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Home My WebLink About13-7275 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -6759 MLD JAMES KNOX 22 YORK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -030A Defendant. -' 7 m ..fir C-) wit, "3 PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS ZC co � . TO: PROTHONOTARY p "� C 73 Please issue a Writ of Scire Facias, against the Defendant, James Knox, in the amount of $4,412.26, in the above - captioned matter. JSDC Law ffice Date: �` I By: Scot Dietterick, Esquire PA ID #55650 Kathryn L. Mason, Esquire PA ID #306779 D S PO Box 650 Hershey, PA 17033 �� "U (717) 533 -3280 q 1 so OF Attorneys for Plaintiff OD Sal Fe as Sc� �ss� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 NO.: 13 -6759 MLD Plaintiff, NO.: VS. JAMES KNOX TYPE OF PLEADING 22 YORK CIRCLE MECHANICSBURG, PA 17050 CIVIL ACTION - WRIT PARCEL #38 -21- 0289 -030A OF SCIRE FACIAS Defendant. FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff TO: DEFENDANT(s) COUNSEL OF RECORD FOR THIS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE PARTY: ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT Scott A. Dietterick, Esquire MAY B ENTERED AGAINST YOU. Pa. I.D. #55650 Kathryn L. Mason, Esquire Pa. I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533 -3280 A ORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 5 Willow Mill Park Road, Suite 3 JSDC LAW OFFICES Mechanicsburg, PA 17050 AND THE DEFENDANTS: 22 York Circle Mecha csburg, PA 17050 A R PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF T THE AL EST E AFFECTED BY THIS LIEN IS 22 Yo Ci a hanicsburg, PA 17050 AT FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -6759 MLD vs. JAMES KNOX 22 YORK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -030A Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249 -3166 Toll Free (800) 990 -9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -6759 MLD VS. JAMES KNOX 22 YORK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -030A Defendant. AVISO USTED HA SIDO DEMONDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249 -3166 Toll Free (800) 990 -9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE #3 MECHANICSBURG, PA 17050 Plaintiff, No.: 13 -6759 MLD VS. -413 - 7791S JAMES KNOX 22 YORK CIRCLE MECHANICSBURG, PA 17050 PARCEL ID# 38 -21- 0289 -030A Defendant. WRIT OF SCIRE FACIAS TO: JAMES KNOX WHEREAS, Silver Spring Township Authority, on November 15, 2013, filed its claim in the Court of Common Pleas of Cumberland County at Municipal Claim No. 13 -6759 MLD, for the sum of $4,412.26, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Silver Spring Township Authority, said Claim filed against property owned by you in Silver Spring Township, located at 22 York Circle, Mechanicsburg, PA 17050, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 277, Page 3956, tax parcel #38 -21- 0289 -030A, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof. — )u �-, 2W'-g&- Aa Ss , LSW Fee PROTHONOT °� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 4 4 Sheriff Jody S Smith r : s�s r Chief Deputy , , y 4; Richard W Stewart , Solicitor �.� .� �, �� .�., } '� St�GLAkD L 3 l PENNSYLVANIA Silver Spring Township Authority Case Number vs. James Knox 2013-7275 SHERIFF'S RETURN OF SERVICE 12/12/2013 03:22 PM-Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Scire Facias by handing a true copy to a person representing themselves to be Gladys Lee, Mother-In-Law., who accepted as"Adult Person in Charge"for James Knox at 22 York Circle, Silver Spring Township, Mechanicsburg, PA 17050. S " V',7-0� DAWN KELL, DEPUTY SHERIFF COST: $3930 SO ANSWERS, December 13, 2013 RbNW R ANDERSON, SHERIFF I , t - eA - o��C L1 cvv IN THE COURT OF COMMON PLEAS OF `L.