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HomeMy WebLinkAbout14-2613 Supreme Court df Pennsylvania Court of•Cdnimo� Pleas For Prothonotary Use Only: CivilCover t Docket No: Shee ,/ �r t CUMBERLAND County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papel:s as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons El Petition E Transfer from Another Jurisdiction E] Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Susquehanna Bank Heather Levesque Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? Q Yes No O (check one) noutside arbitration limits N Is this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? [3 Yes 0 No A Name of Plaintiff /Appel]ant's Attorney: Kimberly M. Colonna 0 Check here if you have no attorney (are a Self - Represented IPro 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 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution Q Debt Collection: Credit Card 0 Board of Assessment Q Motor Vehicle E] Debt Collection: Other 0 Board of Elections Q Nuisance 0 Dept. of Transportation Premises Liability 0 Statutory Appeal: Other S E] Product Liability (does not include E mass tort) 0 Employment Dispute: Q Slander/Libel/ Defamation Discrimination C 0 Other: Employment Dispute: Other Q Zoning Board T ❑ Other: I E] Other: O MASS TORT Asbestos N Tobacco Toxic Tort - DES Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste Other: 0 Ejectment Q Common Law /Statutory Arbitration B El Eminent Domain /Condemnation Declaratory Judgment R Ground Rent E] Mandamus 0 Landlord/Tenant Dispute 0 Non- Domestic Relations LJ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial El Quo Warranto El Dental 0 Partition El Replevin Fil Legal 0 Quiet Title Other: Medical E, Other: Other Professional: Updated 1/1/2011 201 29 t r'L V f 11 � `r `'` Kimberly M. Colonna PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108 -1166 (717) 232 -8000 Attorneys for Plaintiff, Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V . HEATHER LEVESQUE, CHRISTINE LEVESQUE, and JOHN OR JANE DOES, : NO. Defendants NOTICE 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, 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. (Asp CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 232 -7536 2 SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V . HEATHER LEVESQUE, CHRISTINE LEVESQUE, and JOHN OR JANE DOES, : NO. Defendants COMPLAINT IN EJECTMENT Susquehanna Bank, a Pennsylvania banking institution, by its attorneys, McNees Wallace & Nurick LLC, hereby files this Complaint against Defendants Heather Levesque, Christine Levesque, and John or Jane Does and avers the following: The Parties 1. Plaintiff, Susquehanna Bank ( "Susquehanna "), is a Pennsylvania banking institution with its principal place of business at 9 East Main Street, Lititz, PA 17543. 2. Defendant Heather Levesque is an adult individual currently residing at 619 Hummel Avenue, Lemoyne, PA 17043. 3. Defendant Christine Levesque is an adult individual currently residing at 619 Hummel Avenue, Lemoyne, PA 17043. 4. Defendants John or Jane Does ( "Does ") are one or more adult individuals currently residing at 619 Hummel Avenue, Lemoyne, PA 17043. Venue 3. Pursuant to Pa. R. Civ. P. 1052, venue for this ejectment action is proper only in Dauphin County because the real property which is the subject matter of the action is located in Dauphin County. Relevant Chain of Title 4. Pursuant to a Deed In Lieu of Foreclosure (the "Deed ") recorded with the Cumberland County Recorder of Deeds on January 15, 2014, at Instrument No. 2014 - 01150, Susquehanna is the fee simple owner of real property located at 619 Hummel Avenue, Lemoyne, PA 17043, Tax Parcel No. 12 -22- 0824 -145 (the "Real Property "). A true and correct copy of the deed is attached hereto as Exhibit A and incorporated herein by reference. 