HomeMy WebLinkAbout05-6789
Richard M. Squire, Esquire
1.0. No, 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC,
v,
NO, ()~ - &'7P'(
CwLI~
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants.
NOTICE
NOTICE
AVISO
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 of relief requested by the plaintiff. You may
lose money or property or other rights important to you.
Le han dernandado a usted en la corte. Si usted quiere
defenderse de estas demand as expuestas en las paginas
siguientes, usted tiene veinte (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Hace falta
asentar una comparencia escrita 0 en persona 0 con un
abogado y entregar a la corte en forma escrita sus
defensas Ci sus objecciones alas demandas en contra de
su person~l. Sea avisado que si usted no se defiende, la
corte tomara medidas y puede continuar la demanda en
contra suya sin previo aviso 0 notificacion. Ademas, la
corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisiones de esta
demanda. Usted puede perder dinero 0 sus edades u
otros derel::hos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP,
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO
TIENE EL. DINERO SUFICIENTE DE PAGAR TAL
SERVICIO VAYA EN PERSONA 0 LLAME POR
TELFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIRASISTANCIA LEGAL
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
Richard M. Squire, Esquire
Attorney I.D, 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC,
v.
NO. (jf; -
(.7[1 r,<..>LY~
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
COMPLAINT IN EJECTMENT
1. Plaintiff, WM Specialty Mortgage, LLC ("Plaintiff'), is a corporation with an
address c/o Ameriquest Mortgage Company, 505 City Parkway West, Suite 100,
Orange, CA 92865.
2. Defendants are Bobbie Jo Zeigler and any and all unknown occupants
residing at 32 Chestnut Street, Camp Hill, PA 17011 (collectively, "Defendants").
3, At all times material hereto, Plaintiff was, and still is, the owner in fee
simple of the real estate situated at 32 Chestnut Street, Camp Hill, PA 17011
("Property"),
4, The legal description of the Property is described on Exhibit "A" attached
hereto and incorporated herein by reference,
5, The abstract of title to the Property upon which Plaintiff relies is a Sheriff's
Deed from the December 7, 2005 Sheriff's Sale, which deed is currently being
prepared, and is therefore unavailable at this time.
COUNT I: EJECTMENT
6, Plaintiff incorporates the foregoing paragraphs by reference as though
more fully set forth herein,
7, At all times material hereto, Defendants have Llnjustifiably withheld and
continue to unjustifiably withhold possession of the Property from Plaintiff.
8. Despite numerous requests by Plaintiff and despite the granting to Plaintiff
of a Sheriff's Deed, Defendants have unjustifiably refused to vacate the Property
continue to unjustifiably withhold possession thereof from Plaintiff,
9. As the owner of the Property, Plaintiff is entitled to immediate possession
and immediate enjoyment thereof,
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter
judgment in its favor and against Defendants, Bobbie Jo Zeigler and all other persons
found in possession of the Property, for imrnediate possession of the Property; for
immediate ejectment of Defendants; for an award of Plaintiff's attorneys' fees; and for
such other relief as this Court deems just and proper.
COUNT II: ATTORNEY'S FEE~
10, Plaintiff incorporates the foregoing paragraphs by reference as though
more fully set forth herein,
11, Pursuant to 42 Pa, C,S. 92503(7), Plaintiff is entitled to an award of its
attorneys' fees incurred in connection with this matter, as Defendants' conduct in
refusing to dispossess and vacate the Property is per se dilatory, obdurate, vexatious,
in bad faith, and without justification,
12, Plaintiff has incurred $450,00 in attorneys' fees as of this date.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter
judgment in its favor and against Defendants, Bobbie Jo Zeigler and all other persons
found in possession of the Property, for immediate possession of the Property; for
immediate ejectment of Defendants; for an award of Plaintiff's attorneys' fees; and for
such other relief as this Court deems just and proper.
