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Home My WebLink About08-2366Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 Market Street Suite 800 Philadelphia, PA 19103 V. JAMES F. WARNOCK OR OCCUPANTS 574 Valley Street P.O. Box 501 Summerdale, PA 17093 22430-CFC-VJ Attorney for Plaintiff : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff : /? : NO. O$? d-Ndo Givi i lerf4 Defendant(s) CIVIL ACTION - EJECTMENT NOTICE ADVISO 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 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 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 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 Market Street Suite 800 Philadelphia, PA 19103 V. JAMES F. WARNOCK OR OCCUPANTS 574 Valley Street P.O. Box 501 Summerdale, PA 17093 22430-CFC-VJ Attorney for Plaintiff : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff : : NO. D?- d 3 G G 42t-?d- '7Z- Defendant(s) : CIVIL ACTION - EJECTMENT 1. Plaintiff, Federal National Mortgage Association, is the owner of premises known as 574 Valley Street P.O. Box 501, Summerdale, PA 17093, more fully described in the legal description, a true and correct copy is attached hereto, made part hereof and marked as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on March 05, 2008, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, Docket No. 07-1841 civil term where Plaintiff was the successful bidder. 3. The Plaintiff became the owner of the said property by a sheriff's deed recorded on March 24, 2008 in the Office of the Recorder of Cumberland County at Recording No. 200808853. A true and correct copy is attached hereto, made part hereof and marked as Exhibit I1. 4. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The Defendants James F. Warnock or occupants are occupying the said premises without right, and so far as the Plaintiff is informed, without claim of title. WHEREFORE, plaintiff demands judgmen r possession of 574 V Hey Street P.O. Box 501, Summerdale, PA 17093. Martha E. Von Rosenstiel Attorney for Plaintiff G VERIFICATION I verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C:S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff L ' Dated: April 08, 2008 EXHIBIT I AM TW CS*tkl * unit in the property known, named and Identified located in fast eretobere as Creakside Village Condors' slum, has Township, Cumberland County, Pennsylvania, which hrUS Act been submitted to the provisions recording of tttnr Uniform the Recorder o Deeds 68, pa. C.3. 3101 st serq, by Office of Cumberland County, ponnsylvania, on November 29, 1984, in Miscellaneous Book 381, page 71, of a Declas:atioo dated November 28, 1984 which unit is designated as Unit No. 4 In said Declaration. with all right, title and interest, being a 9.0909% and I ion Plans Cle ntthesatfore ? dtDecla?ration of Co dominium and Declara t azin the some promises which Michael c. manning and Loretta R. Manning, husband and wife, by their deed dated September 21, 1988 and recorded March 7, 1990 in the office of the Recorder of Deeds Air,. is and for and conveyed unto Fred P. Cater Record and Cheri 4 Page granted Swaim, as Tettazsts in Common, the ?nsn nd herriin. hey have Ubrinok 'joins in this dead to convoy any to the subject premises. CINMR A" Bt3JSC1 to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants d contained of the Crre ksids village Condominium and restrictions Plans, as and ?'•" ?.Breti?r Ass*clat ion - VrJt AND SUBJSCT to easements, :restrictions, reservations, conditions and rights-of-way of record. AND BEING the same premises which were sold to FEDERAL NATIONAL MORTGAGE ASSOCIATION, as Trustee by the Sheriff of CUMBERLAND County on March 05, 2008 in execution of a judgment in mortgage foreclosure entered in the Court of Common Pleas of CUMBERLAND County Docket No. 07-1841 civil term. a-'-q30T8L1 , vC LA " ? -01 Tax Parcel No. 09-12-2993-071B (U-4) Know all Men by these Presents That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to Federal National Mortgage Association, Fannie Mae, NPDC REAL ESTATE SALE NO. 48 Writ No. 2007-1841 Civil Term Federal National Mortgage Association, by its agent, Fulton Bank VS James F. Warnock Attorney Shawn M. Long ALL THAT CERTAIN unit in the property known, named and identified as Creekside Village Condominium, located in East Pennsboro Township, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Uniform Condominium Act, 68, Pa. C. S. 3101 et seq by the recording in the Recorder of Deeds Office of Cumberland County, Pennsylvania, on November 29, 1984, in Miscellaneous Book 301, Page 71, of a Declaration dated November 28, 1984 which unit is designated as Unit No. 4 in said Declaration. TOGETHER with all right, title and interest, being a 9.0909% interest in and to the Common Elements as is more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. BEING THE SAME PREMISES which Fred P. Connor, married individual and Cheri Ann Swaim, now known as Cheri Ann Uhrinek and Joseph M. Uhrinek, husband and wife, by deed dated June 7, 1996 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 140, Page 900, granted and conveyed unto James F. Warnock. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Declaration Plans, and By-Laws of the Creekside Village Condominium Association. UNDER AND SUBJECT to easements, restrictions, reservations, conditions and rights-of-way of record. SEIZED IN EXECUTION as the property of James F. Warnock on Judgment No. 07-1841 Civil Term. The same having been sold by me to the said grantee on the 5th day of March Anno Domini Two Thousand and Eight (2008) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 30th day of October Anno Domini 2007 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Seven (2007) Number 1841 at the suit of Federal National Mortgage Association against James F. Warnock. In Witness Wereof, I have hereunto affixed my signature this 19th day of March Anno Domini Two Thousand and Eight (2008) R. Thomas Kline, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curtis Long, Prothoribbary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 19th day of March Anno Domini Two Thousand and Eight (2008) P °th , -NOTAF0 PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 I hereby certify that the residence And Post Office address of the Within Grantee is Conveyance Claims P.O. Boa 650043 Dallas, TX 75265-0043 Solicitor C ? REV-183 EX (6-96) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES DEPT. 280603 HARRISBURG, PA 1T128-0603 REALTY TRANSFER TAX STATEMENT OF VALUE See Reverse for instructions y Complete each section and file In duplicate with Recorder of Deeds when (1) the full value/consideration is not set forth in the deed, (2) when the deed is without consideration, or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on: (1) family relationship or (2) public utility easement. If more space is needed, attach additional sheet(s). A CORRESPONDENT - All inquiries may be directed to the following person: Name Telephone Number: Shawn M. Long, Esquire Areacode(717 ) 299-5201 Street Address city State Zip Code 126 East King Street Lancaster PA 17602 B TRANSFER DATA Date of Acceptance of Document Grantor(s) /Lessor(s) Grantee(s)lLassee(s) Sheriff, Cumberland County Federal National Mortgage Association, Fannie Mae, NPDC Street Address Street Address One Courthouse Square Conveyance Claims, P.O. Box 650043 City State Zip Code City State Zip Code Carlisle PA 17013 Dallas TX 75265-0043 G PROPERTY LOCATION 574 Vallev Street East Pennsboro Townshi Cumberland I East Pennsboro Area 09-12-2993-071 B(U-4) D VALUATION DATA successful bid of $1.00 + - 0 - 4. County Assessed Value S. Common Level Ratio Factoi $85,950.00 x 1.22 E EXEMPTION DATA Ia. Amount of Exemption Claimed 1b. Percentage of Interest Com 100% 1.00 2. Check Appropriate Box Below for Exemption Claimed ? Will or intestate succession = successful bid of $1.00 $104 (Name of Decedent) (Estate File Number) ? Transfer to Industrial Development Agency. ? Transfer to a trust. (Attach complete copy of trust agreement Identifying all beneficiaries.) ? Transfer between principal and agent. (Attach complete copy of agency/straw party agreement) ? Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or In lieu of condemnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. Mortgage Book Number 1325 , Page Number 428 ? Corrective or confirmatory deed. (Attach complete copy of the prior deed being corrected or confirmed,) ? Statutory corporate consolidation, merger or division. (Attach copy of articles.) ? Other (Please explain exemption claimed, if other than listed above.) Under penalties of law, I declare that I have examined this Statement, including accompanying information, and to the best of my knowledge and belief, It is true, correct and complete. signature of Correspondent or Responsible Party Date zoo SLon , Es uire 3 r/°? C=) C) c. D ~ri Sty 93 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02366 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSO VS WARNOCK JAMES F ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WARNOCK JAMES F but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT the within named DEFENDANT WARNOCK JAMES F 574 VALLEY STREET NOT FOUND , as to SUMMERDALE, PA 17093 PER NEIGHBOR, 574 VALLEY STREET IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge H1a P/DY C,2 , So answers: _ 18.00 Jam' % '? 16.00 -/? 5.00 R. Th as Kline 10.00 Sheriff of Cumberland County .00 49.00 MARTHA VON ROSENSTIEL 04/25/2008 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02366 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSO VS WARNOCK JAMES F ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT the within named DEFENDANT . OCCUPANT 574 VALLEY STREET NOT FOUND , as to SUMMERDALE, PA 17093 PER NEIGHBOR, 574 VALLEY STREET IS VACANT. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 n .00 y/a g?e? `?`' ? 21.00 So answers-.R. Thomas`-Kline Sheriff of Cumberland County MARTHA VON ROSENSTILE 04/25/2008 Sworn and Subscribed to before me this day of A. D. 22430- CPG -VJ (disc & end) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF VS. JAMES F. WARNOCK OR OCCUPANTS : DEFENDANTS NO: 08-2366 CIVIL TERM PRAECIPE TO MARK CASE DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark this action discontinued and ended without prejudice. Martha E. Von Rosenstiel Attorney for Plaintiff Dated: April 28, 2008 r? ? {_? ?--? ?a f.+,,_: _ ..y f- ? ?? t „?.. --,' r- ,?... > .. `,-, ,:_? ?? ._ C:s "7 =,