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Home My WebLink About14-0838 Supreme Cou'tof Pennsylvania Cour' ofiEd'inmon leas Fos- Prothonotary Use Only: Ci. ille ver�Sh et l^. X t r Docket No: c County I � � �J C►v -� The information collected on this fibrin is used solely for court adininistration purposes. This forth. 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 6__--" S 0 Complaint " Writ of Summons Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead P�ainh'fPs Name: n L � (� Lea efendan �' %j�ame: Ht ` 1 ' v4 T J U /1 l l l�J� Y 1 D ) V J Dollar Amount Requested: Owithin arbitration liniits I Are money damages requested? Yes __ No (check one) outside arbitration limits O N Is this a Class Action Suit? 0 Yes No Is this an MDJAppeal? El Yes 2-go A Name of Plaintiff/Appellant's Attorney: TyA y V I I C • b� V ) U ` , , F_ S "I. 0 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 0 Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection: Other 0 Board of Elections Nuisance 0 Dept. of Transportation Premises Liability 0 Statutory Appeal: Other S Product Liability (does not include E mass tort) � Employment Dispute: Slander/Libel/ Defamation Discrimination 0 C 0 Other: 0 Employment Dispute: Other Zoning Board � Other: , I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: � Ejectment Q Common Law /Statutory Arbitration B 0 Eminent Domain/Condemnation ❑Q Declaratory Judgment Ground Rent Mandamus 0 Landlord/Tenant Dispute ❑ Non- Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial Quo Warranto 0 Dental 0 Partition Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical �ther: 0 Other Professional: V Updated 1/1/2011 �u; f tIF P R07H£ IN' jjk ,( ZG14 FEB 12 PM Darrell C. Dethlefs, Esquire CUN3 1D #s 8 sos BERLAit C{J,'Y Dethlefs - Pykosh Law Group, LLC PENNSYLVANIA 2132 Market Street . Camp Hill, Pennsylvania 17011 Telephone — (717) 975 -9446 Fax — (717) 975 -2309 DDeth1efs@aol.com JAMES C. BITTLE and DARLENE A. IN THE COURT OF COMMON PLEAS BITTLE, CUMBERLAND COUNTY Plaintiffs, V. No. �— ✓ (// diG ROBERT D. HOLUM and HELGA HOLUM, Defendants CIVIL ACTION - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTAONOTARY: Please issue writ of summons in the above case. This case involves real property which is described as follows: 9 Rusty Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. Parcel No.: 38 -22- 0144 -063 A description of the property is attached hereto as Exhibit A . Writ of Summons shall be issued and forwarded to Sheriff. Respec submitted, Date: D Dethlefs, Esquire Dethlefs- Pykosh Law Group, LLC / Attorney Id. No.: 58805 /D3 • ?`s 2132 Market Street Camp Hill, PA 17011 C # I,SSO g (717) 975 -9446 Email: ddethlefs @aol.com ,p #3o /LS CERTIFICATE OF SERVICE I, Darrell C. Dethlefs, Esquire, hereby certify that on February 12, 2014, a true and correct copy of the Praecipe for Writ of Summons was forwarded to the Sheriff for Service on the below- listed owners: Robert D. Holum and Helga Holum 9 Rusty Drive Mechanicsburg, PA 17050 Darrell C. s, Esquire Dethlefs- Pykosh Law Group, LLC Attorney Id. No.: 58805 -� 2132 Market Street :z Camp Hill, PA 17011 (717) 975 -9446 7 Email: ddethlefs @aol.com a_ S° T Exhibit A ALL that:certain lot of ground with the improvements erected thereon situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Rusty Drive (50 feet wide) at the dividing line between Lots Nos. l0A and 9 as shown on the hereinafter mentioned Plan of Lots; thence along said dividing line between Lots Nos. 1 O and 9, South nine (09) degrees sixteen (16) minutes East, a distance of one hundred seventeen and sixty -eight one - hundredths (117.68) feet to