5. Susquehanna acquired the Real Property at a Sheriff's sale. See, Ex.A. COUNT I: EJECTMENT 6. Paragraphs one (1) through five (5) above are incorporated herein by reference. 7. Susquehanna has legal title to the Real Property and therefore, the sole right to possess the Real Property. 8. Heather Levesque and Christine Levesque (the "Levesques ") and /or Does have possession of the Real Property. 9. Susquehanna is presently out of possession of the Real Property. 10. Susquehanna has a present right to immediate possession, and a concomitant right to demand that the Levesques and Does be ejected from the Real Property. 2 WHEREFORE, Plaintiff Susquehanna Bank requests that this Honorable Court eject the Levesques and Does from the Real Property, award possession of the Real Property to Susquehanna Bank, and award Susquehanna Bank its costs of suit. McNEES WALLACE & NURICK LLC By Kim rl . Colonna PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108 -1166 (717) 232 -8000 Attorneys for Plaintiff Susquehanna Bank Date: 3 VERIFICATION k 2 CCa !7. /5 r C e , verify that I am authorized to execute this verification on behalf of Susquehanna Bank and the facts contained in the foregoing document are true and correct to the best of my knowledge or information and belief, and that the same are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: �1 %2S - y EXHIBIT A 0034K3 Tax Parcel No 12 -22- 0824 -145 Know all Men by these Presents That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to Susquehanna Bank 2013 -2723 Civil Term Susquehanna Bank Formerly Susquehanna Bank PA Vs Harold F. Dumais ALL THAT CERTAIN tract of land located in the Borough of Lemoyne, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point on the Northern line of Hummel Avenue, on the dividing line between Lots No. 81 and 82, Section "D" on the plan of lots hereinafter mentioned; thence, in a Westerly direction along the northern line of Hummel Avenue seventeen and one -half (17 -1/2) feet to a point on the line running through the center of the partition wall of the double two and one -half story dwelling house erected in the lot hereby conveyed and on the lot adjoining on the West; thence, in a Northerly direction along said line through the center of said partition wall and beyond one hundred fifty (150) feet, more or less, to Apple Alley; thence, in an Easterly direction along the Southern line of Apple Alley seventeen and one -half (17 -1/2) feet more or less, to Lot No. 81, Section "D: one hundred fifty (150) feet to Hummel Avenue at the point and lace of BEGINNING. BEING the Eastern portion of Lot No. 82, Section "D" on Plan of Lots known as Plan No. 1, Riverton, PA, said plan being recorded in the Cumberland County Recorder of Deeds Office in Decd Book ".1 ", Volume 4, Page 40. HAVING THEREON ERECTED the Eastern one -half of a two and one -half (2 -1/2) story swelling house being known as No. 619 Hummel Avenue, Lemoyne, Pennsylvania. BEING KNOWN as Tax Parcel #12 -22 -0824 -145. SEIZED IN EXECUTION AS THE PROPERTY OF HAROLD F. DUMAIS The same having been sold by me to the said grantee on the 4th day of December Anno Domini Two Thousand and Thirteen (2013) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 2nd of August Anno Domini 2013 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Tenn, Two Thousand and Thirteen (2013) Number 2723 at the suit of Susquehanna Bank Formerly Susquehanna Bank PA —vs- Harold F. Dumais In Witness Whereof, I have hereunto affixed my signature this 16th day of D elember Anno Domini Two Thousand and Thirteen (2013) ` /RoR. Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 16"' day of December Anno Domini Two Thousand and Thirteen {2013} ) 1 — - ProTtEUhary Prurhonotary, Cumberland County Cerllste, PA My Commission Expires the First Monday of ,Ian. 2014 I f r i r I hereby certify that the residence And Post Office address of the Within Grantee is 13511 Label Lane Hagerstown, MD 21740 Richard W. Stewart Solicitor REV-183 EX (o4 -10) RECORDER'S USE ONLY _ REALTY TRANSFER TAX State Tax Paid -- r pennsylvanE STATEMENT OF VALUE DEPARTMENT OF REVENUE Book Number Bureau of Individual. Taxes Page Number PO BOX 280603 Harrisburg, PA 1712M603 See reverse for instructions. Date Recorded Complete each section and file in duplicate with Recorder of Deeds when (1) the full value /consideration is not set forth in the deed, (2) the deed is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt fr tax based on fam relationship or public utility easement. If more space is needed, attach additional sheets. A CORRESPONDENT — All inquiries may be directed to the foltowing person: Name Telephone Number: Willia F. Colby Jr., Esquire/ Keith Moo ney, Esquire - Barley Sn yder (610) 376 -6651 - -..-- Mailing Addres. s City State ZIP Code 50 N. Fifth Street P.O. Box 942 1 Reading PA 119603 B. TRANSFER DATA C. Date of Acceptance of Document Grantors) /Lessor(s) Grantees) /Lessee(s) Cumberland C ounty Sheriff Susquehanna Bank Mailing Address Mailing Address 103 Sou Se cond Street 13511 Label La ne City State ZIP Code City State ZIP Code Carlisle PA 17837 Hagerstown MD 21740 D. REAL ESTATE LOCATION Street Address City, Township, Borough 619 Hu mmel Avenue _ Borough of Lemoyne -- County School District Tax Parcel Number Cumberland West Shore School District 12 -22- 0824 -145 E. VALUATION DATA - WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? ❑ Y ® N 1. Actual Cash Consideration 2. Other Consideration 3. Total Consideration $ 1,284,11 -} = $1, -11 4. County Assessed Value 5. Common Level Ratio Factor 6. Fair Market Value 96,000.00 X .97 = 93,120.00 F. EXEMPTION DATA la. Amount of Exemption Claimed Ib. Percentage of Grantor's Interest in Real Estate 1c, Percentage of Grantor's Interest Conveyed 100% 100% 100% Check Appropriate Box Below for Exemption Claimed. ❑ Will or intestate succession. (Name of Decedent) (Estate Frle Number) ❑ Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ❑ Transfer from a trust. Date of transfer into the trust If trust was amended attach a copy of original and amended trust. ❑ Transfer between principal and agent /straw party. (Attach complete copy of agency /straw party agreement.) ❑ Transfers to the commonwealth, the U.S. and instrumentalities by gift, dedication, condemnation or in lieu of con- demnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of mortgage and note /assignment.) ❑ Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ❑ Statutory corporate consolidation, merger or division. (Attach copy of articles.) ❑ Other (Please explain exemption claimed.) Under penalties of law, I declare that I have examined this statement, including accompanying information, and to the best of my knowledge and belief, it is true, correct and complete. Signature of Correspo ent or Responsible Pa y Date Keith Mooney, Esquire ` FAILURE 70 COMPLETE THIS FORM Pp6PERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECD D THE DEED. TAMMY SHEARER RECORDER OF DEEDS +, CUMBERLAND COUNTY 1 COURTHOUSE SQUARE i CARLISLE, PA 17013 - 717 -240 -6370 = . ter..... , . Instrument Number - 201401150 Recorded On 1/15/2014 At 10:57:55 AM * Total Pages - 5 • Instrument Type - DEED - SHERIFF'S Invoice Number - 154799 User ID - KW • Grantor - DUMAIS, HAROLD F • Grantee - SUSQUEHANNA BANK • Customer - SHERIFF * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT LEMOYNE BOROUGH $0.00 TOTAL PAID $69.00 I Certify this to be recorded in Cumberland County PA o� CIS O G o RECORDER OF DEEDS 1750 * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0034K3 1111111111111 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S ���"~�"^"" " �� ��" " "���� OF CUMBERLAND COUNTY TH�P�0 T1- i0��T��� 7«6MnY 28 PM 2, 54 CUMBERLAND Ty PENNSYLVANIA Susquehanna Bank vs. Heather M Levesque (et aL) Case Number 2014-2613 SHERIFF'S RETURN OF SERVICE 05/15/2014 Sheriff Ronny R Anderson, being duly sworn according to iaw, states he made diligent search and inquiry for the within named Defendant to wit: Jane Doe, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Served" at 619 Hummet Avenue, Lemoyne Borough, Lemoyne, PA 17043. 