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HomeMy WebLinkAbout06-5677Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 Attorney for Plaintiff One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215)563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 Court of Common Pleas Civil Division v. Cumberland County Robert D. Stanacher Or Occupants Term 9 Dulles Drive ~yr~ ~ ~ ~~ Camp Hill, PA 17011 No. ~` - SL I l c~ c _ 51Lh'1 CIVIL ACTION -EJECTMENT *"This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property.** NOTICE 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 (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 and 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 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. 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 141697 1. Plaintiff is Aurora Loan Services, Inc. . 2. Defendant is Robert D. Stanacher Or Occupants. 3. Plaintiff is equitable owner of premises located at 9 Dulles Drive ,Camp Hill, PA 17011 , a legal description of which is attached. 4. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on September 6, 2006 . 5. Plaintiff, by virtue of the above, is the equitable owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same, WHEREFORE, plaintiff seeks to recover possession of said premises. F ancis S. Hallinan, Esquire Attorney for Plaintiff A,COR Search and Abstract Services, Inr.. One Penn Center, 1617 J. F.K. Boulevard, Suite 305 Philadelphia, Pennsylvcusia 19103 (215) 496-0900 FAX (215) 496-()9~4 RECO][t~,UWN)N,R AND I~I1rN CF,~TIFIGATIE Effective Date: 12/112003 Order Number: A$5889 Client Number: 1788671 Premises: 9 DULLES DRTVE, '1'OWNSNIP O1~ CAST PENNSI30R0 CUMBERLAND COt1NTY .PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certif9es that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. 'I'bis Certif;iutte does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mis[alcGS or omissions in a sum not to exceed Two Thousand Dollars. Ix~.scKrPTION ALL TIiAT CF.R7'A1N piece, parcel and tract of Iar~d situate in Eas[ l ennsbaro Township, (°umberlana County, Pennsylvania tttor'e particularly bounded anti described as follows, [o wit: BEGINNING at a point on the Northerly line of Dulles Urive (East) which point is 83 feet East of the Northeasterly corner of Clenwaod Drive (Fast) aiul Dulles Drive (I/ast) and at dividing; Line between Lots Nus. 18 and 19, Block "J", on the hereinal'tcr mentioned Plait of Lots; thence along said dividing lint North 29 degrees 2U minutes East 107,08 feet to a point at the Southerly line of other land now or late of Glenwood Park, lnc; thence along same South 50 degrees 34 minutes East 90.05 feeC to a point at dividing line between Luts Nns. 17 and 18, 131ack "J" on said Pian; thence along said dividing line South 39 degrees 26 minutes West 100 feet to a point on the Northerly Iine of Dulles Drive (F,a.St); thence along same North 50 degrees 34 minutes West 9.89 feet to a point; thence further along the Northerly line oti Dulles Drive in an arc having a radius of 350 feeC io the left in a Westerly direction 61.70 feet to x point, the place of beginning. BEING Lot No. l8, Block "J", in Plan No. 1 of Ridley Park, which plats is recorded in the Office of the Kecorder of reeds in and for Cumberland County, Pennsylvania, in Plan Book 11, Page 2Fi, known as Duilcs Drive (East). 'l'ax I'arcCl /f09-16-1050-237 VERIFICATION Francis S. Hallinan hereby states that he is the attorney for the Plaintiff in this eviction action and is authorized to make this verification. The statements made in the foregoing Civil Action -Ejectment are correct to the best of my knowledge, information, and belief. I was the attorney for the Plaintiff or Plaintiffs predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on the property at the sheriff s sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this property at sheriff s sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ~~ a~ ~c,~rn~ci~S~~~c~~-~ Dat Fr ncis S. Hallinan, Esquire Attorney for Plaintiff N ~ ~• ~ ~~~ ( r;~I._ `b ~ d ~ ,_ . P '.ry ..,p ~' ~~ ~ T -{~_~ 7`'` ~."~ _.a C.. _~ Q ~~ -~~-~; ~_~~" ~ 'r`: W j ~ ~ . .~' ~ `~ ~~,+ -~ .x -< AURORA LOAN SERVICES, INC., Plaintiff v. ROBERT D. STRANACHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION N0. 06-5677 Civil Term PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel for Defendant, Robert D. Stranacher, in the above-captioned case. KEEFER WOOD ALLEN & RAHAL, LLP Date : ~{~/ ~~,6 By 1 dford Dorrance I.D. No. 32147 210 Walnut Street P.O. Box'.19~3 Harrisburg, PA 17108-1963 (717) 255-8014 (Attorneys for Defendant) CERTIFICATE OF SERVICE r I hereby certify that I have this day served a copy of the foregoing document upon the person(s) and in the manner indicated below: First-Class Mail, Postage Prepaid Addressed as Follows: Francis S. Hallinan, Esquire PHELAN HALLINAN & SCHMIEG One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (Attorneys for Plaintiff) Dated: 1 b~(rj~/d6 L Bradford Dorrance .