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Home My WebLink About03-3090THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen J. DiPaolo, Esquire / I.D. No. 79992 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaimiff, DENNIS L. PORTER and OCCUPANTS OF 27 Back Street Plainfield, PA 17081, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 03 -- 3dqt3 CIVIL ACTION EJECTMENT 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 TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE pERSONALLY OR BY ATTORNEY AND FIHNG 1N 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 ANY 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 Cttmberland County Court Administrator 4th bloor Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 03-10023/P031011 I~ HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUHINTES, USTED TIENE (20) DIAS DE PI~ZO A PARTIR DE LA FECHA DE LA DEMANDA y LANOTIFICACION. USTED DEBE PRESENTAR UNA APARIENC1A ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS O SUS OBJEClONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AV1SADO QUE SI USTED NO SE DEF1ENDE, LA CORTE TOMARA MEDIDAS y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION O POR CUALQIER QUE~A O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PEP. DER DINERO, SUS PROP1EDADES O OTROS DERECHOS 1MPORTANTES PARA USTED. LEEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TI~NE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TEI~FONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR IX)NDE USTED PUEDE CONSEGU1R ASISTENCIA LEGAL. Cumberland County Court Administrator 4th Floor Cumberland County Court House 1 Courthouse Square Carlisle~ PA 17013 (717) 240-6200 CIVIL ACTION -- EJECTMENT 1. The Plaintiff, Federal National Mortgage Association, is a corporation authorized to do business within the Commonwealth of Pennsylvania, having its principal place of business at 1900 Market Street, Suite 800, Philadelphia, PA 19103. 2. (a) The Defendant, Dennis L. Porter, is an individual whom Plaintiffbelieves and therefore avers is residing at the property address, that being 27 Back Street, Plainfield, PA 17081, hereinafter referred to as the "Premises". (b) The Defendant, Dennis L. Porter, is an individual whom Plaintiffbelieves and therefore avers is residing at the Premises. (c) The Defendant (Unknown) Occupant(s) is/are individuals whom Plaintiff believes and therefore avers are residing at the Premises. 3. The Premises which are described at Exhibit "A" attached hereto and incorporated herein byreference, were sold at the Cumberland Cotmty Sheriffs Sale conducted on June 11,2003, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment entered in the Court of Common Pleas for Cumberland County at the suit of Atlantic Mortgage and Investment Corporation, a Division ofABN Amro Mortgage Group, Inc. v. Denn/s L. Porter, Debra L. Porter, Stewart H. Porter and Peggy Ann Porter, as Court Docket Number 00-8690. 4. The Premises were purchased by the Plaintiff at the Sheriffs Sale, said sale results being a matter of public record. 5. The Plaintiff acquired title to the Premises on the date of and by virtue of said Sheriffs Sale, and is the real and current entitled owner of said Premises by virtue ora Cumberland County Sheriffs Deed Poll, to be recorded in the Cumberland County Recorder of Deeds' Office at the earliest possible date. 6. The persons in possession of the Premises are believed to be the Defendant(s) in this action and are occupying the Premises without right and without claim to title. 7. The Defendants herein named were duly served with Notices of the Sheriffs Sale held on June 11,2003. 8. Plaintiff has demanded possession of the Premises from the Defendant(s) who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff, Federal National Mortgage Association, respectfully requests entry of judgment for immediate possession of the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. Respectfully Submitted, THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fern, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 ALL THAT CERTAiN tract or lot of grouud with the improvements ahereon erected situate in thc Village of Plainfield, Township of West Penmboro, County of Cumberland, and Sta~e of Pcrmsylva~a, and bounded and described as follows: BEGINNING at a post in the road from Mt. Rock to Hepbum's Mill (now called Burgaer's Mill); thence by said road South 59 1/2 degrees West, 9.54 perches to a post; thence by lot now or formerly of Albert Finkenbinder, North 5 1/2 degrees West 13.8 perches to a post; theuce by lot now or formerly of Samuel Shambaugh, North 82 degrees East, 8.72 perches £o a post; thence by the same, south $ dcgrees West, 10.04 perches to the place of beginning. Containing One Hundred and One (101) perches, more or less, and being improved with a frame dwelling house. Tax Parcel #46-18-1394-077 VERIFICATION BARBARA A. FEIN, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Affidavit, and that the statements made in the foregoing Civil Action Complaint in Ejectment are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: June 26, 2003 THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-03090 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDEP~AL NATIONAL MORTGAGE VS PORTER DENNIS L ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT PORTER DENNIS L unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT - EJECTMENT the within named DEFENDANT 27 BLACK STREET PLAINFIELD, PA 17081 HOUSE HAS BEEN BURNED OUT AND PORTER DENNIS L IS VACANT. , NOT FOUND as to Sheriff's Costs: Docketing 18.00 Service 3.45 Not Found 5.00 Surcharge 10.00 .00 36.45 R. Thomas Kline Sheriff of Curaberland County BARBARA FEIN 07/10/2003 Sworn and subscribed to before me this 76 ~ day of~__ Prot ~lo~ot ary ~ THE LAW OFFICES OF BARBARA A. FEIN, Barbara A. Fein, Esquire / I.D. No. Kristen U. DiPaolo, Esquire / I.D. 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff 53002 No. 79992 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, DENNIS ~.. PORTER and OCCEPANTS OF 27 Back Street Plainfield, PA 17081, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 03-3090 Civil Term PRAECIPE TO SETTLE, DISCONTINUE, AND END TO ?HE PP, OTHONOTARY: Kindly mark the above referenced matter settled, dis{ontinued and ended without prejudice to Plaintiff. Dated: December 29, 2003 THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: ein, Al terney for Plaintiff Attorney I.D. No. 53002