a point at lands now or formerly of William H. Hollinger; thence along said latter lands, South eighty (80) degrees West, a distance of one hundred twenty -nine and forty-nine one- hundredths (129.49) feet to a point; thence North one (0 1) degree fifty -one (5 1) minutes West, a distance of one hundred seventy -seven and twenty -eight one - hundredths (177.28) feet to a point radius of fifty (50) feet, an arc distance of eighty -five and one (1) hundredths (85.01) feet to a point on the same; thence continuing along the Southern side of Rusty Drive, North eighty (80) degrees forty -fou'r (44) minutes East, a distance of fifty -seven and one (1) one - hundredths (57.01) feet to a point at the dividing line between Lots Nos. l0A and 9 as shown on said Plan of Lots, the point an d place of BEGINNING. ,n I i K 7 l� t 4 Z 3. 1 i f. r l f f Darrell C. Dethlefs, Esquire ID # 58805 Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone — (717) 975 -9446 Fax — (717) 975 -2309 DDethlefs@aol.com JAMES C. BITTLE and DARLENE A. IN THE COURT OF COMMON PLEAS BITTLE, CUMBERLAND COUNTY Plaintiffs, V . (I No.. ROBERT D. HOLUM and HELGA HOLUM, Defendants CIVIL ACTION - LAW WRIT OF SUMMONS TO: Robert D' Holum and Helga Holum 9 Rusty Drive Mechanicsburg, PA 17050 You are hereby notified that James C. Bittle and Darlene A. Bittle have commenced an action against you. Date: Prothonotary 3' t Deputy ,4 i4 P Darrell C. Dethlefs, Esquire ID # 58805 Dethlefs - Pykosh Law Group, LLC 201 FEB 12 PM 2132 Market Street Camp Hill, Pennsylvania 17011 CUMBERLAND cG Utq! - Telephone — (717) 975 -9446 PENNS YLVA NI Fax — (717) 975 -2309 DDethlefs@aol.com JAMES C. BITTLE and DARLENE A. IN THE COURT OF COMMON PLEAS BITTLE, CUMBERLAND COUNTY Plaintiffs, V . i No.:/ e3e ROBERT D. HOLUM and HELGA HOLUM, J Defendair !s CIVIL ACTION - LAW PRAECIPE FOR LIS PENDENS TO: Cumberland County Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 NOTICE JS HEREBY GIVEN that an action has been instituted and is now pending in the Cumberland &unty Court of Common Pleas upon the complaint of James C. and Darlene A. Bittle, Plaintiffs against the above -named Defendants, Robert D. and Helga Holum. Kindly enter the above - captioned action as a Lis Pendens against the Defendants Robert D. and Helga Holum's real property which is described as follows: 9 Rusty Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. Parcel No.: 38 -22- 0144 -063 A description of the property is attached hereto as Exhibit A . r Any persons in any manner dealing with the above - described real estate subsequent to the filing of this action willtake subject to the rights of the Plaintiff as established in this action. f E .3ol Respect u y Submitted, E: Dated: f Z 4 Darr Dethlefs, Esquire Dethlefs- Pykosh Law Group, LLC Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975 -9446 Email: ddethlefs @aol.com 5; t ' 1 i' 1 CERTIFICATE OF SERVICE I, Darrell C. Dethlefs, Esquire, hereby certify that on February 12, 2014, a true and correct copy of the Praecipe for Lis Pendens was forwarded to the Sheriff for Service on the below- listed owners: Robert D. "Holum and Helga Holum 9 Rusty Drive Mechanicsburg, PA 17050 Y. Darrell C. Dethlefs, Esquire Dethlefs- Pykosh Law Group, LLC Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975 -9446 Email: ddethlefs @aol.com t; `e F Exhibit A ALL that certain lot of ground with the improvements erected thereon situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Rusty Drive (50 feet wide) at the dividing line between Lots Nos. I OA and 9 as shown on the hereinafter mentioned Plan of Lots; thence along said'dividing line between Lots Nos. IOA