05/15/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent oeorohond<nquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Served" at 619 Hummel Avenue, Lemoyne Borough, Lemoyne, PA 17043. 05/15/2014 04:50 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint in Ejectment by'poroonaUy''handing a true copy to a person representing themse)ves to be the Defendant, to wit: Christine Levesque at 619 Hummel Avenue, Lemoyne Borough, Lemoyne, PA 17043. RONALD HOOVER, OEPDTY 05/15/2014 04:50 PM - Deputy Ronald Hoover, being duly sworn according to Iaw, served the requested Comp?aint in Ejectment by handing a true copy to a person representing themselves to be Christine Levesque, who accepted as "Adult Person in Charge" for Heather M Levesque at 619 Hummel Ave, Lemoyne Borough, Lemoyne, PA 17043. SHERIFF COST: $94.57 May 16, 2014 RONALD HOOVER, DEPUTY SO ANSWERS, RONNYR ANDERSON, SHERIFF OF 7-,L;(LirLFRD0-79g1I'S4 2014 JUL rUQ ' Ppb 1' 3 i PE N NS}YERL C Y NIA COUNTY A ry�A McNEES WALLACE & NURICK LLC Kimberly M. Colonna (PA 80362) 100 Pine Street, P. O. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. HEATHER LEVESQUE, CHRISTINE : LEVESQUE, and JOHN OR JANE . DOES, : NO. 2014-2613 Defendants PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT FOR POSSESSION OF REAL PROPERTY TO THE PROTHONOTARY: Please enter default judgment in the captioned action in favor of Plaintiff, Susquehanna Bank, and against Defendants, Heather Levesque and Christine Levesque, for possession of the property known as 619 Hummel Avenue, Lemoyne, PA 17043, Tax Parcel No. 12-22-0824-145. Judgment is entered pursuant to Pa.R.C.P. No. 1037(b) for failure to file a pleading to Plaintiffs Complaint which contained a notice to defend within twenty (20) days of service thereof, and after 10 -day Notices of intention to file this Praecipe were sent. Pursuant to Pa.R.C.P. No. 237.1, I hereby certify that Notices of intent to take a default judgment were forwarded to Heather Levesque and Christine Levesque, by United States Mail, a 33 iv c � 3G�gll 10°'().c° 1 first class, postage prepaid, on June 10, 2014. The aforesaid Notices were contained within an envelope bearing the return address of the undersigned. Neither of the Notices has been returned to the undersigned as undeliverable or otherwise. Copies of the Notices and Postal Forms 3817 are attached hereto and marked Exhibit "A". Date: June 30 , 2014 McNEES WALLACE & NURICK LLC By Elifrftv-1---- i .er y M. Colonna PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Susquehanna Bank 2 SUSQUEHANNA BANK Plaintiff v. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA HEATHER LEVESQUE, CHRISTINE LEVESQUE, and JOHN OR JANE DOES, : NO. 2014-2613 Defendants TO Heather Levesque 619 Hummel Avenue Lemoyne, PA 17043 IMPORTANT NOTICE Christine Levesque 619 Hummel Avenue Lemoyne, PA 17043 Date of Notice: June 10, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 PAPER TO YOUR 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 32 S. Bedford St. Carlisle, PA 17013 (717) 232-7536 McNEES WALLACE & NURICK LLC By PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Susquehanna Bank UNITED STATES v� IMO POSTAL SERVICE o Certificate Of Mailing ac) This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailing. domestic�Co re) N This form maybe used for end intemational mail 03 r e ) From: Z New, `- es Wallace & Nurick LLC - 100 Pine Street �3R.G p� A McNe _P.O.Box 1166 Ca 7Q o0 66 PA 17108-11�" \ : a Harrisburg, To: 0 _N0 NOO (Q0 • AvMYI-. ' i ( iono pe, P A t i 43 PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED y� POSTALSERVICE ® a PI Certificate Of Mailing This Certificate of Mailing provides evidence that.mail.has been presented to USPS® for mailing. y�,� III :(s This tor, ma""-cr.",...,,.M.,,,. .