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HomeMy WebLinkAbout00-03764 ~<~ . n FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Attorney for Plaintiff Two Penn Center Plaza Suite 900 Philadelphia, P A 19102-1799 (215) 563-7000 COUNTRYWIDE HOME LOANS, INe. F/K/A COUNTRYWIDE FUNDING CORPORATION Court ofComrnon Pleas 6400 LEGACY DRIVE PLANO, TEXAS 75024-3632 Civil Division v. CUMBELAND County STANLEYM. DEIMLER, JR. OR OCCUPANTS 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 Term No. 00 - '}'11. if C iC,)~L 'r~ rTVTT, ArnON -lUF.rTMF.NT-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 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 fmd out where you can get legal help. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 ~l~- . " 1. Plaintiff is COUN1RYWIDE HOME LOANS, INC. F/KJ A COUN1RYWIDE FUNDING CORPORATION. 2. Defendant is STANLEY M. DEIMLER, JR. OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 433 POPLAR CHURCH ROAD, CAMP HILL, P A 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBELAND 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 oftitle. 6. Plaintiff has demanded possession ofthe 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~ A omey for Plaintiff ALL THAT CERTAIN piece or lot of land situate in the Sorough of Worsleysburg, County of Cumberland, Pennsylvania, to wit: IlBGlli!UlIG at a point on the North side of Poplar Church Road, which pout is located South 53 degrees 30 minutes East aJ.ong the North side of Poplar Church Road, a distance of three bundred thirty (330) feet fro. tbe intersection of tbe extension of the North side of Poplar Cburc' Road witb tbe extension of tbe West side of Billside Drive as t'.1I} appear on tbe Plu of Lots of Section .S. of Rivervi...: TIII!HCll al" ~g I;I,e Ilortb aide of Poplar Cburcb Road, South S3 degrees 30 -minutee ~"t, a :,{.,tance of eighty (80) feet to a point: 'rBmICB through tbe center of Lot No. 2 on said Plan, Ilorth 36 degreee 30 minutes Weet, a distance of one bundred forty-two and eighty one-bundredtb (142.08) feet to a point on tbe dividing line between Lot. Iloe. 2 and 17 on said Plan: 'l'HBNCE along the line dividing Lots Nos. 2 and 3 frOJll Lot Ilo. 17 onsaid Plan, Ilorth 53 degrees 30 minutes Bast, a distance of eigbt:' (80) feet to a point, THENCE through Lot No. 3 on said Plan, South 36 degrees 30 minutes East, a distance of one bundred forty-two and eight one-hundredths (142.08) feet to a point on the North side of Poplar Church Road, the Place of BEGINNING. SEING the Bastern thirty-five (35) feet of Lot No. 2 adn the Western forty-five (45) feet of Lot No.3 on the Plan of Lots of Section .S., Riverviev, which Plan is recorded in the Cumberland Counl] Recorder's Office in Plan Sook 10, Page 21. ~.ING TBBREON BRECTED a brick and frame dwelling house numbered 433 poplar Cburch Road, Camp Hill, Pennsylvania. SEING THE SAMB PREHISES which Gerald W. Korte and Joan Gail Korte, his wife, by deed dated October 19, 1982, and recorded in tbe Office of the Recorder of Deeds, Cumberland County, in Sook Z-29, page 107, granted and conveyed unto Joan Gail Korte. The said Joan Gail Korte died on ",""",", .~ l~ SCY.EDULE C - Land Description CanmilmentNunber. 2323 i I t , ~':MC'_,,-:i ~1r~~~~~'. . Premises: 433 Poplar Church Road Camp Hill, PA 17011 ~ ::j\:~:;jf:Z i il)~ ;~,\~ . .\:, ~~. STEW ART TITLE GUARANTY COMPANY - ------ ; ;{~~;i . ; /!f/~: . ,.::./fh. . ~',.,!':I'4~",,,J{;;'--: ~'''''''''f;''olt:..~ ~;~i~~'i . ?.~~~rfftW~ ~]};'!f:iC~ ~7:':\"~~ "~'i~~~ !'-";:';"";~'" :~$i~';~S I. . VERlFICA nON BRANDON-SCIUMBATO Hereby states that he/ she is the is the VICE pJ::u:~mFNT Of Countrywide Home Loans Mortgage servicing agent for the Plaintiff in this matter, that he/she 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 /her 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 unsworn falsification to a ESIDENT Date: r: -/'/- CJCl '~,~il!I'~'"< '"---~~J/I1<f!,;;~~ - !llM~i~j,~ii1l,;~;w4J!i!>\oi~d";;l"",,,, ~~i'"""""~k.."......tiiWU~"'l>>",",,,,,,,,jill4f,j!i>J!-m,;~IliW!i~;re. ~- .....~ -"0" ~~~. 1Il~".- '" ~ .iIlt<2! . ~ -(q '~ ~ ~ .