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For Prothonotary Use Only:
Petition
Declaration of Taking
1' �/:
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Docket No: n
114, 5
3
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 papers as required by law or rules of court.
Commencement of Action:
Petition
Declaration of Taking
❑ Complaint 1_Xi Writ of Summons X
X Transfer from Another Jurisdiction •
Lead Plaintiff's Name:
Deutsche Bank Trust Company Americas, as Trustee
Lead Defendant's Name:
Gregory S. Foulds and Pamela K. Foulds
Dollar Amount Requested: X within arbitration limits
Are money damages requested? ❑ Yes i i No
(check one) ® outside arbitration limits
Is this a Class Action Suit? ® Yes ® No
Is this an MDJAppeal? L I Yes ® No
Name of Plaintiff/Appellant's Attorney: Ryan P. Siney, Esquire / Tucker Arensberg, P.C.
(are a Self -Represented [Pro Se] Litigant)
Check here if you have no attorney
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)
Intentional
ID Malicious Prosecution
Motor Vehicle
El Nuisance
• Premises Liability
• Product Liability (does not include
mass tort)
0 Slander/Libel/ Defamation
0 Other:
MASS TORT
0 Asbestos
Tobacco
Toxic Tort - DES
EI Toxic Tort - Implant
D Toxic Waste
U Other:
PROFESSIONAL LIABLITY
Dental
Legal
Medical
El Other Professional:
CONTRACT (do not include Judgments)
0 Buyer Plaintiff
Debt Collection: Credit Card
Debt Collection: Other
X
0
ff Employment Dispute:
Discrimination
El Employment Dispute: Other
[J Other:
REAL PROPERTY
O Ejectment
O Eminent Domain/Condemnation
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0 Mortgage Foreclosure: Residential
O Mortgage Foreclosure: Commercial
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0 Other:
MISCELLANEOUS
El Common Law/Statutory Arbitration
fJ Declaratory Judgment
0 Mandamus
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Restraining Order
El Quo Warranto
0 Replevin
Other:
Updated 1/1/2011
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY :
AMERICAS, AS TRUSTEE
3 Park Plaza, 16th Floor
Irvine, CA 92814
Plaintiff Docket No.
v.
GREGORY S. FOULDS and
PAMELA K. FOULDS
212 West Allen Street
Mechanicsburg, PA 17055
Defendants
i1ONlj1r`j.I"i
2014 JUN --4 PH 1:27
CUMBERLAND COUNTY
PENNSYLVANIA
Civil Action - Law and Equity
PRAECIPE TO ISSUE WRIT OF SUMMONS
To the Prothonotary:
Please issue a Writ of Summons against the above-named Defendants.
Respectfully submitted,
Dated: June 3, 2014 TUCKER ARENSBERG, P.C.
By
HBGDB:144202-1 026590-165000
Ant ony J. Foschi, ID #55
Ryan P. Siney, ID #209190
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Telephone: 717-234-4121
Facsimile: 717-232-6802
Attorneys for Plaintiff
am:\
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY :
AMERICAS, AS TRUSTEE
Plaintiff
v.
Docket No. ) idt 337 3 (/)-/-/
GREGORY S. FOULDS and Civil Action - Law and Equity
PAMELA K. FOULDS
Defendants
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT:
YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS
COMMENCED AN ACTION AGAINST YOU.
oate
Prothonotary
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK TRUST COMPANY :
AMERICAS, AS TRUSTEE
Plaintiff
v.
GREGORY S. FOULDS and Civil Action - Law and Equity
PAMELA K. FOULDS
Defendants
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT:
YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS
COMMENCED AN ACTION AGAINST YOU.
Date:
Lo ight-t
IN THE COURT OF COMMON PLEAS
ijf\
-, C
... THONG {fVk
OF CUMBERLAND COUNTY, PENNSYLVANIA] JUN -t3 pu 1: 27
DEUTSCHE BANK TRUST COMPANY :
AMERICAS, AS TRUSTEE
Plaintiff
v.
CUMBERLAND COUNTY
PENNSYLVANIA
Docket No. 1 1' J J/ Ivy v
GREGORY S. FOULDS and Civil Action - Law and Equity
PAMELA K. FOULDS
Defendants
PRAECIPE FOR LIS PENDENS
To the Prothonotary:
Please index the above -captioned action as a lis pendens against the real property known
as and located at 212 West Allen Street, Mechanicsburg, Cumberland County, Pennsylvania
17055, identified as parcel identification number 19-23-0567-128 and more fully described in the
Deed recorded by the Cumberland County Recorder of Deeds on July 3, 2002 at Book 252, Page
2663.
I hereby certify that this action affects title to or other interest in the above-described real
property.
Respectfully submitted,
Dated: June 3, 2014 TUCKER ARENSBERG, P.C.
By:
HB GDB:144209-1 026590-165000
An . +ny J. Foschi, ID #55 95
Ryan P. Siney, ID #2091 0
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Telephone: 717-234-4121
Facsimile: 717-232-6802
Attorneys for Plaintiff
00,4 6/1.0.66/4167
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a&k6
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
THE
PROWO�i�� li,F•
MUM 1 l Pt4 : 05
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FRL �ND COUN'
OFC cFiH K RfFF u PE
PENNSYLVANIA
Deutsche Bank National Trust Company
vs.
Gregory S Foulds (et al.)
Case Number
2014-3373
SHERIFF'S RETURN OF SERVICE
06/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Pamela Kay Foulds, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Writ of Summons and Lis Pendens as "Not
Found" at 212 West Allen Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is
vacant.
06/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Gregory S Foulds, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Writ of Summons and Lis Pendens as "Not
Found" at 212 West Allen Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is
vacant per neighbor.
06/12/2014 10:40 AM - Sergeant Jason Vioral, served the requested Writ of Summons and Lis Pendens by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Gregory S Foulds at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA
17013.
06/13/2014 11:00 AM - Sergeant Jason Vioral served the requested Writ of Sum ons a - is Pendens by
"personally" handing a true copy to a person representing themselv-s t• •e the Defendant, to wit:
Pamela Kay Foulds at the Cumberland County Sheriffs Office, One ourthouse Square, Carlisle, PA
17013.
SHERIFF COST: $62.08
June 13, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teieosoft, oc