^.4 l.---.^—. m,.. I. From_ McNees Wallace & Nurick LLC _, z. 100 Pine Street `�v _ ...� 0 P.O. Box 1166 -IOC 116 ill 0-, Harrisburg, PA 17108at, To: �t 1 e-0 CO QOV` t \ek - Ve&c° v e U sem,- / CO. j N O O (g -[q i \IPAnW Irvtn\A' LA7mo j V \ --Q , ) A 11 ak-3 PS Form 3817, April 2007 PSN 7530-02-000-9065 t- FICL C, THE Pi O • HOti O TA 2014 JUL - 1 PM 1:3 PENNSYLVANIA McNEES WALLACE & NURICK LLC Kimberly M. Colonna (PA 80362) 100 Pine Street, P. O. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. HEATHER LEVESQUE, CHRISTINE : LEVESQUE, and JOHN OR JANE . DOES, : NO. 2014-2613 Defendants AFFIDAVIT OF NON-MILITARY SERVICE HEATHER LEVESQUE AND CHRISTINE LEVESQUE TO THE PROTHONOTARY: The undersigned, being duly sworn according to law, deposes and says that to the best of my information and belief that Defendants, Heather Levesque and Christine Levesque, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Service Members Civil Relief Act, f/k/a the Soldier's and Sailor's Civil Relief Act of 1940, 50 U.S.C. App. 501, et seq. McNEES WALLACE & NURICK LLC By Kimberly MT'Colonna 1 PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Susquehanna Bank Date: June 27th 2014 SWJRN and subscribed to before me this 7 —day of June, 2014. Not y Public ` I d My Commission Expires (SEAL) COMMONWEALTH OF PENNSYLVANIA N;,tarial Seal Josepnir'e M. Erinley, Notary Public City of Harrisburg, Dauphin County My Commission Expires Dec. 11, 2017 McNEES WALLACE & NURICK LLC Kimberly M. Colonna (PA 80362) 100 Pine Street, P. O. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. HEATHER LEVESQUE, CHRISTINE : LEVESQUE, and JOHN OR JANE . DOES, : NO. 2014-2613 Defendants NOTICE OF JUDGMENT TO: Heather Levesque 619 Hummel Avenue Lemoyne, PA 17043 You are hereby notified that on Christine Levesque 619 Hummel Avenue Lemoyne, PA 17043 t-3 , , 2014, the following judgment has been entered against you in the captioned case: Judgment for the possession of the property known as 619 Hummel Avenue, Lemoyne, PA 17043, Tax Parcel No. 12-22-0824-145. Judgment is entered pursuant to Pa.R.C.P. No. 1037(b) for failure to file a pleading to Plaintiffs Complaint which contained a notice to defend within twenty (20) days of service thereof, and after 10 -day Notices of intention to file the ecipe for Default Judgment in this action were sent. Dated: 1 Ji V Prothonotary 1 I hereby certify that the proper persons to receive this notice under Pa.R.C.P. No. 236 are: Heather Levesque 619 Hummel Avenue Lemoyne, PA 17043 Christine Levesque 619 Hummel Avenue Lemoyne, PA 17043 McNEES WALLACE & NURICK LLC By Kimberly Colonna PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Susquehanna Bank 2 Z0/4ia rH©No TA F JULAU11 oUr�rBE PM 2: 15 PENNSYLVANIA ©COUNTY McNEES WALLACE & NURICK LLC Kimberly M. Colonna (PA 80362) 100 Pine Street, P. O. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. HEATHER LEVESQUE, CHRISTINE : LEVESQUE, and JOHN OR JANE . DOES, Defendants : NO. 2014-2613 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a writ of possession in the above matter for possession of the following described property: 619 Hummel Avenue, Lemoyne, PA 17043, Tax Parcel No. 12-22-0824-145. I o3.?S (tCLL er l' Date: July 10, 2014 McNEE,ALLACE & NURICK LLC By Kimberly M. Colonna PA 80362 McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Susquehanna Bank a. L'IA4.c`139 I l 3 of- TsSiecl lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK VS. No. 2014-2613 