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Home My WebLink About99-04039 iI 0 NI V IL 0 P. ? V M o? 4 FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 FT MORTGAGE COMPANIES 8001 STEMMONS FREEWAY DALLAS, TX 75247 V. JASON P. RHOADS OR OCCUPANTS 1129 MOUNTAIN ROAD NEWBURG, PA 17240 Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Term . No. 99-lgov Cu 41( r'zt'l CIVIL ACTION - EJECTMENT - 3020 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 telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY 1ND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is FT MORTGAGE COMPANIES 2. Defendant is JASON P. RHOADS OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 1129 MOUNTAIN ROAD, NEWBURG, PA 17240, 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. FRANK FEDERMAN Attorney for Plaintiff ALL THAT CERTAIN tract of land -situate in Upper Mifflin Township, :umberland County, Pennsylvania, bounded and described in accordance with i Plan prepared by Rodney Lee Decker, R.P.L.S., dated February 25, 1993 and .*ecorded in the Office of the Recorder of Deeds for Cumberland County in Ilan 67, page 22. BEGINNING at a point in centerline of Mountain Road, S.R. 4007 at :orner of Lot No. 7, South 22 degrees 56 minutes 05 seconds East 365.00 feet to a point; thence still along Lot Nu, 7, South 08 degrees 15 minutes i5 East 323.53 feet to a point; thence along LwL No. 6 on Plan, South 52 tegrees 32 minutes 30 seconds West 240.00 feet to a point; thence along Lot fo._.,l0.,•North 28 degrees 29 minutes 55 seconds West 450.63 feet to a point ommon to Lots 10, 9 and 8; thence along _Lot No. 9, the following 2 courses nd distances: 1) North 62 degrees 13 minutes 50 seconds East 160.00 feet; ) North 23 degrees 16 minutes 25 seconds West 275.00 feet to a point in !enterline of Mountain Road, S.R. 4007; thence along centerline of Mountain oad, S.R. 4007, North 66 degrees 43 minutes 35 seconds East 200.15 feet to point, the place of BEGINNING. CONTAINING 4.240 acres and designated as Lot No. 8 of Mountain View rchard. BEING the same property which Harry H. Fox, Jr. and Ann G. Fox, usband and wife and John H. Fox and Cinda L. Fox, husband and wife by deed ated November 15, 1995 and recorded December 15, 1995 in the Recorder of eeds Office in and for Cumberland County, Pennsylvania in Record Book 132, age 851 granted and conveyed unto S & A Custom Built Homes, Inc.. PREMISES: 1129 MOUNTAIN ROAD NEWBERG, PA 17240 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 die statements made in die 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: _ 21 Z8 Fr k Federman, Esquire ?` `5 (? ? ? G., ?`J ?? Cl? ?? ?? ??a?? ????? ????? ,? ?. SHERIFF'S RETURN - REGULAR CASE NO: 1999-04039 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES VS. RHOADS JASON P KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon RHOADS JASON P the defendant, at 9:45 HOURS, on the 29th day of July 1999 at 11 CHESTNUT ST NEWVILLE, PA 17241 CUMBERLAND County, Pennsylvania, by handing to JENNIFER RHOADS (WIFE) a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 11.16 Affidavit .00 00 i/ Surcharge 8.00 R` it ne iii - $3 FEDERMAN & PHELAN 07/29/1999 by , l??I epu eri Sworn and subscribed to before me this ?29'_" day of 19A.D. 0A Ir ro ono'y UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Jason P. Rhoads Chapter No. 7 Jennifer R. Rhoads Debtor(s) Bankruptcv N FT Mortgage Companies Movant V. Jason P. Rhoads Jennifer R. Rhoads Respondant (s) ORDER AND NOW, this -- ? day of ,1999,upon consideration of the Motion for Relief and Motion for Default of Movant, FT Mortgage Companies, it is hereby ORDERED that the Order for Relief be entered by default with respect to premises at 1129 