HomeMy WebLinkAbout13-5005 Supreme Coin =of ;Pennsylvania
Cour •of Common leas For Prothonotary Use Only:
Nil,
�Cov_�rlSheet Docket No:
CUMBERND' County SDos "rn
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S X' Complaint 0 Writ of Summons D Petition
E D Transfer from Another Jurisdiction D Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
DEUTSCHE BANK NATIONAL TRUST, et. al. KRISTINA STAMBAUGH, et. al.
T
I Are money damages requested? D Yes 0 No Dollar Amount Requested: Dwithin arbitration limits
(check one) Ooutside arbitration limits
N Is this a Class Action Suit? D Yes El No Is this an MDJAppeal? Yes El No
A Name of Plaintiff /Appellant's Attorney: Andrew J. Marley, Esquire
D Check here if you have no attorney (are a Self - Represented (Pro Se] 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
D Intentional D Buyer Plaintiff Administrative Agencies
D Malicious Prosecution 0 Debt Collection: Credit Card D Board of Assessment
- Motor Vehicle 0 Debt Collection: Other
Nuisance D Board of Elections
0 Dept. of Transportation
D Premises Liability D Statutory Appeal: Other
S Product Liability (does not include
E mass tort) Employment Dispute:
D Slander/Libel/ Defamation Discrimination
C D Other: D Employment Dispute: Other 0 Zoning Board
'I' D Other:
I Other:
O MASS TORT
D Asbestos
N 0 Tobacco
Toxic Tort - DES
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: 0 Ejectment D Common Law /Statutory Arbitration
B Eminent Domain/Condemnation Declaratory Judgment
D Ground Rent D Mandamus
I El Landlord/Tenant Dispute D Non - Domestic Relations
D Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto
D Dental D Partition D Replevin
D Legal in Quiet Title D Other:
D Medical D Other:
0 Other Professional:
Updated 1/1/2011
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
Deutsche Bank National Trust Company as
Trustee for GSAMP Trust 2005 -WMC 1 Pooling
and Servicing Agreement dated as of September
1, 2005 c/o Ocwen Loan Servicing, LLC
1661 Worthington Road, Suite 100 Civil Action:
West Palm Beach, FL 33409
V.
Kristina Stambaugh a/k/a COMPLAINT IN EJECTMENT
Kristina M. Stambaugh and
Richard Stambaugh a/k/a
Richard A. Stambaugh :-
141 East Main Street`
Walnut Bottom, PA 17266 F -
And John/Jane Doe
141 East Main Street c�
Walnut Bottom, PA 17266 r r
Defendant(s)
CIVIL ACTION - EJECTMENT
This is an attempt to collect
a debt and any information obtained
will be used for that purpose.
NOTICE
You have been sued in Court. If you wish to defend the claims set forth in the following pages, you
must take action within twenty (20) days after this Civil Action and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or
for any other claim or relief requested by the plaintiff. You may lose money or property of other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO A 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. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
aM X103 �s
CL41 �
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
800 - 990 -9108
717 -249 -3166
NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ.,
YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN
VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT
WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN
ADMISSION OF LIABILITY BY YOU.
IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE
COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE
OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE
MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION
OF THIS DEBT.
THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
STEVEN K. EISENBERG, ESQUIRE (75736)
M. TROY FREEDMAN, ESQUIRE (85165)
LESLIE J. RASE, ESQUIRE (58365)
CHRISTINA C. VIOLA, ESQUIRE (308909)
ANDREW J. MARLEY (312314)
STERN & EISENBERG, PC
1581 MAIN STREET, SUITE 200
WARRINGTON, PENNSYLVANIA 18976
TELEPHONE: (215) 572 -8111
FACSIMILE: (215) 572 -5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
Deutsche Bank National Trust Company as
Trustee for GSAMP Trust 2005 -WMC1 Pooling
and Servicing Agreement dated as of September
1, 2005 c/o Ocwen Loan Servicing, LLC
1661 Worthington Road, Suite 100
Civil Action:
West Palm Beach, FL 33409
V.
Kristina Stambaugh a/k/a COMPLAINT IN EJECTMENT
Kristina M. Stambaugh and
Richard Stambaugh a/k/a
Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
And John/Jane Doe
141 East Main Street
Walnut Bottom, PA 17266
Defendant(s)
COMPLAINT
CIVIL ACTION - EJECTMENT
1. Plaintiff is Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2005 -
WMC1 Pooling and Servicing Agreement dated as. of September 1, 2005 c/o Ocwen Loan
Servicing, LLC (hereinafter referred to as "Plaintiff') with offices located at 1661
Worthington Road, Suite 100, West Palm Beach, FL 33409.
2. Defendant(s) are Kristina Stambaugh a/k/a Kristina M. Stambaugh and Richard
Stambaugh a/k/a Richard A. Stambaugh, adult individuals residing at 141 East Main
Street, Walnut Bottom, PA 17266 (hereinafter Property) which is described in Exhibit "A"
attached hereto and incorporated herein by reference.
3. Defendant(s) are also John/Jane Doe who are unknown adult individuals residing at the
Property which is described in Exhibit "A" attached hereto and incorporated herein by
reference.
