HomeMy WebLinkAbout05-5042
.
MILSTEAD & ASSOCIATES, LLC
BY: Pin a S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3
450 West 33rd Street, 15th Floor
New York, NY 10001,
Plaintiff,
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
Case No.: OS - Soi./~ Ciu~L~0L~
CIVIL ACTION COMPLAINT
IN EJECTMENT
{00064539}
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MILSTEAD & ASSOCIATES, LLC
BY: Pina S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3
450 West 33rd Street, 15th Floor
New York, NY 10001,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Case No.:
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
CIVIL ACTION (REAL PROPERTY)
LEASE OR EJECTMENT
You have been sued in Court. If you wish to defend against the claims set forth on 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 an attorney and filing in writing with the Court,
your defense or objects 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 claims or relief
requested by the Plaintiff. You may lose money or personal or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
717-249-3166
800-990-9108
{00064539}
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NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
...............................................................................
1. This communication is from a debt collector. This is an attempt to
collect a debt and any information obtained will be used for that
purpose.
2. Unless you dispute the validity of this debt, or any portion thereof,
within 30 days after receipt of this notice, the debt will be assumed to
be valid by our offices.
3. If you notify our offices in writing within 30 days of receipt of this
notice that the debt, or any portion thereof, is disputed, our offices will
provide you with verification of the debt or copy of the judgment
against you, and a copy of such verification or judgment will be mailed
to you by our offices.
{00064539}
"'-...
MILSTEAD & ASSOCIATES, LLC
BY: Pina S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3
450 West 33rd Street, 15th Floor
New York, NY 10001,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
Case No.: OS - .sO'-l~ C;o~l~
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
COMPLAINT IN EJECTMENT
1. Plaintiff, JP Morgan Chase Bank, as Trustee for Equity One, ABS, Inc., Mortgage
Pass- Through Certificates, Series 2001-3 (herein referred to as "Plaintiff') is a bank, conducting
business under the laws of the Commonwealth of Pennsylvania and brings this Ejectment action
against Eric P. Kropiewnicki and KnownlUnknown Occupants (hereinafter referred to
collectively as "Defendants").
{00064539}
...10. . .
2. Defendants are the individuals occupying 433 Hogestown Road, Mechanicsburg,
P A 17050 (hereinafter referred to as "Premises") more fully described in the legal description
attached as Exhibit "A".
3. Plaintiff is the record owner of the Premises where Defendants reside, having filed
a Complaint in Mortgage Foreclosure, proceeded to judgment in that action, and acquired title to
the Premises by a Sheriff Sale, which took place on September 7, 2005, by reason of Writ of
Execution issued out of the Cumberland County Court of Common Pleas. A true and correct
copy of the filed Writ of Execution is attached hereto as Exhibit "B".
4. Defendants are in possession of the Premises without title, color of title, or benefit
of a lease from Plaintiff.
5. Defendants are wrongfully and unlawfully in possession of the Premises.
6. Defendants have no rights of possession to the Premises.
7. By reason of the aforesaid Sheriffs sale, Plaintiff holds paramount title to the
Premises but Defendants continue to unlawfully and willfully retain possession and keep Plaintiff
out of possession thereof and refuse to vacate and deliver up the Premises to Plaintiff.
8. As no landlord tenant relationship exists between Plaintiff and Defendants,
Defendants are not entitled to any specific notice to vacate. The commencement of an action in
foreclosure culminating in a sheriff s sale should have put the Defendants on notice that Plaintiff
intends to recover full interest, title, and possession of the Premises.
9. Notwithstanding the aforesaid, Defendants have willfully remained in possession
of Plaintiffs property and refuse, and still refuse to vacate the Premises and continue to occupy
the same.
{00064539}
-4
WHEREFORE, Plaintiff requests that this Court enter a Judgment for Possession against
the Defendants, Eric P. Kropiewnicki and KnownlUnknown Occupants.
MILSTEAD & ASSOCIATES, LLC
By: ...-;:: '5'~
Pina S. Wertzberger, Esquire
#77274
{00064539}
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VERIFICATION
I, Pina S. Wertzberger, hereby certify that I am an Attorney for Plaintiff and am
authorized to make this verification on Plaintiff s behalf. I verify that the facts and statements set
forth in the forgoing Complaint in Ejectment are true and correct to the best of my knowledge,
information and belief. This Verification is made subject to the penalties of 18 Pa. C.S. ~ 4904,
relating to unsworn falsification to authorities.