~. -~c? i~* ~ ~ ~,~; ~ ~~rn r^ © ~ , -~. y ~'<~ -> E~=% r ~ ~5 , .~~ .~- ~ .-c AURORA LOAN SERVICES, INC., Plaintiff v. ROBERT D. STANACHER OR OCCUPANTS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION N0. 06-5677 Civil Term DEFENDANT'S PRELIMINARY OBJECTIONS TO EJECTMENT COMPLAINT I. MOTION TO DISMISS BASED ON LACK OF JURISDICTION UNDER Pa. R.C.P. No. 1028(a)(1) 1. Plaintiff's complaint is filed against "Robert D. Stanacher or Occupants." As appears on the face of the record, this Court lacks jurisdiction over the person of the named defendants, who have not been properly identified and served in accordance with the Rules of Civil Procedure. II. MOTION RAISING FAILURE TO CONFORM TO LAW OR RULE OF COURT UNDER Pa. R.C.P. NO. 1028(a)(2) 1. Defendant Stranacher incorporates herein by reference paragraph 1 above. 2. Contrary to ra. R.C.P. No. lOF!?!:h!, pa.ai.ntiff has not alleged an abstract of title "from the common source of adverse titles of the parties." 3. Plaintiff impermissibly names "or Occupants" as a party defendant and incorrectly spells defendant's last name. III. MOTION TO DISMISS BASED ON INSUFFICIENT SPECIFICITY UNDER Pa. R.C.P. No. 1028(a)(3) 1. Defendant Stranacher incorporates herein by reference all paragraphs above. 2. The complaint does not specifically and correctly identify the real parties in interest including defendant Stranacher and any other occupants of the subject premises. IV. MOTION TO DISMISS BASED ON LEGAL INSUFFICIENCY OF PLEADING UNDER Pa R.C.P. No. 1028(x)(4) 1. Defendant Stranacher incorporates herein by reference all paragraphs above. 2. As appears on the face of the record, plaintiff has failed to state a cause of action upon which relief can be granted against the incorrectly named and unidentified parties who share a common source of adverse title with plaintiff. WHEREFORE, defendant, Robert D. Stranacher, requests that the complaint be dismissed with prejudice and that the Court grant such other relief as may be appropriate. Respectfully submitted, KEEFER WOOD ALLEN & RAHAL, LLP Date: `~, (/p6 By: j (( Bradford Dorrance I.D. No. 32147 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8014 (Attorneys for Defendant, Robert D. Stranacher) 2 VERIFICATION I, the undersigned, hereby verify and state that: 1. I am counsel for defendant in the foregoing matter, and I am signing this verification in accordance with Pa. R.C.P. No. 1024(c). 2. The facts, if any, contained in the foregoing pleading are true and correct to the best of my knowledge, information, and belief. 3. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: ll ( U Bradford Dorrance e ~ CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of the foregoing document upon the person(s) and in the manner indicated below: First-Class Mail, Postage Prepaid Addressed as Follows: Francis S. Hallinan, Esquire PHELAN HALLINAN & SCHMIEG One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (Attorneys for Plaintiff) Dated: t( ~ ~~ Bradford Dorrance -J •'^) (~ } i~ ., --3 'ter .~ C"J ~f 4,~° _ C~? . _. ~ PHELAN HALLINAN & SCHMIEG, LLP BY: VIVEK SRIVASTAVA, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 202331 ONE PENN CENTER AT SUBURBAN STATIdN 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 vs. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 COURT OF COMMON PLEAS : Cumberland COUNTY . CIVIL DIVISION NO. 06-5677 PLAINTIFF'S RESPONSE TO DEFENDANT'S PRELIMINARY OBJECTIONS Plaintiff, Aurora Loan Services, Inc., by its attorney, Vivek Srivastava, Esquire, hereby responds to the Preliminary Objections of Defendant, Robert D. Stanacher and or Occupants, as follows: I. Motion to Dismiss Based on Lack of Jurisdiction Under Pa.R.C.P. No. 1028(a)(1) 1. Denied. The averments contained in paragraph one (1) are denied as conclusions of law to which no response is necessary. By way of further response, in an ejectment action, Pennsylvania Rules of Civil Procedure allow for the designation of occupants to put forth on the Complaint. By way of further response, Plaintiff s Complaint has been timely and appropriately fined under the Pennsylvania Rules of Civil Procedure and under Pennsylvania Law. II. Motion Raising Failure to Conform to Law or Rule of Court Under Pa.R.C.P. No. 1028(a)(2) 1. Plaintiff incorporates herein by reference the averments of paragraphs one (1) through six (6) of its Complaint and paragraph one (1), above as if set forth herein at length. 