4. On Wednesday, March 6, 2013, (the "Property ") was sold by the Sheriff of Cumberland
County at Sheriffs Sale after due advertisement according to law and under and by virtue
of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County,
in the case of Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2005 -
WMC1 Pooling and Servicing Agreement dated as of September 1, 2005 v. Kristina
Stambaugh a/k/a Kristina M. Stambaugh and Richard Stambaugh a/k/a Richard A.
Stambaugh at Docket Number 2012 -2145.
5. Plaintiff settled with the Sheriff and the Deed in favor of Plaintiff was duly recorded on
July 17, 2013 at Instrument Number 201323550. A true and correct copy of the recorded
deed is attached as Exhibit "A ".
6. By virtue of Sheriffs Sale, Plaintiff is the rightful owner of the Property and is entitled to
possession of the same.
7. Defendants are presently in possession of the Property.
WHEREFORE, Plaintiff, Deutsche Bank National Trust Company as Trustee for GSAMP
Trust 2005 -WMC1 Pooling and Servicing Agreement dated as of September 1, 2005 c/o Ocwen Loan
Servicing, LLC demands that a Judgment in Ejectment be entered in its favor and against the
Defendants.
STERN & EISEN - . RG
Date: , ��� BY:
❑ STEVEN K. EISE B G, ESQUIRE
❑ M. TROY FRE 1 AN, ESQUIRE
❑ LESLIE J. RASE, ESQUIRE
HRISTINA C. VIOLA, ESQUIRE
ANDREW J. MARLEY, ESQUIRE
Stern & Eisenberg, PC
1581 Main Street, Suite 200
Warrington, Pennsylvania 18976
(215) 572 -8111
Fax: (215) 572 -5025
Counsel for Plaintiff
VERIFICATION
Andrew J. Marley, Esquire, hereby states that he is one of the attorneys for Plaintiff; that he has
personal knowledge of the facts averred in the foregoing Complaint insofar as the Complaint is
predicated upon a recorded Sheriff s Deed, which is a public record; and that the statements made in
the foregoing Complaint are true and correct to the best of his knowledge, information and belief. The
undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to nsworn falsification to authorities.
Dated: cru
Andrew J. Marley, Esqu ry
Title:
Tax Parcel No. 41 -31- 2230 -064 002Y10
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 Deutsche Bank National Trust Company
as Trustee for GSAMP Trust 2005 -WMCI
Writ No. 2012 -2145
Civil Term
Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2005 -WMC1
Pooling and Servicing Agreement dated as of September 1, 2005
vs
Kristina Stambaugh, a/k/a Kristina M. Stambaugh
Richard Stambaugh, a/k/a Richard A. Stambaugh
ALL THE FOLLOWING DESCRIBED REAL ESTATE, LYING AND BEING SITUTAE IN THE VILLAGE
OF WALNUT BOTTOM, SOUTH NEWTOWN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEING AT A SET RAILROAD SPIKE IN THE CENTERLINE OF PA TRAFFIC ROUTE 174 (WALNUT
BOTTOM ROAD) AT COMMON CORNER OF LOTS I AND 2 ON THE HEREIN REFERRED TO
SUBDIVISION PLAN; THENCE ALONG COMMON BOUNDARY LINE OF LOTS 1 AND 2, WHICH IS
ALSO THE EASTERLY MOST BOUNDARY OF PARCEL IA, SOUTH THIRTY -SEVEN (37) DEGREES
TWENTY -FOUR (24) MINUTES FIFTY -FIVE (55) SECONDS EAST, NINETY -SIX AND FIFTY-SEVEN
HUNDREDTHS (96.57) FEET TO A SET IRON PIN; THENCE CONTINUING BY SAME, SOUTH
FORTY -FIVE (45) DEGREES FORTY -NINE (49) MINUTES TWENTY -FIVE (25) SECONDS EAST, ONE
HUNDRED EIGHTEEN AND THIRTY HUNDREDTHS (118.30) FEET TO A SF.T IRON PIN IN LINE OF
LAND NOW OR FORMERLY OF RONALD A. BAKER; THENCE ALONG LINE OF LAND NOW OR
FORMERLY OF RONALD A. BAKER, SOUTH FORTY -NINE (49) DEGREES ZERO (00) MINUTES
ZERO (00) SECONDS WEST, THIRTY -NINE AND THIRTY -TWO HUNDREDTHS (39.32) FEET TO A
POINT; THENCE CONTINUING BY THE SAME, SOUTH FORTY -NINE (49) DEGREES ZERO (00)
MINUTES (00) SECONDS WEST, FIFTY AND ZERO HUNDREDTHS (50.00) FEET TO A POINT AT
CORNER OF LAND NOW OR FORMERLY OF RANDY K. BOYER; THENCE ALONG LINE OF LAND
NOW OR FORMERLY OF RANDY K. BOYER, NORTH FORTY -THREE (43) DEGREES FIFTEEN (15)
MINUTES TWO (02) SECONDS WEST, TWO HUNDRED THIRTEEN AND THIRTY -SEVEN
HUNDREDTHS (213.37) FEET TO A POINT IN THE CENTERLINE OF WALNUT BOTTOM ROAD;
THENCE ALONG TI4E CENTERLINE OF WALNUT BOTTOM ROAD, NORTH FORTY -SIX (46)
DEGREES FIFTY -SEVEN (57) MINUTES THIRTY -ONE (3 1) SECONDS EAST, FIFTY AND ZERO
I IUNDREDTHS (50.00) FEET TO A POINT; THENCE CONTINUING BY SAME, NORTH FORTY -NINE
(49) DEGREES FIFTY -SEVEN (57) MINUTES (00) SECONDS, FORTY -THREE AND EIGHTY -THREE
HUNDREDTHS (43.83) FEET TO THE SET RAILROAD SPIKE, THE POINT AND PLACE OF
BEGINNING.