{ `�'� ,P�h CUMBERLAND COUNTY, PENNSYLVANIA ��1^�v A SILVER SPRING TOWNSHIP CIVIL DIVISION �l- yl AUTHORITY, 5 WILLOW MILL PARK ROAD SUITE#3 / MECHANICSBURG, PA 17050 ./ No.: 13-7275 CIVIL TERM No.: 13-6759 MLD Plaintiff, vs. TYPE OF PLEADING: JAMES KNOX PRAECIPE FOR DEFAULT JUDGMENT 22 YORK CIRCLE (Municipal Lien) MECHANICSBURG, PA 17050 PARCEL ID#38-21-0289-030A Defendant. FILED ON BEHALF OF: Silver Spring Township Authority, Plaintiff I Hereby certify that the last known COUNSEL OF RECORD FOR THIS address of Defendant(s) is/are: PARTY: 22 York Circle Scott A. Dietterick, Esquire—PA ID #55650 Mechanicsburg, PA 17050 Kathryn L. Mason, Esquire—PA ID #306779 I, a JSDC LAW OFFICES Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 \k a41 C'\(-- D,3- 9 r 'tN(SI l _3 Fr 2: 3-i IN THE COURT OF COMMON PLEAS OF :" CUMBERLAND COUNTY, PENNSYLVANIA rI � �� , PE !F SYLVAN!A SILVER SPRING TOWNSHIP AUTHORITY • CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE#3 • MECHANICSBURG, PA 17050 • Plaintiff, • No.: 13-6759 MLD vs. • • No.: 13-7275 Civil JAMES KNOX • 22 YORK CIRCLE • MECHANICSBURG, PA 17050 • PARCEL ID#38-21-0289-030A • Defendant. • PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, James Knox,in the amount of$4,412.26, plus interest,penalties, and Quarterly bills after the 3rd Quarter 2013 billing, and additional attorneys' fees and costs reasonable and actually incurred. JSDC Law Offices Date: -(4i— ; I L.-1 By: � �.�.L • Scott A. Dietterick, Esquire PA I.D. #55650 Kathryn L. Mason, Esquire PA I. D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth,personally appeared Kathryn L. Mason, Esquire, attorney for and authorized representative of Plaintiff who,being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Kathryn L. Mason, Esquire Sworn to and subscribed before me this 27th day of February, 2014. Ch A-4 )1 ti . vdoc_ Notary Public I My Commission Expires: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO,DAUPHIN COUNTY My Commission Expires Feb 2,2017 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY • CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE#3 MECHANICSBURG, PA 17050 • Plaintiff, : No.: 13-6759 MLD vs. • • No.: 13-7275 Civil JAMES KNOX • 22 YORK CIRCLE • MECHANICSBURG, PA 17050 PARCEL ID#38-21-0289-030A • Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: James Knox ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on VAI • ,� , 2014. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,412.26 plus interest, penalties, and Quarterly bills after the 3rd Quarter 2013, plus additional attorneys' fees and costs reasonable and actually incurred and for fore' osur d s the Pre Prothonotary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _syttp sfi C:tira-.eq. r��b. Jody S Smith Chief Deputy Richard W Stewart Solicitor I^=N N"7."'E '`� Silver Spring Township Authority Case Number vs. James Knox 2013-7275 SHERIFF'S RETURN OF SERVICE 12/12/2013 03:22 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Scire Facias by handing a true copy to a person representing themselves to be Gladys Lee, Mother-In-Law., who accepted as"Adult Person in Charge"for James Knox at 22 York Circle, Silver Spring Township, Mechanicsburg, PA 17050. DAWN KELL, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, December 13, 2013 RONO R ANDERSON, SHERIFF ;C?CountySuito Sheriff,Teleosott Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY CIVIL DIVISION • 5 WILLOW MILL PARK ROAD, SUITE#3 MECHANICSBURG,PA 17050 Plaintiff, No.: 13-6759 MLD • vs. No.: 13-7275 Civil JAMES KNOX • 22 YORK CIRCLE • MECHANICSBURG,PA 17050 • PARCEL ID#38-21-0289-030A Defendant. : IMPORTANT NOTICE TO: James Knox 22 York Circle Mechanicsburg,PA 17050 DATE OF NOTICE: January 3,2014 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S.Bedford Street Carlisle,PA 17013 Phone(717)249-3166 (800)990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY : CIVIL DIVISION • 5 WILLOW MILL PARK ROAD, SUITE#3 • MECHANICSBURG,PA 17050 Plaintiff, • No.: 13-6759 MLD • vs. • No.: 13-7275 Civil JAMES KNOX • 22 YORK CIRCLE • MECHANICSBURG,PA 17050 • PARCEL ID#38-21-0289-030A Defendant. . AVISO IMPORTANTE A. James Knox FECHA DEL AVISO: January 3, 2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ(10)DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS 1MPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO,VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S.Bedford Street Carlisle,PA 17013 Phone(717)249- 66 (800)990-910 JSDC L OFFIC DATE: I"3 ' 1 BY'- `* tt A. Fgr , squire PAI.r. _ . Kathryn L. Mason, Esquire PA I.D. #306779 Attorneys for Plaintiff P.O. Box 650 Hershey,PA 