Civil Term_ HEATHER LEVESQUE, CHRISTINE LEVESQUE OR JOHN OR JANE DOES 619 HUMMEL AVENUE LEMOYNE, PA 17043 Costs Attorney's $ 243.32 Plaintiff's $ Prothonotary $ 2.25 DUE CO 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)) • SUSQUEHANNA BANK being: (Premises as follows): 619 HUMMEL AVENUE, LEMOYNE, PA 17043, TAX PARCEL NO. 12-22-0824-145 (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. Date 7/11/14 (Seal) - David D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA .C7poUetc 2 of 2 No 14-2613 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSQUEHANNA BANK VS. HEATHER LEVESQUE, CHRISTINE LEVESQUE OR JOHN OR JANE DOES WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 243.32 P1ff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Kimberly M. Colonna, Esq. McNees, Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108 (717) 232-8000 By virtue of this writ, on the Attorney for Plaintiff (s) Where papers may be served day of . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F.1 E t , Sheriff `" 0 '. 014w1j;, Jr- '.HE PROTHONOTtY,ti... �"�r,��� Jody S Smith Chief Deputy *, 1014 JUL 30 AM 3: 34 F. Richard w Stewart CUMBERLAND COUNTY Solicitor � � � P ��""` �� ` ;�- PENNSYLVANIA Susquehanna Bank Case Number vs. 2014-2613 Heather M Levesque(et al.) SHERIFF'S RETURN OF SERVICE 07/29/2014 07:05 PM- Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Christine Levesque at 619 Hummel Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. 07/29/2014 07:13 PM - Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2014 at 1905 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Heather M. Levesque, by making known unto Christine Levesque, adult in charge and sister of defendant, at 619 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $58.33 SO ANSWERS, July 30, 2014 RON �. R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of c0morrl,1_ i HE PRO I HON(.it:i.4:I OFF C=E OF -HE SRERJFF 20 14 AUG 20 PH 2: D I CUMBERLAND COUNTY Y PENNSYLVANIA Susquehanna Bank vs. Heather M Levesque (et al.) Case Number 2014-2613 SHERIFF'S RETURN OF SERVICE 07/29/2014 07:05 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Christine Levesque at 619 Hummel Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. 07/29/2014 07:13 PM - Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2014 at 1905 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Heather M. Levesque, by making known unto Christine Levesque, adult in charge and sister of defendant, at 619 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 08/20/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED at request of plaintiffs attorney. SHERIFF COST: $59.99 SO ANSWERS, August 20, 2014 (c) CauntySuite Sheriff, Te!eosoft, Inc. RONNY R ANDERSON, SHERIFF 3/o077 OF D;. f: -/c, • SEP 30 CU• r PerWIL A 7,0 c S},L1,41,0 McNEES WALLACE & NURICK LLC Kimberly M. Colonna (PA 80362) 100 Pine Street, P. 0. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Susquehanna Bank SUSQUEHANNA BANK : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. HEATHER LEVESQUE, CHRISTINE : LEVESQUE, and JOHN OR JANE : DOES, : NO. 2014-2613 Defendants • PRAECIPE TO DISCONTINUE AND MARK JUDGMENT SATISFIED Please mark the judgment entered in the above -referenced case as SATISFIED and discontinue the action WITHOUT prejudice. Dated: September oIl , 2014 McNEES WALLACE & NURICK LLC By Kimb M. Colonna (PA 80362) 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 Ph. 717-237-5278 Fax. 717-260-1674 Attorneys for Plaintiff Susquehanna Bank CERTIFICATE OF SERVICE The undersigned certifies that, on this date, a true and correct copy of the foregoing document was served upon the following as indicated By first class mail addressed as follows: Heather Levesque Christine Levesque 619 Hummel Avenue Lemoyne, PA 17043 Katie Waters Dated: September 2 t 2014