RICHry M. SQUlR); (SO:"TES. LLC
By: ~,~;') S' , ~ L---
Rich rd M. Squire, Esquire /
Attorney for Plaintiff L-" /
Date: December 28, 2005
VERIFICATION
Richard M, Squire, Esquire, hereby states that he is the attorney for the Plaintiff,
a corporation unless designated otherwise; that he is authorized to make this
Verification and does so in compliance with Pa, R.C,P. S 1024 (c), because of the
exigencies regarding this matter, and because Plaintiff must verify much of the
information through agents, and because he has personal knowledge of some of the
facts averred in the foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his knowledge, information and belief and
the source of his information is public records and reports of Plaintiff's agents. The
undersigned understands that this statement herein is made subject to the penalties of
18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities.
/] /
/ (
Li)j"IL f1J r-'-
, Richard M. Sq ire;E . uire
Date: December 28, 2005
.
EXHIBIT "A"
ALL THAT CERTAIN lot or tract of land situate in the Township of Lower Allen, County
of Cumberland and State of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the south side of Chestnut Street at the corner of Lot No. 16
in the hereinafter mentioned plan of lots; thence along the south side of Chestnut Street
North 71 degrees 51 minutes East 75 feet to a point; thence along the line of Lot No, 18
in the hereinafter mentioned plan of lots South 18 degrees 0 minutes East 117.48 feet
to a point; thence along the line of land now or formerly of Lower Allen Development
Company South 71 degrees 9 minutes West 75 feet to a point; thence along the line of
Lot No. 16 aforesaid North 18 degrees 9 minutes West 118,4 feet to a point, the place
of BEGINNING,
BEING Lot No, 17 in the Plan of Lots of Robert T. Stoner and Charlotte J. Stoner, his
wife, made August 31, 1954, revised April 30, 1957, and recorded in the Office of the
Recorder of Deeds in and for Cumberland County in Plan Book 9, Page 5.
HAVING THEREON ERECTED a dwelling house known as 32 Chestnut Street.
UNDER AND SUBJECT to conditions, easements, restrictions and covenants of prior
record.
D "fA
D t lr(
~ V(
W lfl.
~ .r:.. C>
~ ~ ~
..r::.
~
E
-..l...
I~)
',-
~,
':;~
'.:-_rI
CJ
,:,-\
C')
i'~'
..;:;
9
o
-n
--4
;:;,7!
'_'"..G
,< '~J
c~ 1
;t-::)
r:-:
(..'
o
,.-{
~-::: C-:c)
I,)\-n
-' ~\
?
~
.....
SHERIFF'S RETURN - REGULAR
.
CASE NO: 2005-06789 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WM SPECIALTY MORTGAGE LLC
VS
ZEIGLER BOBBIE JO ET AL
DOUGLAS RUZANSKI
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
ZEIGLER BOBBIE JO
the
DEFENDANT
, at 1715:00 HOURS, on the 6th day of January
2006
at 32 CHESTNUT STREET
CAMP HILL, PA 17011
by handing to
WILLY PRATHER, BOYFRIEND,
ADULT IN CHARGE
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
11.44
.00
10.00
.00
39.44
,,-, ,.,;/ .' /.<<
_..,~;;~"',I /,._~ . .,_ ...",.v.,~/' _
.f'~'" ....;.<::.::;~;:/.;'-.:..,::::,.<':,<, ~?<'>-_"._.-:::j~':ii"~'{"
R. Thomas Kline
Sworn and Subscribed to before
01/09/2006
RICHARD SQUIRE,) I' " 7
Ry. "ti#A~lf/
0-
me this //~ day of
")fl;;~
Pro otar
A.D.
,..
SHERIFF'S RETURN - REGULAR
t
CASE NO: 2005-06789 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WM SPECIALTY MORTGAGE LLC
VS
ZEIGLER BOBBIE JO ET AL
DOUGLAS RUZANSKI
sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
PRATHER WILLY
the
DEFENDANT
, at 1715:00 HOURS, on the 6th day of January
2006
at 32 CHESTNUT STREET
CAMP HILL, PA 17011
by handing to
WILLY PRATHER, BOYFRIEND OF
BOBBIE JO ZEIGLER
a true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing His attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
f~'"
_.,.._...\~.:;.~~'^/'''.::: .....;::.
'f'" ",.
R. Thomas Kline
,f;'>-
01/09/2006
RICHARD SQUIRE
Sworn and Subscribed to before By:
me this
<co
1/ ~
day of
('
,
A.D.
y
Richard M. Squire, Esquire
Attorney I.D, 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-B442
Attorneys for Plaintiff
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC,
v,
NO. 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment in ejectment and for possession of the premises located at
32 Chestnut Street, Camp Hill, PA 17011 in favor of Plaintiff, WM Specialty Mortgage,
LLC, and against Defendants, Bobbie Jo Zeigler, Willy Prather and any and all
unknown occupants, jointly and severally, for failure to answer the Complaint in
Ejectment within twenty (20) days of service thereof,
f1.ARD M. SQUIRE & ASSOCIATES. LLe
Llt I '
Richard M, Squire, Esquir ,
Date: February 7,2006
ENTRY OF JUDGMENT AND
ASSESSMENT OF DAMAGES
AND NOW, this
day of February, 2006, judgment in ejectment and for
possession of the premises located at 32 Chestnut Street, Camp Hill, PA 17011 is
hereby entered in favor of Plaintiff, WM Specialty Mortgage, LLC, and against
Defendants, Bobbie Jo Zeigler, Willy Prather and any and all unknown occupants,
jointly and severally,
~
Richard M. Squire, Esquire
Attorney I.D. 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-6442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
NO. 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants.
CERTIFICATION OF LAST KNOWN ADDRESS
I, Richard M. Squire, Esquire, hereby certify that the last known mailing address
of Defendants, Bobbie Jo Zeigler, Willy Prather and any and all unknown occupants, is
32 Chestnut Street, Camp Hill, PA 17011, and the last known mailing address of
Plaintiff, WM Specialty Mortgage, LLC is clo Ameriquest Mortgage Company, 505 City
Parkway West, Suite 100, Orange, CA 92865,
RICHARD M. SQUIRE & ASSOCIATES, LLC
c:
Date: February 7,2006
Richard M. Squire, Esquire
Attorney 1.0, 04267
Richard M. Squire & Associates, LLC
33 S. Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
NO. 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
CERTIFICATION OF MAILING PURSUANT TO RULE 237.1
I, Richard M, Squire, attorney for Plaintiff, hereby certify that on January 27,
2006, I served a true and correct copy of the 237.1 Notice upon the following
Defendants via first class mail, postage pre-paid:
Bobbie Jo Zeigler
32 Chestnut Street
Camp Hill, PA 17011
Willy Prather
32 Chestnut Street
Camp Hill, PA 17011
TenanUOccupant
32 Chestnut Street
Camp Hill, PA 17011
7 ("
1/
Richard M. Squire, Esq
RICHARD M. SQUIRE & ASSOCIATES, LLC
()JLfi'
Richard M_ Squire, Esquire
Attorney LD. 04267
Richard M. Squire & Associates, LLC
33 S. Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO, 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
TO: Bobbie Jo Zeigler
32 Chestnut Street
Camp Hill, PA 17011
DATE: January 27,2006
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 DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU, UNLESS YOU ACT WITHIN TEN 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
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
RIJ~D M.SOUIR~&_ASSOC"TES. LLe
I ,j'<'il['~;) 7 I L '-_
Richard M, quire, Esqtl1fe
Richard M. Squire, Esquire
Attorney I.D. 04267
Richard M. Squire & Associates, LLC
33 S. Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
NO. 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
TO: Willy Prather
32 Chestnut Street
Camp Hill, PA 17011
DATE: January 27,2006
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 DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN 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
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOllOWING OFFICE TO FIND OUT
WHERE YOU CAN GET lEGAL HELP:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
RICHARD M. SQUIRE & ASSOCIATES, LLC
/)
:', /1..
.,-< Ii"" ,A ". /) '). .L"-
Richard M. Squire, Esqt1'~
Richard M. Squire, Esquire
Attorney I.D. 04267
Richard M. Squire & Associates, LLC
33 S. Brick Lane
Elverson, PA 19520
(610) 913-6442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
NO, 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants,
TO: Tenant/Occupant
32 Chestnut Street
Camp Hill, PA 17011
DATE: January 27,2006
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 DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU, UNLESS YOU ACT WITHIN TEN 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
NOTICE TO A LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
RI7)ARD M. SQUIR~.~ASSOCIATES, LLC
" / /. / ') } ....~
.i " , ,:1 ' ..... i',
ill "J " /, / ( ~ "'-----
~ichard M. Squire, Estfuire
Richard M. Squire, Esquire
Attorney I.D. 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC,
v.
NO, 05-6789 Civil Term
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
CIVIL ACTION
Defendants.
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF MONTGOMERY
Richard M. Squire, being duly sworn according to law, deposes and
says that he is an attorney for Plaintiff, that he is authorized to make this
affidavit on behalf of Plaintiff, and that to the best of his knowledge,
information and belief, neither Bobbie Jo Zeigler nor Willy Prather is in the
military service of the United States, nor any State or Territory thereof or its
allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the
amendments thereto and that the averments herein set forth, insofar as
they are within his knowledge, are correct and true; and insofar as they are based on
information received from others, are true and correct as he verily b
Sworn to and subscribed before me
1')-/11 k
this -L day of f-eh
~~
Notary Publi
COMMONWEAJ:rH OF PENNSYLVANIA
Notarial Seal
JenkintoBrian Corkery, Notary Public
wn Born Montgomery County
My Commission Expires Aug. 14, 2007
Member, Pennsylvania AssOcil'lfion of No~arjes
,200.0
Richard M. Squire, Esquire
Attorney LD. 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-8442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
v,
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
Defendants,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-6789 Civil Term
: CIVIL ACTION
CERTIFICATE OF SERVICE
I, Richard M, Squire, Esquire, hereby certify that I served a true and correct copy
of foregoing Default Judgment package by depositing same on this date in first class
mail, postage prepaid, to the following parties:
Bobbie Jo Zeigler
32 Chestnut Street
Camp Hill, PA 17011
T enantlOccupant
32 Chestnut Street
Camp Hill, PA 17011
Date: February 7, 2006
Willy Prather
32 Chestnut Street
Camp Hill, PA 17011
R"UARD M. SQUIRE & ASSOCIATES, LLC
I '/)
t/!vn2 ( /1
ichard M. Squire, Esquir
c ~ 0 ~
~ ~ ~~ ~
-:: C>
R ~ ~ 0
3 ~ ~ ~
~ ,et-- t
r --7:-
'~.)
~..)
':.' ~n
,. '
t::
c~, --F ,.,;
r "
,"t
r.''!
Richard M. Squire, Esquire
Attorney I.D. 04267
Richard M. Squire & Associates, LLC
33 South Brick Lane
Elverson, PA 19520
(610) 913-6442
Attorneys for Plaintiff
WM SPECIALTY MORTGAGE, LLC,
Plaintiff,
v,
BOBBIE JO ZEIGLER and ANY AND
ALL UNKNOWN OCCUPANTS of
32 Chestnut Street
Camp Hill, PA 17011
Defendants.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 05-6789 Civil Term
CIVIL ACTION
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindly issue a Writ of Possession in the above matter.
Date: February 7,2006
RICHARD M. SQUIRE & ASSOCIATES, LLC
iv!~,1
Richard M, Squire, Esquire
~,
--(- -;;.J ()
:t, ~ 1\-
~ Lv
;cJ ~ ~
'" f' 1-)
~ tr- l
Vi
"
~
~
b-\
t
\;:, -t...J~
..o~~:c~
-l& ~ C .~ g .t' \)
....... ~
\) ..t:: C' C' .l: CY
I ' ;)
() , I I ~
.. t\ r
~ .. ::: - ~
.. ':: ~.~
~
~
.. -
-
(')
~1
(T
~-' -n
I
C')
j'...,
(n
-_.,
i "
10f2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC.