2. Denied. The averments contained in paragraph two (2) are denied as conclusions of law to which no response is necessary. By way of further response, Plaintiff became owner of the premises located at 9 Dulles Drive, Camp Hill, PA 17011 as a result of a foreclosure judicial sale by the Sheriff of Cumberland County on September 6, 2006. 3. Denied. The averments contained in paragraph three (3) are denied as conclusions of law to which no response is necessary. By way of further response, Plaintiff's complaint is proper and timely filed pursuant to Pennsylvania Rule of Civil Procedure and under Pennsylvania Law. III. Motion to Dismiss Based on Insufficient Specificity Under Pa.R.C.P. No. 1028(a)(3) Plaintiff incorporates herein by reference the averments of paragraphs one (1) through six (6) of its Complaint and the paragraphs above as if set forth herein at length. 2. Denied. The averments contained in paragraph two (2) are denied as conclusions of taw to which no response is necessary. By way of further response, Plaintiff's Complaint in Ejectment is proper pursuant to the Pennsylvania Rules of Civil Procedure and under Pennsylvania Law. IV. Motion to Dismiss Based on Legal Insufficiency of Pleading Under Pa.R.C.P. No. 1028(a)(4) 1. Plaintiff incorporates herein by reference the averments of paragraphs one (1) through six (6) of its Complaint and the paragraphs above as if set forth herein at length. 2. Denied. The averments contained in paragraph two (2} are denied as conclusions of law to which no response is necessary. By way of further response, Plaintiff became owner of the premises located at 9 Dulles Drive, Camp Hill, PA 17011 as a result of a foreclosure judicial sale by the Sheriff of Cumberland County on September 6, 2006. By way of further response, Plaintiff is the equitable owner of the premises and is entitled to possession. By way of further response, Plaintiff is demanding possession of the premises. By way of further response, a true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit A. WHEREFORE, Plaintiff respectfully requests that the Court overrule the Preliminary Objections and direct the Defendant to file an Answer to Plaintiffs Complaint. Date: ~ ~ ~~ n~ Respectfully submitted, PHE AN HAL AN & SCHMIEG, LLP Vivek Srivas squire Attorney for Plaintiff EXHIBIT "A" Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215)563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 v. Robert D. Stanacher Or Occupants 9 Dulles Drive Camp Hill, PA 17011 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No. ~.~ ""'S'4~f~ CIVIL ACTION -EJECTMENT ev o O ~ __ -~, t: ~ ~.r.., ~.:: _ ~ -~ ~ rFl~ ~ r- ~~'' N ~ ~G ~`~ Cry-~+t i ~ ``'-t ~ ~ C~~;L~~ ""'This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a discharge in banlcruptry and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property.** NOTICE 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 (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 ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for and 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 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. If you cannot afford to hire a lawyer, this office may tte able to provide you with. information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. C[JN1B'A~D :COUNTY CUMBERLAND COUN'T'Y BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 141697 1. Plaintiff is Aurora Loan Services, Inc. . 3 ' A ~` 2. Defendant is Robert D. Stanacher Or Occupants. 3. Plaintiff is equitable owner of premises located at 9 Dulles Drive ,Camp Hill, PA 17011 , a legal description of which is attached. 4. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on September 6, 2006 . 5. Plaintiff, by virtue of the above, is the equitable owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and o far,as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the .said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. F ancis S. Hallman, Esquire Attorney for Plaintiff . .`s ~` AR~COR Search and Abstract Servzces, Inc. One Penn Center, 1617 J. F. K. Boulevard, Suite 305 Philadelphia, Penruylvunia 19103 (215} ~9b-0900 F~iX (215) 496-()9~4 _~ ? . > RiJCORD OWNER AND LIEN CERTIFICATC Effective Date: 12/1!2003 Order Number: A85889 Client Number: 1788671 Premises: 9 DULLES DI2TVE, 'i'OWNSIiIP Ula EAST PENNSF30It0 CUMBERLAND COtJNTY PI-;NNSYLVANIA Based upon the ex~minatian of evidence in the appropriate public records, Company cerNtSes that the premises endorsed hereon are subject to the liens, encumbrances at~d exceptions to title hereinafter set forth. "Phis Certificate flocs not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its xtegligence, mistakes ar amissigns in a sum not to exceed Two Thousand Dollars. DES~xr~rloly ALL THAT GER7'AiN piece, parcel and, tract of land~~tuate in East I'ennsboro Township, t:umberland County, Nennsylvania rt~ore particularly bbundetl and descrihcd as follow, [o wit: BEGINNING at a paint on the Northerly line of Dulles Urive (East) which point is 83 feet East of the Narthcasterly corner of Glcnwaod Drive (F.a.