HomeMy WebLinkAbout00-04784
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FEDERMAN AND PHELAN
By: Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PAl 9 102-1799
(215) 563-7000
Attorney for Plaintiff
WMC MORTGAGE CORPORATION
P.O. BOX 54089
LOS ANGELES, CA 90054
Court of Common Pleas
Civil Division
v.
CUMBERLAND County
Term
CHARLES JOHNSON
OR OCCUPANTS
232 EAST MULBERRY AVENUE
CARLISLE, P A 170 I3
No. DO -1f7P7
do~L~~
CTVTT, ACTION - RTF,CTMRNT - ~020
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, P A 17013
717-249-3166
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1. Plaintiff is WMC MORTGAGE CORPORATION.
2. Defendant is CHARLES JOHNSON OR OCCUPANTS.
3. Plaintiff is the owner of premises located at 232 EAST MULBERRY AVENUE, 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.
F FEDE
Attorney for Plaintiff
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Sent by: GREG JAVARDIAN LAW OFFICE
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2154429727;
06/27/00 4:56PM;J~#561;Page 313
ALL THAT CERT A1N lot of ground with the improvements thereon erected situated in the First
Ward of the Borough of Carlisle, Cumberland County, Pennsylvania bounded and described as
follows;
BEGINNING at a point on the Southern side of Mulberry Avenue which point is the Northeast
corner ofland !low or formerly of Stewart H. Porter and Peggy A. Porter, h is wife; thence
Southwardly through the center of Ihe partition wall built between the houses numbered 230 and
232,60 feet to a point on line of land now or formerly of Rebecca Neiswanger Wert; thence,
Eastwardly along the latter land, 17 feet 10 inches, more or less, to a point; thence Northwardly
by lands now or formerly of William H. Hooke and Vivian S. Hooke, his wife, and through the
center of Ihe partition wall built between the houses numbered 232 and 234, 60 feet to a point on
the Southern side of Mulberry Avenue; thence Westwardly by the "Southern side of said
Avenue, 17 feet 10 inches, more or less to the place of BEGINNING,
BEING improved with a frame dwelling house known as 232 Mulberry Avenue.
BEING Parcel No. 02-21-0318-317
BEING THE SAME PREMISES wmCH Robert C. Rose, NKJA Robert E. Rose and Wanda
Rose, by deed dated 7/30/98 and recorded 8/3/98, in Deed Book VoL 182, Page 727 in the office
of the Recorder of Deeds of Cumberland County, granted and conveyed unto Charles W.
Johnson and Judith L. Johnson.
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VERIFICA nON
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 unsworn falsification to authorities.
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Fr Federman, squire
Attorney for Plaintiff
Date: C, j;:F /00
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-04784 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WMC MORTGAGE CORPORATION
VS
JOHNSON CHARLES ET AL
SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within COMPLAINT - EJECTMENT
was served upon
JOHNSON CHARLES
the
DEFENDANT
at 1433:00 HOURS, on the 7th day of July
2000
at 232 EAST MULBERRY ST.
CARLISLE, PA 17013
by handing to
JUDY JOHNSON, WIFE OF DEFT.
a true and attested copy of COMPLAINT - EJECTMENT
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
So Answers:
~~~
R. Thomas Kline
me this
10 day of
;'000 A.D.
07/12/2000
FEDERMAN AND PHELAN
JL~~. ~
Deputy Sheriff
By:
Sworn and Subscribed to before