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Home My WebLink About02-4876 FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563'7000 Attorney for Plaintiff Countrywide Home Loans, Inc. 7105 Corporate Drive PIano, TX 75024 Court of Common Pleas Civil Division v. Cumberland County Term Norman R. Neidigh Or Occupants 619 North Pitt Street Carlisle, PA 17013 No.O~ - ~f7fc QiL>J/&~ eTVTT. An'l'TON R.mn'I'MRN'T' ::109.0 NO'l'mR Please be advised tbat this firm is a debt collector attempting to collect a debt. Any information received will be nsed 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. 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Countrywide Home Loans, Inc. 2. Defendant is Norman R. Neidigh and Or Occupants. 3. Plaintiff is the owner of premises located at 619 North Pitt Street, Carlisle, P A 17013, 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). 5. 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 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. ~~A.~nvcn-. F FEDER ,ESQUIRE Attorney for Plaintiff A.LL those c::ertain tract:! or tand and pr,mises sit1..L4tC', lying and being in the Borough of Carl.i31e in the County oCCumberland and Col"l:1monwealth ofPen.nsylvaru.a.. more p.a.r~icu.l4rly dc:scribed. M foUoW'a: T1tA..cr 1: On the West. by North Pitt St:r..t. on t.he North 'by land now OT" formerly of A1ber~ Kelly. on the East by Fairground Lane. and on the South by land [lOW or (Qrmerly or John W. Spangler, SAid premise=- havine- . frontage or twenty feet on Pitt St.reet. and extending back t.o Fa.1r~ound Lane a diataru::c- or 140 teet. more or 1_. TRACT 2: On the West. by Pit,t Street.; on the North by land now or formerly of Alic:e-M. Fry; on the East by Cre.k lAne; and on the South by o~er land:! now or formerly of John W. Spangler. Contnining 6 teet in Cront on Pitt. Street and extendin" at an even width 170 feet,. more or leu, to Creek Lane aCorese.id. BEING the same premi5ee which Ed'W8Zd St.ocer. by h.i:s Deed dated Apri129. 1991. und recorded in the office of the R.ecorCler oC Deeds in and. for Cwnberland County. Pennsylvania... in Deed Book -a"', Voluzne 35. Page 898. ~ant.ed and conveyed unto Thon:aas P. Tucker, Jr.. Grant.or herein. Kimbe1"ly R. Williams, of Cumberland County. Pennsylvan.ia.. joins in this Deed for the expre.s3 purpose or conveying any and all mtsre..:rt.a in said property pursuant to an unr~orded inst.a.ll.c::J.ent =ale Ilgreernenc between Thomaa P. Tucker, Jr. and K.i.mberly R. Willia:na dated June 1. 1994. AND the Sl!!l..id Grantor will wa.rrant .specially t.he property hereby conveyed. PREMISES: 619 NORTH PITT STREET ~ 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. RC.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 unsworn falsification to authorities. Date: /S/~/DC ~~~~ Fr nk Federm n, Esquire Attorney for Plaintiff 'if- (.) "/Q.. G ~ B 0 c_~, ::-') C I'..) --n ';:>--- c::> (3 Lit-:-' , .......... ~ q]i,.: -I W JJ / ~-,j C') () "0 -0 . -\ :~~ '--' ~ ~ F t--"I C) ,-" " ,. ~.. ,. '~~/ ....1 ----( /...: :)1 '-::.,.,: -J ::2 ~j.J -< SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-04876 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS NEIDIGH NORMAN R R. Thomas Kline ,Sheriff or Deputy Sheriff, who being - - - - duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT NEIDIGH NORMAN R but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT FOUND , as to the within named DEFENDANT , NEIDIGH NORMAN R PER NEIGHBOR, PROPERTY IS VACANT AND UTILITIES HAVE BEEN SHUT OFF. Sheriff's Costs: Docketing Service Not Found Surcharge So . ?~-- ,..-? - - ... ... 