17033 FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280 Department of Defense Manpower Data Center Results as of:Feb-26-2014 01:39:49 PM SCRA 3.0 Status Report • s• Pursuant to Servicemembers Civil Relief Act Last Name: KNOX First Name: JAMES Middle Name: E Active Duty Status As Of: Feb-26-2014 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. )410,Aft, Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: L7OAT20C601 E6F0 IN THE COURT OF CtM"DN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Silver Spring Township CIVIL DIVISION Authority : File No.13-6759 MLD / 13-7275 Civil Term (Plaintiff) : Amount Due $ 4,412.26 v Interest from to $ James Knox date of sale Atty's Comm Costs (Defendant(s) TO THE PRO'I'fiONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it- is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION c.> .,S. : .i7:..'.,- - Issue writ of execution in the above matter to the Sheriff of Cumberlar .� County, for debt, interest and costs upon the following described property of l t= ';` , defendant(s) .`r t? �"' 2U -0 c.-,.":.1'2 See Exhibit "A" attached. 7' , -4- PRAFCIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: February 27, 2014 Signature: iii _ , i_A, '-j( N 1�J . . ' at ryn 'anon, squire Print Name: Scott A. Dietterick, Esquire �� 'a - Address: James Smith Dietterick & Connelly LLP I Al) c.v sS�=� �- ,, P 0 Box 650, Hershey PA 17033 t 31. 3 O a" 11320(.01C'o Attorney for: Plaintiff i, Telephone: (717) 533-3280 3 ,��b `i S5OD .L(- P sc�f. Supreme� Court ID No.: 55650 /306779 . 73 1 = 3O �°� 9:s6 36D3 b i'2 - --4-SSlicd- LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of real estate situate in Silver Spring Township, Cumberland County, Commonwealth of Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the Eastern legal right of way line of York Circle at the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along said legal right of way line, South 55 degrees 00 minutes 00 seconds East, a distance of 75 feet to a point; thence North 35 degrees 45 minutes 00 seconds East, a distance of 175 feet to a point at the corner of Lot No. 10 on the hereinafter described subdivision plan; thence along the Western line of said Lot No. 10,North 55 degrees 00 minutes 00 seconds West, a distance of 75 feet to a point at the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along line of Lot No. 2 South 35 degrees 45 minutes 00 seconds West, 175 feet to a point on the Eastern legal right of way line of York Circle,the point and place of BEGINNING. CONTAINING 13,123.71 square feet. BEING Lot No. 1,Final Major Subdivision Plan of Brandywine Village"Extended", dated July 31, 1986, recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Plan Book 51, Page 97. BEING known as No. 22 York Circle, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Jonathan M. Buser and Lori A. Buser,husband and wife,by their Deed dated November 30, 2006, and recorded on December 1, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 277, Page 3956, granted and conveyed unto James Enoch Knox,Jr., a married man. Parcel No.: 38-21-0289-030A Exhibit "A" IN THE COURT OF COMMON PLEAS OF L`'; . _3 Pil 2: 40 CUMBERLAND COUNTY, PENNSYLVANIA C,i MBERLAND COUNT' PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY : CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE#3 • MECHANICSBURG, PA 17050 Plaintiff, • No.: 13-6759 MLD vs. • • No.: 13-7275 Civil • JAMES KNOX • 22 YORK CIRCLE • MECHANICSBURG, PA 17050 • PARCEL ID# 38-21-0289-030A Defendant. : AFFIDAVIT PURSUANT TO RULE 3129.1 Silver Spring Township Authority, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 22 York Circle, Mechanicsburg, Pennsylvania 17050: 1. Name and Address of Owner(s) or Reputed Owner(s): JAMES KNOX 22 York Circle Mechanicsburg, PA 17050 2. Name and Address of Defendant(s) in the Judgment: JAMES KNOX 22 York Circle Mechanicsburg, PA 17050 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: SILVER SPRING TOWNSHIP AUTHORITY Plaintiff BUREAU OF COMPLIANCE Department 280946 Harrisburg, PA 17128 CHASE BANK USA NA 3700 Wiseman Blvd, Bldg 2, 1st Flr San Antonio, TX 78251 and do David J. Apothaker, Esquire 520 Fellowship Road, C306 