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HomeMy WebLinkAbout05-3181 Douglas L. Cassel, Esquire Attorney LD. No. 92895 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 STEPHEN T. MCBRIDE, 717 Market Street Lemoyne, PA 17043 IN THE COURT OF COMMON PLEAS COUNTY, PENNSYLVANIA Plaintiff NO. {J~ - 3/ttl c;J vs. DOUGLAS T. MCBRIDE and REBECCA ANN MCBRIDE, Husband and Wife, 324 South Enola Drive Enola, P A 17025 CIVIL ACTION - LAW AND EQUITY Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Writ of Summons shall be issued and forwarded to ( Douglas L. Cassel. Esquire Attornev LD. No. 92895 3631 North Front Street Harrisburg, P A 1711 0 (717) 232-7661 Names/Address/Telephone No. G /d ( /0 )' I ' Date: WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. ~~ '~ prothonotarrq Date: ~ ,;ll. ~ by Deputy " '- ~ ~ ~ '^' '.J ~ '- ~ ~ ~ c::< f~.'''I :? ", r~? (.Xl o \t;) "" - STEPHEN T. MCBRIDE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. tJS-- ') / &' \ 2005- C".' I DOUGLAS T. MCBRIDE and, REBECCA ANN MCBRIDE, Husband and wife, Defendant : CIVIL ACTION - LAW AND EQUITY PRAECIPE FOR LIS PENDENS TO THE PROTHONOTARY: Please index the above-captioned action in law and in equity as a lis pendens against the following described property: ALL THAT CERTAIN lot or tract of land with the improvements thereon erected, being located in the Borough of Lemoyne, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point seventy-five (75) feet from the Southeast corner of Seventh Street (formerly Lome Street) and Hummel Avenue, and extending along the Southern line of Hummel Avenue in an Easterly direction thirty-five (35) feet to Lot No. 19 and extending back an even width on one hundred fifty (150) feet to Peach Alley. BEING known and numbered as 632 and 634 Hummel Avenue. BEING THE SAME PREMISES which was recorded on the 9th day of December 2004, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 266, Page 2913, granted and conveyed unto Rebecca Ann McBride, married person. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. PARCEL #12-22-0824-167 I hereby certify that this action affects title to or other interest in the above- described real property. Respectfully submitted, By: Dated: G/J rlu) . J es L. oldsm th, Esquire Attorne I.D. No. 27115 Douglas L. Cassel, Esquire Attorney LD. No. 92895 3631 North Front Street Harrisburg, P A 1711 0 (717) 232- 7661 05.429/89299 C) r--' c:.? C-, c:;) u' c... ~7i \~ ~ 1''' - ~ -0 .-'. ~ ! 't, 0) ~ 0 ""' ~ , (.,n ~ '..J ~ ~ o -,) .-\ ~;W; (:-?,(:) -;~.~; ~';S -1" :..:.:\ ::9: STEPHEN T. MCBRIDE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Or- ,)}fl ~ c.\/: I DOUGLAS T. MCBRIDE and, REBECCA ANN MCBRIDE, Husband and wife, Defendant : CIVIL ACTION - LA W AND EQUITY PRAECIPE FOR LIS PENDENS TO THE PROTHONOTARY: Please index the above-captioned action in law and in equity as a lis pendens against the following described property: ALL THAT CERTAIN tract or parcel ofland and premises, situate, lying and beging in the Township of East Pennsboro in the County of Cumberland Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pin, which iron pin is 100 feet east from the eastern line of South Enola Drive, at lands now or formerly of Merle Chronister; thence along said last mentioned lands and lands now or formerly of Jack Bloser, north 54 degrees 00 minutes east, 100 feet to a stake at lands now or formerly of the Grantors herein, being Lot No.3 on the hereinafter mentioned Plan of Lots; thence along the same, south 36 degrees 00 minutes east, 102 feet to a stake at lands now or formerly of Don Gamber; thence along said last mentioned lands, south 54 degrees 00 minutes west 70 feet to an iron pin at lands now or formerly of Nellie E. Villani; thence along said last mentioned lands north 36 degrees 00 minutes west, 27.50 feet to an iron pin; thence continuing along lands now or formerly of Nellie E. Villani, south 54 degrees 00 minutes west, 30 feet to an iron pin at