4.
//wt{ )l
Name: Pina S. Wertzberger, Esquire #: 77274
Title: Attorney
{00064539}
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ALL THAT CERTAJN tract or parcel of land located in the To-wn.sh!p of Silver Spring, County of Cumberland,
Commonwealth of Pennsylvan.i.a. more partiC'U1ar1y bounded and descnoed as follows, to wit:
SITIJATE in Silver Spring Township. Cnmbedmd CoU:llty, Pennsylvania., bounded and described as follows:
BEGmNJNG at a re-bar set on the Southwest side ofHogestown Roa~ P A # 114 (80 foot wide right of way) at a
comer of property now or formerly of Roy D. Kunkle and Bernadine E. Kmilde, his wife; thence exteD.ding from
said beginning point and along Souihwest side of Hogestown Road, P A, # 114, by a curve to the left having a
radius of 1,313.57 feet and length of 143.71 feet to a re-bar set at a comer of property now or formerly ofR-P.
Lambert and Pearl M. Lambert) his wife, thence extending along same, South 81 degrees 5 minutes 00 seconds
West, 295.04 feet to a comer of property, now or formerly of Mary E. Dull; thence extending along same Narth
28 degrees 15 minutes 00 seconds West, 150.00 feet to a re-bat set at a comet of property now or formerly of Roy
D. Knnkle andBemadine R Kunkle. his wife aforementioned; thence extending along same, North 81 degrees 5
minutes 00 seconds East, 320.22 feet to the first mentioned re-bar set and place ofbegimring.
BEING KNOViN AS 433 Hogestown Road, Mechanicsburg, P A 17050
PARCEL ID NO: 38-20-1831-038
lMPROVEMENTS THEREON CONSIST OF: Residential Dwelling
(00042426}
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EXHIBIT A
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In the Court of Common Pleas of Cumberland County, P A
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3
Plaintiff
CIVIL ACTION
NO.: 04-5580 Civil Term
Vs.
Praecipe For Writ of Execution
(Mortgage Foreclosure)
Eric P. Kropiewnicki
Andrea M. Kropiewnicki
Defendant(s)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
1. Directed to the Sheriff of Cumberland County;
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2. Against the Defendant(s) in the above captioned matter;
3. and index this writ against the Defendant(s) as follows:
Eric P. Kropiewnicki
Andrea M. Kropiewnicki
4. Real property involved:
433 Hogestown Road
Mechanicsburg, P A 17050
AMOUNT DUE
INTEREST
From 4/11/05 to Date of
Sale at $22.46 per diem
$136,633.09
$
TOTAL
(Costs to be added)
$
May 4, 2005
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----...--/
(00042426)
EXHIBIT B
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS CUMBERLAND COUNTY
Prothonotary
To: Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, PA 17050
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
Case No.: 2005-05042
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
NOTICE PURSUANT TO RULE 236
Notice
Pursuant to Rule 236 of the Supreme Court ofPennsy1vania, you are hereby notified that a
Judgment has been entered against you in ~above pro4!ding as indicated below.
~o~~O
II /;;"p/o--S
JUDGMENT AS TO POSSESSION
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
Pina S. Wertzberger, Esquire
Milstead & Associates, LLC
856-482-1400
{00073405)
MILSTEAD & ASSOCIATES, LLC
BY: Pin a S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
Case No.: 2005-05042
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, PA 17050,
Defendants.
PRAECIPE TO ENTER
JUDGMENT FOR POSSESSION
TO THE PROTHONOTARY:
Kindly enter Judgment in favor of Plaintiff, IP Morgan Chase Bank, as Trustee for Equity
One, ABS, Inc" Mortgage Pass-Through Certificates, Series 2001-3, and against the Defendants,
Eric P. Kropiewnicki and KnownlUnknown Occupants of 433 Hogestown Road, Mchanicsburg,
P A 17050, for failure to Answer the Complaint in Civil Action - Ejectment.
Service was on made on Defendants, Eric P. Kropiewnicki and KnownlUnknown
Occupants of 433 Hogestown Road, Mchanicsburg, PA 17050, via Sheriff of Cumberland
County on September 29.2005.
