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Home My WebLink About05-1345LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A Plaintiff Vs. RICKY L. SCOTT and TRACEY L SCOTT Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS CIVIL ACTION - LAW IN EJECTMENT 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. CO TO OR TRTF.PHnNF THF. nFF D CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 c 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 T ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVT BERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A Plaintiff VS. RICKY L. SCOTT and TRACEY L SCOTT Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - el, h?- l CIVIL ACTION - LAW IN EJECTMENT C O M P L A I N T 1. Plaintiff, Washington Mutual Bank, F.A., is a corporation with an office located at Post Office Box 1169, Milwaukee, Wisconsin 53201-1169. 2. Defendants, Ricky L. Scott and Tracey L. Scott, are adult individuals whose last known precise residence is 126 C Street, Carlisle, Pennsylvania 17013. 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 March 2, 2005, Defendants were the owners of certain real property known as 126 C Street, Carlisle, Pennsylvania 17013. 10 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriff's Sale held at the Cumberland County Court House on March 2, 2005, 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. 03-3620 at the suit of Washington Mutual Bank, F.A. vs. Ricky L. Scott and Tracey L. Scott. 6. The aforesaid property was purchased at sale by Washington Mutual Bank, F.A., 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. Defendants are presently in possession of the said premises, having come into said possession by virtue of their prior ownership. 9. Plaintiff's Abstract of Title is attached hereto as Exhibit B" WHEREFORE, Plaintiff demands judgment against Defendants 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: P. Haller, Esquire 719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: March 14, 2005 ALL that certain tract of land situate in the Borough of Carlisle, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point on the South side of "C' Street at corner of a sixteen foot alley; thence South along the East side of said alley, 69 feet to a point on lot formerly of William I. Spangler, thence along lot formerly of William I. Spangler, East 30 feet to a point; thence along other land now or formerly of William L Spangler, North 69 feet to a point on the South side of "C" Street; thence along the South side of 'C' Street, West 30 feet to a point and Place of BEGR*MiG. HAVING THEREON ERECTED A DWELLING KNOWN AS 126 C. STREET, CARLISLE, PENNSYLVANIA 17013 BEING THE SAME PREMISES WHICH Kendal R. Hockenberry and Deborah D. Hockenberry by deed dated 2/27/96 and recorded in Deed Book 135, Page 603, granted and conveyed unto Ricky L. Scott and Tracy L. Scott. 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 March 2, 2005. 2. Deed from Kendal R. Hockenberry and Deborah D. Hockenberry dated February 27, 1996 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 135, Page 603, to Ricky L. Scott and Tracy L. Scott. EXHIBIT "B" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. eon . Ha Dated: March 14, 2005 N? -44 1 c v ? Vl( _e r ' C R SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-01345 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINTON MUTUAL BANK FA VS SCOTT RICKY L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who duly sworn according to law, says, that he made a diligent se. inquiry for the within named DEFENDANT SCOTT RICKY L unable to locate Him in his bailiwick. He therefore returns COMPLAINT - EJECTMENT rig ch and was NOT FOUND , ?as to the within named DEFENDANT , SCOTT RICKY L 126 C STREET CARLISLE, PA 17013 Sheriff's Costs: Docketing Service 18. 3 00 .70 So answers - Not Found 5 .00 R. Thomas Kline Surcharge 10. 00 Sheriff of Cumberland County .00 36. 70 PURCELL KRUG HALLER 03/21/2005 Sworn and subscribed to efore me this day of M J Prothdnotar `I I SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-01345 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINTON MUTUAL BANK FA VS SCOTT RICKY L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT SCOTT TRACEY L unable to locate Her in his bailiwick COMPLAINT - EJECTMENT He therefore returns NOT FOUND , the within named DEFENDANT , SCOTT TRACEY L 1 CARLISLE, PA 17013 PROPERTY IS I Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers: R, Thomas Kline Sheriff of Cumberland County PURCELL KRUG HALLER 03/21/2005 Sworn and subscribed to before me this day of r( A. D. (l ro honotary- ing and was to LEON P. HALLER, ESQUIRE PURCELL,KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 05-1345 CIVIL TERM vs. CIVIL ACTION -LAW IN EJECTMENT RICKY L. SCOTT and TRACEY L. SCOTT Defendants PRAECIPE TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned action. By: & HALLER 17719 North front Street Harrisburg,?A 17102 Attorney I 915700 Attorney for Plaintiff Dated: May 2, 2005 ?> ?', c; _ _.? :?-+ _-.. -?, -i _ ?-. -T? ?..-J -' 1(1; Gi r`. --J SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-01345 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINTON MUTUAL BANK FA VS SCOTT RICKY L ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SCOTT RICKY L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT FOUND , as to the within named DEFENDANT SCOTT RICKY L 126 C STREET ISLE, PA 17013 CARLISLE IS VACANT. Sheriff's Costs: So answers ._,---' Docketing 18.00 Service 3.70/ Not Found 5.00 R. Thomas Kline( Surcharge 10.00 Sheriff of Cumberland County .00 36.70 PURCELL KRUG HALLER 05/09/2005 Sworn and subscribed to before me this day of A.D/.? Prbthonotary :-I,-ON P. HALLER, ESQUIRE 1,1RCELL, KRUG & HALLER i719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. RICKY L. SCOTT and TRACEY L. SCOTT Defendants NO. 05-1345 CIVIL TERM CIVIL ACTION - LAW IN EJECTMENT P R A E C I P E TO THE PROTHONOTARY: Kindly Settle and Discontinue the above matter of record. PURCELL, KRUG & HALLER By Leon P. Haller ID #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 !-ATE: September 23, 2008 ?,? . r+y :ohs :43