Mountain Road, Newburg, PA 17240, to allow the Movant to foreclose on its mortgage, which mortgage was recorded in Cumberland County, in Mortgage Book 132, Page 851, to allow the Movant to foreclose on its mortgage, and allow the purchase of said premises at Sheriff's sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. By the Court: Robert J. Woodside, Bankruptcy Judge cc: Judith T. Romano, Esquire Leslie E. Puida, Esquire Brenda L. Brogdon, Esquire Two Penn Center Plaza Suite 900 Philadelphia, PA 19102 Steven P. Miner, Esquire P.O. Box 5300 Harrisburg, PA 171100300 Jason P. Rhoads Lawrence G. Frank, Esquire (Trustee) Jennifer R. Rhoads 2023 North Second Street 11 Chestnut Street Harrisburg, PA 17102 Newville, PA 17241 - A:4•M• i court ?, _? -: .- ; ,: . ?J . 1: - ??? - ; _ _ tT _. ,.. !? i? ?Z FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 TWO PENN CENTER PLAZA Philadelphia, PA 19102 (215) 563-7000 FT Mortgage Companies 8001 Stemmons Freeway vs. Jason P. Rhoads OR OCCUPANTS Plaintiff Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-4039 CUMBERLAND COUNTY PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment With reference to the above captioned matter. Frank Federman, Esquire Attorney for Plaintiff Date: October 8, 1999 SHERIFF'S RETURN - REGULAR CASE NO: 1999-04039 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES vs. RHOADS JASON P HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within REINSTATED COMPLAINT/ EJECTMENT was served upon RHOADS JASON P the defendant, at 11:50 HOURS, on the 22nd day of October 1999 at 11 CHESTNUT STREET NEWVILLE, PA 17241 CUMBERLAND County, Pennsylvania, by handing to JENNIFER RHOADS (WIFE) a true and attested copy of the REINSTATED COMPLAINT/ EJECTMENT together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 7.44 ??• Affidavit .00 ti! Surcharge 8.00 omas R ine, eri $J3.44 FEDERMAN & PHELAN 10/25/1999 / by epu y er Sworn and subscribed to before me this 4 5' day of 19 99 A. D. rot?no?ary WRIT OF POSSESSION :, Ejectment Proceedings PRC_ P 3160 • 3165 etc) ___RT_MD3MPA99_ COMTANIES---------------- y. ___ rtASDRY._]190ARS _DR l2CCUPAtTC&---_-_-. i -_-1129_21QS1lTl/1x11_BDd]L------------------ i NEWBURG, PA 17240 CONDAONIVEALTH OF PE.Y SYLV•ANIA: COON-rY OF CUN[BERL?.N'D: r.\? THE COURT OF CO%[N[ON PLE4S OF CL-%[BERLAND COUN-r-y, ?EVYSYLV.?-%4J.iL - ---- Tern io-- No. 99_4039--- Civil --------- ----- - No. ---------•---------------------- T^.m ------ Cons A--- - ------------------------------- .S_ 140_10-- or•d s` 5--------- 1.00 Prornv. ----------------------------- ?---------- CUMBERLAND To the Sheriff oi ________________.------------------ Coun:c. Penna. [? To sadsiv die judpnen: for possession is :be abo ve na?er you a:e di:ec:eci :o decver possession ci the . iowmg described gropeny w: FT MORTGAGE COMPANIES ------- ----------------------------- ---- ----------------------------------------------------------------------------------------- ?!a arff s being P:e=m 3s foi ows) : 1129 MOUNTAIN ROAD NEWBURG, PA 17240 i:' To sa-isr ' + se casts i;aiasc the defeadaac ;s, you are directed ro :ev+• _pon anv proper of de deien- dart s; arc' sea cis ter or rnei. :rcerest :ereia. CURTIS R. LONG '------------------ .---° ------------- Prochonom.n-. Cr-t P14 Cou.? of Cunber!rd Co P. my _ December 8, 1999 c? 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O i 1 .