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HomeMy WebLinkAbout14-0650 t o, Supreme Court of Pennsylvania Court of Common Pleas For Proitronotayy Use Chr(r. Civil Cover Sheet D ocket No: Cumberland County Al— LT6 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the film g and service of pleadings or other papers as required by law or rules of court. S Commencement of Action: E x Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Takin Lead Plaintiff's Name: LSF8 MASTER Lead Defendant's Name: MICHAEL V. KITNER OR OCCUPANTS T PARTICIPATION TRUST I O N Are money damages requested?: ❑ Yes X No Dollar Amount Requested: within arbitration limits A (Check one) outside arbitration limits Is this a Class Action Suit? ❑ ❑ Yes ❑ X No Is this an MDJ A eal? [] Yes ❑ X No Name of Plaintiff /Appellant's Attorney: Martha Von Rosenstiel, Esg. ❑ Check here if you are a Self (Pro Se) Litigant Nature of the Case Place an `.X,; to the left of the ONE case category that most accurately describes your PRI.If 4RY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not Inchtde u Ton) _ CONTRACT (do ;?or inchtde. 3urdgmew s) CIti'IL APPEALS 0 Intentional ❑ Buyer Plaintiff Administrative Agencies Q Malicious Prosecution 0 Debt. Collection: Credit Card ❑ Board of Assessment Q Motor Vehicle Q Debt Collection: Other ❑ Board of Elections nuisance Dept. of Transportation Premises Liability ❑ Statutory Appeal: Other S i0 Product Liability (does not include moss tout) ❑ Employment Dispute: E Q Slander /Libe.1! Defamation Discrimination Q Employment Dispute: Other ❑ Zoning Board C Q Other: p Other: T Q Other: Q NIASS TORT ❑ Asbestos N Q Tobacco 0 Toxic Tort - DES REAL PROPERTY MISCELLANEOUS Q Toxic T ort - Implant r Q Toxic. Waste ❑ Other: � Ejectrneut [] Cauanou Lan - /Statutory Arbitration B Q Eminent Domain`Condetuuation ❑ Declaratory Judgment ❑ Ground Rent. Mandannts Q Landlord/Tenant Dispute Non- Domestic Relations Q Mortgage Foreclosure: Residential Restrainiug Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure: Commercial ❑ Quo Warranto 0 Dental ❑ Partition ❑ Replevin Q Legal ❑ Quiet Title ❑ Other: Q Medical 0 Other: Q Other Professional: Updated I /1/2011 r,LEU 1' ICE 33611- CFC -EM Martha E. Von Rosenstiel, P.C. O T HE P RO THONO TARY Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 10k FEB -4 PM 2' 1 Secane, PA 19018 CUMBERLAND 'COUNTY (610) 328 -2887 PENNSYLVANIA Attorney I.D. #52634 LSF8 MASTER PARTICIPATION TRUST COURT OF COMMON PLEAS OF 13801 Wireless Way CUMBERLAND COUNTY Oklahoma City, OK 73134 Plaintiff V. NO. Ct U�l��� MICHAEL V. KITNER OR OCCUPANTS 1419 Pheasant Drive South Carlisle, PA 17013 Defendant(s) CIVIL ACTION - EJECTMENT NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le ban demandado a usted en la corte. Si usted quiere defenderse de set forth in the following pages, you must take action within twenty (20) estas demandas expuestas en las paginas siguientes, usted tiene days after this complaint and notice are served, by entering a written veinte (20) dias de plazo al partir de la fecha de la demanda y la appearance personally or by attorney and filing in writing with the court notificacion. Hace falta a sentar una comparencia escrita o en your defenses or objections to the claims set forth against you. You are persona o con un abogado y entregar a la corte en forma escrita sus warned that if you fail to do so the case may proceed without you and a defensas o sus objeciones a las demandas en contra de su persona. judgment may be entered against you by the court without further notice Sea a visado que si usted no se defiende, la corte toma ra medidas y for any money claimed in the complaint or for any other claim or relief puede continuar la demanda en contra suya sin previo aviso o requested by the plaintiff. You may lose money or property or other notificacion. Ademas, la corte puede decidir a favor del rights important to you demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW. THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT . ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER A UN ABOGADO, LE PODEMOS DAR INFORMACION LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 063. 