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HomeMy WebLinkAbout14-6223 1012312014 15:12 (FAX) P.0021002 Supreme Cq -''yE ennsylvania Colli �°C�E2I2Mo �leas For Prothonotary Use Only: 1 f . s n' s Docket No; S r. CU LNC} Y County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the cling and service of leadin s or other papers as re uired b law or rules ofcourt. Commencement of Action: Q Complaint I ' Writ of Summons Petition S �'"� Transfer from Another Jurisdiction [3 Declaration of Taking C Lead Plaintiff s Name. bead Defendant's Name- Church of God Noma Carolyn J. Myers T T Are mons damages requested? Yes © No Dollar Amount Requested: Mwithin arbitration limits y (check one) ©outside arbitration limits Q N { Is this a Class Action Suit? M Yes ® No Is this an MDT Appeal? 1 Yes M1 No A Name of Plaintiff/Appellant's Attorney: Brian K. Zellner, Esquire 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 PRf1KARY CASE. If you are snaking 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 Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution Debt Collection:Credit Card rl Board of Assessment Motor Vehicle © Debt Collection:Other ® Board of Elections Nuisance Q Dept.of Transportation Q Premises Liability 'L1 Statutory Appeal:Other Product Liability(does not include Employment Dispute: mass tort) Q Slander/Libel/Defamation Discrimination C [3 Other: Employment Dispute:Other © Zoning Board T Q Other: I f Other: .Q MASS TORT Q Asbestos N Q Tobacco E3 Toxic Tort-DES Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Ejectment © Other,: �E Q Common Law/Statutory Arbitration ® Eminent Domain/Condemnation )Declaratory Judgment n Ground Rent Mandamus ®Landlord/Tenant Dispute Non-Domestic Relations Q Mortgage Foreclosure:Residential Restraining aOrder__ PROFESSIONAL LIABLiTY ® Mortgage Foreclosure:Commercial Q 0 Dental Partition n Replevin 0 Legal Quiet Title ©Other: Q Medical Other: Other Professional: Updated 11112011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION Plaintiff(s)&Address(es) CHURCH OF GOD HOME 801 N. Hanover Street Carlisle, PA 17013 VS. Case No. Civil Term Defendant(s)&Address(es) Civil Action CAROLYN J. MYERS 801 N. Hanover Street Carlisle, PA 17013C_- 2-- f inC) `� �" OR WRIT OF SUMMONS ; �' - PRAECIPE F _ 4 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to Attorne Sh ri lease Circle choice Date : 1,0 2 L I ignature of Attorney Print Name: Brian K. Zellner, Esquire Address: 2608 N. 3rd Street Harrisburg, PA 17110 Telephone#:717-774-1357 Supreme Court ID Number: 59262 0000 • OL WRIT OF SUMMONS 119. 7S� 1 C�# Cv S3 ff Lf TO: Carolyn J. Myers eo-3101lo J YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S)HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk,Civil Division Date: byX12' � � Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHURCH OF GOD HOME, Plaintiff v. CAROLYN J. MYERS, Defendant „o w. 14a3 Gut CIVIL ACTION PRAECIPE FOR LIS PENDENS r- 0-1 TO THE PROTHONOTARY: Please issue a Lis Pendens against the real property owned by Carolyn J. Myers located at 5401 Laurie Lane, Enola PA 17025, Cumberland County, Pennsylvania, PIN 10-14-0842-071, Deed Book I, Volume 22, Page 354. A true and correct copy of the Deed is attached hereto as Exhibit "A". Date: if) Brian K. Zellner, Esquire Hynum Law, P.C. 2608 N. 3rd Street Harrisburg, PA 17110 717-774-1357 Attorney for Plaintiff alvA 6 Ili 50pci ati'1 COI gelss gtv t401-/ !1�.18.8.�. II. .SI IIti1Ii0t. HURL U 6"n nt o • fm ro lodl.,deel — Owv.i shut Poe, Herrn ILO. I-.. 101..4 P. e benat ' MADE THE ' " day of May our Lord one thousand nine hundred and sixty-seven (1967) in the year of BETWSE?V REGENT CONSTRUCTION COMPANY, a corporation organized and existing u der.the laws of the Commonwealth of Pennsylvania, with a place of business in the Township of Silver Spring, County of Cumberland and State of Pennsyl- vania, Grantor, • A N D HARRY N. MYERS and CAROLYN J.