Kindly enter Judgment as to Possession of the property located at 433 Hogestown Road,
Mchanicsburg, P A 17050.
(00073405)
MILSTEAD & ASSOCIATES, LLC
BY: Pina S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
Eric P. Kropicwnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
Case No.: 2005-05042
AFFIDAVIT OF ADDRESSES
STATE OF NEW JERSEY:
SS
COUNTY OF CAMDEN:
I, Pina S. Wertzberger, being duly sworn according to law, upon my oath, depose and
say:
1.
10001.
2,
17050.
3.
I certify that the Plaintiffs address is 450 West 33rd Street, I 5th Floor, New York, NY
I certify that the Defendants' address is 433 Hogestown Road, Mchanicsburg, P A
I certify that the foregoing information is true and correct to the best of my
knowledge, information and belief.
'Istead & A s ciates, LLC
r r, Esquire
Attorney J.D. No. 7274
(00073405l
MILSTEAD & ASSOCIATES, LLC
BY: Pina S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drivc E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
Case No.: 2005-05042
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, PA 17050,
Defendants.
AFFIDAVIT OF NON-MILITARY
SERVICE
STATE OF NEW JERSEY:
SS
COUNTY OF CAMDEN:
I, Pina S. Wertzberger, Esquire, Attorney at Law, being duly sworn according to law,
upon my oath, depose and say:
1. That the Defendants are not in the Military, Naval of Air Services ofthe United States
of any other Country within the provision of the Soldiers' and Sailors' Civil Relief Action of
Congress, as amended; and
2. That the Defendants are at least 21 years of age and reside at 433 Hogestown Road,
Mchanicsburg, P A 17050. The affiant has ascertained thc foregoing information by personal
inquiry and knowledge and makes this Affidavit with the authority.
{0007340S}
MILSTEAD & ASSOCIATES, LLC
~
BY: Pina S. Wertzberger, Esquire
ATTORNEY ID NO.: 77274
Woodland Falls Corporate Park
220 Lake Drive E., Ste 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorneys for Plaintiff
File # 1.03084
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage Pass-
Through Certificates, Series 2001-3,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Vs.
Case No.: 2005-05042
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, PA 17050,
Defendants.
AFFIDAVIT OF SERVICE
STATE OF NEW JERSEY:
SS
COUNTY OF CAMDEN:
I, Pina S. Wertzberger, Esquire, Attorney at Law, being duly sworn according to law,
upon my oath, depose and say:
1. I am a member of the firm of Michael J. Milstead, Esquire, attorneys for Plaintiff in
the above entitled cause of action.
2. Notice, Rule 237.1 was forwarded to the Defendants at their place of residencc by
regular mail on October 24, 2005 and has not been returned to this office, so it can be assumed
that same has been delivered to Defendants. A true and correct copy of said Notice is attached
hereto as Exhibit "A."
Milstead & Associates, LLC
er, Esquire #77274
(00073405)
. .. MILSTEAD & ASSOCIATES, LLC
BY: Pina S. Wertzberger, Esquire
ID No. 77274
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
JP Morgan Chase Bank, as Trustee for
Equity One ABS, Inc., Mortgage Pass-
Through Certificates Series 2001-3,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
No.: 2005-05042P
Vs.
Eric P. Kropiewnicki,
and
KnownlUnknown Occupants
433 Hogestown Road
Mechanicsburg, PA 17050
Defendant( s ).
TO: Eric P. Kropiewnicki
433 Hogestown Road
Mechanicsburg, P A 17050
KnownlUnknown
433 Hogestown Road
Mechanicsburg, PA 17050
DATE OF NOTICE: October 24, 2005
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT. THIS NOTICE IS SENT TO YOU IN AN ATEMPT TO COLLECT
THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF
LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by
attorney and file in writing with the court your defenscs or objections to claims set forth against
you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered
(00069563)
EXHIBIT A
Page I of 2
, 4 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 NOTICE TO DEFEND
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
Pina S. Wcrtzberger, Esquire # 77274
{00069563)
Page 2 of 2
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PRAECIPE FOR WRIT OF POSSESSION
Commonwealth of Pennsylvania
County of Cumberland
JP Morgan Chase Bank, as Trustee for
Equity One, ABS, Inc., Mortgage
Pass-Through Certificates, Series 2001-3,
COURT OF COMMON PLEAS
NUMBER 2005-05042
Plaintiff,
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, P A 17050,
Defendants.
