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Home My WebLink About02-5937 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 Gordon Sheriff Or Occupants 575 Graham Woods Road Carlisle, P A 17013 No, 0,,/- 5137 ~~ CTVTT, An'l'TON R.mn'I'MRN'T' ::109.0 NO'l'TnR Please be advised tbat 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 L Plaintiff is Countrywide Home Loans, Inc, 2, Defendant is Gordon Sheriff and Or Occupants, 3, Plaintiff is the owner of premises located at 575 Garham Woods Road, 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~ .:?-~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ALL TH.'tT CERTA [N tr.act of land with the improvements thereon erected situale in Upper Frankford Township. Cumberland County, Pennsylvania. being described as Lot No. 7 of the Hobbyhorse Acres SUbdivision prepared by Douglas S. Brehm. R,S. dated July 23. 1989 and recorded in Cumberland County Plan Book 60, Page 20 llnd more fully bounded and described as follows: BEGINNING at at point on the eastern dedicated right of way line of 50 foot wide Grahams Wood Road (T -448) at the di viding line between Lots 7 and [Ion the above-memion.:d subdivision plan; thence along said dividing line North 88 degrees 37 minutes 45 seconds Easr 166.45 feet to a point; thence along same South 62 degrees 58 minutes 05 seconds East J 15.00 feelto a point; thence along same South 12 degrees 49 millutes09 seconds Wcst 182,26 fecllo a point: thence along lhe dividing line belween LulS 7 and 8 on said plan North 65 degrees 23 minutes 33 seconds West 256,94 feet ro a point on lhe eU:itern dedicated right of way of Graham, Wood Road (T-448); thence along said ,ight of way line by a curve to lhe lefr with a radius or 983.93 feet an arc distance of 1I9.19 fee: to a poinc.the Place of DE GINNING. CONTAINING 43,452.28 square fee: and having thereon e~ected a single family dwelling with mailing address of 575 Grahams Wood Road, Grfisle, Pennsylvania~ Propeny Address: 575 Graham Woods Road. Carlisle, PA 1701J TAX L D, ~ 43-05-04 t 9-03 t Vestin2' Information: Vested by Warranty Deed, dated 9/30/96, given by Russell R. Wilson, II and Pall R. Schremer Wilson, husband and wife to Gordon E. Sheriff and Nancy L. Sheriff, husband and wife and recorded lO/t/96 in Liber Book: 146 Page: 943 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, See, 4904 relating to unsworn falsification to authorities. Date: 12/2/02 +~ -ft' Frank Federman, Esquire Attorney for Plaintiff ~ ~ ~ - 0 ~ cJ (") c! - c: ........ )2: -." -{:: l <'"1 ~ 'l-- r ~.) 0<\ L_. C \ .~C 'I -t' Oi <....)', - 0lC)\ -. '. ~ ,-',,) c/' . "^ "-,) ('I 0' I SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-05937 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYRWIDE HOME LOANS INC VS SHERIFF GORDON 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 SHERIFF GORDON but was unable to locate Him In his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , SHERIFF GORDON HOUSE IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 4.14 5.00 10.00 .00 37.14 ~ So an .: /'. . Thomas Kli e ' Sheriff of Cumberland County FEDERMAN & PHELAN 01/08/2003 Sworn and subscribed to before me this L.- n day of (jnuA'1 /0 c) 00.3 A. D . 9rt/, - Q )hdl,~, ~ Pr onotary 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 ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Gordon Sheriff Nancy Sheriff Defendant( s) No. 02-5937 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:. ~)~ Francis S. Hallinan, Esquire Attorney for Plaintiff PHS# 66509 ~ c:;::l 0"' o C"') --' \ ;;:- -:t;I.~ ~:::: q, ~-n 1""1 r:: -n f'I\. :~~~; .J~-r (:) -(") .;~ :. <'::) \0 ':--\ ':E': ~ - - o --l