~ 8 ~ ~ ~ 0 c.'::) 0 1 g d c: C~) -n <'" , tJfj5 ~.;:: o.y 'TIn, ',:;-;;; I 2::~:}:.: i"\.) . -j;~J ~ -c> ~ S5 S-~~ Cl ~c.- ~~~? ~ p: J:,:'. ~~~ ~-S ..,~(-) ._,.~ ?c\ -,,~ 9 ;::5 fir J ).......c s;! :z: -j -~ :1J --- 0''\ -< ,.-. - SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-03764 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DEIMLER STANLEY M JR 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 DE IMLER STANLEY M JR but was unable to locate Him in his bailiwick, He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , DEIMLER STANLEY M JR HOUSE AT ABOVE ADDRESS IS EMPTY, Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.30 5.00 10.00 .00 42.30 omas Kline riff of Cumberland County F o PHELAN Sworn and subscribed to before me this /2!? day of ~ ~ A.D, Q'lt" f1 ~~;..//~ Pr t onotary C1VTT, ACTION - KTF,CTMF,NT _ 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCXATION 2 LmERTY AVENUE CARLISLE, PA 17013 717-249-3166 TRUE COpy FROM RECORD In Testlmony whereof, I here unto set my hand ............ ~ said~~~r at Carlisle, Pa. . ~~~~ AU , IiliilH t t I - 1. Plaintiff is COUNTRYWIDE HOME LOANS, INe. FIKJA COUNTRYWIDE FUNDING CORPORATION. 2. Defendant is STANLEY M, DEIMLER, JR. OR OCCUPANTS. 3, Plaintiff is the owner of premises located at 433 POPLAR CHURCH ROAD, CAMP HILL, P A 17011 , a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBELAND 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. F FEDE A mey for Plaintiff ~ Be i f I 'I ~~!o'~;:-:.~.' - ~i~vi~ r '1;..1.; .,i; '~'~" -~- ;:-,\~. ,! ,'.'1 SCY.EDULE C . Land DescrlpUon Canmi011&n1 Ntmber. 2323 ALL THAT CERTAIN piece or lot of land situate in the Sorough of Wormleysburg, County of Cumberland, Pennsylvanl.a, to wit: BBGDIllIlIG at a point on the North dde of Poplar Church Road, which po!.nt is located South 53 degrees 30 lIIi.nutes Baat along the Borth side of Poplar Church Road, a distan..e of three hundred thirty (330) feat fro. the intersection of the extension of the North side of Poplar Churc:' Road. with the extension of the West side of Bllldde Drive as t' ~ .ppear on the Plan of Lots of SectiOIl oS' of Riv"rYi_r TlIBIICB al"'-,g tl.e Worth side of Poplar Church Road, South 53 degrees 30-lIinutes ~..t, a :'t-:tance of eighty (80) feet to a pointr "........... through -the cellter of Lot Bo. 2 on said Plan, Worth 36 degrees 30 aiAutes West, . distance of one hundred forty-t_ and eighty Oil_hundredth (142.08) feet to . point on the dividing line betweell Lots Woa. 2 and 17 011 sdd Planr 'l'IIBHa along the line dividing Lots Boa. 2 and 3 frOlll Lot No. 17 olla.id Plan, Borth 53 degrees 30 llinutes Bast, " distance of eight:. (80) feet to a point, TBBHCB through Lot No. 3 on sdd Plan, South 36 degrees 30 ainutes Bast, a distance of one hundred forty-two and eight one-hundrsdths (142.08) feat to . point on the Borth side o! Poplar Church Road, the Place of BBGIIIIUNG. SBING the Bastern thirty-five (35) feet of ,Lot No. .2adn the Western forty-five (45) feet of Lot Bo. 3 on the Plan of Lots of Section oS', Rivervi_, ..hich Plan is recorded in the CUlIIberland Counl.j' Recorder's Office in Plan sook 10, Page 21. ~.IBG TBBR!ON BRECTED a brick and frame dwelling house numbered 433 Poplar Church Road, Camp Bill, Pennsylvania. BBIBG TBB SAHB PREMISBS which Gerald W. ltorte and Joan Gail ltorte, his ..ife, by deed dated October 19, 1982, and recorded in the Office of the Recorder of Deeds, Cumberland County, in Sook Z-29, page 107, granted and conveyed unto Joan Gail Korte. The sald Joan Gall Korte died on Premises: 433 Poplar Church Road Camp Hill, PA 17011 STEWART TITLE GUARANTY COMPANY "h .___" '";~ - ._~~~ ~ ..~.4.t'>- }~~I:'! :tJ~~~: 1:,~i~i-,~- ,,,,,,,"," . <' VERIFICATION BRANDONSCIUMBATO Hereby states that hel she is the is the 'lIeF p~F~lnFNT Of Countrywide Home Loans Mortgage servicing agent for the Plaintiff in this matter, that helshe 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 /her 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 unsworn falsification to a ESIDENT Date: r: -I '/ - CJ(7 . 41''1<<1,,,,,,,,,"' ,(,;',; r;]i!!"/ ~~ ~~...,~""-,, ~ir:,_ ~ "," JUH za , ')':I~i~F ~1'$~ r, p~ " v :~~ , .. - C I' ; ~_:.. , -. " i, . <, '