti &Vitti &Associates, P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412)281-1725 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff Jody S Smith `� ��Y�i�tr #�� �^ c-v P P1 02 Chief Deputy �.� Richard W Stewart " �;��(�.. 7- PENP6 Y l Solicitor � . �F TwE a�ERIFF VA qI PNC Bank National Association Case Number vs. Robert E. Swavola 2013-4435 SHERIFF'S RETURN OF SERVICE 11/05/2013 06:16 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Robert E. Swavola at 21 Poplar Drive, Silver Spring, Mechanicsburg, PA 17050. JASON KIN8LE EPUTY 11/14/2013 12:34 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Found"at 18 Jane Lane, North Middleton Township, Carlisle, PA 17013. Residence is vacant. SHERIFF COST: $60.30 SO ANSWERS, November 15, 2013 RON R ANDERSON, SHERIFF (ci CounryS�i,e Shereft,Tel�,osef; , l r s` Li 201 r JAY -6 PM 2: 16 C'i lBcF;tA,'D CQI,f #TY NIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION, CIVIL DIVISION NO. 13-4435 Civil Plaintiff, PRAECIPE FOR DEFAULT JUDGMENT AND CERTIFICATION OF MAILING AND AFFIDAVIT OF vs. NON-MILITARY SERVICE Code 040 EJECTMENT ROBERT E. SWAVOLA and/or Filed on behalf of TENANT/OCCUPANT, Plaintiff Counsel of record for this Defendants. party: Louis P. Vitti, Esquire Supreme Court#01072 Vitti & Vitti &Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412)281-1725 o IN/ 54 (-1/6/1 3. 0/// TVO7tC1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. PRAECIPE FOR DEFAULT JUDGMENT TO: CUMBERLAND COUNTY PROTHONOTARY Please enter judgment in favor of Plaintiff PNC Bank, National Association, and against Defendant Robert E. Swavola for possession and/or ejectment as a result of the Defendant's failure to file an Answer and/or a responsive pleading for the property located at 18 JANE LANE, CARLISLE, PA 17013. VITT &VITTI & ASSOCIATES, P.C. C/Adr Louis P. Vitti, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. CERTIFICATION OF MAILING I,Louis P.Vitti,do hereby certify that a Notice of Intention to Take Judgment was mailed to the Defendants, in the above-captioned case on December 4, 2013, giving ten (10) day notice that judgment would be entered should no action be taken. VITT &VITTI &ASSOCIATES,P.C. BY ouis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 18th day of December, 2013. Notary P f,lic • • mOF , SherrY 1 sal House,Notary public Gty Of Ittsbu gh,At(r;t:oy: „C®Unty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. IMPORTANT NOTICE TO: Robert E. Swavola Tenant/Occupant 21 Poplar Drive 18 Jane Lane Mechanicsburg,PA 17050 Carlisle,PA 17013 Date of Notice: 12/4/2013 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(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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING 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 ON 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 1-800-990-9108 (717) 249-3166 \JTII& ASSOfc- P.y. BY: afr 4A-44.4..-1-,` I Louis P. Vitti Esquire Attorney for Plaintiff 215 Fourth Avenue Pittsburgh,PA 15222 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,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.** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY, BEFORE me,the undersigned authority,personally appeared Louis P. Vitti, Esquire,who, being duly sworn according to law, deposes and says that he is advised and believes that DEFENDANT is not presently in the active military service of the United States of America and not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act,and that the averments herein set forth,insofar as they are within his knowledge,are correct, and true;and insofar as they are based on information received from others,are true and correct as he verily believes. This Affidavit is made under the provisions of the So 'ers and Sailors Civil Relief Act of 1940. ouis P. Vitti, Esquire SWORN to and subscribed before me this 18th day of December, 201 . 1 X11 i Notary P 4ic Notarial Seal ShefrY L,House Notary Pub', lc at1'OIPllrgh, aM,,_,;.. .,Sul opronwssion Ott ExN;res May ::5,2025 ,icon.-- ,-•�..,.....� Supreme Cote e ,, i 0, 0 , Cou ftCOIriIQO Pleas For Prothonotary Use Only: CI b 'sheet Docket No: W5 11 j CUM>RLQNb = ;�` County 3 `. 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 ruler of court. Commencement of Action: S El Complaint E3 Writ of Summons Petition Transfer from Another Jurisdiction [3 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: PNC Bank, National Association Robert E. Swavola T Dollar Amount Requested: ® within arbitration limits I Are money damages requested? M Yes 0 No (check one) outside arbitration limits O N Is this a Class Action Suit? Q Yes F1 No Is this an MDJ Appeal? 