717 - 249 -3166 800 - 990 -9108 J MARTHA E. VON ROSENSTIEL, P.C. 33611- CFC -EM Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST COURT OF COMMON PLEAS OF 13801 Wireless Way CUMBERLAND COUNTY Oklahoma City, OK 73134 Plaintiff V. NO. MICHAEL V. KITNER OR OCCUPANTS 1419 Pheasant Drive South Carlisle, PA 17013 ; Defendant(s) CIVIL ACTION - EJECTMENT 1. Plaintiff, LSF8 Master Participation Trust, is the owner of premises known as 1419 Pheasant Drive South, Carlisle, PA 17013, more fully described in the legal description, a true and correct copy is attached hereto, made part hereof and marked as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on December 04, 2013, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, Docket No. 2013 -3393 where Plaintiff was the successful bidder. 3. The Plaintiff became the owner of the said property by a sheriff's deed recorded on January 15, 2014 in the Office of the Recorder of Cumberland County at Instrument No. 201401156, said Deed being a matter of public record and said recording information provided in lieu of a copy of the Deed, pursuant to Pa.R.C.P. 1019(g). 4. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The Defendants Michael V. Kitner or Occupants are occupying the said premises without right, and so far as the Plaintiff is informed, without claim of title. WHEREFORE, plaintiff demands judgment for possession of 1419 Pheasant Drive South, Carlisle, PA 17013. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Ro ens iel, Esquire Heather Riloff, Es Attorneys for Plaintiff 4i VERIFICATION I verify that the statements made in the foregoing documents are true and correct and are matters of public record. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rose stiel, Esquire Heather Riloff, Esq 're Attorneys for Plainti Dated: January 28, 2014 R„ a EXHIBIT I ALL THAT CERTAIN piece or parcel of land situated in North Middleton Township, Cumberland County, Pennsylvania, more particularly shown on a certain plan entitled Final Subdivision Plan of Phase Il and lit of Pheasant Run Estates for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania Scale: I "--.50' by Gerrit J. Betz Associates, Inc., Engineers & Surveyors, 6 East Main Street, Shiremanstown, Pennsvlvania, which plan is tiled in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland. County. Said lot is more particularly bounded and described as follows: BEGINNING at a point on the western right of way line of Pheasant Drive South, said point also being at the dividing line between Lot Nos. 47 and 48, as shown on the above referred to plan; thence from said point of beginning along the aforesaid dividing line of Lot Nos, 47 and 48, North 83 degrees 10 minutes 21 seconds Nest, 145.45 feet to a point; thence along land shown as "Recreation and Green Area" on said Plan, North 06 degrees 49 minutes 39 seconds East, 18.00 feet to a point; thence along the dividing line between Lot Nos. 48 and 49 on said Plan, South 83 degrees 10 minutes 21 seconds East, 141.37 feet to a point on the western right of way line of Pheasant Drive South; thence along said right of way line by a curve to the left with a radius of 125.00 feet, 18.50 feet to a point, the Placc of BEGINNING. BEING Lot No. 48 of Pheasant Run Estates, Section 11 recorded in Plan Book 29, Page 7. TOGETHER. with the right, in common with others, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. SITBJ ECT to Declaration of Covenants recorded in Misc. Book 242, Page 843 in the Office of the Recorder of Deeds for Cumberland County. HAVING THEREON FRECTED a two -story townhouse known and numbered as 1419 Pheasant Drive South, Carlisle, PA 17013. BEING Parcel lD No. 29 -17 -1583 -092 BEING tl:te same premises which Sermjet B. Ingle, single woman, by Deed dated March 30, 2006. and recorded April 21, 2'006 in the Office of the Recorder of Deeds for the County of Cumberland in Book 274, Page 610, granted and conveyed unto Michael V. Kitner, single rxaan, in fee. AND BEING the same premises which were sold to LSF8 MASTER PARTICIPATION TRUST, as Trustee by the Sheriff of CUMBERLAND County on December 04, 2013 in execution of a judgment in mortgage foreclosure entered in the Court of Common Pleas of CUMBERLAND County Docket No. 2013 -3393. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson j t � { J, ` -i ` Sheriff ,,1,;it fi 1tgf Jody S Smith t f ' C ��! E t I P 3: Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor - PENNSYLVANIA LSF8 Master Participation Trust Case Number vs. 2014-650 Michael Vance Kitner SHERIFF'S RETURN OF SERVICE 02/06/2014 09:53 AM - Sheriff Ronny R Anderson, 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 Served" at 1419 Pheasant Drive South, North Middleton Township, Carlisle, PA 17013. Defendant Michael Kitner was served with a copy of the Complaint in Ejectment. 