CONTAINING A TOTAL AREA OF 18,793 SQUARE FEET (0.431 ACRES)
BEING KNOWN AND DESIGNATED AS LOT NO.I ON A SUBDIVISION PLAN ENTITLED "SURVEY
POR MARY O. BOWERS" PREPARED BY STEVEN P. WOLFE, PROFESSIONAL LAND SURVEYOR,
DATED 4/11190, WHICH SUBDIVISION PLAN HAS BEEN APPROVED BY THE APPROPRIATE
MUNICIPAL AUTHORITIES AS AND FOR A SUBDIVISION PLAN AND IS RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN
PLAN BOOK 69, PAGE 36.
BEING KNOWN AS: 141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266
PROPERTY ID NO.: 41 -31- 2230 -064
TITLE TO SAID PREMISES IS VESTED IN RICHARD A. STAMBAUGH AND KRISTINA M.
STAMBAUGH, I IUSBAND AND WIFE BY DEED FROM RANDY V. SINGLETON DATED 06/30/2005
RECORDED 07/06/2005 IN DEED BOOK 269 PAGE 3862.
EXHIBIT
The same having been sold by me to the said grantee on the 6th day of March
Anno Domini Two Thousand and Thirteen (2013) after due advertisement according to
law, under and by Virtue of a Writ of Execution issued on the 9th of October Anno
Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Twelve (2012) Number 2145 at the suit of
Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2005 -WMC1
Pooling and Servicing Agreement dated as of September 1, 2005 —vs-
Kristina Stambaugh, a/k/a Kristina M. Stambaugh and Richard Stambaugh,
a/k/a Richard A. Stambaugh
In Witness Whereof, I have hereunto affixed my signature this 9th day of April
Anno Domini Two Thousand and Thirteen (2013)
nny. .Anderson, Sheriff
Commonwealth of Pennsylvania, ss.
County of Cumberland
Before the undersigned, David D. Buell, Prothonotary of the Court of Common
Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson,
Sheriff 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 deed might be recorded. Witness my hand and seal of said Court, this 9th day
Of April Anno Domini Two Thousand and Thirteen (2013)
Pro notary
My Com
ftftwtary, 0jmbesW CountMyy Ceft* PA
tM FketVw4ay of Jan. 2014
.�' I hereby certify that the residence
;`,•' fi. And Post Office address of the
Within Grantee is
2001 Australian Avenue, Bay 1
Riviera Beach, FL 33404
Richard W. Stewart
Solicitor
REV. 163 EX (4 -10)
RECORDER'S U ONLY
REALTY TRANSFER TAX State Tax Paid
pennsylvania STATEMENT OF VALUE 3a 3 O
6EG. {RTMtNT OF REVENUE �
Bureau of Individual Taxes Page Number
PO BOX 280603
Harrisburg PA 17128.0603 See Reverse for Instructions Date Recorded
Complete each section and file in duplicate with Recorder of Deeds when (1) the full value /consideration is not set forth in the deed, (2)
the deed Is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is
wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach additional sheets.
A. CORRESPONDENT — All inquiries may be directed to the following person:
Name Telephone Number
UDREN LAW OFFICES, PC 856 -669 -5400
Street Address ity State ZIP Code
111 WOODCREST RD., STE 200 1 1
�HERRY HILL F3 P8003
B. TRANSFER DATA Date of Acceptance of Document
Grantor(s) /Lessor(s) Grantees) /Lessee(s)
D eutsche Bank National Trust Company, as Trustee for GSAMP
Sheriff of Cumberland County Trust 2005 -WMCI
Street Address Street Address
One Courthouse Square 2001 Australian Avenue, Bay 1
City State IP Code ity State ZIP Code
Carlisle A r,7013 ivies Beach VL h3404
C. REAL ESTATE LOCATION
Street Address ty, Township, Borough
141 East Main Street outh Newton Townshi
County 77 rch000l District ax Parcel Number
Cumberland Spring SD 1-31- 2230 -064
D. VALUATION DATA
1. Actual Cash Consideration 2. Other Consideration 3. Total Consideration
$1,970.30 $1,970.30
4. County Assessed value 5. Common Level Ratio Factor 5. Fair Market Value
$136,Cb0.00 X 1.00 5136,000.00
E. EXEMPTION DATA — WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? ® Y [] N
la. Amount of Exemption Claimed 1b. Percentage of Grantor's Interest in Real Estate lc. Percentage of Grantor's Interest Conveyed
100% 1 100% 1 100%
2.Check Appropriate Box Below for Exemption Claimed
Will or intestate succession.