•i , i C V- 1< V¢ M i I ; ? I Q ? T o d a [? i F r sn `N'I FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 Suite 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 FT MORTGAGE COMPANIES ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION vs No. 99.4039 JASON P. RHOADS OR OCCUPANTS CUMBERLAND County 1129 MOUNTAIN ROAD NEWBURG, PA 17240 PRAFCIPF FOR.IIJI) MFNT IN FIFCTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, FT MORTGAGE COMPANIES and against the Defendant(s) JASON P. RHOADS and OR OCCUPANTS for possession of premises 1129 MOUNTAIN ROAD, NEWBURG, PA 17240 for failure to file an Answer within twenty (20) days of service. I hereby certify that according 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. FRANK FEDERI? AN, CS' IRE Attorney for Plaintiff Default Judgment entered as indicated above. DATE FEDERMAN AND PHELAN Frank Federman, Esquire Identification Number 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FT MORTGAGE COMPANIES V. JASON P. RHOADS OR OCCUPANTS TO: JASON P. RHOADS OR OCCUPANTS 1129 MOUNTAIN ROAD NEWBURG, PA 17240 DATE OF NOTICE: November 12, 1999 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-4039 CIVIL THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE You are in default because 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: :RLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 Frank Federma , Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 Suite 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 FT MORTGAGE COMPANIES vs JASON P. RHOADS OR OCCUPANTS 1129 MOUNTAIN ROAD NEWBURG, PA 17240 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 99-4039 CUMBERLAND County 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. (b) That defendant JASON P. RHOADS Or occupants, is over 18 years of age, and resides at 1129 MOUNTAIN ROAD, NEWBURG, PA 17240. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. RANK FEDE 1-IAN, ESQUIRE Attorney for Plaintiff rJ- (il S? v? b PRAECIPE 1:011 WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FT MORTGAGE COMPANIES COURT OF COMMON PLEAS CIVIL DIVISION vs JASON P. RHOADS OR OCCUPANTS 1129 MOUNTAIN ROAD NEWBURG, PA 17240 No. 99-4039 CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of 1129 MOUNTAIN ROAD, NEWBURG, PA 17240 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTION' Being Known as No. 1129 MOUNTAIN ROAD L FR NK FEDER AN, ESQC/UrlrRE0? ATTORNEY FOR PLAINTIFF >- cr3 CO a 1 - /- c. 1 a', i_: O? U umberlandd County, Pennsylvania, houndedtandndescribedfinlacco dance with Plan prepared by Rodney Lee Decker, R.P.L.S., dated February 25, 1993 and ecorded in the Office of the Recorder of Deeds for Cumberland county in !an 67, page 22. BEGINNING at a point in centerline of Mountain Road, S.R. 4007 at orner of Lot No. 7, South 22 degrees 56 minutes 05 seconds East 365.00 eet to a point; thence still along Lot No. 7, South 08 degrees 15 minutes 5 East 323.53 feet to a point; thence along Lot No. 6 on Plan, South 52 egrees 32 minutes 30 seconds West 240.00 feet to a point; thence alonq Lot 0.x.0-,.North 28 degrees 29 minutes 55 seconds West 450.53 feet to a point ommon to Lots 10, 9 and 8; thence alone _Lot No. 9, the following 2 courses nd distances: 1) North 62 degrees 13 minutes 50 seconds East 160.00 feet; ) North 23 degrees 16 minutes 25 seconds West 275.00 feet to a point in enterline of mountain Road, S.R. 4007; thence along centerline of Mountain oad, S.R. 4007, North 66 degrees 43 minutes 35 seconds East 200.15 feet to point, the place of BEGINNING. CONTAINING 4.240 acres and designated as Lot No. 8 of Mountain View rchard. BEING the same property which Harry H. Fox, Jr. and Ann G. Fox, lusband and wife and John H. Fox and Cinda L. Fox, husband and wife by deed fated November 15, 1995 and recorded December 15, 1995 in the Recorder of eeds Office in and for Cumberland County, Pennsylvania in Record Book 132, ;age 851 granted and conveyed unto S & A Custom Built Homes, Inc.. PREMISES: 1129 MOUNTAIN ROAD NEHBERG, PA 17240 _y Ll C\l N G_. C1 f t C?- cn R'I.I U 2I - I? !.. f`