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