❑ Transfer to Industrial Development Agency. (N ame o Decedent) a e i e Number
❑ Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.)
❑ Transfer From a trust. Date of transfer into the trust
If trust was amended attach a copy of original and amended trust.
❑ Transfer between principal and agent/straw party. (Attach complete copy of agency /straw party agreement.)
❑ Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or in lieu of
condemnation. (If condemnation or In lieu of condemnation, attach copy of resolution.)
® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of Mortgage and note /Assignment.)
❑ Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.)
❑ Statutory corporate consolidation, merger or division. (Attach copy of articles:)
® Other (Please explain exemption claimed, if other than listed above.)
Transfer from the Sheriff to the mortgagee as a result of an action in mortgaige foreclosure.
Under penalties OT 1aW, I declare that i h ave — examined this statement, including accompanying
infor ation nd to the best of my and belief it is true correct and complete.
R9 4ta " 3 ) 7//3
FAIL E T OMPL HI RM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY
RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
4
717 -240 -6370 -
_ . ,
Instrument Number - 201323550
Recorded On 7/17/2013 At 3:22:26 PM * Total Pages - 5
• Instrument Type - DEED - SHERIFF'S
Invoice Number - 142172 User ID - BMM
• Grantor - STAMBAUGH, RICHARD A
• Grantee - CUMBERLAND COUNTY
• Customer - SHERIFF
* FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS /ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES — $12.50
RECORDER OF DEEDS This page IS IIOW art
PARCEL CERTIFICATION $15.00 P g P
FEES of this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
BIG SPRING SCHOOL $0.00
DISTRICT
SOUTH NEWTON TOWNSHIP $0.00
TOTAL PAID $68.00
I Certify this to be recorded
in Cumberland County PA
f CM5
s
�-
RECORDER ° O D EDS
t�so
" - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
002Y10
III IIIIIIIIIIII I I Illlllli III
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
of trriliberf,
Jody S Smith
Chief Deputy 2013 �'I 1 2:,-;
Richard W Stewart CUMBERLAND LCUia
CUMBERLAND" " ' '' PENNSYLVANIA
IA
Deutsche Bank National Trust Company
vs. Case Number
Kristina Stambaugh (et al.) 2013-5005
SHERIFF'S RETURN OF SERVICE
09/13/2013 01:32 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint
in Ejectment by handing a true copy to a person representing themselves to be Kristina Stambaugh, wife
of defendant, who accepted as"Adult Person in Charge"for Richard A Stambaugh at 141 E. Main Street,
South Newton Township, Walnut Bottom, PA 17266.
01111111r Asir
S ,'rr'?r SHALL, DEPUTY
09/13/2013 01:32 PM - Deputy Shawn Gutshall, 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: Kristina Stambaugh at 141 E. Main Street, South Newton Township, Walnut Bottom,
PA 17266.
'A , HALL, I •UTY
09/13/2013 01:32 PM- Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint
in Ejectment by handing a true copy to a person representing themselves to be Kristina Stambaugh ,
who accepted as"Adult Person in Charge"for John/Jane Doe at 141 East Street, South Newton
Townwhip, Walnut Bottom, PA 17266.
(4/)rA7eerff
-Ar TSHAL�UTY
SHERIFF COST: $75.82 SO ANSWERS,
September 20, 2013 RONNY R ANDERSON, SHERIFF
,z;u^cvt u!ee hc-if "e'.>osef• '..c
STEVEN K.EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165) , !:MI l 2 PM � J
CHRISTINA C.VIOLA,ESQUIRE(308909) 1 `"
ANDREW J.MARLEY,ESQUIRE(312314)
STERN&EISENBERG PC ` ` "' � C O")NT.{
1581 MAIN STREET,SUITE 200 PEN�� YVI�
WARRINGTON,PA 18976
TELEPHONE:(215)572-8111
FACSIMILE:(215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for GSAMP Trust 2005-WMC1 Pooling and Docket#: 13-5005 Civil
Servicing Agreement dated as of September 1, 2005
c/o Ocwen Loan Servicing, LLC
(Plaintiff)
v.
Kristina Stambaugh a/k/a Kristina M. Stambaugh and
Richard Stambaugh a/k/a Richard A. Stambaugh
And John/Jane Doe
(Defendant(s))
PRAECIPE FOR JUDGMENT IN POSSESSION
TO THE PROTHONOTARY:
Kindly enter judgment in ejectment for possession of the following described property in favor
of the Plaintiff and against the Defendants KRISTINA STAMBAUGH A/K/A KRISTINA M.
STAMBAUGH AND RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH AND
JOHN/JANE DOE for failure to respond with in twenty (20) days pursuant to the Pennsylvania
rule of civil procedure.