-MYERS, his wife, of the Township of Hampden, County, of Cumberland and State of Pennsylvania; Grantees, WITNESSETH, that the said . Regent Construction Company for and in consideration ofthe own' of Thirteen. -thousand Eight hundred and Fifty Dollars (t13,B,50.00) lawful money of the United States of America, unto it weit and truly paid by the said Harry N. Myers and Carolyn J. Myers, his wife, at and before the.sealing and delivery of these prescnt4,' the receipt whereof is hereby acknowledged, has granted, bargained, sold, aliened, • enfeoffed, released and confirmed; and by these presents does grant, bargain, sell, alien, enfeoff, release and confirm unto the said Harry N. Myers and Carolyn J. Myers, his wife, their and assigns, • ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern line of Laurie Lane, at the northeast corner of Lot No. 4, Block "E", as shown on the hereinafter mentioned Plan of Lots; thence ')y the southern line of Laurie Lane, North 85 degrees 24 minutes East, one hundred twenty-one and forty-two one -hundredths (121.42) feet to a point; thence by lands of Long, South.l9 degrees 31 minutes East, one hundred twenty-six and forty-three one -hundredths (126.43) feet to .a point; thence by lands of Stone, South 85 degrees 24 minute6 West, one hundred fifty-four and sixty-eight one -hundredths (154.68) feet to a point; thence by the dividing line between Lots Nos. 4 and 5, Block "E", North:4 degrees 36 minutes West, one hundred twenty-one and ninety-eight.one-hundredths (121.98) feet to a point on the southern line of Laurie Lane, the point- and place of BEGINNING. BEING Lot No. 5, Block,"E" in the Plan of Lots of Glenda Crest, which Plan is of record. in the Cumberland County Recorder's Office in Plan Book 11, at Page 9. ' SUBJ$CT the the set back line as shown on the said Plan and to the 5 foot utility easement along the east and south line of said lot. BEING a part of the same premises which Glenn Wert, et ux, by Deed dated August 8,,.1964, and recorded in the Cumberland County Recorder's •Office in Deed Book "H", Volume 21, at Page 74J,•gr2nted and conveyed unto Regent Construction Companyr:. the grantor herein. Q: n&kit � (�,Ne•C‘AILL1r School Dist. Cumb. Co.. Pau 1% Reel Filets bender Teo Data V141 • Comb. Co. oh,. Col. AO. Wa..7-2.2eAGf 354 t I TOGETHER with all and singular ways, waters, water -courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, title, in- terest, property, claim and demand whatsoever, of S. in law, equity, or otherwise howsoever, of, in and to the same and every part thereof, TO HAVE AND TO HOLD the said hereditaments and premises hereby granted or mentioned and intended so to be with the appurtenances, unto the said Harry N. Myers and Carolyn J. Myers; his wife, their heirs and assigns, to and for the only proper use and behoof of the said Harry N. Myers and Carolyn J. Myers, his wife, their heirs and assigns forever. AND the said grantor hereby covenant, and agree, that it will. warrant the property hereby conveyed. generally IN WITNESS WHEREOF, the said Regent Construction Company has caused this Indenture to be signed in its corporate name by its President, and has caused to be affixed hereunto the common and cor- porate seal of the said corporation, attested by its Secretary, the day and year first above written. REGENT CONSTUCTION COMPANY gy BOOKZ 22?AGE 355 111.11.111 . 111 ..111._.1.1. LIU.. 11111111.1 IL JIL.LU .1 1.11LIII.111 11.II II. I ILL111.11111.111. JEIII Lit .1 I .J11.1. L I 1J .1_ LILL. LLIL....111.111111111. .. I . :1 State of Pennsylvania County of Cumberland On this, the day of May , 19 67, before me, the undersigned officer, personally appeared Robert E. Goodling who aciawweldged himself to be the President of Regent Construction Company a corporation, and that he as such President , being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of the corporation by himself as President. In witneas whereof, I hereunto set my hand and offic 10.8ApaiNi, 110/ARY bly Commission Expire" July 21, Mitre Cif litatunoliston, Pa. Dauphin Coanty • • i;•.. . . ... • CERTIFICATE OF RESIDENCE do hereby certify that the precise residence and complete post office address of the within named grantee is State of County of .7),7 er/ a1 ) j9t/ aLl" Attorney for 3ns. RECORDED on this day of....W.42/71; A. D. 194Z, in the Recorder's office of said County, in Med Roeder" Vol. • , Page —S. 474 Given under nip hand and the sjdf the said ogee, t date above written. 100i1 -22r€ 356 • •, ..•, -• ..... • • 1...1.,.tono.....Recorder„ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i'LE -OFFi r.. THE ?ROI HOHU A 2014 NOV"3 PM 3: 56 CUMERLAND COUNTY PENNSYLVANIA A OP- :Ca OF THE sHERIFF Church of God Home, Inc. vs. Carolyn J Myers Case Number 2014-6223 SHERIFF'S RETURN OF SERVICE 10/24/2014 Deputy Shawn Gutshall, being duly sworn according to law, served the requested Writ of Summons & Lis Pendens by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Carolyn J Myers at 801 N. Hanover Street, North Middleton, Carlisle, PA 17013. ••16.1W GUTSHALL, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, October 27, 2014 RONK R ANDERSON, SHERIFF (c) CountySU,� O Sheriff, Teleosor, Inc.