~t) and Dulles Drive ,(Lust) and at dividing line between Lots Nos- 18 and 19, 131oek "J", nn the hereinat'icr mentioned Plan of Lats; thence along said dividing line North 29 degrees 2U minutes East 107.0$ feet w a point at the Southerly line of other land now or late of Glenwood Park, Inc; thence along same South 30 degrees 34 minutes Fast 90.03. feet to a paint at dividing line between Lots Nos. 17 and 18, Ric~ck "J" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 1(30 feet. to a paint ott tha Northerly line of 17u11es Drive (East); thence along same Narth 50 degrees 34 minutes West y.$9 feet to a point; thence further along the Northerly line of Dulles Drive in an arc having a riYdius of 330 feet to tl~e left in a Westerly direction 61.70 feet to a paint, the place of beginning. 13EiNG Lc~t No. I8, Black "J", in Plan No. 1 of Ridley Park, which pla>a is recorded in kl~c Office of the Recorder of L3edd.4 in and for Gumbcrland County,' Pennsylvania, in P1An l3aak 11, Fage 26, known as Duties Drive (East}, Tax Parcel lf09-16-1 U50-237 ;;, `:_ VERIFICATION Francis S. Hallinan hereby states that he is the attorney for the Plaintiff in this eviction action and is authorized to make this verification. The statements made in the foregoing Civil Action -Ejectment are correct to the best of my knowledge, information, and belief. I was the attorney for the Plaintiff or Plaintiffs predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on-the property at the sheriffs sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this properly at sheriffs sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 _ ~ %.: 4.. relating to unsworn fatsification to authorities. a~ o~ _ "S~/G.~c~ Dat Fr .Weis S. Hallinan, Esquire attorney for Plaintiff +>' _ - . ~: _- RECEIPT FOR PAYMENT Cumberland Countyy Prothonotary's Office Receipt Date 9/28/2006 Carlisle, Pa 17013 Receipt Time 10:52:03 Receipt No. 183559 AUROA LOAN SERVICES INC (VS) STANACHER ROBERT D Case Number 2006-05677 Received of PD PHELAN HALLINAN SCHMIEG IM Total Non-Cash..... + 55.50 Check# 538769 Total Cash......... + .00 Change ............. - .00 Receipt total...... = 55.50 Distribution Of Payment Transaction Description Payment Amount COMPLAINT 35.00 CUMBERLAND CO GENERAL FUND TAX ON CMPLT .50 BUREAU OF RECEIPTS AND CONTROL SETTLEMENT 5.00 CUMBERLAND CO GENERAL FUND AUTOMATION 5.00 CUMBERLAND CO AUTOMATION FUND JCP FEE 10.00 BUREAU OF RECEIPTS AND CONTROL 55.50 VERIFICATION Vivek Srivastava, Esquire, hereby states that she is the attorney for the Plaintiff in this action, that she is authorized to make this Verification, and that the statements made in the foregoing Response to Preliminary Objections are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. PHE DATE: ~ ~° By: & SCHMIEG, LLP Vivek Srivastava, Esquire Attorney for Plaintiff One Penn Center at Suburban Station 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103-1814 (21 S) 563-7000 ~-.' ~;~ ~ ~,, ~~, m ~' -> -~ _ ,_~ ` j ' 7 C.~ ~ "- ti .. r-a .,~ ~ -< PHELAN HALLINAN & SCHMIEG, LLP BY: VIVEK SRIVASTAVA, ESQUIRE IDENTIFICATION NO. 202331 ONE PENN CENTER AT SUBURBAN STATION 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 vs. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS Cumberland COUNTY CIVIL DIVISION NO. 06-5677 CERTIFICATE OF SERVICE I hereby certify that a copy of the Plaintiffs Response to Preliminary Objections, Praecipe, and attached documents were served upon counsel for the Defendant by first class mail, postage prepaid, at the address and on the date listed helnw~ Bradford Dorrance, Esquire 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 DATE: rya ~-t { ~ r3" C.-. -n -_ %"'~ ilk f '~ ~ ~ / ' ~ ~~G q.,~ PRAECIl'E FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. --------------------------------------------------------------------------------------------------------------------- Aurora Loan Services, Inc. COURT OF COMMON PLEAS 601 5th Avenue Cumberland COUNTY Scottsbluff, NE 69361 CIVIL DIVISION vs. NO. 06-5677 Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 1. State matter to be argued (i.e., plaintiff s motion for new trial, defendant's demurrer to complaint, etc.): Defendant's Preliminary Objections 2. Identify counsel who will argue case: (a) for plaintiff: Joseph Schalk, Esquire Address: Phelan Hallinan & Schmieg, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (b) for defendant: Bradford Dorrance Address: Keefer Wood Allen & Rahal, LLP 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 3. I will notify all parties in writing within two days that this case has b n li ed for argument. 