PREMISES: 141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266
STERN& EISENBERG, PC
BY
M. TRO REEDMAN
Att• eys for Plaintiff
916 Scpd
auk
J:\ANGELA\POSSESSIONS\CUMBERLAND\OCWEN.STAMBAUGH.11.13.DOC g* . 9 " !ck
vb\)*(1 \e
N
' r
STEVEN K.EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165)
CHRISTINA C.VIOLA,ESQUIRE(308909)
ANDREW J,MAgLEY,ESQUIRE(312314)
STERN&EISENBERG PC
1581 MAIN STREET,SUITE 200
WARRINGTON,PA 18976
TELEPHONE:(215)572-8111
FACSIMILE:(215)_ 72-5025
(COUNSEL FOR PLAINTIFF)
• IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for GSAMP Trust 2005-WMC1 Pooling and Docket#: 13-5005 Civil
Servicing Agreement dated as of September 1, 2005
c/o Ocwen Loan Servicing,LLC
(Plaintiff)
v.
Kristina Stambaugh a/k/a Kristina M. Stambaugh and
Richard Stambaugh a/k/a Richard A. Stambaugh
And John/Jane Doe
(Defendant s))
CERTIFICATION UNDER RULE 237.1
I, the undersigned attorney on the Writ and attorney for Plaintiff, hereby certify that a
ten-day notice was required, a copy of which is attached hereto.
STERN& SENBERG, PC
BY:
M. OY FREEDMAN
• ttorneys for Plaintiff
J:\ANGELA\POSSESSIONS\CUMBERLAND\OCWEN.STAMBAUGH.11.13.DOC
STERN&EISENBERG PC
THE SHOPS AT VALLEY SQUARE
1581 MAIN STREET,SUITE 200
WARRINGTON,PA 18976
TELEPHONE: (215)572-8111
FACSIMILE:(215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for GSAMP Trust 2005-WMC1 Pooling and Docket #: 13-5005 Civil
Servicing Agreement dated as of September 1, 2005
c/o Ocwen Loan Servicing, LLC TEN DAY NOTICE
(Plaintiff)
v.
Kristina Stambaugh a/k/a Kristina M. Stambaugh and
Richard Stambaugh a/k/a Richard A. Stambaugh
And John/Jane Doe
(Defendant(s))
NOTICE PURSUANT TO Pa.R.C.P. 237.1
TO: Kristina Stambaugh a/k/a Richard Stambaugh John/Jane Doe
Kristina M. Stambaugh Richard A. Stambaugh 141 East Main Street
141 East Main Street 141 East Main Street Walnut Bottom, PA 17266
W-arnut Bottom,Pk-172-66 — Walnut-Bottom;PA-17
Date of Notice: Thursday, October 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 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:
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
800-990-9108
717-249-3166
STERN-&-EISFNBE C.,Pc-
.
•
A6rney for Plaintiff : `
J:\Angela\Ten Day\Cumberland\Ocwen.Stambaugh.10.13.docx .�
STEVEN K.EISENBERG,ESQUIRE(75736)
M.TROY FREEDMAN,ESQUIRE(85165)
CHRISTINA C.VIOLA,ESQUIRE(308909)
ANDREW J.MARLEY,ESQUIRE(312314)
STERN&EISENBERG PC
1581 MAIN STREET,SUITE 200
WARRINGTON,PA 18976
TELEPHONE:(215)572-8111
FACSIMILE:(215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for GSAMP Trust 2005-WMC1 Pooling and Docket#: 13-5005 Civil
Servicing Agreement dated as of September 1, 2005
c/o Ocwen Loan Servicing,LLC
(Plaintiff)
v.
Kristina Stambaugh a/k/a Kristina M. Stambaugh and
Richard Stambaugh a/k/a Richard A. Stambaugh
And John/Jane Doe
(Defendant(s))
AFFIDAVIT OF NON-MILITARY SERVICE
•
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF BUCKS
I, the undersigned, being duly sworn according to law, deposes and says,to the best of his
knowledge, information and belief, Defendants':
1. Last-known address is:
141 East Main Street, Walnut Bottom, PA 17266
2. Are over the age of twenty-one.
3. Are not now nor have been within the last six (6) months in the Armed Services of the
United States as defined in the Soldiers' Civil Relief Act of 1940, as amended.
COMMONWEALTH Olt PENNSYLVANIA STERN&EI:' NBERG, PC
NOTARIAL SEAL Notary HARRIGAN,Notary Public BI,:
Warrington Twp.,Bucks County
My Commission Expires November 26,2016 M. T i' d Y FREEDMAN
orneys for Plaintiff
Sworn to and subscribed ,f
before me this 11-day
of OVemIir ,2013.
4.4 ia4C
J:\ GELA\POSSESSIO•" CUMBERLAND\OCWEN.STAMBAUGH.1 1.13.Doc
SCR
tafi
Ott
Status Rep
Pursuant to Servicerriembers Civil Relief Act
ga..
Last Name: STAMBAUGH
First Name: KRISTINA
Middle Name:
Active Duty Status As Of: Nov-07-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty.Status Date
Left Active Duty Within,367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status Within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,arc
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVE!
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
)411iiiiy,
' __
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
sca;.
