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HomeMy WebLinkAbout13-6270 Supreme Couftb f Pennsylvania Court of Com m_o ► leap For Prothonotary Use Ont)�: C vi1 Sheet r.. I A Docket No: CUMBERLAND': -s•� r ° ,� Coiitrify ( n aid The irtforrrration collected on this form is used solely for court administration purposes. This form does not supplerrren.t or replace the filing and ser>>ice of pleadings or other papers as required by la}i or rules of court. Commencement of Action: S M Complaint 0 Writ of Summons Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: MIDFIRST BANK JARRETTiSUMNER T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? Ej Yes P9 No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? n Yes No Is this an MDJAppeal? 0 Yes ® No A, Name of PWntiff/Appellant's Attorney: Leon P. Haller ® Check here if you have no attorney (are a Self- Represented [Pro Sel 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 © Intentional Buyer Plaintiff Administrative Agencies n Malicious Prosecution Debt Collection: Credit Card n Board of Assessment Ej Motor Vehicle El Debt Collection: Other 0 Board of Elections n Nuisance 0 Dept. of Transportation Q Premises Liability 0 Statutory Appeal: Other S Ej Product Liability (does not include mass tort) M Employment Dispute: E n Slander/LibeU Defamation Discrimination C n Other: n Employment Dispute: Other E3 Zoning Board ®Other: T T Q Other: O MASS TORT 0 Asbestos N Q Tobacco Toxic Tort -DES n Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Ejectment � Q Common Law /Statutory Arbitration Other: 0 Eminent Domain/Condemnation Meclaratory Judgment B n Ground Rent El Mandamus n Landlord/Tenant Dispute n Non - Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 13 Quo Warranto 0 Dental Partition n Replevin Q Legal Q Quiet Title n Other: E] Medical n Other: Q Other Professional: Updated 1/112011 F 1�.E0 O F IC' ' p 1. it 1 1 - FIR 0 N ' 0 lftlli LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 20 2 5 AM 10. L. 4 1719 NORTH FRONT STREET HARRISBURG, PA 17102 -2392 C UMBERLAND COUNTY (717)234 PEENNSYLVANIA ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA a�6 Plaintiff NO. VS. CIVIL ACTION - LAW IN EJECTMENT JARRETT SUMNER Defendant N O T I C E YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17 013 1- 800 - 990 -9108 717-249-3166 a wn� z A F� i o�q�35� N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1- 800 - 990 -9108 717 - 249 -3166 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 -2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. VS. CIVIL ACTION - LAW IN EJECTMENT JARRETT SUMNER Defendant C O M P L A I N T 1. Plaintiff, MidFirst Bank, is a corporation with an office located at 999 N.W. Grand Boulevard, Suite 100, Oklahoma City, Oklahoma 73118 2. Defendant, Jarrett Sumner, is an adult individual whose last known precise residence is 114 East Main Street, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to September 4, 2013, Defendant was the owner of certain real property known as 114 East Main Street, Mechanicsburg, Pennsylvania 17055. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on September 4, 2013, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 12- 7227 -Civil at the suit of MidFirst Bank vs. Jarrett Sumner. 6. The aforesaid property was purchased at sale by MidFirst Bank, the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriff's Sale, Plaintiff acquired title to the said premises. 8. Defendant is presently in possession of the said premises, having come into said possession by virtue of his prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit "B" WHEREFORE, Plaintiff demands judgment against Defendant in Ejectment for recovery of premises described in Exhibit " A " attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & HALLER By: Leon P. Haller, 1719 North Front Street Harrisburg, PA 17102 -2392 (717)234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: October 21, 2013 ,Y a� ALL THAT CERTAIN house and lot of ground situate on the south side of East Main Street, In the Second Ward of the Borough of Mechanlubvrg, Cumberland County, Permsylvanm, hounded on the north by East Main Street, an the east by land now or late of Harry Wei, on the south by Stouffer Alley, on the west by land now or late of Shepley, said lot being 17.1 feet in width on said street ,17.1 feet In width on said allay, and 157 feet in depth; the house on said lot erected be" known as 114 East Main Street. THE ABOVE