Mount Laurel,NJ 08054 4. Name and Address of the last record holder of every mortgage of record: PHH MORTGAGE CORPORATION 4001 Leadenhall Road Mt. Laurel,NJ 08054 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM Cumberland County Courthouse BUREAU One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: DEPARTMENT OF REVENUE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 UNKNOWN SPOUSE OF 22 York Circle JAMES KNOX Mechanicsburg, PA 17050 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal 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. JSDC LAW OFFICES DATED: 0( . /' )�1 BY: (--�/�� Scott A. Dietterick, Esquire Pa. I.D. #55650 Kathryn L. Mason, Esquire Pa. I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SILVER SPRING TOWNSHIP AUTHORITY • CIVIL DIVISION 5 WILLOW MILL PARK ROAD, SUITE#3 • MECHANICSBURG, PA 17050 Plaintiff, No.: 13-6759 MLD vs. • • No.: 13-7275 Civil , JAMES KNOX : 22 YORK CIRCLE • -ate t MECHANICSBURG, PA 17050 • PARCEL ID#38-21-0289-030A 37 Defendant. : NOTICE OF SHERIFF'S SALE y OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 James Knox 22 York Circle Mechanicsburg, PA 17050 TAKE NOTICE: That the Sheriffs Sale of Real Property(Real Estate)will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday,June 4,2014, at 10:00 a.m.prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 22 York Circle Mechanicsburg, Pennsylvania 17050 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-7275 Civil Term No. 13-6759 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: James Knox A SCHEDULE OF DISTRIBUTION,being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty(30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact,be made unless someone objects by filing exceptions to it,within ten(10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held,to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JSDC LAW OFFICES DATED: ,' •t�C "I BY: ' t.... kkurl Scott A. Dietterick, Esquire Pa. I.D. #55650 Kathryn L. Mason, Esquire Pa. I.D. #306779 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff VIA CERTIFIED MAIL—RETURN RECEIPT REQUESTED and VIA PERSONAL SERVICE BY THE CUMBERLAND COUNTY SHERIFF LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of real estate situate in Silver Spring Township, Cumberland County, Commonwealth of Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the Eastern legal right of way line of York Circle at the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along said legal right of way line, South 55 degrees 00 minutes 00 seconds East, a distance of 75 feet to a point;thence North 35 degrees 45 minutes 00 seconds East, a distance of 175 feet to a point at the corner of Lot No. 10 on the hereinafter described subdivision plan; thence along the Western line of said Lot No. 10,North 55 degrees 00 minutes 00 seconds West, a distance of 75 feet to a point at the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along line of Lot No. 2 South 35 degrees 45 minutes 00 seconds West, 175 feet to a point on the Eastern legal right of way line of York Circle,the point and place of BEGINNING. CONTAINING 13,123.71 square feet. BEING Lot No. 1,Final Major Subdivision Plan of Brandywine Village"Extended", dated July 31, 1986, recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Plan Book 51,Page 97. BEING known as No. 22 York Circle, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Jonathan M. Buser and Lori A. Buser,husband and wife,by their Deed dated November 30, 2006, and recorded on December 1, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 277, Page 3956,granted and conveyed unto James Enoch Knox,Jr., a married man. Parcel No.: 38-21-0289-030A Exhibit"A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-7275 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SILVER SPRING TOWNSHIP AUTHORITY Plaintiff(s) From JAMES KNOX (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$4412.26 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$.50 Attorney Paid$139.30 Due Prothonotary 9 Li:50 Other Costs$ y.j D sal Fubuc �/ Date:3/3/14 (f David D. Buell,Protho otary By: Deputy REQUESTING PARTY: Name : KATHRYN L. MASON,ESQ. Address: JAMES SMITH DIETTERICK&CONNELLY LLP,PO BOX 650,HERSHEY,PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No.306779 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY `- E P 11 ON O -f 1( v 2014 AUG _it AH .9:35 CUMBERLAND COUNTY OFF IC FTRE $ti£R!FF PENNSYLVANIA at Silver Spring Township Authority vs. James Knox Case Number 2013-7275 SHERIFF'S RETURN OF SERVICE 03/27/2014 12:38 PM - Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 22 York Circle, Silver Spring - Township, Mechanicsburg, PA 1750, Cumberland County. 