• ,,-1..r.,
f Status Rppott
Pursuant to crvicemem Civil Relief Act
Last Name: STAMBAUGH
First Name: RICHARD
Middle Name:
Active Duty Status As Of: Nov-07-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty,Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status:.
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,an
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIV(
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
)41411# Yijil e
-� _ ar-
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
STEVEN K.EISENBERG,ESQUIRE(75736) - f j �' t1 it.' Li
M.TROY FREEDMAN,ESQUIRE(85165)
CHRISTINA C.VIOLA,ESQUIRE(308909) :;i3 NOV 12 PM 2: 56
ANDREW J.MARLEY,ESQUIRE(312314) y
STERN&EISENBERGPC �1'3I RI_AND COUNTY
1581 MAIN STREET,SUITE 200 PENNSYLVANIA
WARRINGTON,PA 18976
TELEPHONE:(215)572-8111
FACSIMILE:(215)572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Deutsche Bank National Trust Company as Trustee
for GSAMP Trust 2005-WMC1 Pooling and Docket#: 13-5005 Civil
Servicing Agreement dated as of September 1,2005
c/o Ocwen Loan Servicing,LLC
(Plaintiff)
v.
Kristina Stambaugh a/k/a Kristina M. Stambaugh and
Richard Stambaugh a/k/a Richard A. Stambaugh
And John/Jane Doe
(Defendant(s))
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindly issue the Writ of Possession in the above matter in favor of the Plaintiff and
against the Defendants KRISTINA STAMBAUGH A/K/A KRISTINA M. STAMBAUGH AND
RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH AND JOHN/JANE DOE.
PREMISES: 141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266
STERN & EIS, BERG, PC
°tilt" -1S 0 (� BY:
0S•� S ti `' M. T •Y FREEDMAN
5 Q U
t%
• torneys for Plaintiff
-Lts S7 f D
,Dva
c) 15 IOC
J:\ANGELA\POSSESSIONS\CUMBERLAND\OCWEN.STAMBAUGH.11.13.DOC
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or
ALL THE FOLLOWING DESCRIBED REAL ESTATE LYING AND BEING SITUTAE IN THE VILLAGE
OF WALNUT BOTTOM,SOUTH NEWTOW_N TOWNSHIP,CUMBERLAND_C.GU�IT_Y, - ------ — -- - .-.-_. ._-. ...--
PENNSYLVANIA,MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEING AT A SET RAILROAD SPIKE IN THE CENTERLINE OF PA TRAFFIC ROUTE 174(WALNUT
BOTTOM ROAD)AT COMMON CORNER OF LOTS I AND 2 ON THE HEREIN REFERRED TO
SUBDIVISION PLAN;THENCE ALONG COMMON BOUNDARY LINE OF LOTS I AND 2,WHICH IS
ALSO THE EASTERLY MOST BOUNDARY OF PARCEL 1A,SOUTH THIRTY-SEVEN(37)DEGREES
TWENTY-FOUR(24)MINUTES FIFTY-FIVE(55)SECONDS EAST,NINETY-SIX AND FIFTY-SEVEN
HUNDREDTHS(96.57)FEET TO A SET IRON PIN;THENCE CONTINUING BY SAME,SOUTH
FORTY-FIVE(45)DEGREES FORTY-NINE(49)MINUTES TWENTY-FIVE(25)SECONDS EAST,ONE
HUNDRED EIGHTEEN AND THIRTY HUNDREDTHS(118.30)FEET TO A SET IRON PIN IN LINE OF
LAND NOW OR FORMERLY OF RONALD A.BAKER;THENCE ALONG LINE OF LAND NOW OR
FORMERLY OF RONALD A.BAKER,SOUTH FORTY-NINE(49)DEGREES ZERO(00)MINUTES
ZERO(00)SECONDS WEST,THIRTY-NINE AND THIRTY-TWO HUNDREDTHS(3932)FEET TO A
POINT;THENCE CONTINUING BY THE SAME,SOUTH FORTY-NINE(49)DEGREES ZERO(00)
MINUTES(00)SECONDS WEST,FIFTY AND ZERO HUNDREDTHS(50.00)FEET TO A POINT AT
CORNER OF LAND NOW OR FORMERLY OF RANDY K.BOYER;THENCE ALONG LINE OF LAND
NOW OR FORMERLY OF RANDY K.BOYER,NORTH FORTY-THREE(43)DEGREES FIFTEEN(15)
MINUTES TWO(02)SECONDS WEST,TWO HUNDRED THIRTEEN AND THIRTY-SEVEN
HUNDREDTHS(213.37)FEET TO A POINT IN THE CENTERLINE OF WALNUT BOTTOM ROAD;
THENCE ALONG THE CENTERLINE OF WALNUT BOTTOM ROAD,NORTH FORTY-SIX(46)
DEGREES FIFTY-SEVEN(57)MINUTES THIRTY-ONE(31)SECONDS EAST,FIFTY AND ZERO
HUNDREDTHS(50.00)FEET TO A POINT;THENCE CONTINUING BY SAME,NORTH FORTY-NINE
(49)DEGREES FIFTY-SEVEN(57)MINUTES(00)SECONDS,FORTY-THREE AND EIGHTY-THREE
HUNDREDTHS(43.83)FEET TO THE SET RAILROAD SPIKE,THE POINT AND PLACE OF
BEGINNING.