and 9, South nine (09) degrees sixteen (16) minutes East; a distance of one hundred seventeen and sixty -eight one - hundredths (117.68) feet to a point at lands now or formerly of William H. Hollinger; thence along said latter lands, South eighty (80) degrees West, a distance of one hundred twenty -nine and forty -nine one - hundredths (129.49) feet to a point; thence North one (0 1) degree fifty -one (5 1) minutes West, a distance of one hundred seventy -seven and twenty -eight one - hundredths (177.28) feet to a point radius of fifty (505 feet, an arc distance of eighty -five and one (1) hundredths (85.01) feet to a point on the samd thence continuing along the Southern side of Rusty Drive, North eighty (80) degrees forty -four (44) minutes East, a distance of fifty -seven and one (1) one - hundredths (57.01) feet to a point at the dividing line between Lots Nos. 1 O and 9 as shown on said Plan of Lots, the point anti place of BEGINNING. �i i r Darrell C.Dethlefs,Esquire ID#58805 2014 FEB 21 AM 9: 0 Dethlefs-Pykosh Law Group,LLC 2132 Market Street COUNT Camp Hill,Pennsylvania 17011 CUMBERLAND i Telephone—(717)975-9446 PENNSYLVANIA Fax—(717)975-2309 DDethlefs@aol.com JAMES C. BITTLE and DARLENE A. IN THE COURT OF COMMON PLEAS BITTLE, CUMBERLAND COUNTY Plaintiffs, v. . No.: 14-838 Civil Term ROBERT D. HOLUM and HELGA HOLUM, Defendants CIVIL ACTION - LAW PRAECIPE TO RELEASE LIS PENDENS TO THE PROTHONOTARY: Kindly release the above-captioned Lis Pendens against the Defendants Robert D. and Helga Holum's real property. Respectfully S : itted, Dated: a 6 I tl IL�� 0� - efs Darrell C. e Esquire q Dethlefs-Pykosh Law Group, LLC Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Email: ddethlefs @aol.com 1'w PROTHCIHO1.',., 2014 FEB 21 AM : 0 7 Darrell C. Dethlefs,Esquire iLa C ! , ID#58805 PENNSYLVANIA Dethlefs-Pykosh Law Group,LLC 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 DDethlefs(a aol.com JAMES C. BITTLE and DARLENE A. IN THE COURT OF COMMON PLEAS BITTLE, CUMBERLAND COUNTY Plaintiffs, v. . No.: 14-838 Civil Term ROBERT D. HOLUM and HELGA HOLUM, Defendants CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE WRIT OF SUMMONS i TO THE PROTHONOTARY: Please discontinue writ of summons in the above case. Respectful s bmitted, Date: ‘? )( 1 Darrell 1 ethlefs, Esquire Dethlefs-Pykosh Law Group, LLC Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Email: ddethlefs @aol.com Ronny R Anderson Sheriff JndyS Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE .-�0�H��0T�� ?0\� �8A 17 %�0: 00 -� CUMBERLAND [HUN-Y PENNSYLVANIA ' tit Ciiiigorly4 :4). Off cz'OF THE S'HERIFF James C Bittle (et at.) vs. Robert D Holum (et al.) Case Number 2014-838 SHERIFF'S RETURN OF SERVICE 02/18/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Helga Holum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons, Praecipe for Lis Pendens and Legal Description aa "Not Found" sd0 Rusty Drive, Silver Spring, Mechanicsburg, PA 17050 There was a "Sold" sign in the yard and to this date, March 12, 2014, the Mechanicsburg Postmaster has not been able to provide a forwarding address for the defendant. 03/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert D Holum, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons, Praecipe for Lis Pendens and Legal Description as "Not Found" at 9 Rusty Drive, Silver Spring, Mechanicsburg, PA 17050. There was a "Sold" sign in the yard and to this date, March 12, 2014, the Mechanicsburg Postmaster has not been abfe to provide a forwarding address for the defendant, SHERIFF COST: $65.79 SO ANSWERS, March 12, 2014 RDN R ANDERSON, SHERIFF (c) CourffySuite Sheriff, Teleosoff,