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HomeMy WebLinkAbout14-1265IN RE: UPSET TAX SALE HELD SEPTEMBER 19, 2013 BY THE CUMBERLAND COUNTY TAX CLAIM BUREAU PROPERTY OF: MARIA TRAGOULIAS DAVID MCCARTNEY TAX PARCEL NO.: 21-06-0015-002 TR06106 125 Peach Lane- mobile home n.k.a 37 Peach Lane V.I.N. 11104974 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014 - 1 p PETITION FOR RULE FOR JUDICIAL SALE The Cumberland County Tax Claim Bureau, by its attorney, Keith 0. Brenneman, Cumberland County Assistant Solicitor, files this Petition for Rule for Judicial Sale, as follows: • Your Petitioner is the County of Cumberland through its Tax Claim Bureau, a Bureau created by the Real Estate Tax Sale Law. 72 P.S. §5860.101, et seq. 2. Pursuant to 72 P.S. §5860.610, your Petitioner respectfully represents as follows: a. Tax claim upon which the property was exposed for sale: 2011 and 2012 Cumberland County, Library and Middlesex Township real estate taxes and 2011-12 and 2012-13 School real estate taxes. Total amount of taxes, including penalty, interest, and cost as of date of tax sale: $247.01. b. Neither the owner, his, her, their, or its heirs, successors, assigns, or legal representatives, or any lien creditor, or his, her, their or its heirs, successors or legal representatives, or any other person interested, has caused discharge of tax claim or removal from tax sale. c. The property was exposed to public sale pursuant to 72 P.S. §5860.601 on: September 19, 2013. d. Before exposing the property to public sale the Bureau fixed the upset sale price, pursuant to 27 P.S. §5860.605, which upset price was $270.88. Petition for Judicial Sale (Parcel No. 21-06-0015-002 TR06106 Tragou ias ) Page 1 e. Your Petitioner, the Bureau, was unable to obtain a bid at the public sale sufficient to pay the said upset price. 3. Attached hereto, marked Exhibit "A," and incorporated herein by reference as if fully set forth herein, is a copy of a vehicle record abstract from the Pennsylvania Department of Transportation, Bureau of Motor Vehicles, referencing the mobile home by V.I.N. number 11104974 and owner as David A McCartney and Maria A Tragoulias. The tax parcel number of the property as recorded in the Cumberland County assessment office is 21-06-0015-002 TR06106 and owner as Maria Tragoulias and David McCartney. The property is situate in the Township of Middlesex, Cumberland County, currently known at 37 Peach Lane. 4. The names and addresses of known parties holding tax and municipal claims, liens, mortgages, ground rents, charges and estates against the property are as follows: a. Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, Pennsylvania 17013 Delinquent taxes as of February 1, 2014: $305.86 (Includes 2011, 2012 and 2013 county/municipal real estate taxes and 2011-12, 2012-13 and 2013-14School taxes). Said amounts will continue to accrue interest and costs. All delinquent claims must be satisfied to stay Judicial sale. b. Frank Roberto, Tax Collector 270 N Old Stonehouse Road Carlisle, PA 17015 2014 County and Municipal estimated real estate taxes at face in the amount of $7.06. c. Middlesex Township 350 N Middlesex Road, Ste 1 Carlisle PA 17013 Taxing authority of all delinquent municipal real estate taxes collected by the Tax Claim Bureau and current municipal taxes collected by Frank Roberto, Tax Collector. Petition for Judicial Sale (Parcel No. 21-06-0015-002 TR06106 Tragoulias) Page 2 d. Cumberland Valley School District 6746 Carlisle Pike Mechanicsburg PA 17055 Taxing authority of all delinquent school real estate taxes collected by the Tax Claim Bureau. e. Country Manor West Mobile Home Park 2 Apple Alley Carlisle PA 17013 Subject property is situate on rented lot no. 125 in