18.00 10.35 5.00 10.00 .00 43.35 R. Thomas Kl'ne Sheriff of Cumberland County FEDERMAN & PHELAN 11/05/2002 Sworn and subscribed to before me this if.' y- day of ~~ J V1J ;L; A.D, P~to~0~2t',li.. . ; 'q&t' - - FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Countrywide Home Loans, Inc. 7105 Corporate Drive PIano, TX 75024 Court of Common Pleas Civil Division v. Cumberland County Term Norman R. Neidigh Or Occupants 619 North Pitt Street Carlisle, PA 17013 No. 0)., _ J./ P7-b (!IO'l(~lvt t:nTTT. At:'1'TnN -w..TRt:'l'MRN'l' ~1l?1l ~n'1'Tt:-w. Please be advised that this firm is a debt collector attempting to collect a debt. Any information received 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. 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. "-.~ ~-. , rhe ,1 , .~ CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 rr:>r, 1'": cn,..}y FR;)I'~ ""E-CORD t"~ -~,t.; _, ",'J~ . ,",., . 'fii \1""\ In T(;~;bw.\j\1 WIl"~roof, I ilere ullto sot my haM 1,':;1 the seal of said Court at Canlsle, Pa. Inls Jt;, ~y t ~ ~L> ____ . ~) /MY fl-<. onotalY 1. Plaintiff is Countrywide Home Loans, Inc. 2. Defendant is Norman R. Neidigh and Or Occupants. 3. Plaintiff is the owner of premises located at 619 North Pitt Street, Carlisle, PA 17013, 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) . 5. 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 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ALL these certain 'rac," of land and pr;>"uses sitUAte, lying and beini: in the Borough of Carlisle in the Ceunty of Cumberland and eo=onwealth e( Pennsylvacia. more ;>ar"cul.4Z"ly descibed M foUew.: TRACT 1: On the We" by North PiU Strut; en the Nerth by land neW or fe.",erly of Albert KeUy; on the EAst by Fslrgreund LAne: and on the South by land "ow o. fermerly of Jehn W. Spangler. SRid premises baving e frontage of t"Wenty feet on Pitt Street. and e"",nding back to :;'llIrl:""ound LAne a diat.anc:~ or 140 feet. more or 1..... TRACT 2: On the W_ by Pitt Street; on the Nerth by laAd now or formerly of Alice.M. Fr.r. on the East by Creek lAne: and on the Seuth by o<her lands ""w or (ormerly of John W. Spongier. Centmning 6 feet In !ront on Pitt Street and enendlnli: at an lOVen width 170 (eet, more or IdS. to Creek Lane atoresaid. l:ll!:ING the same premises which Ed.....d Stoner, by his Deed dzlted Apri129. 1991. und recorded in the ocnce of the Recorder of Deecls In _d for Cumberland County, pennsylvania. In r;Jeed Book -S", Velume 35, Page 898. iTanted _d conveyed unto Thomas P. Tucker. Jr.. Grantor herein. Kimberly R. WiIlia:n:s. of Cumberland County, PennI'Ylv...u... join:> In this D.sd Cor the e:<press purpose of conveying any und all Inter~ in said property p..,-sua.nt to an unreo:orded instAllment oale ag-reement between Thomaa P. Tucker. Jr. and K)mberly R. W\Iliama dsted June 1.. 1994. AND the said Grantor will warrant. 8pecia.Uy t.ho property hereby conveyed. PREMISES: 619 NORTH PI'IT STREET , 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 unsworn falsification to authorities. Date: /O/L/IDC I '! . I .~.H~I Fr nk Federm n, Esquire Attorney for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Countrywide Home Loans, Inc. ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Norman Neidigh Defendant( s) No. 02-4876 PRAECIPE TO THE PROTHONOTARY: X Please mark the above referenced case Discontinued and Ended without prejudice. _Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: -si 1\ lo( ~M~ Francis S. Hallinan, Esquire Attorney for Plaintiff r.:;;; = cf' if> .-r, ~\J \'-) c..:> S.o:; ~~ -<. -c ~. -"' Sf. ~ f1'l~ -om '.'9 '\~~1~\ ~\ -n -.')--. ',%.9. b'" ..~,\ ~; ;;.:: {;-? o N