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Home My WebLink About01-7231 FX . "-.J.Hi~~,.i - FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 Attorney for Plaintiff One Penn Cellter @ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Wells Fargo Bank Minnesota, N.A. successor by merger to Norwest Bank Minnesota, N.A.llS Trustee of Salomou Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, series 1999 AQ-2 under The Pooling and Servicing Agreement dated as of November 1, 1999 without recourse Court of Common Pleas 505 South Main Street Orange, CA 92868 Civil Division v. Cumberland County Term Mildred E. Meutzer Or Occupants 346 Mountainview Road Mount Holly Springs, P A 17065 No.C>1-7c231 Go~l ~~ nVTT, ACTION - KW.CTMF.NT _ l/l2/1 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 telepbone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 . ~~.~ , I .- '> '''';'';''_'lJl~~k~r:< . .. 1. Plaintiff is Wells Fargo Bank Minnesota, N.A. successor by merger to Norwest Bank Minnesota, N.A.as Trustee of Salomon Brothers Mortgage Securities VlI, mc., Floating Rate Mortgage Pass-Through Certificates, series 1999 AQ-2 under The Pooling and Servicing Agreement dated as of November 1, 1999 without recourse. 2. Defendant is Mildred E. Mentzer Or Occupants. 3. Plaintiff is the owner of premises located at 346 Mountainview Road, Mount Holly Springs, P A 17065 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). S. 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 oftit1e. 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. er----- F FED 1\ttorney for la' ff I~ ' ",h_ -' ":'-d~"-i'="~~*",""J-" _ DESCRIPTION ALL THA T CERTA.l~ cract of land situate in Dickinson Township, Cumberland County, Pennsylvania bounded and described as follows, together with improvements thereon erected. ON the ;:-.forth bv land now or formerlv of Earl Diven; on the East bv a.Mountain Road leading to the Sand Bank: ~n the South by land formerly of Harry Shenk now ~r formerly of Ed.na Sowe;s; and on the West by a Mountain Road leading to the Sand Bank. CONT...I.INE'lG 70 perches more or less. LESS HOWEVER that crac[ of land conveyed by John J. Cromer to Robert Sowers by Deed dated October 25, 1950 and recorded in the Cumberlana,County Recorder's Office in Deed Book "0', Vol. 1... page 116 being the Northern 80 feet of the above described cract of land. TAX PARCEL # 08-33-1936-006 RECORD m,V:"iER TITLE TO SAID PRE.MISES [5 VESTED IN Mildred E. Menrzer by Deed from William H. Medley, singleman and Mildred E. Menrzer, singlewoman dated 10/30/78 recorded 11/9/82 in Deed Book Volume Y-29 page 698. '. '. ~ --- ~ .l..._1 -~ ~ ~'. - ~ -" '''&i<J,ii''~~M " VERIFICATION 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. Date: /1 ~/IJ/ , :'iJI'~i1JIl~~!l'~~j~$>-Jir~1Wnl'~~i,~!;",,:c\".'d~~""'.'<;1".i- ~ ",'" .',~"'~ - h,L,~.. ~ 1~1! , """.., ,__.m! II ..."IL., ,-, '.'~.'.""_'~"_"" ,,' ;",,: '~1'~; ','.,;" '~,.1'~J'lw!l;..il,0Jiit~~~":il~1lficm~h JiilI~ 1 p ~ ~ _J~~~ $l) "-3 ~o' o ~ C>c.~ ..0 - I C),- o...j I ~,~ --t: _ ,~., ,.;".,.,=,,, < ~,.' "{,,,,.~,," ^'.~ ~ . "? ".. ,,"~,~. ~," , ,', .~ ." -' o c -~ om min ?-:::rf ~~ r:: ,", :;::=:'---' ~0 ",,-0 PC Z =< - C> n 'Tl t::l 111 n N co -0 :J;: N .. ".:J " 'i l;;: '"P' ~~~~~ ~71~ ~, -~ 53 -< N O"l " f0J " ' ~ '-I ~~","""",-""",-~,'",<C,""",,"-i,,''' SHERIFF'S RETURN - REGULAR CASE NO: 2001-07231 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA N A VS MENTZER MILDRED E DOUGLAS DONS EN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon MENTZER MILDRED E the DEFENDANT , at 0950:00 HOURS, on the 2nd day of January ,2002 at 346 MOUNTAINVIEW ROAD MOUNT HOLLY SPRINGS, PA 17065 by handing to MILDRED E. MENTZER a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.55 .00 10.00 .00 32.55 ?"~~ R. Thomas Kline me this ~~ day of 01/03/2002 FEDERMAN & PHELAN By: Q~ Q~ eputy Sheriff Sworn and Subscribed to before ~J..., A.D. Q~ othonotary ~ .- L I '~l !"JI'i!"'_",,~"~O:_:"- , 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 Wells Fargo Bank Minnesota, N.A. ATTORNEY FORPLAThITWF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Mildred E. Mentzer Defendant( s) No. 01-7231 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:~ ~rlL>.\14,jj Francis S. Hallinan, Esquire Attorney for Plaintiff 'f]' ;JJj~i&?-i:" : .....;~>. 1'1" ~ ~-" -""d~~~lJ.j2';jj'!~~);';d,:,g,:"h:~l h',;;i)~, :,~~_~~~~~,.I\!,;,\,;+,j;i!;'''Ld;imii!!1fi'ili-'liW~mM"~'''lIJj'= ~5 'fI( ~A"<<'~~c~o~,J~4~j1;,~,:,:~~Jd;::::,.:~JJ~.cj,!:;."i:t,;,~",d,:}1,:$H,,1'1'Jt,-,,".~s"M~,",1l')k .",~,W",.."),~>,],;1~"K,,m,ll:, .."\TI"".,~~"",,,_ ',',,~,,(-J"'''', :m.,Q"J" .. - ,",~ ,,~_,,_.. _> . ~ ",'-, ;...,"~,~ ~ (") ~ 'TJL':t. rrlj"\ ~~i-": g'i~:~ -,~" ..::::.:._, 5.; '~~~:~ :r:: -~ -< ..~ ~~'. ...., = = "" (/) rr1 -0 l'.} CT"I o 'Tl 5:' n"i:D r:: -rJ:m :fJO,' n :::::10 '""1:'<11 -,.--." \,~(-) am ~ :D .< -0 ::t: 'c? c::> o ~~ ~ " -~..~<> ..