Country Manor Mobile Home Park. 5. The last known address of the owner of the property as set forth in the assessment records of Cumberland County is: Maria Tragoulias and David McCartney, 125 Peach Lane, Carlisle PA 17015. Certified mail sent to Respondents has been received. WHEREFORE, Your Petitioner prays your Honorable Court to grant a rule upon all interested parties, including those listed at paragraphs four and five of the within z Petition, to show cause why a decree should not be made that the property be sold, freed and cleared of tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents, pursuant to Section 612 of the Real Estate Tax Sale Law. 72 P.S. §5860.612(a). Date: Respectfully submitted, Keith 0. Brenneman, Assistant Solicitor Cumberland County 44 West Main Street Mechanicsburg PA 17055 (717) 697-8528 Attorney I.D. # 47077 Petition for Judicial Sale (Parcel No. 21-06-0015-002 TR06106 Tragoulias) Page 3 VERIFICATION I, Melissa F. Mixell, Tax Claim Bureau Director, depose and say that the facts set forth in the foregoing Petition for Rule for Judicial Sale are true and correct based partly upon personal knowledge and the remainder upon information and belief; I understand that this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: i„ -quo Melissa . Mixell, Dire tor Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 (717) 240-6366 Petition for Judicial Sale (Parcel No. 21-06-0015-002 TR06106 Tragoulias) Page 4 PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT I0/21/13 09^20 PAGE 1 OWNER : DAVID A MCCARTNEY & MARIA A TRAGUULIAS 125 PEACH LN CARLISLE PA 17015 TITLE NUMBER : 253578I8 TAG NUMBER • VIN : 11104974 MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS REDMAN ' NO ` NO TITLE BRAND INFORMATION 132940753000012 008 LESSEE : NONE TITLE DATE : 02/27/74 REGISTRATION EXPIRY DATE: BODY TYPE : MH ' ODOMETER READING *EXEMPT BY FED LAW DUPLICATE TITLE COUNT : 0 VEHICLE YEAR : 1974 STOLEN DATE 111; NO TITLE BRANDS EXIST FOR THIS TITLE' LIEN INFORMATION . NO LIENS EXIST FOR THIS TITLE ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE IT (8:08 AM TO 5:00 PM) 1-800-932-4600 717-412-5308 1-800-228-8676 717-412-5380 WWW.DOT.STATE.PA.U5 IN RE: UPSET TAX SALE HELD IN THE COURT OF COMMON PLEAS SEPTEMBER 19, 2013 OF CUMBERLAND COUNTY, BY THE CUMBERLAND COUNTY PENNSYLVANIA TAX CLAIM BUREAU PROPERTY OF: MARIA TRAGOULIAS DAVID MCCARTNEY TAX PARCEL NO.: 21 -06- 0015 -002 TR06106 125 Peach Lane- mobile home n.k.a. 37 Peach Lane V.I.N. 11104974 NO. 2014 - ja('S' RULE TO SHOW CAUSE AND NOW, this j ' fay of ry , 2014 upon consideration of the within Petition, a Rule to Show Cause is issued upon all interested parties to appear and show cause why a decree should not be made that the property which is the subject of the within Petition be sold freed and cleared of all tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents. Service of this Rule shall be made to all parties listed at paragraphs four and five of the within Petition in the manner provided by Section 611 of the Real Estate Tax Sale Law 72 P.S. §5860.611. This is not a summons, you are not required to appear before the court, however you must appear if you desire to preserve your right to any interest or value in the real estate which is the subject of this proceeding. If you do not appear you may lose any ownership interest in the property or any right to any lien or other security interest in the property. Rule returnable 2014 at A. / -ire Courtroom Number Pennsylvania. , at Cumberland County Courthous- e • c - • • • e Square, Carlisle, T omas A. Placey j. Common Pleas Judge :r fiL 2C I R 13 PM 1: 37 CLIIBERLAND LOLINIV Keith 0. Brenneman, Esquire PE NN SYLVANIA 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorney ID #47077 Assistant Solicitor, Cumberland County IN RE: UPSET TAX SALE HELD SEPTEMBER 19, 2013 BY THE CUMBERLAND COUNTY TAX CLAIM : BUREAU PROPERTY OF: MARIA TRAGOULIAS DAVID MCCARTNEY TAX PARCEL NO.: 21-06-0015-002 TR06106 125 Peach Lane — mobile home n.k.a. 37 Peach Lane V.I.N. 11104974 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014 — 1265 CIVIL MOTION TO RESCHEDULE RULE RETURABLE DATE ON JUDICIAL SALE Cumberland County Tax Claim Bureau, by its attorney, Keith 0. Brenneman, Esquire, Cumberland County Assistant Solicitor, files this Motion and in support thereof states the following: 1. On or about March 7, 2014 Petitioner Cumberland County Tax Claim Bureau filed a Petition For Rule For Judicial Sale requesting this Court to grant a Rule on all interested parties to show cause why a decree should not be made that the property subject to the Petition should not be sold at a judicial sale. 2. This Court issued a Rule to Show Cause on March 7, 2014 with a Rule returnable March 26, 2014. 3. Petitioner neglected to advise the Court that due to various service requirements applicable to the Rule to be issued by the Court with respect to a judicial sale of property, that a Rule returnable date should be scheduled at least sixty days in the future. 4. Petitioner requests the Court to establish a date for the Rule returnable at least sixty days after the filing of this Motion. 5. This matter has been assigned to the Honorable Thomas A. Placey who issued the Rule to Show Cause dated March 7, 2014. WHEREFORE, Cumberland County Tax Claim Bureau requests this Court to reissue a Rule to Show Cause with respect to the proposed judicial sale of the subject property containing a Rule returnable date at least sixty days after the date of the filing of this Motion. Keith O. Brenneman, Esquire Snelbaker & Brenneman, P. C. 44 W. Main Street Mechanicsburg, PA 17055 (717) 697 -8528 Assistant Solicitor, Cumberland County Date: March 13, 2014 VERIFICATION I verify that the statements made in the foregoing Motion are true and correct. 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. Keith O. Brenneman Cumberland County Assistant Solicitor Date: March 13, 2014 IN RE: UPSET TAX SALE HELD : IN THE COURT OF COMMON PLEAS OF SEPTEMBER 19, 2013 BY THE : CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNTY TAX CLAIM : BUREAU : NO. 2014 —1265 CIVIL PROPERTY OF: MARIA TRAGOULIAS DAVID MCCARTNEY TAX PARCEL NO.: 21 -06- 0015 -002 TR06106 125 Peach Lane — mobile home n.k.a. 37 Peach Lane V.I.N. 11104974 RULE TO SHOW CAUSE co CD 7 w AND NOW, this l day of , 2014, upon consideration of the Petition For Rule For Judicial Sale and the Motion filed by Cumberland County Tax Claim Bureau requesting a change to the Rule returnable date, a Rule to Show Cause is issued upon all interested parties to appear and show cause why a decree should not be made that the property which is the subject of the within Petition be sold freed and cleared of all tax and municipal claims, liens, mortgages, charges and estates, except separately taxed ground rents. Service of this Rule shall be made to all parties listed at paragraphs four and five of the within Petition in the manner provided by Section 611 of the Real Estate Tax Sale Law 72 P.S. §5860.611. This is not a summons, you are not required to appear before the court; however, you must appear if you desire to preserve your right to any interest or value in the real estate which is the subject of this proceeding. If you do not appear you may lose any ownership interest in the property or any right to any lien or other security interest in the property. Rule returnable , 2014 at .M. in Courtroom No. 6, at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY J. Thomas A. Placey Common Pleas Judge • ����U��"�����U���^�����U�����U������������ ~°" "~~"�"" " ~� OFFICE "-.