lands now or formerly of Elmer Benner, being Lot No. I on the hereinafter mentioned Plan of Lots; thence along said last mentioned lands, north 36 degrees 00 minutes west, 74.50 feet to an iron pin, the point and Place of BEGINNING. BEING Lot No.2 on Plan of Marlin E. Watts et ux which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 23, Page 24. HAVING THEREON ERECTED a two-story frame dwelling house which has the address of 324 South Enola Drive (rear), Enola, Pennsylvania, together with a block garage. TOGETHER with a right-of-way eight feet in width, extending from land of the Grantors, which is contiguous and to the east of the premises herein conveyed, to South Enola Drive and extending along the southern line of the premises herein conveyed for the laying and maintaining of underground pipe lines for the transmission of water, sewage and gas from and to the aforesaid premises of the grantors herein, together with free ingress, egress and regress to and for the said Grantors, their heirs and assigns, and tenants or possessors of said premises, contiguous to the premises herein granted and conveyed, for the purpose of repairing, replacing or maintaining said pipe lines. I hereby certify that this action affects title to or other interest in the above- described real property. Respectfully submitted, By: Dated: O/dl!O) J . oIds ith, Esquire Attorney I.D. No. 27115 Douglas L. Cassel, Esquire Attorney I.D. No. 92895 3631 North Front Street Harrisburg, P A I7l! 0 (717) 232-7661 05-429/89304 , ~ ~ C) "'-" c.:::> 0 C C:::;;) ."f1 .~ (;j-j ~ <....- \ c::~ ~ ~ f') ~ ~ ~ -0 ", ~ -~ ~ (~,) 0 Ul -- SHERIFF'S RETURN - REGULAR CASE NO: 2005-03181 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCBRIDE STEPHEN T VS MCBRIDE DOUGLAS T ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MCBRIDE DOUGLAS T the DEFENDANT , at 2125:00 HOURS, on the 29th day of June 2005 at 15 THOMAS DRIVE MECHANICSBURG, PA 17055 by handing to DOUGLAS MCBRIDE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 19.24 .37 10.00 .00 47.61 So Answers: "~g:e:~.c~~ R. Thomas Kline 06/30/2005 CALDWELL & KEARNS h. ,."" me t :LS 1",- qo~~, AD " (2 //'uPP,., +.; Iprothonotary . day of Sworn and Subscribed to before By: SHERIFF'S RETURN - REGULAR CASE NO: 2005-03181 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCBRIDE STEPHEN T VS MCBRIDE DOUGLAS T ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MCBRIDE REBECCA ANN the DEFENDANT , at 2125:00 HOURS, on the 29th day of June , 2005 at 15 THOMAS DRIVE MECHANICSBURG, PA 17055 by handing to DOUGLAS MCBRIDE, HUSBAND a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: .....r.~"~ ..;~it ..f,'//..'? .~''; ';;1,i;;..:~,',:,,"~~t'":-~~;:';'~' ;!t"~'4~J ;t. y R. Thomas Kline 06/30/2005 CALDWELL KEARNS Sworn and Subscribed to before By: me this /~ ~ day of e},i. ~,{ A.D. Il '--11fL~ () /J.;#P,~,# rothonotary STEPHEN T. MCBRIDE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.05-3181-Civil DOUGLAS T. MCBRIDE and, REBECCA ANN MCBRIDE, Husband and wife, Defendant : CIVIL ACTION - LAW AND EQUITY PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Please remove from the index the Lis Pendens on the following property in the above-captioned action, while this action shall be continued solely as a civil action: ALL THA T CERTAIN tract or parcel ofland and premises, situate, lying and beging in the Township of East Pennsboro in the County of Cumberland Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pin, which iron pin is 100 feet east from the eastern line of South Enola Drive, at lands now or formerly of Merle Chronister; thence along said last mentioned lands and lands now or formerly of Jack Bloser, north 54 degrees 00 minutes east, 100 feet to a stake at lands now or formerly ofthe Grantors herein, being Lot No.3 on the hereinafter mentioned Plan of Lots; thence along the same, south 36 degrees 00 minutes east, 102 feet to a stake at lands now or formerly of Don Gamber; thence along