4. Argument Court Date: January 24, 2006 Date: i ~ ly ~ ~ Attorney or Plaintiff ~ ~ ~~ ,~ V~ {- F ~ ~~ ~~ ~ PHELAN HALLINAN & ~~CHMIEG, LLP BY: VIVEK SRIVASTA~'A, ESQUIRE IDENTIFICATION NO. 2()2331 ONE PENN CENTER AT SUBURBAN STATION 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 vs. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 ORDER ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS Cumberland COUNTY CIVIL DIVISION NO. Ob-5677 AND NOW, this (o N,, day of 1~eG . , 2006, upon consideration of the Preliminary1 Objections of Defend-aFnt,~iobert D. 1Stanac~hleror Occupants, and and pw'.;~~t~o zn ?~rc~~cJ't oT Cocaasct on tN~ d~ ~aral~r ~w,~~ Plaintiffs Response thereto, it is hereby ? ~ ~ n ORDERED and DECREED that the Preliminary Objections are overruled. Defendant has a pf~riod of twenty (20) days from the date of this Order within which to file an Answer to the Corr~plaint. BY THE COURT: •- ?u ~..._ ~~-.. ~~ F< ~~ ~~ ~-0 ~ ~ ~- a ~_ ~, ;~~.e~ ,~ , ~, ~ z _ ~:: _~y~ ~..~ ~ ~_~ ~ ~.~ ~.: -.~ 28 Aurora Loan Services, Inc. IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. Robert D. Stanacher NO. 06-5677 CIVIL TERM ORDER OF COURT AND NOW, December 7, 2006, by agreement of counsel, the above-captioned matter is continued from the December 6, 2006 Argument Court list. Counsel is directed to relist the case when ready. Joseph Schalk, Esquire For the Plaintiff Bradford Dorrance, Esquire 1~ ~ ~ ~ ~ For the Defendant ` Court Administrator By the Edgar B. Bayley, . kam a 1 ~~r.,V" ~ fi !~ }7 ~~it: ~u ~. ~ i~~t.i 1~ f DVS .'..'`t`F '~~ ~`.1 1 i~(1.~~ ~~,., ~ ~ -a PHELAN HALLINAN & SCHMIEG, LLP BY: VIVEK SRIVASTAVA, ESQUIRE IDENTIFICATION N0.202331 ONE PENN CENTER AT SUBURBAN STATION 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NF 69361 VS. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 I hereby certify that a copy of the Order of December 6, 2006 overruling the Preliminary Objections was served upon counsel for the Defendant by first class mail, postage prepaid, at the address and on the date listed below: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS Cumberland COUNTY CIVIL DIVISION NO.06-5677 Bradford Dorrance, Esquire 210 Walnut Street P.O. Bax 11963 Harrisburg, PA 17108-1963 DATE: l (~ ~P PHELA HA LINAN Vivek Srivastava, Esqu Attorney for Plaintiff LLP ~x j t •'' ~~~, a 1. / J ~ ~~ AURORA LOAN SERVICES, INC., Plaintiff v. ROBERT D. STANACHER OR OCCUPANTS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION N0. 06-5677 Civil Term NOTICE TO PLEAD T0: Plaintiff, Aurora Loan Services, Inc. and its attorney, Francis S. Hallinan You are hereby notified to file a written response to Defendant's enclosed new matter within 20 days from service hereof or a judgment may be entered against you. Respectfully submitted, KEEFER WOOD ALLEN & RAHAL, LLP Dated: 2- Z~ (~~ By: 1 ;~5 Bradford Dorrance I.D. No. 32147 210 Walnut Street P. 0. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8014 ATTORNEYS FOR DEFENDANT AURORA LOAN SERVICES, INC., Plaintiff v. ROBERT D. STANACHER OR OCCUPANTS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 06-5677 Civil Term ANSWER WITH NEW MATTER 1. Admitted on information and belief. 2. Admitted. 3-4. Admitted. 5-6. Admitted in part; denied in part. Plaintiff's and defendant's respective counsel are negotiating for defendant and certain occupant(s) to remain in possession on a short-term basis. WHEREFORE, defendant requests that the complaint be dismissed with prejudice. NEW MATTER 7. Plaintiff has failed to state a cause of action upon which relief can be granted against the incorrectly named and unidentified parties who share a common source of adverse title with plaintiff. V~IIiEREFORE, defendant requests that the complaint be dismissed with prejudice. Defendant requests such other relief as the Court may deem appropriate. Respectfully submitted, KEEFER WOOD ALLEN & RAHAL, LLP Date : ) ~2 r'Z- ! 0 6 BY : ~,~-~ ( Bradford Dorrance I.D. No. 32147 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8014 (Attorneys for Defendant, Robert D. Stranacher) 2 VERIFICATION I, the undersigned, hereby verify and state that: 1. I am counsel for defendant in the foregoing matter, and I am signing this verification in accordance with Pa. R.C.P. No. 1024(c). 2. The facts, if any, contained in the foregoing answer with new matter are true and correct to the best of my knowledge, information, and belief. 3. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: /Z,,1 "Z~ ~a6 'l/ ~ Bradford Dorrance CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of the foregoing document upon the person(s) and in the manner indicated below: First-Class Dail Postage Pret~aid Addressed as Follows: Francis S. Hallinan, Esquire PHELAN HALLINAN & SCHMIEG One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (Attorneys for Plaintiff) Dated: )- Zl O~ Bradford Dorrance ~~ ~=~ c - ~ ~-. r--= :=r -_- c~ r~a -- `' - - ;' ; ~~ •- =~ `" C, =Wc: ._ SHERIFF'S RETURN - REGULAR CASE NO: 2006-05677 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AURORA LOAN SERVICES INC VS STANACHER ROBERT D SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon STANACHER ROBERT D the DEFENDANT at 1150:00 HOURS, on the 4th day of October 2006 at 9 DULLES DRIVE CAMP HILL, PA 17011 by handing to ROBERT STANACHER 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: So Answers: Docketing 18.00 S e rv i c e 13.2 0 ~ ~' = a_,,,~ _.f ~'/o'~~ Affidavit . 00 _,/ Surcharge 10.00 R. Thomas Kline ~~ 41.20 / 10/06/2006 PHELAN HALLINAN SCHMIEG ,~rlCd/OL" Sworn and Subscibed to By: ~~ IC before me this day Deputy eriff of A.D. ., PHELAN HALLINAN &SCHMIEG, LLP `BY: Sheetal R. Shah-Jani, Esquire Identification No.: 81760 One Penn Center at Suburban Station Suite 1400 1617 J.F.K. Blvd. Philadelphia, PA 19103-1814 (215)563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 Plaintiff vs. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No.: 06-5677 -Civil Term PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER Plaintiff hereby incorporates by reference paragraphs one (1) through six (6) of its Complaint as if set forth herein at length. 7. Denied. The averments of paragraph seven (7) contain conclusions of law to which no answer is warranted. By way of further response, Plaintiff is the current titled owner of the property located at 9 Dulles Drive, Camp Hill, PA 17011 by virtue of the Sheriff's Sale held on September 6, 2006 and the subsequent Sheriff's Deed recorded on September 21, 2006. WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant as requested in Plaintiff s Complaint. Respectfully submitted, PHELAN HALLINAN &SCHMIEG, LLP y Date: January 9, 2007 Sheetal R. Shah-Jani, Es Attorney for Plaintiff J ~. VERIFICATION Sheetal R. Shah-Jani, Esquire, hereby states that she is the attorney for the Plaintiff in this action, that she is authorized to make this verification, and that the statements made in the foregoing Reply to New Matter are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. PHELAN HALLINAN & SCHMIEG, LLP .. , Date: January 9, 2007 Sheetal R. Shah-Jani, I Attorney for Plaintiff One Penn Center at Su Suite 1400 ~'" 1617 J.F.K. Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 PHELAN HALLINAN & SCHMIEG, LLP BY: Sheetal R. Shah-Jani, Esquire Identification No.: 81760 One Penn Center at Suburban Station Suite 1400 1617 J.F.K. Blvd. Philadelphia, PA 19103-1814 (215)563-7000 Aurora Loan Services, Inc. 601 5~' Avenue Scottsbluff, NE 69361 Plaintiff vs. Robert D. Stanacher or Occupants 9 Dulles Drive Camp Hill, PA 17011 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No.: 06-5677 -Civil Term CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiffs Reply to Defendant's New Matter was sent via first class mail to the person listed below on the date indicated: Bradford Dorrance, Esquire Keefer Wood Allen & Rahal, LLP 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-8000 Date: Januarv 9 2007 Sheetal R. Shah-Jani Attorney for Plaintiff s--~ Q t'n ~ -rt J j i/ E"`~ [`~ t ~ ~ ~{? f s .y- ^~ , r i _~r~~ ~4 ;i ~~-~f~i '--i -~ Phelan, Hallman and Schmieg, LLP By: Francis S. Hallman, Esquire Identification No. 62695 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF Aurora Loan Services, Inc. . vs Robert D. Stanacher Or occupants . 9 Dulles Drive Camp Hill, PA 17011 TO THE PROTHONOTARY: COURT OF COMMON PLEAS CIVIL DIVISION No. 06-5677 Civil Term Cumberland County Kindly enter Judgment in Ejectment in favor of the Plaintiff, Aurora Loan Services, Inc. and against the Defendant(s) Robert D. Stanacher and Or occupants for possession of premises 9 Dulles Drive, Camp Hill, PA 17011 pursuant to the attached fully executed Consent Judgment dated February 27, 2007. S~ Francis 5. Hallman, Esquire Attorney for Plaintiff Default Judgment entered as indicated above. DATE t PHELAN HALLINAN & SCHMIEG, LLP BY: Jenine R. Davey, Esquire IDENTIFICATION NO.: 87077 One Penn Center at Suburban Station Suite 1400 1617 J.F.K. Blvd. Philadelphia, PA 19103-1814 (21 S) 563-7000 Aurora Loan Services, Inc. 601 5th Avenue Scottsbluff, NE 69361 vs. Robert D. Stanacher Or Occupants 9 