CONTAINING A TOTAL AREA OF 18,793 SQUARE FEET(0.431 ACRES)
BEING KNOWN AND DESIGNATED AS LOT NO.1 ON A SUBDIVISION PLAN ENTITLED"SURVEY
FOR MARY O.BOWERS"PREPARED BY STEVEN P.WOLFE,PROFESSIONAL LAND SURVEYOR,
DATED 4/11190,WHICH SUBDIVISION PLAN HAS BEEN APPROVED BY THE APPROPRIATE
MUNICIPAL AUTHORITIES AS AND FOR A SUBDIVISION PLAN AND IS RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA IN
PLAN BOOK 69,PAGE 36.
BEING KNOWN AS:141 EAST MAIN STREET,WALNUT BOTTOM,PA 17266
PROPERTY ID NO.:41-31-2230-064
•
1of 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR GSAMP TRUST
2005-WMC1 POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1,
2005 C/O OCWEN LOAN SERVICING, LLC
VS. No. 13-5005 Civil Term
KRISTINA STAMBAUGH a/k/a KRISTINA M. STAMBAUGH and RICHARD
STAMBAUGH a/k/a RICHARD A. STAMBAUGH and JOHN/JANE DOE(Occupants)
141 East Main Street
Walnut Bottom, PA 17266
Costs
Attorney's $ 224.57
Plaintiffs $
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))
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR GSAMP TRUST
2005-WMC1 POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1,
2005 C/O OCWEN LOAN SERVICING, LLC
being: (Premises as follows):
141 East Main Street, Walnut Bottom, PA 17266
***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.
David D. Buell, Prothonotary,
Common Pleas Court of Cumberland County 'A
Date 11!12/13_ i /p
2 of 2
No 13-5005 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR GSAMP
TRUST 2005-WMCI POOLING AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1,2005 C/O OCWEN LOAN SERVICING, LLC
VS.
KRISTINA STAMBAUGH a/k/a KRISTINA M. STAMBAUGH and RICHARD
STAMBAUGH a/k/a RICHARD A. STAMBAUGH and JOHN/JANE DOE
(Occupants)
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 224.75
Plff(s) $
Prothy $ 2.25
Sheriff $
Plaintiff(s)attorney name and address:
M. TROY FREEDMAN, ESQUIRE- ID# 85165
STERN &EISENBERG PC
1518 MAIN STREET, SUITE 200
WARRINGTON, PA 18976
215-572-8111
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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson L+J JP i
Sheriff J
Jody S Smith La l3 NO'S 22 AM IO: o
Chief Deputy
Richard W Stewart f3cR LRNia
Solicitor �E� t r ,F �; PENNSYLVANIA
Deutsche Bank National Trust Company
vs. Case Number
Kristina Stambaugh (et al.)
2013-5005
SHERIFF'S RETURN OF SERVICE
11/19/2013 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 of 141 E. Main Street, South Newton Township, Walnut
Bottom, PA 17266, but was unable to locate the Defendant in his bailiwick.The only residents of 141 E.
Main Street, South Newton Township, Walnut Bottom, PA 17266 are defendants Kristina Stambaugh and
Richard Stambaugh. The Sheriff therefore returns the within requested Writ of Possession as"Not
Found" pertaining to OCCUPANT.
11/19/2013 02:02 PM - 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
Kristina Stambaugh,wife of defendant Richard Stambaugh, and the Adult in Charge for the defendant, to
wit: Richard Stambaugh at 141 E. Main Street, South Newton Township, Walnut Bottom, PA 17266,
Cumberland County, informed Defendant of contents of same.
11/19/2013 02:02 PM - 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: Kristina Stambaugh at 141 E. Main Street, South Newton Township, Walnut
Bottom, PA 17266, Cumberland County, informed Defendant of contents of same and posted Sheriffs
Notice on premises.
SHERIFF COST: $66.07 SO ANSWERS,
I
Y
November 22, 2013 RONiR ANDERSON, SHERIFF
;helit,if;FGSoft..'...,.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff - �-�
Jody S Smith 4,00
Chief Deputy
Richard W Stewart r
Solicitor OFFICE OFTHE$I HERI r 37ta
."u. - .
CD
-
mow;
Deutsche Bank National Trust Company Case Number
vs.
Kristina Stambaugh (et al.) 2013-5005
SHERIFF'S RETURN OF SERVICE
11/19/2013 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 of 141 E. Main Street, South Newton Township, Walnut
Bottom, PA 17266, but was unable to locate the Defendant in his bailiwick.The only residents of 141 E.
Main Street, South Newton Township, Walnut Bottom, PA 17266 are defendants Kristina Stambaugh and
Richard Stambaugh. The Sheriff therefore returns the within requested Writ of Possession as"Not
Found" pertaining to OCCUPANT.
