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HomeMy WebLinkAbout00-04785 "I "" " -;,'~- , ~,: , , FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, P A 19102-1799 (215) 563-7000 Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 Court of Common Pleas Civil Division v. CUMBERLAND County Term AMANDA CARBAUGH OR OCCUPANT 113 BUNGALOW ROAD ENOLA,PA 17025 No. 06 - i.t1P-S G.~~t '-r~ rTVTT, ArTTON - KTF,rTMRNT - ]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 yon 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, PA 17013 (717) 249-3166 . ~o ...;~-' .~,;;;," 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC., F/KIA NORWEST MORTGAGE, INC.. 2. Defendant is AMANDA CARBAUGH OR OCCUPANT. 3. Plaintiff is the owner of premises located at 113 BUNGALOW ROAD, ENOLA, PA 17025, 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. ~l~~ F NKFEDE N Attorney for Plaintiff ". . --, , :;',\- DESCRIPTION ALL THAT CERT AI~ lots or pieces of land, with the improvements thereon erected, situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BOUNDED on the West by Duke Street; on the North by Bungalow Road; on the East by an alley; and on the South by Lot No. 133 on the hereinafter mentioned Plan of Lots. BEING Lots Nos. 13:+, 135', 136, and 137 on Plan of Lots known as Shady Lane; East Pennsboro Township, Cumberland County, Pennsylvania, as laid out by Arthur C. Young, said Plan being recorded in the Office of the Recorder of Deeds in Cumberland County Plan Book I, Page 92. LOTS Nos. 134 and 135 having thereon erected a two and one-half story frame dwelling known as 139 Bungalow Road (now known as 113 Bungalow Road), Enola, Pennsylvania. LOTS NOS. 134, 135 and 136 each containing 50 feet in front on Duke Street and extending Eastwardly in depth 150 feet to said alley; Lot No. 137 being an irregularly shape lot lying North of Lot No. 136 at the Southeast intersection of Bungalow Road and Duke Street. Tax Parcel# 09-13-1002-173 TITLE TO SAID PREMISES IS VESTED IN Timothy F. Carbaugh and Amanda L. Carbaugh, his wife by Deed from John H. Kulp and Vickie L. Kulp, his wife dated 5/31/95 recorded 6/2/95 in Deed Book 122 Page 1190. ~".- '" ~-; I i . VERIFICATION MARK WOOTEN Hereby states that he/ she is the is the EVICTION SPECIALIST Of NORWEST MORTGAGE. INC. 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 authorities. ~~~ p Date: JUNE 28, 2000 I" ....-- n"" 'iII&di!-- ~-'~"""~""'~~I'~~lII~.~":!,$Jtt~"'''.MI;l!OiOO'!.iiW~,~__;i:iliillh....::l .- ""._"' _u~u. --1lrilli........~~~d . . '.- ""~~ - " "_''''''"iilIIIilrti,J tJ (J .t ~ -l:: ~ 'i ~ 't 0 0 0 og . c C> ~ C3 b ~ ,,?S: " L- .-:, ~ 0 mtD f= ~ 2m t- ,'-:; -r; ~, ",.... , I 2C r-~' I .-~-;n'l (f)> '..Jl ::,:,1 C;:J ....... --<:'''' -.. r-; (.~j , , ~ '1:) ~ ~:-:~ () "'- ",. ;-~:n j ~o :::t:: '-0 ::;:.~ C') >c om 2: t..- s;! =<! '0 :1] -< . > " (j, SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-04785 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS CARBAUGH AMANDA 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 I defendant, DEFENDANT CARBAUGH AMANDA but was unable to locate Her in his1bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOTICE , NOT FOUND , as to the within named DEFENDANT , CARBAUGH AMANDA DEFT. NO LONGER RESIDES AT ADDRESS STATED, PROPERTY IS VACANT. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 9.92 5.00 10.00 .00 42.92 ~ .' Tho~as Kline Sheriff of Cumberland County FEDERMAN & PHELAN 08/01/2000 ~~~ "Ub"O:::":ffO~" ~ "~ '" ",', "~! , ( FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, P A 19102-1799 (215) 563-7~OO Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, mc., FfKlA NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTIE, NC 28217 Court ofCornmon Pleas Civil Division v. CUMBERLAND County Term AMANDA CARBAUGH OR OCCUPANT 113 BUNGALOW ROAD ENOLA, PA 17025 No. 00 - J.f'1R!) C(.)c:CT~ r.TVTT, Ac.nON - Kmc.TMF.NT - 3/12/1 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 LmERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 TRUE COPY FROM RECORD In TlI8tImonywherllOf, I oom unto set my hand ....~of:r..~. at _Po. '-~-_.~. .:'~ , ~ t~ .".'-.:'. ..,~"h, """ 1. Plaintiff is WELLS FARGO HO!vIE MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC.. 2. Defendant is AMANDA CARBAUGH OR OCCUPANT. 3. Plaintiff is the owner of premises located at 113 BUNGALOW ROAD, ENOLA, PA 17025, 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 infonned, 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. -j~~, F FEDE Attorney for Plaintiff _ .j, "--'~'", ",-. '.'.";"", DESCRIPTION - ALL THAT CERTAI~ lots or pieces of land, with the improvements thereon erected, situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more panicuIarly bounded and described as follows, to wit: BOID-i"DED on the West by Duke Street; on the North by Bungalow Road; on the East by an alley; and on the South by Lot No. 133 on the hereinafter mentioned Plan of Lots. . BEING Lots Nos. 13'+, 135, 136, and 137 on Plan of Lots known as Shady Lane; East Pennsboro Township, Cumberland County, Pennsylvania, as laid out by Arthur C. Young, said Plan being recorded in the Office of the Recorder of Deeds in Cumberland County Plan Book 1, Page 92. LOTS Nos. 134 and 135 having thereon erected a two and one-half story frame dwelling known as 139 Bungalow Road (now known as 113 Bungalow Road), Enola, Pennsylvania. LOTS NOS. 134, 1:35 and 136 each containing 50 feet in front on Duke Street and extending Eastwardly in depth 150 feet to said alley; Lot No. 137 being an irregularly shape lot lying North of Lot No. 136 at the Southeast intersection of Bungalow Road and Duke Street. Tax Parcel# 09-13-1002-173 TITLE TO SAID PREMISES IS VESTED IN Timothy F. Carbaugh and Amanda L. Carbaugh, his wife by Deed from John H. Kulp and Vickie L. Kulp, his wife dated 5/31/95 recorded 6/2/95 in Deed Book 122 Page 1190. ~~ _I, VERIFICATION MARK WOOTEN Hereby states that he! she is the is the EVICTION SPECIALIST Of NORWEST MORTGAGE. INC. 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 authorities. . Al-;$~ p Date: JUNE 28, 2000 I ~' ~ ~ ',._~ -~ ...-- .~ "~lIIIiIIIMI '_H' ~ f:;:F: ". II .'lL " ~~-,> " ~ ~ r.' , _ _~_'__m :,:FF : -:-'{ ~ ~ ~ ~ ~ "'~ ~ ,~..,.^'r ~"._"___ :R1!l!Jil";w.!Ij!l"!W~~i/.'1'R"!~i"~l!!lIi<'~~~,.,...",,, ~"', "