03/31/2014 07:53 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Angelique Knox, wife, who accepted as "Adult Person in Charge" for James Knox at 22 York Circle, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 06/03/2014 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 07/01/2014 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 07/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,022.67 July 30, 2014 ic, CountvSL, to Bneriff, Teleosoft. Enc. SO ANSWERS, RONR ANDERSON, SHERIFF 413-0 Pd ' Co ,5bpd- C.) C) - On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as 22 York Circle, Mechanicsburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Real Estate Coordinator :_? • LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-7275 Civil Term Silver Spring Township Authority vs. James Knox Atty.: Scott A. Dietterick ALL THAT CERTAIN tract or parcel of real estate situate in Sil- ver Spring Township, Cumberland County, Commonwealth of Pennsyl- vania, more particularly bounded and described as follows: BEGINNING at a point on the Eastern legal right of way line of York Circle at the corner of Lot NO.2 on the hereinafter described subdivision plan; thence along said legal right of way line, South 55 degrees 00 minutes 00 seconds East, a distance of 75 feet to a point; thence North 35 degrees 45 minutes 00 seconds East, a distance of 175 feet to a point at the corner of Lot No. 101 on the hereinafter described subdivision plan; thence along the Western line of said Lot No. 10, North 55 degrees 00 minutes 00 seconds West, a distance of75 feet to a point at the corner of Lot NO.2 on the hereinafter described subdivision plan; thence along line of Lot NO.2 South 35 degrees 45 minutes 00 seconds West, 175 feet to a point on the Eastern legal right of way line of York Circle, the point and place of BEGINNING. CONTAINING 13,123.711 square feet. BEING Lot No.1, Final Major Subdivision Plan of Brandywine Village "Extended", dated July 31, 1986, recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Plan Book 51, Page 97. BEING known as No. 22 York Circle, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Jonathan M. Buser and Lori A. Buser, husband and wife, by their Deed dated November 30, 2006, and recorded on December I, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book 277, Page 3956, granted and conveyed unto James Enoch Knox, Jr., a married man. Parcel No.: 38-21-0289-030A. 72 ,The Pp�trioj-News Co. 42.20 Tebhnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 be atriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds 'J afatv Paid.Cnlintu.nf..nnuphin in Miscellaneous Book "M",Volume 14, Page 317. �AUT"2013-7275 Civil Term Silver Spring Township Authority Vs James Knox Atty: Scott A Dietterick ALL THAT CERTAIN tract or parcel l of real estate situate in Silver Spring Township, Cumberland County, Commonwealth of Pennsylvania, mor particularly bounded and desc ed as follows: BEG ING at a point on the Easte legal right of way line of York Circle at the corner of Lot NO.2 on the hereinafter described subdivision plan; thence along said legal right of way line, South 55 degrees 00 minutes 00 seconds East, a distance of 75 feet to a point; thence North 35 degrees 45 minutes 00 seconds East, a distance of 175 feet to a point at the corner of Lot No. 10 on the hereinafter described subdivision plan; thence along the Western line of said Lot No. 10, North 55 degrees 00 minutes 00] _c nrlc WQct riictana. of 75_feet`t o This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 Sworrvto and subscribed before m is 0 day of May, 2014 A.D. Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES