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HomeMy WebLinkAbout02-1820IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE adk/a RONALD D. BLYSTONE, Defendant. CWIL DIVISION NO.: 02-1820 MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, PNC Mortgage Corp. of America n/k/a Washington Mutual Home Loans, Inc., by and through its attorneys, Grenen & Birsic, P.C., and files the within Motion for Special Service of Civil Action - Complaint in Pursuant to Special Order of Court, under Pennsylvania Rule of Civil Procedure 430 as follows: 1. On April 12, 2002, Plaintifffiled a Civil Action, Complaint in Ejectment against the Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, at the above term and number. 2. On or about April 12, 2002, Plaintiff delivered to Cumberland County Sheriffa copy of the Civil Action, Complaint in Ejectment, with instructions that it be served upon Defendant at the last known address being 1438 Bridge Street, New Cumberland, PA 17070. 3. On or about May 13, 2002, Cumberland County Sheriff notified Plaintiff that they were unable to serve Defendant at 1438 Bridge Street, New Cumberland, PA 17070, with a copy of the Complaint since Defendant could not be found at said address. A true and correct copy of the Sheriff's return is marked Exhibit "A", attached hereto and made a part hereof. 4. An Affidavit of the Plaintiffstating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, is marked Exhibit "B", attached hereto and made a part hereof. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct Cumberland County Sheriff to post a copy of the Complaint on the property at 1438 Bridge Street, New Cumberland, PA 17070, and permit the Plaintiff to serve Defendant, Ronald E. Blystone aJk/a Ronald D. Blystone, by mailing a tree and correct copy of the Complaint by certified mail, return receipt requested and by first class mail, postage pre-paid to 1438 Bridge Street, New Cumberland, PA 17070. Service of the Complaint shall be deemed complete and valid upon posting and mailing by the Plaintiff. BY: GRENEN & BIRSIC, P.C. Krist~ne M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT "A" SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-01820 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PNC MORTGAGE CORP OF AMERICA VS BLYSTONE RONALD E ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT BLYSTONE RONALD E AKA RONALD D BLYSTONE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , , NOT FOUND , as to BLYSTONE RONALD E AKA RONALD D the within named DEFENDANT , BLYSTONE , UNABLE TO LOCATE AFTER 14 ATTEMPTS. PAPER EXPIRED. Sheriff's Costs: Docketing 18.00 Service 35.19 Not Found 5.00 Surcharge 10.00 .00 68.19 So answers': R [T~omas Kline Sheriff of Cumberland County GRENEN & BIRSIC 05/13/2002 Sworn and ~ubscribed to before me this day of A.D. Prothonotary EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., VS. Plaintiff, CIVIL DIVISION NO.: 02-1820 RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. AFFIDAVIT PURSUANT TO PA. R.C.P. 430 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Faust, Esquire, of GRENEN & BIRSIC, P.C., attorneys for Plaintiff, deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, named in the above-captioned matter: 1. On or about June 17, 2002, Plaintiff mailed to the United States Postmaster at New Cumberland, Pennsylvania 17070, a certain Request for Change of Address or Boxholder Information Needed for Service of Legal Process for Defendant. 2. On or about June 26, 2002, Plaintiff received a response from the aforementioned United States Postmaster stating that there is no change of address order on file and that mail is deliverable at 1438 Bridge Street, New Cumberland, PA17070. A true and correct copy of said response is marked Exhibit "1", attached hereto and made a part hereof. 3. A search of a nationwide computer database found a current address of 1438 Bridge Street, New Cumberland, PA 17070 for Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone. A true and correct copy of said search is marked Exhibit "2", attached hereto and made a part hereof. 5. The Defendant is listed in the Cumberland Area telephone directory. 6. A search of the Cumberland County Voter Registration records revealed that Defendant is registered to vote in Cumberland County. The record also reveals that the address of the defendant is, 1438 Bridge Street, New Cumberland, PA 17070. Finally, affidavit deposes and says that the last known address of Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, is 1438 Bridge Street, New Cumberland, PA 17070. Kristine M. Fan/st, Esquire SWORN to and subscribed before me this I'-~-dayof ~ .,2002. NOTARY PUBLIC Notarial Seal Patricia A. Townsend, NoraD' Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2003 Member, Pennsylvania Association o! Notaries Exhibit "1" Postmaster New Cumberland, PA 17070 City, State, ZIP Code Date June 17, 2002 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (ifa box holder) for the following: Name: Ronald E. Blystone a/kda Ronald D. Blystone Address: 1438 Bridge Street NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney for Plaintiff 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: PNC Vs. Blystone 4. The court in which the case has been or will be heard: Court of Common Pleas 5. The docket or other identifying number if one has been issued:02~1820 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. ,/Signature (J Carolyn Grimes Printed Name Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY ~,N.o change of address order on file. Not known at address given. Moved, left no forwarding address No such address. POSTMARK NEW ADDRESS OR BOX_HOLDER'S NAME and STREET ADDRESS Exhibit "2" Sehrch- 3 Results - 180-34-995~ DBL YSTONE, RONALD Page 1 of 2 THTS DATA TS FOR ZNFORHATZONAL PURPOSES ONLY PERSON LOCATOR - P-TRAK Name: DBLYSTONE, RONALD Also Known As: BLYSTONE, RONALD D Address: 1438 BRIDGE STREET NEW CUMBERLlqD, PA 17070 Address Updated: 8/1/2000 Previous Addresses: 312 GRAHAM STREET I{ARRISBURG, PA 17110 Address Updated: 7/19/2001 303 ELEVENTH STREET NEW CUMBERLAND, PA 17070 Address Updated: 7/19/2001 317 HERR STREET HARRISBURG, PA 17102 Address Updated: 7/19/2001 2810 FAIRVIEW ROAD CAMP HILL, PA 17011 Address Updated: 7/19/2001 Birthdate: 8/1931 On File Since: 8/1/2000 Source: My..~9~[(~e_s_ > F~o?!.~_ Bu_s_!ge~$ & As~et Loca~t0[~ > EZFIND Combined Person Locator Nationwide Terms: 180-34-9956 (Edit Search) View: Full Date/Time: Tuesday, July 2, 2002 - 11:56 AM EDT Ab0~!..~_ex!~.~Xis ?~mls an _d ~C99~!t!_° n~ ~0pyfi~)[ © 2002 LexisNexis, a division of Reed Elsevier Inc. All rights reserved. http://www~~exis~c~m/research/retrieve?-m=54368d487~47aa4b9273939~245d7a9d&-br~ws 7/2/2002 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of Complaint in Ejectment Pursuant to Special Order of Court was mailed to the following on this 1 '~'{h day of dt~l~ 2002, by first class U.S. Mail, postage pre-paid: Ronald E. Blystone aJk/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 GRENEN & BIRSIC, P.C. Kristine M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOAN, INC., CIVIL DIVISION Plaintiff, NO.: VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, TYPE OF PLEADING De~ndant. CIVIL ACTION , COMPLAINT IN EJECTMENT TO DEFENDANT You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF ~ /'O A-TToR~Y FOR PLA~F I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 9451 Corbin Avenue Northridge, CA 91324 AND THE DEFENDANT IS: 1438 Bridge Street New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS Cumberland Borough (CITY, BORO, TOWNSHIP) (WARD) ATTORNEY FOR PLAINTIFF FILED ON BEHALF OF PLAINTIFF: PNC Mortgage Corp. of America n/k/a Washington Mutual Home Loans, Inc. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Faust, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOAN, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. CIVIL DIVISION NO.: NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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. Lawyer Referral Service Cumberland County Courthouse 4~h Floor One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOAN, INC., Plaintiff, CIVIL DIVISION NO.: VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. CIVIL ACTION - COMPLAINT IN EIECTMENT PNC Mortgage Corp. of America, n/k/a Washington Mutual Home Loans, Inc., by its attorneys, Grenen & Birsic, P.C., files this Complaint in Ejectment, as follows: 1. Plaintiff is a lending institution duly authorized to conduct business in the Commonwealth of Pennsylvania with a place of business located at 9451 Corbin Avenue, Northridge, CA 91324. 2. The Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone is an individual whose last known address is 1438 Bridge Street, New Cumberland, PA 17070. 3. On or about March 6, 2002, the real property and improvements thereon commonly known as 1438 Bridge Street, New Cumberland, PA 17070(hereinafter "Premises") were sold to Plaintiff pursuant to the Sheriff's Sale in Cumberland County. A true and correct copy of the legal description of said property is marked as Exhibit "A", attached hereto and made a part hereof. 4. At the time of the Sheriff Sale, Defendant was occupying the Premises. 