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Home My WebLink About03-3066FEDERMAN AND PHELAN, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff JP Morgan Chase Bank Formerly Known As The Chase Manhattan Bank Successor By Merger To Chase Bank of Texas, National Association, Formerly Known As Texas Commerce Bank, N.A. As Trustee And Custodian By: Saxon Mortgage Services, Inc. F/K/A Meritech Mortgage Services, Inc. F/K/A Meritech Mortgage Services, Inc. As Their Attorney-In-Fact 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 Michael R. Femmer Or Occupants 1138 Newville Road Carlisle, PA 17013 Court of Common Pleas Civil Division Cumberland County Term Please he advised that this firm is a debt collector attempting to collect a debt. Any inforn~tion received will be used for that purpose. If you have previously reeeived 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 rehef 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. CIYMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is JP Morgan Chase Bank Formerly Known As The Chase Manhattan Bank Successor By Merger To Chase Bank of Texas, National Association, Formerly Known As Texas Commerce Bank, N.A. As Trustee And Custodian By: Saxon Mortgage Services, Inc. F/K/A Meritech Mortgage Services, Inc. F/K/A Meritech Mortgage Services, Inc. As Their Attorney-In-Fact. 2. Defendant is Michael R. Femmer and Or Occupants. 3. Plaintiff is the owner of premises located at 1138 Newville Road, Carlisle, PA 17013, a legal description of which is attached. Plaintiff became owner of said premises by a Deed from the Sheriff of Cmnberland County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 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 dehver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. By: FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff · ,~ . -, ..... . , , , . . . . ...... .. . , .. , . · ..... · ...~ I~,~';,~-.,.- ~ L~ O~ A.g~m. (1~}. r~,~r.r.~ .~ ~ ~ ~,~,~ ~.-, ,: ,~',~ .~ f.. ,~,..., , . . .~ ..... . . . ..... ,. · ., .. . . ..... . ~.~, )~,~,.,~.. ~LZ ...... .., , . - ., .. . .,; .,~, .. .- ~ ,,....,, .~ ..... ~, .. .,.. - · .~. . ~. .~,~.-.K. , ,, T~E ~'S~D p~ISE~'IS ~.T~ ~ MI~ R. ~, .$Y,D~ FROM '.. . 12/27/99, ~ l/V/00, IN D~ ·BOOK '214,. PAG~ .642. " 2920'-179.2-025 '- ~t3~ .NSWV~, L~. VERIFICATION Francis S. Hallinan, 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. R.C.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. Sec. 4904 relating to unsworn falsification to authorities. Date: Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF' S RETURN CASE NO: 2003-03066 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JP MORGAN CHASE BANK ET AL VS FEMMER MICHAEL R REGULAR JASON VIOR31L , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT was served upon FEMMER MICHAEL R DEFENDANT , at 2047:00 HOURS, on the 15th day of July at 1138 NEWVILLE ROAD CARLISLE, PA 17013 by handing to MICHAEL FEMMER a true and attested copy of COMPLAINT - EJECTMENT Sheriff or Deputy Sheriff of who being duly sworn according to law, the ., 2 o together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this g ~ day of ZP~othonotary J ' ' So Answers: R. Thomas Kline 07/16/2003 FEDERMAN & PHELAN By: ~ty Sheri~fff FEDERMAN AND PHELAN L.L.P. BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank formerly known as The Chase Manhattan Bank successor by merger to Chase Bank of Texas, National Association, formerly known as Texas Commerce Bank, N.A., as Trustee and Custodian by Saxon Mortgage Services, Inc. ffk/a Meritech Mortgage Services Inc., f/k/a Meritech Mortgage Services, Inc COURT OF COMMON PLEAS VS Michael R. Femmer Or Occupants 1138 Newville Road Carlisle, PA 17103 CIVIL DIVISION No. 03-3066 Civil Term Cumberland County PRAECIPE FOR .HIDGMENT IN E.I'ECTMI;~NT TO ~I'H I~: PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, JP Morgan Chase Bank formerly known as The Chase Manhattan Bank successor by merger to Chase Bank of Texas, National Association, formerly known as Texas Commerce Bank, N.A., as Trustee and Custodian by Saxon Mortgage Services, Inc. f/k/a Meritech Mortgage Services Inc., f/k/a Meritech Mortgage Services, Inc. and against the Defendant(s) Michael R. Femmer and Or Occupants for possession of premises 1138 Newville Road, Carlisle, PA 17103 for failure to file an Answer within twenty (20) days of service. I hereby certify that accord/ag to Rule 237.1, written 10 day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. . (,~,~orney for Plaintiff Default Judgment entered as indicated above. DATE FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 56%7000 JP MORGAN CHASE