11/19/2013 02:02 PM- 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
Kristina Stambaugh,wife of defendant Richard Stambaugh, and the Adult in Charge for the defendant, to
wit: Richard Stambaugh at 141 E. Main Street, South Newton Township, Walnut Bottom, PA 17266,
Cumberland County, informed Defendant of contents of same.
11/19/2013 02:02 PM - 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: Kristina.Stambaugh at 141 E. Main Street, South Newton Township, Walnut
Bottom, PA 17266, Cumberland County, informed Defendant of contents of same and posted Sheriffs
Notice on premises.
01/27/2014 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of
the premises described as 141 East Main Street, Walnut Bottom, PA 17266.
SHERIFF COST: $130.73 SO ANSWERS,
January 27, 2014 RON N Y R ANDERSON, SHERIFF
e�'a4 aos
(c)County8uitc 5henfl,Teiee soft,L;c.
Ap
ALL THE FOLLOWING DESCRIBED REAL ESTATE LYING AND BEING SITUTAE IN THE VILLAGE
OF WALNur BOTTOM,SOUTH NEWTOWN TQ_WNSNiP,_C1JMBERLAND.000i�1T`�,
PENNSYLVANIA,MORE PARTICULARL'f DESCRIBED AS FOLLOWS: - --'
BEING AT A SET RAILROAD SPIKE IN THE CENTERLINE OF PA TRAFFIC ROUTE 174(WALNUT
BOTTOM ROAD)AT COMMON CORNER OF LOTS I AND 2 ON THE HEREIN REFERRED TO
SUBDIVISION PLAN;THENCE ALONG COMMON BOUNDARY LINE OF LOTS I AND 2,WHICH IS
ALSO THE EASTERLY MOST BOUNDARY OF PARCEL]A,SOUTH THIRTY-SEVEN(37)DEGREES
TWENTY-FOUR(24)MINUTES FIFTY-FIVE(55)SECONDS EAST,NINETY-SIX AND FIFTY-SEVEN
HUNDREDTHS(96.57)FEET TO A SET IRON PIN;THENCE CONTINUING BY SAME,SOUTH
FORTY-FIVE(45)DEGREES FORTY-NINE(49)MINUTES TWENTY-FIVE(25)SECONDS EAST,ONE
HUNDRED EIGHTEEN AND THIRTY HUNDREDTHS(11 5.30)FEET TO A SF,T IRON PIN IN LINE OF
LAND NOW OR FORMERLY OF RONALD A-BAKER;THENCE ALONG LINE OF LAND NOW OR
FORMERLY OF RONALD A.BAKER,SOUTH FORTY-NINE(49)DEGREES ZERO(00)MINUTES
ZERO(00)SECONDS WEST,THIRTY-NINE AND THIRTY-TWO HUNDREDTHS(39.32)FEET TO A
POINT;THENCE CONTINUING BY THE SAME,SOUTH FORTY-NINE(49)DEGREES ZERO(00)
MINUTES(00)SECONDS WEST,FIFTY AND ZERO HUNDREDTHS(50.00)FEET TO A POINT AT
CORNER OF LAND NOW OR FORMERLY OF RANDY K.BOYER;THENCE ALONG LINE OF LAND
NOW OR FORMERLY OF RANDY K.BOYER,NORTH FORTY-THREE(43)DEGREES FIFTEEN(15)
MINUTES TWO(02)SECONDS WEST,TWO HUNDRED THIRTEEN AND THIRTY-SEVEN
HUNDREDTHS(213.37)FEETTO A POINT IN THE CENTERLINE OF WALNUT BOTTOM ROAD;
THENCE ALONG THE CENTERLINE OF WALNUT BOTTOM ROAD,NORTH FORTY-STX(46)
DEGREES FIFTY-SEVEN(57)MINUTES THIRTY-ONE(3 1)SECONDS EAST,FIFTY AND ZERO
I IUNDREDTHS(50.00)FEET TO A POINT;THENCE CONTINUING BY SAME,NORTH FORTY-NINE
(49)DEGREES FIFTY-SEVEN(57)MINUTES(00)SECONDS,FORTY-THREE AND EIGHTY-THREE
HUNDREDTHS(43.83)FEET TO THE SET RAILROAD SPIKE,THE POINT AND PLACE OF
BEGINNING.
CONTAINING A TOTAL AREA OF 18,793 SQUARE FEET(0.431 ACRES)
BEING KNOWN AND DESIGNATED AS LOTNO.1 ON A SUBDIVISION PLAN ENTITLED"SURVEY
FOR MARY 0.BOWERS"PREPARED BY STEVEN P.WOLFE,PROFESSIONAL LAND SURVEYOR,
DATED 4111190,WHICH SUBDIVISION PLAN HAS BEEN APPROVED BY THE APPROPRIATE
M UNICIPAL AUTHORITIES AS AND FORA SUBDIVISION PLAN AND 1S RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA IN
PLAN BOOK 69,PAGE36.
BEING KNOWN AS:141 EASTMAIN STREET,WALNUT BOTTOM,PA 17266
PROPERTY ID NO.:41-31-2230-064
i
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