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HomeMy WebLinkAbout02-4774THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen J. DiPaolo, Esquire / I.D. No. 79992 425 Commerce Drive, Suite 100 Fert Washingten, PA 19034 (215) 653--7450 Attorneys fer Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIAT ION, Plaintiff, SCOTT R. KUHN and OCCUPANTS OF 708 Cock]in Street, Hechanl0sburg, PA 17055 Defendants. COURT OF COMHON PLEAS CUMBERLAND COUNTY - CIVIL ACTION EJEC~4ENT NOTICE NOTICIA CIVIL ACTION -- EJECTMENT 1. The Plaintiff, Federal National Mortgage Association, is a corporstion authorized to do business within the Commonwealth of Pennsylvania, having its principal place of business at 1900 Market Street, Suite 800, Philadelphia, PA 19103. 2. (a) The Defendant, Plaintiff believes and therefore avers is add~ess, %hat being 708 Cecklin Street, Scott R. Kuhn, is an individual whom residing at the property Mechanicsburg, PA 17055, hereinafter referred to as the "Premises". {b) The Defendant, Scott R. Kuhn, is an individual whom Plaintifl believes and therefore avers is residing at the Premises. (c) The Defendant (Unknown) Occupant(s) is/are lndividu.~-s whom Plaintiff believes and therefore avers are residing at the Premises. hereto and Cumber 1 and after du6 of a Writ Court The Premises which are described at Exhibit "A" attached incorporated herein by reference, were sold at the County Sheriff's Sale conducted en September 4,2002, advertisement and according te law, under and by virtue of Execution issued te satisfy a Judgment entered in the Common Pleas for Cumberland County at the suit ef Washinqton Mutual Home Leans, Inc. v. Scott R. Kuhn, as Court Docket Number 02-655-Civil. 4. The Premises were purchased by the Plaintiff at the Sheriff's Sale, said sale results being a matter of public record. The Assignment ©f Bid frem the foreclesing mortgagee in faver ef ~his Piai~tiff was filed with the Sheriff's Department. 5. The Plaintiff acquired title te the Premises en the date of and ky virtue ef said Sheriff's Sale, and is the real and current entitled owner ef said Premises by virtue efa Cumberland Ceunty Sheriff's Deed Poll, to be recerded in the Cumberland County Recorder of Deeds' Office at the earliest possible date. 6. ?he persens in pessession of the Premises are believed te be the 86 fendant (s) in this actien and are occupying the Premises witheut right and witheut claim te title. 7. The Defendants herein ~lamed were duly served witk~ Netices ef ~he Sheriff's Sale held on September 4,2002. 8. Plaintiff has demanded possessien e~ the Premises £rem the Defendant{s) who have refused te deliver up the pessession tNereof. WHEREFORE, the Plaintiff, Federal National Mortgage Association, respectfully requests entry ef judgment for immediate possession of the Premises, issuance efa Writ ef Possession and a judgment of its costs and disbursements in this action. Respectfully Submitted, THE LAW OFFICES OF BARBARA A. BY: Barbara A. Fein, Attorney for Attorney I.D. FEIN, P.C. Esquire Plaintiff No. 53002 DESCRIPTION ' ~ ALL THAT CERTAIN piece or parcel of l~nd situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded ~nd described as follows: BEOINNING at a point on the Southern line of Cocklin Street, said point being at the dividing line between Lot Nos. 97 and 98 on the hereinafter mintinned Plan of Lots; thence continuing along the southern line of Cocklin Stxeet on a curve to the fight having a radius of 175 feet, an arc length of 112.30 feet to a point; thence along the same South 70 degrees 28 minutes East, two and eighteen hundredths (2.18) feet to a point; thence along the same ou a curve to the left having a radius of 225 feet an arc length of 164.28 feet to a point; thence along the same North 67 degrees 42 mir~utes east, five and ninety hundredths (5.90) feet to a point; thence along the same on a curve to the fight having a radius of 17 feet, an arc length of 26.45 feet to a point on the Western line of Allendale Road; thence continuing along the W~stem line of Allendale Road south 23 degrees 10 minutes East ten arid ninety-six hundredths (10.96) feet to a point; thence along the line of land now or formerly of Shelly south 65 degrees 24 minutes West, two h, nttred seventy-six and sixty hundredths (276.50) feet to a point at the dividhtg line between Lot Nos. 97 and 98 on said plan; thence along said dividing line North 22 degrees 09 minutes West, one buuclrad forty-one and fifty-four hundredths (141.54) feet to a point on the Southern line of Cocklin Street, the place of Begiunlug. BI~NG Lot No. 97 on Plan No. 5, Plot 'B" of Heritage Ac~es, said plan being recorded in the Cumberland Couaty Recorder's Office in Plan Book 22, Page 184. HAVING thereon erected a single brick and aluminum ranch-type dwelling with one-car garage, known and numbered as 708 Cockliu Street. Tax Parcel #17-24-.0789-199 VERIFICATION BARBARA A. FEIN, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Affidavit, and that the statements made in the fo~egoinq Civil Action Complaint in Ejectment are true and correct to the best ef her knowledge, information and belief. TNe undersigned understands that this statement herein is made subjec~ to the penalties ef 18 Pa. C.S.A. Section 4904 relating to unsworn ~!alsification to authorities. Dated: September 30, 2002 THE L~W OFFICES OF BARBARA A. FEIN, B Y: B~ ~ P .Co SHERIFF'S RETURN - REGULAR CASE NO: 2002-04774 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSO VS KUHN SCOTT R 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 KUHN SCOTT R the DEFENDANT , at 1550:00 HOURS, at 708 COCKLIN STREET MECHANICSBURG, PA 17055 SCOTT R KUHN on the 3rd day of October 2002 by handing to 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 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this ~ day of ~C~-- ~2 ~z~ J_ A.D. honorary So Answers: R. Thomas Kline 10/04/2002 BARBARA FEIN Deputy She~iff~'~ THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen J. DiPaolo, Esquire / I.D. No. 79992 Suite 100, 425 Cormmerce Drive Fort Washington, PA 19034 (215) 653-7450 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, SCOTT R. KUHN and OCCUPANTS OF 708 Cocklin Street Mechanicsburg, PA 17055, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 02-4774 PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark the above referenced matter settled, discontinued and ended without prejudice to Plaintiff. Dated: December 16, 2002 THE LAW OFFICES (DF BARBARA ~IN, Barbara A. Fein, Esqu~[e Attorney for Plainti~[~[ Attorney I.D. No. 530~2 P.e.