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HomeMy WebLinkAbout02-3280Law Office of Federman and Phelan By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Altegra Credit Company 150 Allegheny Center Mall Pittsburgh, PA 15212 Court of Common Pleas Civil Division Cumberland County Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 terlll No. - 3oa 0 CML ACTION - E[ECTMENT - 302~ **This firm is a debt collector attemp~ng 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 Hen 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 wamed 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. Cumberland County Cumberland County Bar Assodation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 1. Plaintiff is Altegra Credit Company. 2. Defendant is Charles E. Dougherty or occupants. 3. Plaintiff is the owner of premises located at 18 Hummel Avenue, Camp Hill, PA 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of Cumberland County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). Plaintiff, by virtue of the above, is the 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 rifle. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of the same. WHEREFORE, plaintiff seeks to recover possession of said premises. NK FEDERM~aN Attorney for Plaintiff Premises: lffHUMMEL AVENUE, TOWNSHIP OF LOWER ALLEN /./CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute tide insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. D.ESCR/PTION ALL THAT CERTAIN piece or parcel of land situate in Lower Allen Township, County of Cumberland and State of Pennsylvania bounded and described as follows, to wit: BEGINNING at a point on the Northern line of Hummel Avenue. as laid down by the W. Gorgas Es~t~/, which point is two hundred eighty (280) feet West of the division line of Property No 16' ,r, .... ,, ........ Western hue of Milltown Road, at ceflter t . . -- · , u~s~c ~ortnwaroly at ri Bt all les ' the r of the partition wall of ' ~,,,~ ,,.~:~:_:__ L g.. g w~th Hummel Avenue, throu h the more or less, to a point on the th~s ,~,, ,~ujutum§ aouse aha ~eyond one hundred nineteen (llg~fect, Southern line of a public road; thence Westwardly along the Southern line of said Public Road thirty-five (35) feet, more or less, to a point on the division line of Lot No. 20; thence Southwardly along said division line one hundred nineteen (119) feet, more or less, to the Northern line of Hummel Avenue and thence Eastwardly along the Northern line of said Hummel Avenue thirty-five (35) feet to a point, the place of beginning. HAVING thereon erected a brick dwelling house, known and numbered as 18 in said Plan of Lots. Tax Map #22-0536 Parcel #36 VERIFICATION Frank Federman, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to take this Verification, pursuant to Pa. R.C.P. 1024 (c) and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unswom falsification to authorities. Date: rm~tk Federrnan, Esquire Attorney for Plaintiff 0 ~ khf~ 0 f~ 0 ~U tOR~ ~ ~ o o ~j 0 [~ o o U' k< o o FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Altegra Credit Company 150 Allegheny Center Mall Pittsburgh, PA 15212 VS. Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill; PA 17011 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No. 02-3280 Civil Action in Ejectment MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Michele M. Bradford, Esquire moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by certified mail and regular mail, and in support thereof avers as follows: 1. Plaintiff commenced this action by filing a Complaint in Ejectment. 2. Attempts to serve Defendant(s) with the Complaint have been unsuccessful. Plaintiff attempted to serve the Defendant(s) on August 13, 2002, as indicated by the Affidavit of Service attached hereto as Exhibit A. 3. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results from there are attached hereto as Exhibit B. 4. Plaintiff submits that is has made a good faith effort to locate the Defendant(s), but has been unable to do so. 5. Plaintiff verified through property inspection on August 23, 2002 that the property was occupied by an unknown person. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail and posting of the premises. Michele M. Bradford, Esquire Attorney for Plaintiff EXHIBIT "A" SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-03280 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ALTEGRA CREDIT COMPANY VS DOUGHERTY CHARLES E R. Thomas Kline , Sheriff , who being duly sworn according ,to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: DOUGHERTY CHARLES E unable to locate Him in his bailiwick. but was He therefore returns the COMPLAINT - EJECTMENT the Within named DEFENDANT NOT SERVED , as to , DOUGHERTY CHARLES E PER NEIGHBOR, ONLY HOME ON WEEKENDS AND A STRANGER IS TAKING CARE OF DOG. SOMEONE WAS THERE BUT WOULD NOT ANSWER DOOR OR PHONE. Sheriff's Costs: Docketing 18.00 Service 31.05 Affidavit .00 Surcharge 10.00 .00 59.05 So answems-.~ J ~ -~ R.' THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY FEDERMAN & PHELAN 08/13/2002 Sworn and subscribed to before me this day of A.D. Prothonotary EXHIBIT "B" SKN Data Research Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 2-3208PA Attorney Firm: Federman & Phelan Subject: Charles E. Dougherty Current Address: 18 Hummel Ave. Camp Hill, PA 17011 Property Address: 18 Hummel Ave. Camp Hill, PA 17011 Mailing Address: 18 Hummel Ave. Camp Hill, PA 17011 I Scott Nulty, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Charles E. Dougherty - 184-48-8637 B. EMPLOYMENT SEARCH Charles E. Dougherty - unknown C. INQUIRY OF CREDITORS The creditors indicate that Charles E. Dougherty reside(s) at: 18 Hummel Ave. Camp Hill, PA 17011 II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Indicated that Charles E. Dougherty reside(s) at: 18 Hummel Ave. Camp Hill, PA 17011 - 717-737-2068 III. INQUIRY OF NEIGHBORS R. Deibert 16 Hummel Ave. and he verified that Charles E. Dougherty reside(s) at: 18 Hummel Ave. Camp Hill, PA 17011 IV. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE Charles E. Dougherty - 18 Hummel Ave. Camp Hill, PA 17011 V. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE Per the PA Department of Motor Vehicle Charles E. Dougherty reside(s) at: last known address. VI. OTHER INQUIRIES A. DEATH RECORDS As of July 1, 2002 Vital Records has no death record on file for Charles E. Dougherty. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.) none C. COUNTY VOTER REGISTRATION The Cumberland County Voter registration has a registration for Charles E. Dougherty residing at: last known address. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Charles E. Dougherty -YOB 1956 B. A.K.A. none * All accessible public databases have been checked and cross-referenced for the above named individual(s). * Please be advised all database information indicates the subject resides at the current address. 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. I hereby verify that the statements made herein are true and correct to the best of my knowledge, info.nation and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIANT Scott Nulty SKN Data Research Inc. President Sworn to and subscribed before me this day of~2002 Notarial Seal Margaret E. Nu[tT, Notary Public East Goshen Twp Chester County My Commission Expires Dec. 19, 2005 Member, Pennsylvania Association Of Notaries FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff Altegra Credit Company 150 Allegheny Center Mall Pittsburgh, PA 15212 VS. Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 Court of Common Pleas Civil Division Cumberland County No. 02-3280 Civil Action in Ejectment MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Although Plaintiff has attempted to serve Defendant(s) with the Complaint, Plaintiff's attempts have been unsuccessful. A true and correct copy of the Affidavit of No Service is attached hereto, made part hereof, and marked Exhibit A. Accordingly, Plaintiff ordered an investigation into the whereabouts of Defendant(s). A true and correct copy of the Affidavit of Reasonable Investigation is attached hereto, make part hereof, and marked Exhibit B. The Affidavit reflects that Plaintiff's investigator has make at least three types of inquiries listed under Rule 403.1(B)(1). Copies of any written responses obtained are attached to the Affidavit. The Affidavit also specifies the inquiries made, responses made, and dates thereof, in accordance with Rule 430.1(B)(2). As Plaintiff's within motion and its affidavit are both in compliance with the applicable Pennsylvania and local rules, Plaintiff respecth~lly requests that its motion be granted. WHEREFORE, Plaintiff respectfully requests pe~-ii-dssion to serve the Complaint by certified mail and regular marl and posting of the premises. DATE: September 6, 2002 Respectfully submitted: Michele M. Bradford, Esquire Attorney for Plaintiff VERIFICATION Michele M. Bradford, 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 Motion for Service of the Complaint Pursuant to Special Order of Court are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made su~ect to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. DATE: September 6, 2002 Michele M. Bradford, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center @ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff Altegra Credit Company 150 Allegheny Center Mall Pittsburgh, PA 15212 VS. Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 Court of Common Pleas Civil Division Cumberland County No. 02-3280 Civil Action in Ejectment CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Motion for Service Pursuant to Special Order was served by first class mail on the Defendant (s) on the date listed below: Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 DATE: September 6, 2002 Michele M. Bradford, Esquire Attorney for Plaintiff ALTEGRA CREDIT COMPANY, Plaintiff V. CHARLES E. DOUGHERTY OR OCCUPANTS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3280 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of September, 2002, upon consideration of PlaintiWs Motion for Service Pursuant to Special Order of Court, the motion is granted to the extent that service of the complaint may be made by (1) First Class and Certified Mail to Charles E. Dougherty or occupants at 18 Hummel Avenue, Camp Hill, PA 17011, said service to be complete upon mailing, (2) Posting of the said property and (3) Publication once in a newspaper of general circulation in Cumberland County and in the Cumberland Law Journal. BY THE COURT, Michele M. Bradford, Esq. FEDERMAN AND PHELAN Suite 1400 One Penn Center ~ Suburban Station Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Federman and Phelan, LLP BY: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 JFK Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 A]tegra Credit Company Plaintiff VS. Charles E. Dougherty Or occupants Defendants Attorney for Plaintiff Court of Common Pleas Civil Division NO. 02'3280 Civil Cumberland County PRAECIPE TO REINSTATE CML ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. ~~nG;quire Attorney for Plaintiff Date: ~qop*~.,h~ %~, ~002 SHERIFF'S RETURN - CASE NO: 2002-03280 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALTEGRA CREDIT COMPANy VS DOUGHERTY CHARLES E REGULAR VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DOUGHERTY CHARLES E the DEFENDANT at 1656:0~ HOURS, at 18 HUMMEL AVENUE on the 30th day of ~eptember, 2002 CAMP HILL, PA 17011 POSTED PROPERTY AT 18 HUMMEL by handing to AVENUE CAMP HILL 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 18.00 Service 9.66 Posting 6.00 Surcharge 10.00 .00 43.66- Sworn and Subscribed to before me this ~ ~ day of ~ ~ ~32~ A.D. rothonotar~ - So Answers: R. Thomas Kline 10/01/2002 FEDERMAN & PHELAN Deputy Sherif~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE I.D. #12248 SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA. 19103 (215) 563-7000 Altegra Credit Company Charles E. Dougherty or occupants ATFORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland COUNTY :No. 02-3~0-CNfl AI~II")AVIT ~1~' ~I~'RVI~i~. VIA R'Kf'~.I ~I'.AR ~ C17RTI'l~''l~l~) 'M'AFI. I hereby certify that a true and correct copy of the Civil Action in Ejectment in the above captioned matter was sent by Regular and certified Mail, return receipt requested, to the Following person(s) f'h~rlo~ 1~ I-~n,,ghoety. ne neo,,~nt~ at 1~ Fl,,mmol Avon,,o. f'~m.n l-lill. PA 17011 on Ootnhor ~l; ~flfl~ Ltl accordance with the Order of Court dated $o?omhor 17. 9nfl~ The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unswom Falsification to authorities. Attorney for Plaintiff Date' c~rtnho~ ~, ~Nfl? Federman and Phelan By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 philadelphia, PA 19103 (215) 563-7000 Altegra Credit Company ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION VS Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 No. 02-3280 Cumberland County PR AECIPF, FOR .IIIDGMENT IN I*,.IF,,CTM1E, NT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Altegra Credit Company and against the Defendant(s) Charles E. Dougherty and or occupants for possession of premises 18 Hummel Avenue, Camp Hill, PA 17011 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of PlaintiWs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is aRached hereto. Default Judgment entered as indicated above. I?llANK FEDEI~MAN, ESQUIRE Attorney for Plaintiff DATE FEDERMAN AND PHELAN Frank Federman, Esquire Identification Number 12248 One Penn Center Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Altegra Credit Company Charles E. Dougherty Or occupants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 02-3280 TO: Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 DATE OF NOTICE: Oetoher 24. 