Praecipe for Writ of Possession
TO THE PROTHONOTARY:
Issue Writ of Possession in the above matter for possession of:
433 Hogestown Road, Mechanicsburg, P A 17050
(see attached description)
~-
Pina S. erger, Esquire
I.D, # 7727
Attorney Fo Plaintiff
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
856-482-1400
{00073406}
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ALL THAT CERTAlN tract or parcel of land located in the Township of Silver Spring. County of Cumberland,
Co=onwealth ofPennsy1varda, more particul!tt'ly bounded and desCn'bed as follows, to wit:
SITUATE in Silver Spring Township, Cumberland COUllty, Pennsylvania, bounded and descnbed as follows:
BEGINNING at a re-bar set on the So'Uthwest side of ROgestoWll Road, P A # 114 (80 foot wide right of way) at a
comer of property now or formerly efRoy D. Kunkle and Bernadine E. K1mk1e, his wife; thence ~ding from
said beginning point and along Southwest side of Hegestown Road, P A, #114, by a curve to the left having a
radius ofI,313.57 feet SJld length ef143.71 feet to a re-bar set at a comer of property now or formerly erR.p.
Lambert and Pearl M. Lam.bert, bis wife, thence ext~ntlillg along same, South 81 degrees 5 minutes 00 seconds
West, 295.04 feet to a comer of property, now or formerly of Mary E. Dull; the:nce extending along same North
28 degrees 15 minutes 00 seconds West, 1$0.00 feet to a re-bat set at a comer of property now or formerly of Roy
D. KImkle andB...-n.n;ne E. Kunkle, his wife aforementioned; thence extending along same, North 81 degrees 5
minutes 00 seconds East, 320.22 feet to the first mentioned re-blll" $cl and place of beginning.
BEING KNOWN AS 433 Hogestown Road, Mechanicsburg, P A 17050
PARCELIDNO: 38-20-1831-038
IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling
{00042426)
\
Commonwealth of Pennsylvania
County of Cumberland
Court of Common Pleas
JP Morgan Chase Bank, as Trusteefor
Equity One, ABS, Inc., Mortgage
Pass-Through Certificates, Series 2001-3,
COURT OF COMMON PLEAS
NUMBER 2005-05042
Plaintiff,
Vs.
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, PA 17050,
Defendants.
Writ of Possession
To the Sheriff of McKean County:
(1) To satisfy the judgment for possession in the above matter, you are directed to deliver
possession of the following described property to: JP Morgan Chase Bank, as Trustee for Equity One,
ABS, Inc., Mortgage Pass-Through Certificates, Series 2001-3
433 Hogestown Road, Mechanicsburg, PA 17050
(see attached description)
(2) To satisfy costs against the defendants, you are directed to levy upon the property of the
defendants and sell their interest therein:
Eric P. Kropiewnicki and
KnownlUnknown Occupants of
433 Hogestown Road
Mechanicsburg, P A 17050
Pina S. Wertzberl!er #77274
(856)482-1400
Deputy
(Seal)
(00073407)
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ALL THAT CERTAIN tract or parcel of land located in the Township of Silver Spring, County of Cumberland,
Co=onwealth of Pennsylvania, more particularly bounded and descn'bed as follows, to wit
SITUATE in Silver Spring Township, Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a re-bar set on the Southwest side of Ilogestown Road, P A # 114 (80 foot wide right of way) at a
comer of property now or formerly of Roy D. K11lllde and Bernadine E. Ktmkle, his wife; thence extco.ding from
said beginning point and along Southwest side of Hogestown Road, P A, # 114, by a curve to the left having a
radius ofl,313.57 feet and length of143.71 feet to are-bar set at a corner of property now or formerly ofR-P.
Lambert and Pearl M. Lambert, his wife, thence extentli1)g along same, South 81 degrees S minutes 00 seconds
West, 295.04 feet to a comer ofpropcrty, now or formerly ofMa:ry E. Dull; thence extending along same North
Z8 degrees IS minutes 00 seconds West, 1S0.00 feet to a re-bat set at a comer of property now or formerly of Roy
D. Kunkle and Bemadine E. Kunkle, his wife aforementioned; thence extending along same, North 81 degrees 5
minutes 00 seconds East, 320.22 feet to tlu: first mentioned re-ber set and place of beginning.