BANK FORMERLY KNOWN AS THE CHASE MANHATTAN BANK SUCCESSOR BY MERGER TO CHASE BANK OF TEXAS, NATIONAL ASSOCIATION, FORMERLY KNOWN AS TEXAS COMMERCE BANK, N.A. AS TRUSTEE AND CUSTODIAN BY: SAXON MORTGAGE SERVICES, INC. F/K/A MERITECH MORTGAGE SERVICES, INC. Plaintiff VS. MICHAEL R. FEMMER Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION : CUMBERLAND COUNTY : NO. 03-3066 CIVIL TERM FILE COPY TO: MICHAEL R. FEMMER 1138 NEWVILLE ROAD CARLISLE, PA 17013 DATE OF NOTICE: &UGII.qT 5, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.I~ YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANTNOTICE You are in default becanse you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,,/LAWRElx CE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PllELAN L.L.P. BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 12248 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F, Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF JP Morgan Chase Bank formerly known as The Chase Manhattan Bank successor by merger to Chase Bank of Texas, National Association, formerly known as Texas Commerce Bank, N.A., as Trustee and Custodian by Saxon Mortgage Services, Inc. f/l~a Meritech Mortgage Services Inc., f/k/a Meritech Mortgage Services, Inc Plaintiff VS Michael R. Femmer Or Occupants 1138 Newville Road Carlisle, PA 17103 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION No. 03-3066 Civil Term Cumberland County VERIFICATION OF NON-MII,ITARV NERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. Co) That defendant Michael R. Femmer Or occupants, is over 18 years of age, and resides at 1138 Newville Road, Carlisle, PA 17103. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. PRAECIPE FOR WIL1T OF POSSESSION COMMONWEALTH OF PENNSYLVANIA County of Cumberland JP Morgan Chase Bank formerly known as The Chase Manhattan Bank successor by merger to Chase Bank of Texas, National Association, formerly known as Texas Commerce Bank, N.A., as Trustee and Custodian by Saxon Mortgage Services, Inc. f/Ida Meritech Mortgage Services Inc., f/k/a Mefitech Mortgage Services, Inc COURT OF COMMON PLEAS CIVIL DIVISION Michael R. Femmer Or Occupants : 1138 Newville Road Carlisle, PA 17103 No. 03-3066 Civil Term Cumberland County pRAR. CTPF~ FOR W~IT OF POS~I~,~q~ION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 1138 Newville Road, Carlisle, PA 17103 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 1138 Newville Road %-Ri'T OF POSSESSION' ' E]ecmien: ProceedLugs PRC P 3 i60 - 3 t65 e:c~ JP MORGAN CHASE BANK. . . 'e~'l. '.%5' ~.'-lE- COL'.=,.- C'T ~.,~..L,£0}4'-~" ' ?LZ.~ ~..-' - No..9.1~Q§tS_-_CXv_j,!__T_e_r_m__s ......... Term 20 No ................................ ?..-'vm 20 ...... ~. iii,lO .k::'? ................................ ~ ............ ,=~:-'r. ............................ ~ ..... _i_:o_o_ CO.M?,IO.N%VEAL TD. i OF COU5 ~--'Y OF CUMBERLAND To :he ~he~ of ................................... Ceur, v :1' To JP MORGAN CHASE BANK...etal. ........................................................................................... bei.~: .P.-w~--;.~'~ ~ fo,"ow~ : 11.38 NEWVILLE ROAD CARLISLE, PA 17103 Dar_- AUCRJST 21, 2003 · CURTIS R. LONG - 2 £ c~me<t "~¢ within n~.m.--~ .......................................................................... ~'.'s ~¢~'on of the .~r~.~r.i~ d~b.~ .~l.a <he ~.~Fur%~.n~nc.~. zad ._~]tlI..D_E_P_OS~SF~IiI~ RETURNED STAYED AS PER ATT¥ 9/22/03 ................................................................ Ac~ y_a ~.e_ .C o_a t s_: _ _ _15/1. Oil Sheriff's Costs· Sheriff's Costs: 33.10 · 116.90 E~k~i-ng- ......... i~-~(DO ......................................................................... Poundage .65 .P_r_q _t _h_o_ _n_o_ _t _a_r_ y_z ..... _1_._ O{}. ................................... R~f~nr~eff_t~.A~tSr_Oh__~/2~/O3 Milage 3.45 Surcharge 10. O0 33.10 ....................................................................... FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff JP MORGAN CHASE BANI( FORMELY KNOWN AS THE CHASE MANHATTAN BANK SUCCESSOR BY MERGER TO CHASE BANK OF TEXAS, NATIONAL ASSOCIATION, FORMELY KNOWN AS TEXAS COMMERCE BANK, N.A., AS TRUSTEE AND CUSTODIAN BY SAXON MORTGAGE SERVICES, INC., F/K/A MERITECH MORTGAGE SERVICES INC., F/K/A MERITECH MORTGAGE SERVICES, INC. Plaintiff VS. MICHAEL R. FEMMER OR OCCUPANTS Court of Common Pleas CUMBERLAND County No. 03-3066 CIVIL TERM Defendant(s) _PRAECIPE TO WITHDRAW COMPLAINT~ _WITHDRAW JUDGMENT AND DISCONTINUE AND E~ND ACTION~ WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, withdraw the judgment and mark this case discontinued and ended, upon payment of your costs only. Attorney for Plaintiff