DESCRIBED PREMISES are mare por&ulady bounded and described In acmaence with a survey made by Richard L, Ernest, R.S., dated May 27, 1981, as follows: BEGINNING at a lag halt an the southaM Tina of fast Main Street Wing 148.2 Beet east by sarne from South Arch Street: thence North 88 degrees 55 minutes East by the Southem line of East Main Street 17.1 feet to a point at punch hole, thence South 6 minutes East 157 feet to an iron pin an the perrharn lute at Stauffer Alley, thence South 88 degrees 55 minutes Vilest by the northern rme of Stauffer Alley 17.1 feet to an iron pin, thane North 5 minutes Wait 157 feet to She point and place of BEGINNING. WDK PACE UNDER AND SUBJECT, NEVERTHELESS, to conditions, restrictions, rights -Of-mm and easements ' of Out record pertaining to said premises. EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on September 4, 2013. 2. Deed from Anthony L. Crisci dated March 11, 2005 and recorded March 21, 2005 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Book 268, Page 139, to Jarrett Sumner. EXHIBIT "B" Re: Jarrett Sumner Loan No. 53473103 Property: 114 East Main Street, Mechanicsburg, PA 17055 VERIFICATION I verify that the statements made in the foregoing Complaint in Ejectment are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C. S. Section 4904 relating to unsworn falsification to authorities. MIDFIRST ANK By: Jane Rhoades Vice President MidFirst BanK Title Dated: 01,923113 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 11LED-Q''- ;ice Jody S Smith Chief Deputy yy 2013 NOV –8 Phi 3; 59 Richard W Stewart : Solicitor OFF CE�- ri-ES RIFF t UM$ERLAND COUNTY PENNSYLVANIA Midfirst Bank vs. Case Number Janet Sumner 2013-6270 SHERIFF'S RETURN OF SERVICE 11/06/2013 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, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Found"at 114 E. Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant. SHERIFF COST: $44.30 SO ANSWERS, November 06, 2013 RONIV R ANDERSON, SHERIFF (c;CcurtvS�:e Sheriff,Te,easeft.Lac. LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 13-6270 CIVIL vs. CIVIL ACTION - LAW IN EJECTMENT JARRETT SUMNER �-, ��, S2 Defendant PRAECIPE i> ro TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned action. PURCELL, KRUG & HALLER By: Leon--f. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: November 22, 2013II l8R1(oOL3 22�'-48&57 • SHERIFF'S OFFICE OF CUMBERLAND COUNTY t-� - Ronny RAnderson -0 a r:;.:, Sheriff rn r of Crraiitirtpy� `. Jody S Smith „sti�v rJ r' Chief Deputy =o ' Richard W Stewart <r Solicitor OF6 ECr r :NF- d Cr 5C G3 PN..) Midfirst Bank vs. Case Number Jarrett Sumner(et al.) 2013-6270 SHERIFF'S RETURN OF SERVICE 12/02/2013 08:25 PM- Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Jarrett Sumner, the defendant who accepted as"Adult Person in Charge"for OCCUPANTS at 114 East Main Stree , Mechanicsburg Borough, Mechanicsburg, PA 17055. BRIAN GRZYBe KI, D.1TY SHERIFF COST: $39.30 SO ANSWERS, December 03, 2013 RONNY R ANDERSON, SHERIFF (c)Coun,tySuit Shoriff,To!€osoft,Inc. LEON P. HALLER, ESQUIRE 4 t�� NiJPr't�ffte PURCELL, KRUG & HALLER j 1719 NORTH FRONT STREET ply 13 Fig 3• 3 HARRISBURG, PA 17102 -2392 ATTORNEY FOR8PLAINTIFF 1' NNSYLVAN1ATY MIDFIRST BANK • IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • NO. 13 -6270 CIVIL vs . • CIVIL ACTION - LAW • IN EJECTMENT JARRETT SUMNER • • Defendant • PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT FOR POSSESSION OF REAL PROPERTY TO THE PROTHONOTARY: Enter default judgment in ejectment for possession of the premises 114 East Main Street, Mechanicsburg, Pennsylvania 17055, described in the attached legal description in favor of Plaintiff and against the Defendant, Jarrett Sumner , and his successors, heirs and assigns for failure to answer the Complaint within twenty (20) days after service thereof on December 2 , 2013 I hereby certify that the Notice of Default required by Pa . R. C . P . 237 . 1 was mailed to Defendant above named on December 26 , 2013 . PURCELL, KRUG & HALLER By : Leon P. Haller , Esquire 1719 North Front Street Harrisburg, PA 17102 -2392 (717 ) 234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: January 7 , 2014 I10 SC3 pCi (RI C /L# J9s3 306(4/s hi6'h ce LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 -2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 13-6270 CIVIL vs . CIVIL ACTION - LAW • IN EJECTMENT • • JARRETT SUMNER • • Defendant NOTICE OF ENTRY OF JUDGMENT BY DEFAULT TO: Jarrett Sumner Defendant in the above action You are hereby notified that on , 2014 , Judgment by Default has been entered against you in the above action for possession of the real property described in the attached legal description, for the reason that you failed to file an Answer to the Complaint within 20 days after the said C- plaint was served u n you on December 2 , 2013 . ). +s Proth• ry I hereby certify that the names and address of the proper persons to receive this notice under Pa .R. C . P . 