2002 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANTNOTICE 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 (10) days from the date of this notice, a Judgment may be entered against you without a heating 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: CUMBERLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 F~nk Feaerman, gsquire Attorney for Plaintiff Federman and Phelan By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 56a-?000 Altegra Credit Company VS Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-3280 Cumberland County VF, RIFICATION OF NON-MI1 ~ITARY ~qFRVICF, FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) 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 Charles E. Dougherty Or occupants, is over 18 years of age, and resides at 18 Hummel Avenue, Camp Hill, PA 17011. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unswom falsification to authorities. IRE y for Plaintiff PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA Altegra Credit Company COUNTY OF Cumberland COURT OF COMMON PLEAS CIVIL DWISION vs Charles E. Dougherty or occupants 18 Hummel Avenue Camp Hill, PA 17011 No. 02-3280 Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession off 18 Hummel Avenue, Camp Hill, PA 17011 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 18 Hummel Avenue ATTORNEY FOR PLAINTIFF · ~cm~ses: I~HUMMEL AVENUE, TOWNSHI 'i/CUMBERLAND COUNTY P OF LOWER ALLEN PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, m/stakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Lower Allen Township, County of Cumberland and State of Pennsylvania bounded and described as fo/lows, to wit: BEGINNING at a point on the Northern line of Hu ~s~t~, Which point is two hun,~ ..... mmel Ave ue - : o~vJ~lon line of Pro ....... ,~-~u e~gnty (280) feet Weo~-~-~ ~n~. , ,~s la~d down by the W ce~iter of th .... ...v,~-y ~o. 16; thence Northwar l~, o~ [:~. me .Western line of Milltow --. ~,orgas "'"'~ laa~tltlOn wall of this and ~,~:~:--.d.:., -~gnt angles with rt.,,.~, . n Road, at the more or less, to a point on the South · . -,~j-mmg house and bev,,.,~ ^ :-~.-,mc~ ,'tvenue, through the line of said Public Road thirty ~,,~ r~ l?ne of a pubhc road; the .- ~,~,~ ,,ne hundred nineteen (119) feet, -'~-"*'~ ~.~-~,~ feet, more or les~ ~,- ~ - ri. ce Westwardly along the S 20; thence Southwardly along said division line one hundred nineteen (I 19) feet, more or less, to the ~, ~,a point on the division line of Northern line of Hummel Avenue and thence Eastwardly along the Northern line of said HUmmel Avenue thirty-five (35) feet to a point, the place of beginning. HAVING thereon erected a brick dwelling house, known and numbered as 18 in said Plan of Lots. Tax Map//22-0536 Parcel//36 . W~'T OF ?0SS£$$~0N ALTEGRA CREDIT COMPANY -- C~RLES E. DOUGHERTY OR OCCUPANTS CO.NfMO:'N%¥EALT-f~ OF P~N--N'STLVA.N-L~.: COL.'?,,%Ty OF CL-.'3,LBF_R.L.Ny,zD: Ejecn-nenr Proceedings PRC P 3[60 . 3[65 erc, L'~' T'L:-.~. COURT OF C03,C,£GN ?L.~.~.~ OF No. 02-3280 ................................ T -~."m 20_ ...... ................................ T _ .-zr~ 20_ ...... ................................ PUff s .............................. ~ .... To :he She~ o£ CUMBERLAND ................................... . .. ". il To ~,x'd..ffv ~e ~ud~- . ALTEG~ CREDIT COMPANy .......................................................................................... P!aL~ riff ~ be.L-ng-: {P:'~""~--;$¢-~ :~ fo;"c~) : 18 HUMMEL AVENUE, CAMP HILL, PA 17011 .: 2' To 3~.W_4C'.,- !':e costs ~':-.sc '--he daa: .~ &."d ie:l 32~ :"-er .ar ~n~:' Novamber __l_2a _._2_0_0_ _2 ........... [ c',,,~e<t 'he wigeon n'"."'n~'~- ...................................................... Stayed this date, Property is Vacant, As per Atty Federman ............ .......................................................................................... Advance Costs: ~50.00 Sheriff:'s Costs: .................................... ~h~i~ ~:~-~i~-¢ ...... ~---~-:~- ................... ?/_:~- ..... Pounda~ ........... ~ .... ' ..................................... ' p)%-~nGE ar y ~. O0 --- Milage 9; 66 RefumdC~ s ~¥¢h~ ......... 2~ &'g0~ ............................................. Posting 6.00 55.75