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Home My WebLink About03-5958THE LAW OFFICES OF BARBARA A. FEI'N, 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, Plaintiff, CARL E. HOLLINGSWORTH and OCCUPANTS OF 5 Wayne Road Camp Hill, PA 17011, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION EJECTMENT NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAFNST THE CLALMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTEI~ING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEy AND FR,ING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAIN ST 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 PROPERYY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE TH1S 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 Court Administrator 4th Floor Cumberland County Court House I Courthouse Square Carlisle, PA 17013 (717) 240-620q 03-103 89/P0315 ] 5 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZG A pART~. DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA~ SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USrED SIN PREVIO AVISO O NOTIFICACION O POR CUALQIER QUEJA O ALIVIO QUE ESPEDIDO EN L4k PETICION DE DEMANDA. USTED PUEDE PEKDER DINERO, SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TiENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTKA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCLA LEGAL Cumberland County Court Administrator 4th Floor Cumberlal~d County Court }louse 1 Courthouse Square Carlisle, PA 170] 3 (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, Ste 800, Philadelphia, PA 19103. 2. (a) The Defendant, Carl E. Hollingsworth, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 5 Wayne Road, Camp Hill, PA 1701 l, hereinafter referred to as the "Premises". (b) The Defendant, Carl E. Hollingsworth, is an individual whom Plaintiff believes 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 by reference, were sold at the Cumberland County Sheriffs Sale conducted on September 3, 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 Mortgage Electronic Registration Systems, Inc. v. Carl E. Hollingsworth, as Court Docket Number 03-1632 Civil Term. 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 of a 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 September 3, 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. FE1N, P.C. Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D, No. 53002 ALL THAT CERTAIN piece of parcel of land, with the buildings and improvements thereon erected, being known as Lot No. 111 on revised plan of lots laid out for Allen Park Development Corporation, called "Cumberland Park", as recorded in Plan Book 4 Page 86, Cumberland County Records. Situate on the Westerly side of Wayne Road (formerly Avenue "L'), Cumberland Park, Town. ship of Lower Allen, County and Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to-wit: BEGINNING at a point on the Westerly side of Wayne Road, (formerly Avenue "L") 50 feet wide at a distance of 450.02 feet measured South 26 degrees 26 minutes 30 seconds East from the intersection of the said side of Wayne Road (formerly Avenue "L")with the Southerly side of Cumberland Drive (formerly Avenue"F") 50 feet wide both lines produced; thence along the Westerly side of Wayne Road (formerly Avenue "L"), South 26 degrees 26 minutes 30 seconds East, a distance of 1.30 feet to a point of curve; thence still along the said side of Wayne Road (formerly Avenue "L") in a Southerly direction along a line curving to the right having a radius of 239.44 feet to the arc distance of 70 feet to a point; thence along Lot No. 112 South 68 degrees 55 minutes 30 seconds 'West a distance of 110.32 feet to a point; thence along other lands of Allen Park Development Corporation North 26 degrees 26 minutes 30 seconds East, a distance of 60 feet to a point; thence along the Lot No. 110 North 63 degrees 33 minutes 30 seconds East a distance of 120 feet to the first mentioned point and place of begiuning. UNDER AND SUBJECT of said reservations and restrictions as contained in prior deeds. 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 unswom falsification to authorities. Dated: November 11, 2003 THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY:~in~, E~'re~' Attorney for Plaintiff Attorney I.D. No. 53002 THE 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, Plaintiff, CARL E. HOLLINGSWORTH and OCCUPANTS OF 5 Wayne Road Camp Hill, PA 12011, DefendantS. cOURT OF COMMON PLEAS CUMBERLAND CouNTY 03-5958 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark the above referenced matter discontinued and ended without prejudice to settled, Plaintiff. THE LAW OFFICES OF BARBARA A. FEIN, Attorney I.D. No. 29992 P.O. Dated: i}ecember 1, 2003 SHERIFF'S RETURN - NOT SERVED CASE NO: 2003-05958 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORT ASSOCIAT VS HOLLINGSWORTH CARL E ET AL R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: HOLLINGSWORTH CARL E unable to locate Him COMPLAINT - EJECTMENT but was in his bailiwick. He therefore returns the the within named DEFENDANT NOT SERVED , as to , HOLLINGSWORTH CARL E 5 WAYNE ROAD CAMP HILL, PA 17011 SERVICE STOPPED PER FAf~ FROM ATTORNEY. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Soanswer.//answe : ~ /R. Thomas Klfr~e Sheriff of Cumberland County BARBARA FEIN 11/17/2003 Sworn and subscribed to before me this /4 day of ~~_. A.D. Prothonotary