02/06/2014 04:37 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Vance Kitner at 1419 Pheasant Drive South, North Middleton Township, Carlisle, PA 17013. JASON KIN9`CE , DEPUTY SHERIFF COST: $50.78 SO ANSWERS, February 07, 2014 RONNY R ANDERSON, SHERIFF MARTHA E. VON ROSENSTIEL, P.C. 33611CFJ-EM Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST : COURT OF COMMON PLEAS 13801 WIRELESS WAY • CUMBERLAND COUNTY OKLAHOMA CITY OK 73134 PLAINTIFF VS. • r.w, : CASE NO: 2014-00650 MICHAEL V. KITNER OR OCCUPANTS r-i - • 1419 PHEASANT DRIVE SOUTH CARLISLE PA 17013 • s-- DEFENDANT(S) • c: PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in the above captioned Ejectment action for failure of the above named defendants to file an answer within twenty days from date of service thereof. I hereby certify that Notice as provided in Rule 237.5 has been duly given, and that the time limits provided for in that notice have expired as evidenced by the attached Exhibit I. Property Address: 1419 PHEASANT DRIVE SOUTH CARLISLE PA 17013 MARTHA E. VON ROSEN'.TIEL, P.C. BY: artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: March 11, 2014 S'es .)ct_44/1 C.krif t.32q R, .?tf r MARTHA E. VON ROSENSTIEL,P.C. #33611CTD - EM Martha E. Von Rosenstiel,Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST : COURT OF COMMON PLEAS 13801 WIRELESS WAY : CUMBERLAND COUNTY OKLAHOMA CITY, OK 73134 PLAINTIFF VS. •• MICHAEL V. KITNER OR OCCUPANTS : CASE NO: 2014-00650 1419 PHEASANT DRIVE SOUTH CARLISLE, PA 17013 •• DEFENDANT •• • TO: Michael V. Kitner 1419 Pheasant Drive South Carlisle, PA 17013 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 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, 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 2 LIBERTY AVENUE CARLISLE, PA I7013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL P.C. BY: A Ma t'a E. Von Rosenstiel, Esquire Heather Riloff, Esquire _ Attorneys for Plaintiff Dated: 2/27/14 MARTHA E. VON ROSENSTIEL, P.C. #336I 1CTD-EM Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST : COURT OF COMMON PLEAS 13801 WIRELESS WAY : CUMBERLAND COUNTY OKLAHOMA CITY, OK 73134 PLAINTIFF VS. •• MICHAEL V. KITNER OR OCCUPANTS : CASE NO: 2014-00650 1419 PHEASANT DRIVE SOUTH CARLISLE, PA 17013 •• DEFENDANT •• TO: Occupants 1419 Pheasant Drive South Carlisle,PA 17013 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 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, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIE , P.C. BY: Martha E. Von Rosenstiel,Esquire f Heather Riloff, Esquire Attorneys for Plaintiff Dated: 2/27/14 a MARTHA E. VON ROSENSTIEL, P.C. 33611CFJ-EM Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST : COURT OF COMMON PLEAS 13801 WIRELESS WAY : CUMBERLAND COUNTY OKLAHOMA CITY OK 73134 . PLAINTIFF : VS. . MICHAEL V. KITNER OR OCCUPANTS : CASE NO: 2014-00650 1419 PHEASANT DRIVE SOUTH . CARLISLE PA 17013 . DEFENDANT(S) . • AFFIDAVIT OF NON MILITARY SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual(s) involved in this action is/are the former owner(s)/occupant(s) of the premises described in the ejectment underlying action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the defendant(s) and occupant(s). Said procedures were followed in connection with the instant ejectment proceeding. 4. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. On information and belief, named defendant(s) and occupant(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act of 2003, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to penalties of 18 Pa C.S. Section 4904 relatin• o unsworn falsification to authorities. MART. A E. VON ROSENSTI'IL, P.C. BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: March 11, 2014 MARTHA E. VON ROSENSTIEL, P.C. 33611CFJ-EM Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff LSF8 MASTER PARTICIPATION TRUST : COURT OF COMMON PLEAS •• CUMBERLAND COUNTY Plaintiff • • VS. : No: 2014-00650 MICHAEL V. KITNER OR OCCUPANTS • • Defendants • • CERTIFICATE OF SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the praecipe to enter judgment in the above matter was made upon the following: Michael V. Kitner Occupants 1419 Pheasant Drive South 1419 Pheasant Drive South Carlisle,PA 17013 Carlisle, PA 17013 by regular first class mail, postage prepaid, deposited with the United States Postal Service on 3/11/2014. