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Home My WebLink About03-5266Federman and Phelan, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 GMAC Mortgage Corporation 500 Enterprise Road, Suite 150 Horsham, PA 19044 Jackie Keck Or Occupants 602 East Keller Street Mechanicsburg, PA 17055 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No, d)~ -~.~/~ ~TVTT, ACq'ION - **This finn is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a ~ge in ba~cruptcy emd this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only entorcement of a lien against property.** 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 ffyou 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. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is GMAC Mortgage Corporation. 2. Defendant is Jackie Keck Or Occupants. Plaintiff is equitable owner of premises located at 602 East Keller Street, Mechanicsburg, PA 17055, a legal description of which is attached. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on September 3, 2003, Plaintiff, by virtue of the above, is the equitable 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. PlainUff 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. nan, Esquire /~ttorney for Plaintiff ALL THAT CEP-,.AIN piece or parcel of land aii:uata in the ~c3~3u~ of Mechanic~sb~.;rg, Cumberland Co., Pennsylvania, mom particularly Secaon H; ~ )rice Sou~ 5 degrees 17 minutes East, a dis~nce or 135.~g feet to a Lot IJ=. 13 on said Plan; ~ence along ~id Lot No. 13, South 88 17.04 feet ~ '~ No. 31, Se~on H; thence No~h 18 d~raas 8S minutes place of ~EG;NNING. Francis S. Hallinan hereby states that he is the attorney for the Plaintiff in this ~viction action and is authorized to make this verification. The statements made in the foregoing Civil Action - Ejectment are correct to the best of my knowledge, information, and belief. I was the attorney for the Plaintiff or Plaintiffs predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on the property at the sheriffs sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this property at sheriffs sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date ~Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-05266 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPOP~ATION VS KECK JACKIE REGULAR ROBERT BITNER , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT KECK JACKIE DEFENDANT , at 1114:00 HOURS, at 602 EAST KELLER STREET MECHANICSBURG, PA 17055 SARAH KECK, DAUGHTER a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 9th day of October , 2003 by handing to - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Service 6.90 . Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 34.90 10/10/2003 FEDERMAN & PHELAN Sworn and Subscribed to before me this /d~ day of ~j J~ A.D. ~! Prothonotary , ' FEDERMAN AND PHELAN L.L.P. By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff GMAC Mortgage Corporation COURT OF COMMON PLEAS VS CIVIL DMSION No. 03-5266-Civil Term Jackie Keck Or Occupants 602 East Keller Street Mechanicsburg, PA 17055 Cumberland County PRAECIPE FOR .HYDGMENT 1N E.IECTMF, NT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment m favor of the Plaintiff, GMAC Mortgage Corporation and against the Defendant(s) Jackie Keck and Or Occupants for possession of premises 602 East Keller Street, Mechanicsburg, PA 17055 for failure to file an Answer within twenty (20) days of service. I hereby certify that accorchng to Rule 237.1, written 10 day notice of PlaintifPs 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. ~l:t~rney 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 (215) ~63-7000 GMAC MORTGAGE CORPORATION Plaintiff VS. JACKIE KECK OR OCCUPANTS Defendants ATTORNEY FOR PLAiNTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-5266 CIVIL TERM TO: JACKIE KECK OR OCCUPANTS 602 EAST KELLER STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: OCTOBER 30, 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.IF 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. 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W1THOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW~ER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~,JIAWRENCE T. PHEEAN, ESQUIRE FRANCIS S. HALL1NAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN L.L.P. By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 GMAC Mortgage Corporation VS Jackie Keck Or Occupants 602 East Keller Street Mechanicsburg, PA 17055 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 03-5266-Civil Term Cumberland County VERIFICATION OF NON-MI1JTAR¥ SERVICE FRANCIS S. HALLINAN, 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 Jackie Keck Or occupants, is over 18 years of age, and resides at 602 East Keller Street, Mechanicsburg, PA 17055. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA GMAC Mortgage Corporation vs Jackie Keck Or Occupants 602 East Keller Street Mechanicsburg, PA 17055 County of Cumberland COURT OF COMMON PLEAS CIVIL DIVISION No. 03-5266-Civil Term Cumberland County PRAF, CIPE FOR V/RIT 13F PO,q.qFq%qll3N TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 602 East Keller Street, Mechanicsburg, PA 17055 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 602 East Keller Street r Plaintiff ALL THAT CERAIN piece or paccel of land situate in the Bomugl. of 17.04 fee~ to JACKIE KECK OR OCCUPANTS No ................................ ~' - .-zrm 20_ ..... .~::'~.. ............................... s___A!4_:_4_o__ ? ~c.',.y ............................. S ..... 3_._0_0___ CO U.~, ~'T%' OF CUMBERLAND ................................... .......................................................................................... b~L-:~: . P.-t-'--'.~-~ ~ ,o~ow~) : 602 EAST KELLER STREET MECHANICSBURG, PA 17055 November 13,, 2003 f c~ :he wid~in n~ .......................................................................... :e an...e ~ses~n o~ ~ ~c~i~ d~ ~i:h :he ~':~=c~. ~nd WRIT OF EXECUTION RETURNED STAYED~ PROPERTY IS VACANT. .......................................................... ~aV~--~' ~ ..........i~b~ ...... ~barA~_'_ ~_.~ ~_ ~_~ ..................................... ~S~X~ ~_'4._~PA~_~ ........ A7, ~_3 ...... Docketing 18.00 102.47 ~p~pJ_~ ........... , ~A ........................................................................... Pro ~h. 1. O0 ~L~ ........... X,}-t ................................ · e~u~e~. ~o- AC ~F - aa- -1-1/-~/~ 3 .... Surcharge 20.00 ~/.D3 ~,~i~~ '-' r,,' JACKIE KECK OR OCCUPANTS 03-5266-Civil Term T-~r'~ 20_ ..... ................................. T - .~"~ 20 ............................... ~___3_!~_ _-_a_o_ _ ~ ............................. ~ ........... ?~o=~' ............................. ~ ..... 3_._0_0___ COU* r-VY OF CUMBERLAND To i--e 5h~ of _---. ............................... .......................................................................................... Pbd=dff 602 EAST KELLER STREET MECHANICSBURG, PA 17055 . Curtis R. Long ........ 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 GMAC MORTGAGE CORPORATION Plaintiff VS. JACKIE KECK OR OCCUPANTS Defendant(s) Court of Common Pleas CUMBERLAND County No. 03-5266 C.T. PRAECIPE TO WITHDRAW COMPLAINT, VACATE JUDGMENT AND DISCONTINUE AND END ACTION~ WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, vacate the judgment and mark this case discontinued and ended, upon payment of your costs only. F/rrank Federman / Attorney for Plaintiff