0 Yes FE No A Name of Plaintiff/Appellant's Attorney: Louis P. Vitti, Esquire PAID #01072 i Check here if you have no attorney (are aSelf- Represented [Pro SeJ Litigant) 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 Judgments) CIVIL APPEALS E3 Intentional [I Buyer Plaintiff Administrative Agencies Malicious Prosecution [3 Debt Collection: Credit Card Board of Assessment Motor Vehicle Debt Collection: Other Board of Elections Nuisance Dept. of Transportation S � Premises Liability [3 Statutory Appeal: Other Product Liability (does not include Employment Dispute: E mass tort) Slander/Libel/ Defamation Discrimination C [3 Other: Employment Dispute: Other [3 Zoning Board T 0 Other: I Other: O MASS TORT Asbestos N [3 Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste ®x Ejectment 13 ® ��_ Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation [3 Declaratory Judgment 0 Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LL&BLITY 1! Mortgage Foreclosure: Commercial Quo Warranto El Dental n Partition El Replevin 0 Legal E] Quiet Title El Other: ® Medical Other: Q Other Professional: Updated 1/1/2011 • pry �.1 fi JA -6 P q 2: t 6 N SAS No LVt 14 TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION, CIVIL DIVISION NO. 13-4435 Civil Plaintiff, PRAECIPE FOR WRIT OF POSSESSION AND AFFIDAVIT OF LAST KNOWN ADDRESS vs. Code 040 EJECTMENT ROBERT E. SWAVOLA and/or Filed on behalf of TENANT/OCCUPANT, Plaintiff Counsel of record for this Defendants. party: Louis P. Vitti, Esquire Supreme Court#01072 Vitti &Vitti &Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 411 (412) 281-1725 031/1 a (C.6?)/ "frir I CZ sOLL s D. S.--bitk - �� .Fsva .R x//7 (lift 1.fl°45c,A„,./ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. PRAECIPE FOR WRIT OF POSSESSION TO: CUMBERLAND COUNTY PROTHONOTARY Please issue a Writ of Possession in the above-captioned case for the property situate at 18 Jane Lane, Carlisle, PA 17013. VITTI & VITTI &ASSOCIATES, P.C. 4:_ u.- outs P. Vitti, Esquire Attorney for Plaintiff J , EXHIBIT "A" LEGAL DESCRIPTION, That certain tract or parcel of land and promises.situate,lying and being in the Township of North Middleton in the County of Cumberland and Commonwealth of Pennsylvania.morc particularly described as follows: Being Lot No.3 on the Plan of se ction 9 of Moll Manor as recorded in the Office of the Recorder of Deeds for Cumberland Couruy in Plan Book 24,Page 1041 containing 85 feet along Jane Lane.having a depth along the South or 125 feet along 1,ot No.4 on said Plan,having is width in the rear along the East of 85 feet and having a depth along the North along Lot No.2 on said Plan or 125 feet. Being the same premises which Gzry B. Davis;widow ar,conveyed unto Robert E.Swavola and Joyce A,Sway ola.husband and wife,by deed dated January 15, 1992 and recorded January 17, 1992 in the©files of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Book M3$,Page 212. Parnel No:26.16-1496.074 Commonly known as 18 Jane Lane.Carlisle.PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavo la and/or Tenant/Occupant, Defendants. AFFIDAVIT I,Louis P.Vitti,do hereby swear that,to the best of my knowledge,information and belief,the Defendant,Robert E. Swavo la,was the owner of the real property on which the Plaintiff seeks to execute. That the Defendant's last known address is 21 Poplar Drive,Mechanicsburg,PA 17050. de .411111). Louis P. Vit77uire SWORN to and subscribed before me this 18th day of December, 2013. A t _ of Notary P ic „-,oF AtitaildSom Shan L HOw otyot pitzte ./ otegio CQIntriLNCOr'L 411tY 3,2015 • EXHIBIT "A" LEGAL DESCRIPTION That certain.tract or parcel of land and prornisos,situate,lying and being in the Township of North Ir iddfeton in the County of'Cumberland and Commonwealth of Pennsylvania.more particularly described as follows: Being Lot No.3 on the Plan of'Se ctic n 4 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24,Page 104:containing,85 Feet along Jane Lane.ha3 nt a depth along the South oft 25 feet along I,ot No 4 on said Plan,having a width in the rcar along the fast of 8$ feet and having a depth along the North along Lot No.2 on said Plan o f 125 feet. Being the same premises which Gary B. Davis,widower.conveyed unto Robert E.8wavola and Joyce t1..Sway oleo husband and wife,by deed dated January 15, 1992 and recorded January 17, 1992 in the Office of the Recor'derof Deeds in and for Cumberland County,Pennsylvania in Book 1435,Page 212. Parcel No:26.16 1046.074 Commonly known as 18 Jane Lane,Carlisle,PA 17013 lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION VS. No. 13-4435 Civil Term ROBERT E. SWAVOLA AND/OR TENANT/OCCUPANT 18 JANE LANE, CARLISLE, PA 17013 Costs Attorney's $ 320.80 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)) PNC BANK,NATIONAL ASSOCIATION being: (Premises as follows): 18 JANE LANE,CARLISLE, PA 17013 ***PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** (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. ,D2A4t.A.-I Le_. avid D.Buell,Prothonotary, Common Pleas Court of Cumberland Cou ty, PA Date 1/6/14 •c7 (Seal) • 2 of 2 No 13-4435 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION VS. ROBERT E. SWAVOLA AND/OR TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 219.10 P1ff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: LOUIS P.VITTI, ESQUIRE- ID# 01072 VITTI&VITTI&ASSOC., P.C. 215 FOURTH AVENUE PITTSBURGH, PA 15222 412-281-1725 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank,National Association, NO. 13-4435 Civil Plaintiff, vs. Robert E. Swavola and/or Tenant/Occupant, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Robert E. Swavola Tenant/Occupant 21 Poplar Drive 18 Jane Lane Mechanicsburg, PA 17050 Carlisle, PA 17013 You are hereby notified that a judgment was entered in the above-captioned proceeding on the /'`A day of J 6t A✓c--/y , 20+3. ol..0/ Judgment is as follows: Be advised that judgment was entered in default of an Answer for Possession and in eviction and/or ejectment i e above-mentioned case. Pr rtioA -tact ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, 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.**