~~ ~=" CUMBERLAND COUNTY " RonnyRAnderson FiLEO-OFFICE ~�_ THE PROTHONOTARY Jody SSm�h Chief Deputy F�|chowdVVStevxort Solicitor ."��v�*6. *° r,� ' ~ 204 APR 24 FM 3! i'A CUMBERLAND COUNTY PENNSYLVANIA Cumberland Coun��m[]�mBu�au vs. Maria Tragoulias (et al.) Case Number 2014-1265 SHERIFF'S RETURN OF SERVICE 03/26/2014 08:35 AM - Deputy Tim Black being duly sworn according to law, served the requested Rule to Show Cause by handing a true copy to a person representing themselves to be Melissa Mixell, Director, who accepted as "Adult Person in Charge for Cumberland County Tax Claim Bureau at 1 Courthouse Square, Room 10G. Carlisle Borough, Carlisle, PA17013. TIM BLA K, DEPUTY 03%26/2014 10:10 AM - Deputy William Cline, being duly sworn according to law, served the requested Rule to Show Cause by hariding a true copy to a person representing themselves to be Scott Furman, Property Manager, who accepted as "Adult Person in Charge" for Country Manor West MHP at 2 Apple Alley, Middlesex Township, Cadio|e, PA 17015. AM CLINE, DEPUTY 03/26/ 2014 10:37 AM - Deputy William Cline, being duly sworn according to law, served the requested Rule to Show Cause by handing a true copy to a person representing themselves to be Ann Montomayro, Front Deak, who accepted as "Adult Person in Charge" for Cumberland Valley School District at 6746 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17055. 03/202014 09:10 AM - Deputy Jamie DiMartle, being duly sworn accor ing to law, served the requested Rule to Show Cause by handing a true copy to a person representing themselves to be Eileen Gault, Township yWanager.whoaccaptedos'Adu\tPwmoninCharge'forN1idd|eoexTownehipat35ONN1\dd\aoexRoad. Suite 1, Middlesex Township, Carlisle, PA 17013. 03/31/2014 02:40 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Rule to Show Cause by "personaily" handing a true copy to a person representing themselves to be the Defendant, to wit: Maria Tragoulias at 125 Peach Lane N/K/A 37 Peach Lane, Middlesex Township, Cudim|e, PA 17015. STEPHEN BENDER, DEPUTY 0.3,,!, 1,1,?Q14 02:40 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Rule to Show Cause by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: David McCartney at 125 Peach Lane N /K/A 37 Peach Lane, Middlesex Township, Carlisle, PA 17015. STEPHEN BENDER, DEPUTY 03/31/2014 03:15 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Rule to Show Cause by "personally" handing a true copy to a person representing themselves to be the lienholder, to wit: Middlesex Township Tax Collector Frank Roberto at 270 N Old Stone House Road, Middlesex Township, Carlisle, PA 17015. STEPHEN BENDER, DEPUTY SHERIFF COST: $162.42 SO ANSWERS, April 10, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. IN RE: UPSET SALE HELD September 19, 2013 by the Cumberland County Tax Claim Bureau PROPERTY OF: Maria Tragoulias David McCartney ED {=#E PROTHDN 7T1`:s;`x ?MR MAY 15 PH 2: 16 CUMBERLAND COUNTY IN THE COURT PENNO Lvr,Y lv1MN PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2014-1265 CIVIL Tax Parcel No. 21-06-0015-002 TR06106 125 Peach Lane — mobile home . : n.k.a 37 Peach Lane V.I.N. 11104974 PRAECIPE TO WITHDRAW PETITION FOR JUDICIAL SALE To the Prothonotary: Please withdraw the Petition For Rule For Judicial Sale with respect to the above matter and mark the same discontinued due to the respondents satisfying outstanding real estate tax amounts plus costs due on the subject property for the years 2011, 2012 and 2013. Date: May 15, 2014 Keith O. Brenneman, Esquire Attorney ID No. 47077 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Assistant Cumberland County Solicitor