BEING KNOWN AS 433 Hogestown Road, Mechanicsburg, P A 17050
PARCEL ID NO: 38-20-1831-038
IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling
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WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JP MORGAN CHASE BANK, AS
TRUSTEE FOR EQUITY ONE, ABS, INC.,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2001-3
VS. No, 05-5042 Civil Term
ERIC P. KROPIEWNICKI AND
KNOWN/UNKNOWN OCCUPANTS OF
433 HOGESTOWN ROAD
MECHANICSBURG, P A 17050
Costs
Attorney's
Plaintiffs
Prothonotary
$ 115.50
$
$ 1.00
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))
JP MORGAN CHASE BANK, AS TRUSTEE FOR EQUITY ONE, ABS, INC., MORTGAGE
PASS-THROUGH CERTIFICATES, SERIES 2001-3
being: (Premises as follows):
ERIC P. KROPIEWNICKI AND KNOWNIUNKNOWN OCCUPANTS OF
433 HOGESTOWN ROAD, MECHANICSBURG, P A 17050
(2) To satisfy the costs against the defendant (5) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) 'jterest therei )
rtofCumberland County, PA
Date NOVEMBER 28, 2005
(Seal)
By: Irene Morrow
Deputy
.
'.
2012
No 05-5042 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
JP MORGAN CHASE BANK, AS TURSTEE FOR EQUITY ONE,
ABS, INC., MORTGAGE P ASS- THROUGH CERTIFICATES, SERIES
2001-3
VS.
ERIC P. KROPIEWNICKI AND KNOWNIUNKNOWN OCCUPANTS OF
433 HOGESTOWN ROAD
MECHANICSBURG, P A 17050
WRIT OF POSSESSION
P.R.c.P. 3160-3165 ETC.
Costs
Att'y
Plff (s1
Prothy
Sheriff
$ 115,50
$
$ --.l.QQ
$
Plaintiff (5) attorney name and address:
PINA. S. WERTZBERGER, ESQUIRE
220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
856-482-1400
J.D. # 77274
Attorney for Plaintiff(s)
Where papers may be served
By virtue of this writ, on the _ day of , . 1 caused the within
named , to have possession of the premises described with the
appurtenances, and
So Answers,
Sworn and subscribed to before me this
Day of
Sheriff
By
Prothonotary
Deputy
,
"
OFFICE OF THE SHERIFF
Cln'1e:-~::~ .f, t!2 f"'r'}.!!TY. r/\
By virtue of this writ, on the 13th day of January, 2006 . I caused the within
~~ JP Morgan Chase BanK Z005 tl'll!@ve a>ssa~im at' e premises described ~
~ 433 Ho estown Road Mecha'nlc'sbti PA 17055
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subscribed to before me this ,'t-
Sheriff's Return:
Docketing
Surcharge
Prothonotary
Poundage
Possession
Milage
'. 18.00
2$.00
1.00
1.58
30.00
9.60
80.18
Advance Costs: 200.00
Sheriff's Costs: 80.18
119. 82
Refunded to Atty on 1/13/06
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WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JP MORGAN CHASE BANK, AS
TRUSTEE FOR EQUITY ONE, ABS, INC.,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2001-3
VS. No. 05-5042 Civil Term_
ERIC P. KROPIEWNICKI AND
KNOWN/UNKNOWN OCCUPANTS OF
433 HOGESTOWN ROAD
MECHANICSBURG, P A 17050
Costs
Attorney's
Plaintiff s
Prothonotary
$ 115.50
$
$ 1.00
COMMONWEALTH OF PENNSYL VANIA:
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 ofthe following described property to: (Plaintiff(s))
lP MORGAN CHASE BANK, AS TRUSTEE FOR EQUITY ONE, ABS, INC., MORTGAGE
PASS-THROUGH CERTIFICATES, SERIES 2001-3
being: (Premises as follows):
ERIC P. KROPIEWNICKI AND KNOWNIUNKNOWN OCCUPANTS OF
433 HOGESTOWN ROAD, MECHANICSBURG, P A 17050
(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) inte st therein. 1
fCumberland County, P^
Date NOVEMBER 28. 2005
(Seal)
By: Irene Morrow
Deputy