236 is : Jarrett Sumner 114 East Main Street Mechanicsburg, PA 17055 Leon P. Haller Attorney for Plaintiff A LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234 -4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • NO. 13 -6270 CIVIL vs . ▪ CIVIL ACTION - LAW • IN EJECTMENT JARRETT SUMNER • Defendant To: JARRETT SUMNER 114 EAST MAIN STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: DECEMBER 26, 2013 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717) 249 -3166 PURCELL, KRUG & - -- ER --- " Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717 ) 234-4178 Attorney ID #15700 Attorney for Plaintiff . k LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 -2392 (717 ) 234 -4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 13-6270 CIVIL vs . CIVIL ACTION - LAW . IN EJECTMENT • JARRETT SUMNER . • • Defendant . NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) ss : COUNTY OF DAUPHIN ) LEON P. HALLER, attorney for Plaintiff, being duly sworn according to law, deposes and says that he is a duly constituted representative for the Plaintiff in the above captioned action; that he is duly authorized to make this affidavit; that he has personal knowledge, information and belief, that Defendant of the real estate described in the Complaint are not in the Military or Naval Services of the United States or its allies or otherwise within the provisions of the Soldiers ' and Sailors ' Civil Relief Act of 1940, as amended. A copy of the se.. - hrough the Defense Manpower Data Center website is attached. Leon P. Haller Attorney for Plaintiff SWORN tp a d subscribed before me this �.ay of J.i..ry, 2014 . 404 t Plar4 IP i :1•J ',...1-■._7"- f/ Notary Pu.is My commission expires : (SEAL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEA; BONITA E PRUSSACK Notary Public HARRISBURG CITY;DAUPHIN COUNTY My Commission Expires Sep 26,2017 Department of Defense Manpower Data Results as of:Jan-O6-201408:29:30 • Center SCRA 3.0 ,q 't°° Status Report Pursuant to Servicemembers Civil Relief Act Last Name: SUMNER First Name: JARRETT Middle Name: Active Duty Status As Of: Jan-06-2014 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 of 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,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 14vvit logidipeirp7,4,... Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 -2392 (717) 234 -4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 13-6270 CIVIL vs . CIVIL ACTION - LAW • IN EJECTMENT • JARRETT SUMNER • Defendant ENTRY OF JUDGMENT BY DEFAULT AND NOW, on this day of , 2014 , default judgment is hereby entered against the Defendant, Jarrett Sumner , and his successors, heirs and assigns, in ejectment for possession of the premises described in the attached legal description. joribc3tosit jap Prothonotary ALL THAT CERTAIN house and tot of ground situate on the south side of East Main Street,in the Second Ward of the Borough of Mechanic9berg,Cumberland County,Pennsylvania,bounded on the north by East Main Street, on the east by land now or late of Harry Omer,on the south by Stouffer Alley,on the west by land now or late of Shepley,said lot being 17.1 feet In width on said street, 17.1 feet in width on said alley,and 157 feet in depth;the house on said lot erected being known as 114 East Main Street. THE ABOVE DESCRIBED PREMISES are more particularly bounded and described in accordance with a survey made by Richard L.Ernest,R.S..dated May 27, 1981,as follows: BEGINNING at a lag bolt on the southern line of East Main Street,hung 148.2 feet east by same from South Arch Street thence Korth 89 degrees 55 minutes East by the Southern line of East Main Street 17.1 feet to a point at punch hole;thence South 5 minutes East 157 feet to an iron pin on the northern line of Stouffer Alley;thence South 89 degrees 55 minutes West by the northern line of Stouffer Alley 17.1 feet to an iron pin;thence North 5 minutes West 157 feet to the point and place of