said last mentioned lands, south 54 degrees 00 minutes west 70 feet to an iron pin at lands now or formerly of Nellie E. Villani; thence along said last mentioned lands north 36 degrees 00 minutes west, 27.50 feet to an iron pin; thence continuing along lands now or formerly of Nellie E. Villani, south 54 degrees 00 minutes west, 30 feet to an iron pin at lands now or formerly of Elmer Benner, being Lot No.1 on the hereinafter mentioned Plan of Lots; thence along said last mentioned lands, north 36 degrees 00 minutes west, 74.50 feet to an iron pin, the point and Place of BEGINNING. BEING Lot No.2 on Plan of Marlin E. Watts et ux which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 23, Page 24. HAVING THEREON ERECTED a two-story frame dwelling house which has the address of 324 South Enola Drive (rear), Enola, Pennsylvania, together with a block garage. -, TOGETHER with a right-of-way eight feet in width, extending from land ofthe Grantors, which is contiguous and to the east of the premises herein conveyed, to South Enola Drive and extending along the southern line of the premises herein conveyed for the laying and maintaining of underground pipe lines for the transmission of water, sewage and gas from and to the aforesaid premises of the grantors herein, together with free ingress, egress and regress to and for the said Grantors, their heirs and assigns, and tenants or possessors of said premises, contiguous to the premises herein granted and conveyed, for the purpose of repairing, replacing or maintaining said pipe lines. I hereby certify that this action affects title to or other interest in the above- described real property. Respectfully submitted, CALDWELL & KEARNS By: Dated: '1~ /0 ) I Ja L. olds Ith, Esquit Attome LD. No. 27115 Douglas L. Cassel, Esquire Attorney LD No. 92895 3631 North Front Street Harrisburg, P A 1711 0 (717) 232-7661 05-429/92551 CERTIFICATE OF SERVICE AND NOW, this --4L day Of'y;.,ly~ I , 2005, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Brian K. Zellner, Esquire Law Office of Darrell C. Dethlefs PO Box 368 Camp Hill, PA 17011 CALDWELL & KEARNS By 1/ J?j(jA~ I { - C) ;"1 .--' .., ~ \1\. f,'1. \ , -' , ~ ~ f") ~ ~ ~ . - '- -l:::. , (;~) ~ ~ .~". """ '" \~ c;j ~ ~ ~, \....J - STEPHEN T. MCBRIDE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.05-3181-Civi1 DOUGLAS T. MCBRIDE and, REBECCA ANN MCBRIDE, Husband and wife, Defendant : CIVIL ACTION - LAW AND EQUITY PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Please remove from the index the Lis Pendens on the following property in the above-captioned action, while this action shall be continued solely as a civil action: ALL THAT CERTAIN lot or tract of land with the improvements thereon erected, being located in the Borough of Lemoyne, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point seventy-five (75) feet from the Southeast corner of Seventh Street (formerly Lorne Street) and Hummel A venue, and extending along the Southern line of Hummel Avenue in an Easterly direction thirty-five (35) feet to Lot No. 19 and extending back an even width on one hundred fifty (150) feet to Peach Alley. BEING known and numbered as 632 and 634 Hwnmel Avenue. BEING THE SAME PREMISES which was recorded on the 9th day of December 2004, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 266, Page 2913, granted and conveyed unto Rebecca Ann McBride, married person. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. PARCEL # 12-22-0824-167 I hereby certify that this action affects title to or other interest in the above- described real property. Respectfully submitted, CALDWELL & KEARNS By: Dated: ~/1~ r 05.429/92552 CERTIFICATE OF SERVICE . 4 ' AND NOW, this /;6 day of "f~/ , 2005, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Brian K. Zellner, Esquire Law Office of Darrell C. Dethlefs PO Box 368 Camp Hill, PA 17011 CALDWELL & KEARNS By -r/t~ V-\ ,-, (J c"""':.) 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