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTI' L, P.C. BY: _ Martha E. Von Rosenstiel, Esquire ' Heather Riloff, Esquire Attorneys for Plaintiff Dated: 3/11/2014 Aitti OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Michael V. Kitner or Occupants 1419 Pheasant Drive South Carlisle, PA 17013 LSF8 MASTER PARTICIPATION TRUST •• COURT OF COMMON PLEAS PLAINTIFF •• CUMBERLAND COUNTY VS. MICHAEL V. KITNER OR OCCUPANTS • DEFENDANT(S) •• NO: 2014-00650 • Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment for possession has been entered against you in the above proceeding as indicated below: Prothonotary Judgment by Default Money Judgment 4' Judgment in Replevin X Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number:610-328-2887. 33611CFJ-EM 33611 CPG-EM Praecipe for Writ of Possession (Pa.R.C.P. 3160-3165) COUNTY OF CUMBERLAND LSF8 MASTER PARTICIPATION TRUST COURT OF COMMON PLEAS DOCKET NO. 2014-00650 v. ATTORNEY I.D. #52634 MICHAEL V. KITNER OR OCCUPANTS T , r-,, TO THE PROTHONOTARY: cn Kindly issue Writ of Possession in the above Ejectment matter. , 1419 Pheasant Drive South Carlisle, PA 17013 MARTHA E. VON ROSENSTI L, P.C. BY: 4 !rtha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff 'Eepb. g GAF P4-1$. s'v A .1 1 63 ti t e cAt 6 3.2/7 as .s� a - 3o32GA lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LSF8 MASTER PARTICIPATION TRUST VS. No. 2014-650 Civil Term_ MICHAEL V. KITNER OR OCCUPANTS 1419 PHEASANT DRIVE SOUTH CARLISLE,PA 17013 Costs Attorney's $ 199.53 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)) LSF8 MASTER PARTICIPATION TRUST being: (Premises as follows): ***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. ./ vid D. Buell,Prothonotary, ommon Pleas Court of Cumberland County, PA Date 3/20/14 (Seal) 2 of 2 No 2014-650 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA LSF8 MASTER PARTICIPATION TRUST VS. MICHAEL V. KITNER Or Occupants WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 199.53 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: MARTHA E. VON ROSENSTIEL, ESQUIRE - ID# 52634 MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, SUITE SECANE, PA 19018 610-328-2887 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ---' ��ve _|'�/E]' Fc/�: THE - ° ..^ ''.ONDLW; NMR�A �� 3: �Q 28 '' " �� CUMBERLAND Ty LSF8 Master Participatio Trust vs. Michael Vance Kitner Case Number 2014-650 SHERIFF'S RETURN OF SERVICE 03/27%2014 07:43 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 27, 2014 at 1943 hours a true copy of the within wr of possession was attempted to be served upon the defendant, to wit: Michael Vance Kitner, of 1419 Pleasant Drive South, Carlisle, Cumberland County, Pennsylvania 17013. The property was found to be vacant. Therefore, the within Wr of Possession is being returned with no service as the defendant, Michael Vance Kitner was NOT FOUND. NOTE: Deputies spoke with a neighbor who advised that the defendant moved ou over a week ago. SHERIFF COST: $42.03 SO ANSWERS, March 28, 2014 RONNYR ANDERSON, SHERIFF (c) CounfySuito Sheriff, Teleosoft, inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson i' ' QCE Sheriff cn*m OF THE PROTHONOTARY Jody S Smith Chief Deputy 2004 APR 23 PM 2: 46 e�J�� Richard W Stewart CU T�� Solicitor w�CEwrneo^a�p ' COUNTY PENNSYLVANIA LSF8 Master Participatio Trust vs. Michael Vance Kitner Case Number 2014-650 SHERIFF'S RETURN OF SERVICE 03C27/2014 07:43 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 27, 2014 at 1943 hours a true copy of the within wr of possession was attempted to be served upon the defendant, to wit: Michael Vance Kitner, of 1419 Pleasant Drive South, Carlisle, Cumberland County, Pennsylvania 17013. The property was found to be vacant. Therefore, the within Wr of Possession is being returned with no service as the defendant, Michael Vance Kitner was NOT FOUND. NOTE: Deputies spoke with a neighbor who advised that the defendant moved out over a week ago. 04/23/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this wri of possession is returned STAYED, per request from plaintiff's attorney. Property is vacant. SHERIFF COST: $43.72 April 23, 2014 SO ANSWERS, RONNYR ANDERSON, SHERIFF 6 ^��«� 304/^�'�«