2013
10.15

( PDF )

IN THE MONTGOMERY COUNTY COURT OF COMMON PLEAS
NORRISTOWN, PENNSYLVANIA

Terance Healy :
  : #2013-29976
v. :
  :
David R. Miller :
Jennifer K. Miller :

Emergency Praecipe for Immediate Eviction / Order of Possession

1. Plaintiff respectfully requests the immediate action of this court to remove the defendant’s from his home and property and restore possession to the rightful, proper and legal owner of the home.

2. The evidence of fraud and deception in every document and activity relating to the conveyance of the property warrants immediate action.

3. There is reason to believe that the property and residence will be irreparably damaged or destroyed as: the fraudulent conveyance of the title is evident and the defendants cannot demonstrate or present any valid or correct title or deed or right to possession of the property and residence.

4. Defendants have been served with NOTICE, and the property posted, regarding trespassing on July 26, 2013.

5. Defendants have been served the Civil Complaint filed in this matter on October 3, 2013. This is confirmed by signed certified receipt from the US Post Office on October 4, 2013.

6. plaintiff has presented in the Civil Complaint the documents which demonstrate his rightful, lawful ownership of the property and residence.

WHEREAS, plaintiff respectfully requests this honorable Court issue an Ex Parte Order for Possession authorizing the Sheriff’s Department to take immediate action to remove, eject and prevent the Defendants from occupying the property and residence.

Respectfully

Terance Healy




CASE DOCUMENTS
Civil Complaint – Action in Ejectment ( PDF )

Emergency Praecipe for Immediate Eviction / Order of Possession( PDF )

Emergency Praecipe for Immediate Eviction/Order of Possession (Addendum)( PDF )

Defendant’s Preliminary Objections and Defendant’s Memorandum of Law ( PDF )

Plaintiff Responds to Defendant’s Preliminary Objections and Defendant’s Memorandum of Law
( PDF )

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