VS,
No, 05-6789 Civil Term_
BOBBIE 10 ZEIGLER AND ANY AND
ALL UNKNOWN OCCUPANTS
32 CHESTNUT STREET
CAMP HILL, P A 170 II
Costs
Attorney's
Plaintiff s
Prothonotary
$ 134,94
$
$ 1,00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(I) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WM SPECIALTY MORTGAGE, LLC
being: (Premises as follows):
32 CHESTNUT STREET, CAMP HILL, P A 17011
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell hislher (or their) inte~st therein,
mbcrland County, P A
'.
Date FEBRUARY 8. 2006
(Seal)
By: Irene Morrow
Deputy
(
...
20(2
No 05-6789 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC,
VS.
BOBBIE JO ZEIGLER ANY AND
ALL UNKNOWN OCCUPANTS OF
32 CHESTNUT STREET
CAMP HILL, PA 17011
WRIT OF POSSESSION
P.R.c.P. 3160-3165 ETC.
Costs
Att'y
Plff (sl
Prothy
Sheriff
$ 134,94
$
$ 1.00
$
Plaintiff (s) attorney name and address:
RICHARD M, SQUIRE, ESQUIRE
33 SOUTH BRICK LANE
ELVERSON, PA 19520
610-913-8442
I.D, # 04267
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the _ day of . I 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
Deputy
Prothonotary
" .
--
. .
~
By virtue of this writ, on the 12 t b1ay of A p r il ,2 006 , I caused the within
named WM Siicia I t Y Mar tgage . to have possessionofthepre!llises describe<M~XX
~~~ 32 Chestnut St, Camp Hill, PA 1/011
Sworn and subscribed to before me this u; e
D>'O'p;~
SO~~
"\ .1 Sheriff ~ /
By( ~ 0 qc4- [\1'\. ..)'00.14/
Sheriff's
Docke ting
Sucharge
Poundage
Pro thy
Possession
Milage
Return:
, 18.00
20.00
5.73
1.00
30.00
26.40
101.13
Advance Costs:
Sheriff's Costs:
150.00
101. 73
48.87
Refunded to Atty on 4/13/06
Cl
'(',
...
..>
""
..S>
-......
.~'
"~\~
,~~
LO :11 't;/ (, 93.l qOOi
\f1.~ ~ ~ ~J 03:JHU1N '111:1381-/ no
.:lO 301,:/,;/0
~'
.,>~
'.r~<;y
,Y lJ">
\. ~531n
Ru.-.. /719 '13
\.
, .
20f2
No 05-6789 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
WM SPECIALTY MORTGAGE, LLC.
VS.
BOBBIE JO ZEIGLER ANY AND
ALL UNKNOWN OCCUPANTS OF
32 CHESTNUT STREET
CAMP HILL, PA 17011
WRIT OF POSSESSION
P.RC.P. 3160-3165 ETC.
Costs
Att'y
Plff(s}
Prothy
Sheriff
$ 134,94
$
$ 1.00
$
Plaintiff(s) attorney name and address:
RICHARD M, SQUIRE, ESQUIRE
33 SOUTH BRICK LANE
ELVERSON, PA 19520
610-913-8442
J.D, # 04267
Attorney for Plaintiff(s)
Where papers may be served
By virtue oftbis writ, on the _ day of , , I caused tbe within
named , to have possession of the premises described witb the
appurtenances, and
So Answers,
Sworn and subscribed to before me tbis
Day of
\
By
, -'
\ Slleriff
Protbonotary
Deputy
.' ~
.
.
,
1012
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WM SPECIALTY MORTGAGE, LLC.
VS,
No, 05-6789 Civil Term_
BOBBIE JO ZEIGLER AND ANY AND
ALL UNKNOWN OCCUPANTS
32 CHESTNUT STREET
CAMP HILL, PA 17011
Costs
Attorney's
Plaintiff's
Prothonotary
$ 134,94
$
$ 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))
WM SPECIALTY MORTGAGE, LLC
being: (Premises as follQws):
32 CHESTNUT STREET, CAMP HILL, P A 170 II
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
of mberland County, PA
Date FEBRUARY 8. 2006
(Seal)
By: Irene Morrow
Deputy