Dulles Drive Camp Hill, PA 17011 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No. 06-5677 CIVIL TERM AND NOW, This ~ day of ~• , 2007 it is hereby agreed by and between Aurora Loan Services, Inc. (hereinafter "Plaintiff'), by and through its counsel, Jenine R. Davey, Esquire, and Robert D. Stanacher (hereinafter "Occupant"}, by and through his counsel, Bradford Dorrance, Esquire as follows: WHEREAS, Plaintiff is the real owner of the property located at 9 Dulles Drive, Camp Hill, PA 17011 (hereinafter referred to as Premises"), by Sheriff s Sale in Cumberland County on September 6, 2006; WHEREAS, Plaintiff filed a ejectment complaint (hereinafter the "Complaint") against the Occupant on or about September 27, 2006 for possession of the premises; WHEREAS, Robert D. Stanacher is the Defendant/Occupant of the subject premises; WHEREAS, DefendantlOccupant filed Answer to Plaintiff s Complaint on December 21, 2006; WHEREAS, the parties to this Stipulation for Judgment are desirous of resolving the issues raised in the Complaint. AND NOW THEREFORE, each in consideration of the promises to the other, to be legally bound thereby, Plaintiff and Defendant/Occupant agree as follows: 1. That judgment is hereby entered for Plaintiff and against Defendant/Occupant for possession of the Premises. 2. Defendant/Occupant shall peacefully vacate the Premises no later than March 1, 2007. 3. Plaintiff may immediately move forward and file the Stipulation for Judgment and obtain the first available lockout date after March 1, 2007. 4. No further stays and defenses will be filed by the Defendant/Occupant. 5. Any future Bankruptcy filings by Defendant/Occupant shall not apply to Plaintiff s ejectment action, and Defendant/Occupant will stipulate to grant Plaintiffrelief from the Bankruptcy automatic stay upon Plaintiff s request. 6. Defendant hereby releases and forever discharges Plaintiff, its successors and assigns, predecessors, servicers, agents, employees, officers, directors, representatives, and attorneys from any and all claims, demands, damages, or liabilities whether now known or unknown arising out of or in any way connected to Plaintiffs Complaint in Ejectment. f `~ ` 7. The foregoing represents the true and complete agreement between the parties any amended or extension thereof shall not be valid, unless in writing, signed by all signatories to this agreement. 8. This Stipulation maw executed on Counterpart. Date: ~ Je R. avey, Esquire Att ey for Plaintiff Date: Z ~-3 ~ ~- radford Dorrance, Esquire Attorney for Defendant; Robert D. Stanacher _, Phelan, Hallinan and Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Aurora Loan Services, Inc. vs Robert D. Stanacher Or occupants 9 Dulles Drive Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 06-5677 Civil Term Cumberland County Francis S. Hallinan, Esquire, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knov~ledge of the following facts, to wit: (a) That the defendants} is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant Robert D. Stanacher Or occupants, is over 18 years of age, and resides at 9 Dulles Drive, Camp Hill, PA 17011. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. Jc-!~ ~ f F ancis S. Hallinan, E's`quire Attorney for Plaintiff ~- ~~ A C d ~~ --~ ~^ ~`~-- •o c -~ r-> : _7 ~~ -:~.. t ,'z ~t-~ -'t w 1 ~=-~ PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland Aurora Loan Services, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs Robert D. Stanacher Or occupants 9 Dulles Drive Camp Hill, PA 17011 No. 06-5677 Civil Term Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE FROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 9 Dulles Drive, Camp Hill, PA 17011 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 9 Dulles Drive F ncis S. Hallinan, Esquire ATTORNEY FOR PLAINTIFF ~ll, T_ ~'~ Q .~ o ..p `SJ .~ c ~ ~ ~ ~ u Q _. ~,9 ` ~ Q C n 1 w ~ n "~. r-.> C'? f- .a ~~,~ ~" ~ -rrt ~i... ;- 0" ~ .-~ -~-~. r-~~t _.. ~;.~, ~ ~, ~~~ ~..7 ~-,~ w.~-- ,',... ~6~ l1 • ~ _,~. _ _' ~~ ~ • ,~ WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) 4 AURORA LOAN SERVICES , INC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-5677- CIVIL Term No. Term vs. ROBERT D. STANACHER OR OCCUPANTS Costs Atty. ~ $ 120.70 Pl'ff (s) $ Prothy. $ ~ _ no 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: AURORA LOAN SERVICES, INC. being: (Premises as follows): 9 DULLES DRIVE, CAMP HILL, PA 17011 Plaintiff (s) (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. notary, C Co of Cumberland County, Pennsylvania Date March 7, 2007 (SEAL) BY= Deputy a. ~ \ C] ~.O ~r ~ xr o 'G r ~ ~ CD ~ d ~ ~ 9 C ~ ~, ~ b `~ ,~ ~. a' p~-- ~' ~ r ~, ~, a. d b ~ co O_ ,~ ~ ~ ~ -n `.