5. Plaintiff, by virtue of said Sheriff's Sale, is the owner of the Premises and therefore right to immediate possession and title to the Premises is in Plaintiff and not in Defendant. 6. On March 14, 2002, counsel for Plaintiff sent written notice to the Defendant to vacate the Premises on or before March 29, 2002. A true and correct copy of said Notices are marked Exhibit "B", attached hereto and made a part hereof. 7. Defendant is occupying, using and enjoying the Premises without right and to Plaintiff's knowledge without claim of title. 8. Defendant is unjustly and unlawfully obtaining possession of the Premises to the detriment of Plaintiff. WHEREFORE, Plaintiffdemands judgment against Defendant for possession of the Premises known as 1438 Bridge Street, New Cumberland, PA 17070, together with such other relief as this Honorable Court may deem necessary. BY: GRENEN & BIRSIC, P.C. Kris~ine M. F'aust,"E~ssquire PA ID. #77991 Attorneys for Plaintiff Nine West, One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT A ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of"Hillside," as recorded in the Office for the Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNING at the southwest corner of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence westwardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty (150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence northwardly along the eastern line of said sixteen (16) feet wide street twenty-five (25) feet more or less to the southern line of Fifteenth Street; thence in an eastwardly direction along the southern line of Fifteenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEiNG the northern half of Lot No. 1, Section "C" on said Plan of"Hillside." BEiNG the same premises which Patrick M. Smith and Rita Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. Blystone. GRENEN & BIRSIC, P.C. ATTORNEYS AT LAW ONE GATEWAY( CENTER NINE WEST PITTSBURGH, PA 15222 (412) 281-7650 FAX (412) 281-7657 EMAIL grenbirs~mdi.net March 14, 2002 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND FIRST CLASS MAIL, POSTAGE PREPAID Ronald E. Blystone a/k/a Ronald D. Blystone or Current Occupant 1438 Bridge Street New Cumberland, PA 17070 RE: NOTICE TO VACATE Dear Mr. Blystone or Current Occupant: As you may be aware, this firm represents PNC Mortgage Corp. of America in connection with the above-captioned matter. As you may also be aware, PNC purchased the property at a sale conducted by the Sheriff of Cumberland County on March 6, 2002. Accordingly, PNC is now the record title owner of the property. Our client has recently informed me that you remain on this property. The purpose of this letter is to notify you that you must vacate the premises on or before fifteen (15) days fi.om the date of this letter. If you fail to vacate the premises on or before that date, PNC will institute formal legal action to have you removed fi.om the premises. I trust that such will not be necessary. If you have any questions, please feel flee to contact me. Very truly yours, Kristine M. Faust 0?08-02 Og:56am From-;RENEN & BIRSIC 4122814398 T-?SR P.OZ/OZ F-408 Thc undersigned, and duly authorized representative of Plaintiff, deposes and says subject to Q~e penalties of 18 Pa. C.S.A. §4904 r~iadng to unswom falsification to authorities tha~ Q~e £acts sel forth in the foregoing Complain~ are true and correct to his information and belief. JUL ~ ~ 2002' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., NO.: 02-1820 Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. ORDER OF COURT AND NOW, to wit, this '~ ~' ' day of l~) ,2002, upon consideration of the within Motion for Special Service of the Complaint in Ej ectment Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, with a true and correct copy of Plaintiff's Complaint, by causing Cumberland County Sheriff to post the real property, being 1438 Bridge Street, New Cumberland, PA 17070, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by first class mail, postage pre-paid at 1438 Bridge Street, New Cumberland, PA 17070. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. C1VIL DIVISION ) NO.: 02-1820 ) ) ) ) ) ) ) ) ) ) ) ) ) ) PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT IN EJECTMENT TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Ejectment with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. CIVIL DIVISION ) ) NO.: 02-1820 ) ) ) ) ISSUE NO.: ) ) ) TYPE OF PLEADING: ) ) PRAEC[PE TO REINSTATE ) CIVIL ACTION - COMPLAINT ) EJECTMENT ) ) CODE- ) ) ) FILED ON BEHALF OF PLAINTIFF: ) PNC Mortgage Corp. of America n/k/a ) Washington Mutual Home Loans, Inc. ) ) ) COUNSEL OF RECORD FOR THIS ) PARTY: ) ) Kristine M. Faust, Esquire ) Pa. I.D. #77991 ) ) GRENEN & BIRSIC, P.C. ) Nine West ) One Gateway Center ) Pittsburgh, PA 15222 SHERIFF'S RETURN - REGULAR CASE NO: 2002-01820 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC MORTGAGE CORP OF AMERICA VS BLYSTONE RONALD E ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - EJECTMENT was served upon BLYSTONE RONALD E AKA RONALD D BLYSTONEthe law, DEFENDANT at 1438 BRIDGE , at 1509:00 HOURS, STREET NEW CUMBERLAND, PA 17070 POSTED PROPERTY AT 1438 BRIDGE STREET, a true and attested copy of COMPLAINT on the 12th day of August by handing to NEW CUMBERLAND - EJECTMENT 2002 together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 11.73 Posting 6.00 Surcharge 10.00 .00 45.73 Sworn and Subscribed to before me this /g~ day of /~,~ ~.~ ~b A. D. ' Prothonotary So Answers: R. Thomas Kline 08/13/2002 GRENEN & BIRSIC By: · //[~ ~'~D~~rlff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. CWIL DWISION NO.: 02-1820 TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Ejectment) FILED ON BEHALF OF PLAINTIFF: PNC Mortgage Corp. of America, n/k/a Washington Mutual Home Loans, Inc. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. CWIL DWISION NO.: 02-1820 PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the ej ectment against Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone for possession of the premises known as 1438 Bridge Street, New Cumberland, PA 17070. BY: GRENEN & BIRSIC, P.C. Kris~ne M. Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAII,ING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Sworn to and subscribed before me this c~_ I~day of ~Nr~'--cm._~ ,2002. Notary Public Nolarial Seal Patricia A. Townsend, Notary Public City of Pittsburgh, Allegheny County My Commisskm Expires June 2, 2003 Member, Per~nsvlv~nl~ Asqr~c, iation et Notanes IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., VS. Plaintiff, RONALD E. BLYSTONE A/K/A RONALD D. BLYSTONE, ) CIVIL DMSION ) ) NO.: 02-1820 ) ) ) ) ) ) ) TO: Defendant. Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 DATE OF NOTICE: October 3, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAIl.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRrrING 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 By: FIRST CLASS MA~t., POSTAGE PREPAID GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Pa. I.D. # 77991 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., CIVIL DIVISION NO.: 02-1820 Plaintiff, VS. TYPE OF PLEADING: RONALD E. BLYSTONE aYk/a RONALD D. BLYSTONE, Proof of Service Defendant, FILED ON BEHALF OF: PNC Mortgage Corp. of America, et al. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., VS. Plaintiff, RONALD E. BLYSTONE aJk/a RONALD D. BLYSTONE, Defendant. CWIL DIVISION NO.: 02-1820 PROOF OF SERVICE Kristine M. Anthou, Attomey for Plaintiff, PNC Mortgage Corp. of America, et al. being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs Complaint in this matter on Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone: 1. Pursuant to Order of Court dated July 25, 2002, service of the Complaint in Ejectment upon Defendant was deemed complete and valid upon mailing by the Plaintiff by certified mail, return receipt requested, and by first class mail, postage prepaid, addressed to 1438 Bridge Street, New Cumberland, PA 17070, and by posting of a copy of the Complaint, by Cumberland County Sheriff at the property located at 1438 Bridge Street, New Cumberland, PA 17070. A true and correct copy of said Order of Court is marked Exhibit "A", attached hereto and made a part hereof. 2. On August 20, 2002, Plaintiff mailed the Complaint in Ejectment to Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, at 1438 Bridge Street, New Cumberland, PA 17070, by certified mail, return receipt requested and by first class mail, postage prepaid. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7099 3400 0010 4165 8090 and the Certificate of Mailing, evidencing service by certified mail and first class mail on the identified Defendant, are marked Exhibit "B", attached hereto and made a part hereof. 3. On or about August 12, 2002, Cumberland County Sheriff, posted the Complaint on the property located at 1438 Bridge Street, New Cumberland, PA 17070. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. BY: GRENEN & BIRSIC, P.C. e M..~mthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS.~i~DAY OF kQ>x'r:~r-~t~2~ , 2002. Notary Public Patricia A. Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2003 Member, Pennsylvania Association ot Notaries EXHIBIT A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP. OF AMERICA n/k/a WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, NO.: 02-1820 Defendant. ORDER OF COURT AND NOW, to wit, this day of ~ ,2002, conmderat upon ' ion of the within Motion for Special Service of the Complaint in Ejectment Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, with a true and correct copy of Plaintiff's Complaint, by causing Cumberland County Sheriff to post the real property, being 1438 Bridge Street, New Cumberland, PA 17070, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by fn'st class mail, postage pre-paid at 1438 Bridge Street, New Cumberland, PA 17070. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. TRUE COPY FROM In TestSrnony whereof, i here unto set rny and the seal af said Cou~ at Carlis~, P~ BY THE COURT: EXHIBIT B 060~ ~9'~h 0'~00 00hE 660~ .CERTIFICATION OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Proof of Service was mailed by U.S. First Class Mail, postage pre-paid, on the ~ [ g~3( Day of 0 0~42)¢e~t~ , 2002, to the following: Ronald E. Blystone aJk/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 GRENEN & BIRSIC, P.C. BY: Kris[k~M. A~ou, Esquire Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., CIVIL DIVISION Plaintiff; NO.: 02-1820 VS. ISSUE NUMBER: RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. TYPE OF PLEADING: Praecipe for Writ of Possession CODE- FILED ON BEHALF OF PLAINTIFF: PNC Mortgage Corp. Of America, n/k/a Washington Mutual Home Loans, Inc.,. COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, n/k/a WASHINGTON MUTUAL HOME LOANS, INC., CIVIL DIVISION Plaintift; NO.: 02-1820 VS. RONALD E. BLYSTONE ~a RONALD D. BLYSTONE, Defendant. PRAEC1PE FOR WRIT OF POSSESSION TO:PROTHONOTARY Kindly issue a Writ of Possession in the above-captioned matter for the premises known as 1438 Bridge Street located in the borough of New Cumberland County of Cumberland, Pennsylvania and more particularly described in PlaintifFs Complaint in Ejectment filed in the instant proceeding. GRENEN & BIRSIC, P.C. BY: F.._-- -/v( C</~r:/Cc*~t. _ Krist~he M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 ~ 3165 etc.) THE SECRETARY OF v~'r~RANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEPARTM~I~T OF VETERANS AFFAIRS JEFFREY E. DIETRICK AND CAROL A. DIETRICK 555 BROWNS LANE E~OLA, PA 17025 No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3712 Civil Term Costs Term Att'y. $ 167.20 PI'fi(s) $ Prothy. $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of CLIVlBERIAND 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: THE SECRETARY OF V~2r~RANS AFFAIRS, AN OFFICER OF THE UNITED STATES OF AMERICA, THE DEP/Xa:~TMENT OF VETER/x2qS AFFAIRS Plaintiff (s) being: (Premises as follows): 555 BRC~NS LANE t~qOLA, PA 17025 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date SEPTEIqBER 23, 2002 (SEAL) CURTIS R. LONG Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania t Deputy By virtue of this writ, on the day of I caused the within named have possession of the premises described with the appurtenanccs, and WRIT OF EXECUTION RETURNED STATED AS PER ATTY WINEKA THIS DATE, PROPERTY , to IS VACANT Sheriff's Costs: Advance cn~ 150.O0 Docketing: 18.00 Sheriff's Costs 60.53 Surcharge 1.18 89.47 Prothonotary 1.00 Milage 10.35 Surcharge 30.00 60.53 Refunded to Att¥ on 10/31/02 Sworn and subscribed to before me this day of '~c~e~ Prothonotary r ~ ~qheriff WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) lINC MORTGAGE CORP. OF AMERICA, N/K/A WASHINGTON MUTUAL FffDME LOANS, INC. VS. RONALD E. BLYSTONE A/K/A NONALD D. BLYSTONE 1438 BRIDGE STREET N~I~(3L~ERLAND, ~ 17070 No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1820 CIVIL Term Costs Att'y. $ 183.42 Pl'ff (s) $ Prothy. $ ]. 00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of ~RLAND County, Pennsylvania (l) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: PNC MORTGAGE CORP. OF AMERICA, N/k/A WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff (s) being: (Premises as follows): 1438 BRIDGE STREET NEW CUIqBERLAND, PA 17070 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date NOVI~X~ER 1, 2002 (SEAL) CURTIS R. LONG Prolhonotmy, Common Pleas Court of Cumberland County, Pennsylvania Deputy By virtue of this writ, on the day of I caused the within named have possession of the premises described with the appurtenances, and RETURNED ABANDON[D, NO ACTION TAKEN IN SlX MONTHS. WRIT OF POSSESSION SHERIFF'S COSTS: Pr o Lho~crt~az27- Docketing Pou~e 1.03 Mi!fg~:i~ Sur~h,~ge 20.00 ~!::~.~ 52.45 Sworn and ~ubscribed to before me this day of~~~'/. Prothonotary Advance Costs: 150.00 Sheriff's Costs 52.45 97.55 Refunded to Atty on 9/9f¢3