BEC3lNNlNG. BOOK 268 PACE 139 UNDER AND SUBJECT,NEVERTHELESS,to conditions,restrictions,rights-of-way aria easements of prior record pertaining to said premises. r - • • LEON P. HALLER, ESQUIRE t .'tu HGkf7 r.A i PURCELL, KRUG & HALLER 21/14 41 13 1719 NORTH FRONT STREET P?' 3: 31 HARRISBURG, PA 17102 -2392 CUMBERL , ATTORNEY FOR8PLAINTIFF pE�5l, s}/�.VAN A ��`� MIDFIRST BANK • IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • NO. 13-6270 CIVIL vs . • CIVIL ACTION - LAW • IN EJECTMENT JARRETT SUMNER • • Defendant . PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue a Writ of Possession against Jarrett Sumner in the above matter for the possession of the premises set forth in the attached legal description. PURCELL, KRUG & HALLER By : Leon P. Haller , Esgaiire 1719 North Front Street Harrisburg, PA 17102 -2392 (717 ) 234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: January 7 , 2013 CLUJJ g Zpac)ed)5, ?0, I, ($0, 9s 'Zito (0) . ® ,."1S LiS `` N41 /94025223 IN SD " "u rU , s ;00t4 � rr a � (1)05s ,22ir a/ ayy. is d - ALL THAT CERTAIN house and lot of ground situate on the south side of East Main Street,in the Second Ward of the Borough of Mechanicsburg,Cumberland County,Pennsylvania,bounded on the north by East Main Street,an the east by land now or late of Harry 13rner,on the south by Stouffer Alley.on the west by lend now or late of Shapley,said lot being 17.1 feet in width on said street, 17.1 feet in width on said alley,and 157 feat in depth;the house on said lot erected being known as 114 East Main Street. THE ABOVE DESCRIBED PREMISES are more particularly bounded and described In accordance with a survey made by Richard L. Ernest,R.S..dated May 27, 1981,as follows: BEGINNING at a lag bolt on the southern line of East Main Street,being 148.2 feet east by same from South Arch Street;thence North 89 degrees 55 minutes East by the Southern line of East Mein Street 17.1 feet to a point at punch hole;thence South 5 minutes East 157 feet to an iron pin on the northern foe of Stouffer Alley;thence South 89 degrees 55 minutes West by the northern fine of Stouffer Alley 17.1 feet to an iron pin;thence North 5 minutes West 157 feet to the paint and place of BEGINNING. GODK 268 PACE 13 UNDER AND SUBJECT,NEVERTHELESS,to conditions,restrictions,rights-af•way and easements of prior record pertaining to said premises. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MIDFIRST BANK VS. No. 13-6270 Civil Term_ JARRETT SUMNER 114 EAST MAIN STREET MECHANICSBURG, PA 17055 Costs Attorney's $ 244.10 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)) MIDFIRST BANK being: (Premises as follows): 114 EAST MAIN STREET, MECHANICSBURG, PA 17055 ***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. 112i� David D. Buell, Prothonotary, Common Pleas Court of Cumberland C unty, PA Date 1/13/2014 (Seal) 2 of2 No 13-6270 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MIDFIRST BANK VS. JARETT SUMNER WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 244.10 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s) attorney name and address: LEON P. HALLER, ESQUIRE - ID# 15700 PURCELL, KRUG&HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 717-234-4178 Attorney for Plaintiff(s) Where papers may be served By virtue of this writ, on the day of , . I caused the within named ,to have possession of the premises described with the appurtenances, and So Answers, Sworn and subscribed to before me this Day of , Sheriff By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE t TI-IOI T -, :* ot Jody S Smith 21014 FEB 12 PM 3: 53 Chief Deputy Richard W Stewart CUKBERLAN1J COUNTY Solicitor PENNSYLVANIA Midfirst Bank vs. Case Number Jarrett Sumner(et al.) 2013-6270 SHERIFF'S RETURN OF SERVICE 02/11/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jarrett Sumner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as"Not Found"at 114 E. Main Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Nine attempts at service were made with negative results. Deputies did note that the doors were padlocked shut; water had been shut off by United Water Company on 01-03-14; however, mail is still being delivered to the residence. It is believed the property is vacant; however, someone could be "squatting" inside. 02/12/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED at request of plaintiffs attorney. SHERIFF COST: $70.53 SO ANSWERS, February 12, 2014 RONR ANDERSON, SHERIFF c2- .ZSP�!•Cr, - f'y9�a 'P't'y 3 d1S-9r