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Home My WebLink About01-5670FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD HORSHAM, PA 19044 BARRY E. ZOOK OR OCCUPANTS 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET ENOLA, PA 17025 Court of Common Pleas Civil Division CUMBERLAND County Term No. o, - .r vo CIVH, ACTION - E.IECTMENT - 3020 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 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 mtief 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 Premises: 601 HUNTINGTON AVENUE, A/MA 25 HUNTINGTON STREET, TOWNSHIP OF EAST PENNSBORO 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 title 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. DESCRIPTION ALL THAT CERTAIN tract or parcel of land with the buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the Northwesterly comer of Huntington Street and Chester Avenue; thence along the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to a point; thence North 2 degrees 30 minutes West, 142 feet to a point at the Southerly line of a 15 feet public alley; thence along same North 87 degrees 30 minutes East, 100 feet to a point on the Westerly line of Chester Avenue aforesaid; thence along same South 2 degrees 30 minutes East, 142 feet to a point the place of beginning. BEING premises known as No. 60t Huntington Avenue, formerly known as 25 Huntington Street. VERIFICATION Frank Federman, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that he is authorized to take this Verification, 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. 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. ( Fr~lk Fed~lgrnan,/l~squire ~'Attomey fbx..PJF, fintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (:215) $63-7000 ATTORNEYFORPLAINTIFF GMAC MORTGAGE CORPORATION V$ BARRY E. ZOOK OR OCCUPANTS 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET ENLOA, PA 17025 COURT OF COMMON PLEAS CIVIL DIVISION No. 01-5670 CUMBERLAND County PRAECIPE FOR .H]DGMF, NT IN E.IECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejecanent in favor of the Plaintiff, GMAC MORTGAGE CORPORATION and against the Defendant(s) BARRY E. ZOOK and OR OCCUPANTS for possession of premises 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET, ENLOA, PA 17025 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 Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE Attorney for Pla/rfflff FEDERMAN AND PHELAN Frank Federman, Esquire Identification Number 12248 ATTORNEY FOR PLAINTIFF One Penn Center ~ Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD HORSHAM, pA 19044 : COURT OF COMMON PLEAS : CIVIL DMSION BARRY E. ZOOK OR OCCUPANTS : CUMBERLAND COUNTY : No. 01-5670 CIVIL TERM TO: BARRY E. ZOOK OR OCCUPANTS 601 HUNTINGTON AVENUE A/K/A 25 HUNTINGTON STREET ENOLA, PA 17025 DATE OF NOTICE: NOVI~MRER 7. 2001 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. IMPORTANT NOTICE 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 hearing 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 Attorney for Plaintiff FEDERMAN AND PHELAN L.L.P. BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION VS BARRY E. ZOOK OR OCCUPANTS 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET ENLOA, PA 17025 ATTORNEy FOR PLA/NTIFF COURT OF COMMON PLEAS CIVIL DMSION No. 01-5670 CUMBERLAND County VERIFICATION 01~ NON.MII~ITAR¥ ~FRVICE 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. Co) That defendant BARRY E. ZOOK Or occupants, is over 18 years of age, and resides at 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET, ENLOA, PA 17025. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. ESQUIRE PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION v$ BARRY E. ZOOK OR OCCUPANTS 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET ENLOA, PA 17025 COURT OF COMMON PLEAS CIVIL DIVISION No. 01-5670 CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 601 HUNTINGTON AVENUE, A/KJA 25 HUNTINGTON STREET, ENLOA, PA 17025 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET ATTORN~f~OR PLAINTIFF I t i C ~ ¢=~ ~ wirZ~in nm-aG GMAC Mor.t~ag~e. Corporation :o ~ .u.n.t. _%n__g?_ _n._S_ia.?_°?_ :_. _~i _ .~.!9~_ ~. X~!A. M~]E _ i~. ~p_ _ ~%6~_g K~ ................. Sheriff's Costs: Sheriff's Costs: $ 90.27 '~o~'k~-~irrg': .... -$---~ 8:-08- ......................... Adaz a"b-c ~- -C'o-~ ~-~ ~ ........ -f5T~OU ........... Poundage 1.77 59.73 ~r~l~kam-- ............ l--Q0- ........................................................................ Milage 19.50 Possession ..................... ~0.~0- ........................ _R~_f. urud ~ _I.a. Ati_y. ~2/-2/g~. .............. Surcharge 20.00 $ 90.27 Premises: 601 HUNTINGTON AVENUE, A/K/A 25 HUNTINGTON STREET, TOWNSHIP OF EAST PENNSBORO 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 title 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. DESCRIPTION j ALL THAT CERTAIN ~ract or parcel of land with the buildings and improvements thereon erected situate in East Penn~boro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the Northwesterly corner of Huntington Street and Chester Avenue; thence along the Northerly line of Huntington Street South 87 degrees 30 minutes West, 100 feet to a point; thence North 2 degrees 30 minutes West, 142 feet to a point at the Southerly line of a 15 feet public alley; thence along same North 87 degrees 30 minutes East, 100 feet to a point on the Westerly line of Chester Avenue aforesaid; thence along same South 2 degrees 30 minutes East, 142 feet to a point the place of beginning. BEING premises known as No. 601 Huntington Avenue, formerly known as 25 Huntington Street.