~ O ~ ~ s~ ~ i ~- o 0 0 ~ ~z r~ H o~ ~ y ~ O ~ ~ ~ 7d ny y ~ d c y 00 0 ~ ~ zn ~ ~ H 0 W ~ ~ o n ~ -~- b yo a zz ~z H ~~ r~ c~ ~~ zo By virtue of this writ, on the day of I caused the within named have possession of the premises described with the appurtenances, and 0 0 to Sworn and subscribed to before me'this day of ~ , Prothonotary So Answers, Sheriff By Deputy O o~ v I C') H H r .~~?f1CO~t Search cind Abstract Serv~res, Itac. One Penn Center, 1617 J. F.K. Poulevard, Suite 305 Phidc~delphia, Pertnsytvania 19103 (21 S) 49fi-0900 F~1 X (21 S) 49b-U9U4 K1~;C0~ OWNLR AND I~IH:N C_+RTIFICATF Cffec:tive Date: 12/1/2003 Order Number: ASS88y Client Number: 1788671 Premises: 9 DUI.LES DRTVE, '1'OWNSI-TIP Ul~ CAST PENNSBOR{) CUMBERLAND COIIIVTY .P1~fNSYLVANIA Based upan the examination of evidence in the appropriate public records, C:ampany certiiics that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. 'Phis Certificate dots not constitute title insurat~ee; liability hereunder is assumed rry the Company solely in tits capacity as an abstractor fcrr il.s 1.~egligenc:e, mistakes or omissions in a sum not to exceed Two Thousand Dollars. ~~s~KrPTION ALL THAT GFR'1'AIN piece, parcel and tract of land situate in Eas[ PciYnstroro Township, (:umberland County, Nennsy[vania Ytlore particularly bounded and descril~cd as follows, to wit; BCGINNING at a paint on the Northerly line of Dulles Drive (East} which point is 83 feet ~;ast of the Narthcasterly corner of Glenwood Drive (Fn~st) and. Dulles Drive (Cast) dnd at dividing line between Lots Nus. 1K and 19, I31uek "J", an the hereinal'tcr mentionetl Pian of l..ots; thence along Said dividing line North 29 degrees 2U minutes East 107.08 feet to a point at the Southerly line of other land ncrw err late of Glenwood Park, Inc; thence along carne South 50 degrees 34 minutes East 90.05 feet to a point at dividing Line between Lots Nas. l7 aad 18, Block "J" ern said Plan; thence along said dividing line 5outlz 39 degrees 26 minutes Vest 100 feet to a point on tl~e Northerly line of Dulles Drive (Fast); thence along same North 50 degrees 34 minutes West 9. $9 feet to a point; thence further along the Northerly line of Dulles Drive in an arc having a radius of 350 feeC io the left in a Westerly direction b1.7Q feet to a point, the place of beginning. BE1NG Lot Na. 18, Black "J", in Pla» No. 1 of Ridl+ry Park, wluc:h plan is recorded in the Office of the Recorder of i)eeds in and for Gun~krcrland County, Pennsylvania, in Plan Soak 1I, Page 26, known as 1)ullcs Drive (East). Tax Marcel ld09-16-1 U50-237 ~~: , ~ r PHELAN HALLINAN £~ SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. I.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 AURORA LOAN SERVICES, INC. vs. Plaintiff ROBERT D. STANCHER OR OCCUPANTS Defendant(s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 06-5677-CIVIL TERM PRAECIPE TO LVITHDRAW COMPLAINT, SATISFY JUDGMENT AND DISCONTINUE AND END ACTION. WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, satisfy the judgment and mark this case discontinued and ended, upon payment of your costs only. ~ ~~~~ o ~ Date Francis S. Hallinan Attorney for Plaintiff PHS # 141697 ~ .- -~ ~ =~ ~, ,~ ~ ~' .. '"~ '`t~o fT ~ ~~ ~ p WRIT OF POSSESSION (Ejectment Proceedings PROP 3160 - 3165 etc.) AURORA LOAN SERVICES, INC 1 IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA vs. ROBERT D. STANACHER OR OCCUPANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: No. 06-5677- CIVIL Term No. Term Costs Atty. ~ $ i2o.7o PI'ff (s) $ Prothy. $ i n~ 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: AURORA LOAN SERVICES, INC. Plaintiff (s) being: (Premises aS follows): 9 DULLES DRIVE, CAMP HILL, PA 17011 .~.. ~. `"- R1 TRUE. ~r .: ~..,a+d-n~. (2) To satisfy the costs against the defendant (s) you aze directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. C ~ of Cumberland County, Pennsylvania Dace March 7, 2007 By. ~s>~at.I Deputy ~. ~,~t,' ~ ~~ d ro~ ~ xr ~_ rd M .~j 3 ~~ a~ r o ~' N a v 0 0 -, ~v fy, ~» b ro ~ ~ o ~ .-. ~ `~ ~ ~ n 0 b9 fi4 b9 ffl 0 :~' C ~~ ~~ ;b O W ~ ro o~ O a ~~ o, ~ ~ ~z By virtue of this writ, on the day of I caused the within named have possession of the premises described with the appurtenances, and 0 H d x lTl 7d 0 0 n n b z H o~ r c n t:f H z -....~ ;_~ ~_ ~~ cr _. `N~ •: L~J _,'_ ^J Q ~H rn yo zc dH n0 y0 z~ zz ~b ,~ r <~ a~ ~~ ~_~ . ~.~~' -- -`~, ---: z z 0 0 O rn i H C H r to Writ of Possession Returned Stayed 3/28/07 per Att Sheriff's Return• Advance Costs: 150.00 Sheriff's Costs: 55.45 • 94.55 Poundage 1.09 Prothy 1.00 o Att on 3/28/07 Surcharge 20.00 5 5.4 5 / ~. to vle ~ ~--L_._ Sworn and subscribed to before me this day of ~ , So Answers, ,~' S~e~r~ff _ ~ ~ n '~ ~ ~! Rv d~