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Home My WebLink About00-06978 .. , , , . : 'l....."""'- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH AMERICAN MORTGAGE COMPANY, Plaintiff, v. CHRISTIAN B. SCHRAGA, by his attorney-in-fact, LORI A. PAGANA, and TERRE TENANTS, Defendants TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. WELTMAN, WEINBERG & REIS CO., L.P.A. By:h~o~'TNil~' I HEREBY CERTIFY THIO ADDRESS OF PLAINTIFF IS: clo Wellman, Weinberg & Reis Co., L.P.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 AND THE DEFENDANTS ARE: 1426 Timber Chase Drive Mechanicsburg, PA 17055 WELTMAN, WEINBERG & REIS CO., L.P.A. By:~(\r- 'M. ~\\.. ~ A ORNEYS FOR PLAINTIFF t HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS: 1426 Timber Chase Drive Mechanicsburg, PA 17055 Township of Hampden WELTMAN, WEINBERG & REIS CO., L.P.A. BY~~C\.lu.uL. A RNEYS FOR PLAINTIFF NO.: c::Jo - 1:.971> e,():CT~ ISSUE NO.: CODE: TYPE OF PLEADING: COMPLAINT IN EJECTMENT FilLED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: JON A. McKECHNIE, ESQUIRE Pa.I.D.#36268 WELTMAN, WEINBERG & REIS CO., L.P.A. Firm #339 2601 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 434-7955 WWR#01781553 -,- __J.: ---*-" , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH AMERICAN MORTGAGE COMPANY, Plaintiff, v. NO: CHRISTIAN B. SCHRAGA, by his attorney-In-fact, LORI A. PAGANA, and TERRE TENANTS, Defendants NOTICE TO DEFEND 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 twenty (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 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 Liberty Avenue Carlisle, PA 17013 717-249-3166 "'....... , , II ~_,;i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH AMERICAN MORTGAGE COMPANY, Plaintiff, NO: d1J - (,'171 C;;;;.t JiUW-' v. CHRISTIAN B. SCHRAGA, by his attorney-In-fact, LORI A. PAGANA, and TERRE TENANTS, Defendants COMPLAINT IN EJECTMENT - PURCHASER AT SHERIFF'S SALE 1. Plaintiff is North American Mortgage Company ("Bank") with an address of 231 East Avenue, Suite 200, Albion, NY 14411. 2. Defendants are Christian B. Schraga, by his attorney-in-fact, Lori A. Pagan a Terre Tenant, individuals, residing at 1426 Timber Chase Drive, Mechanicsburg, PA 17055. 3. Plaintiff is in the process of acquiring the title by the settling with the Sheriffs Office. 4. Said Sheriffs Deed will be issued pursuant to a Sheriffs Sale duly held in Cumberland County on September 6, 2000 by virtue of a Writ of Execution issued on June 13, 2000. 5. Said Sheriffs Sale was authorized under the terms of a foreclosure action and judgment thereon in the Court of Common Pleas of Cumberland County at No. 2000-564. - - i I '~",,,.'\ 6. Defendant, Christian B. Schraga, by his attorney-in-fact, Lori A. Pagana, herein was owner of said property by virtue of a Deed from Lisa A. Starsinic, single, to Christian B. Schraga, married, by deed dated September 17,1998 and recorded with the Recorder of Deeds of Cumberland County on September 21, 1998 at Deed Book Volume 185, Page 710, Parcel No. 10-15-1283-008. A description of said property is attached as Exhibit "A". 7. Defendants have no valid legal right to possession and title to said premises. 8. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants. WHEREOF, Plaintiff, North American Mortgage Company, seeks judgment for the possession of the aforesaid premises. Respectfully submitted, ~~~~< Jon A. McKechnie, Esq. WEL TMAN,WEINBERG, & REIS, CO., L.P.A. 2601 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ~~-~'-~- ,'" _'- L--l .-"J ~"t~ij IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTH AMERICAN MORTGAGE COMPANY, Plaintiff, NO: 2000-564 vs. , CHRISTIAN B. SCHRAGA, by his Attomey-in-fact, LORI A. PAGANA, Defendants LONG FORM DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. 1426 (the 'Unit"), of Timber Chase, A Townhouse Condominium (the "Condominium"), located in Hampden Township, Cumberland County, Pennsylvania. which Unit is designated in the Declaration of Condominium of Timber Chase, A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plan recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 508, Page 602 and Right of Way Plan Book 11, Page 13; as amended in Miscellaneous Books 513, Page 360, 524, Page 978; 528, Page 838; 533, Page 87; 540, Page 235; and 544, Page 1020; and in Right of Way Plan Book 11, Pages 15, 23,31,43, 54 and 66 respectively. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid Declaration of Condominium, as last amended. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans. as last amended. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. BEING the same premises which Lisa A. Starsinic, a single woman, by Deed dated September 17, 1998 and recorded on September 21, 1998 at Deed Book Volume 185, Page 710 and recorded in the Recorder's Office of Cumberland County, granted and conveyed to Christian B. Schraga, a married man. WELTMAN, WEINBERG & REIS, CO., L.PA ~\r.- \^';,--L\C~' Jon A. McKechnie Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 :XHIBIT=-~-' ~;, \ l' "_J '._1_1 Cllkti VERI FICA TION The undersigned does hereby verify subject to the penalties of 18 PAC.S. 3 4904 relating to unsworn falsifications to authorities, that he/she is Timothv R. Hapeman Vice President ,of (TITLE) North American Mortqaqe Companv (COMPANY) , plaintiff herein, that he/she is duly authorized to make this verification. and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. Timothy R. Hapeman ~'ll@l~#.',I\"'.i!"~i<i'ii!<itil;l:~~~,,=iW!if*,'ili';""''''i''M'''I!'',''ec:k"\,".ii,,",,.,~.",,:,0,~',;.I,.4i;~~'1I!if~~~~)~--" '. ~ . c_" __,~" ;;',4 il ~ ~ ig i1{ ~ ~ h & 0 (;) ...... ~ 8 l.r) 0 ,~ 0 ~ 0 C> C G -r, .lJ I ?"" 0 .-4 1.) I "'TJ(;'_; ;,~) 1.) )J f1lf<-' -4 ~ ~ z-- -J 8 u:;. If' ~, ' <~-) t r:::: -"':'-1 .. $ )~C ~'_...M :::;::C', ::'? >t~ -.J 5~. ::::l f'..) :< -<. '-' -< . I I .' ~ '''>- SHERIFF'S RETURN - REGULAR CASE NO: 2000-06978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH AMERICAN MORTGAGE COMPAN VS SCHRAGA CHRISTIAN B ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon SCHRAGA CHRISTIAN B - BY HIS ATT-IN-FACT LORI PAGANA the DEFENDANT , at 0017:04 HOURS, on the 19th day of October ,2000 at 2241 CANTERBURY DRIVE MECHANICSBURG, PA 17055 by handing to LORA A. PAGANA 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 6.20 .00 10.00 .00 34.20 So Answers: r~~1'<~( R. Thomas Kline 10/20/2000 WELTMAN, WEINBERG & REIS Sworn and Subscribed to before By: ~~@~~~ D puty heriff' me this o?.3 M-\ day of [!>~~0 AD . 0 ">n.dL 4.fJ~ . P othonotary , 7