HomeMy WebLinkAbout09-4679U?
GOLDBECK McCAFFERTY & MCKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY I.D. #56129
SUITE 5000 MELLON INDEPENDENCE CENTER
701 Market Street
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
Plaintiff
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Defendants
Term G VJ I
No. 0 - 4l/7?
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 the 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 :%rther notice for any money claim in the Complaint of 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 CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row, Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE
CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA
DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU
ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE
PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE
PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA
QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR
RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE
SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300.
LEGAL SERVICES INC
8 Irvine Row, Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, PA 17013
COMPLAINT IN EJECTMENT
Plaintiff is FANNIE MAE, International Plaza II, 14221 Dallas Parkway, Suite 1000,
Dallas, TX 75254-2916.
2. Defendants are HARPREET S. GULERIA, and OCCUPANTS.
3. Plaintiff is the owner of property located at 1920 Kent Drive, Camp Hill, PA 17011, by
virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on
7/9/2009 at Instrument # 200923833. A true and correct copy of the legal description of
the Property is attached to this Complaint.
4. Plaintiff is entitled to immediate possession of the Property.
5. The Defendants, HARPREET S. GULERIA and OCCUPANTS, are occupying the
Property without right, and so far as the Plaintiff is informed, without claim of title.
6. Plaintiff has demanded possession of the Property from the Defendants and
OCCUPANTS, who have refused to deliver up possession of the same.
WHEREFORE, Plaintiff requests judgment for possession of the Property.
GOLDBECK McCAFFERTY & McKEEVER
Ay:ii hae l McKeever, Esq.
VERIFICATION
i
Gk__ on behalf of the Plaintiff corporation within named do hereby verify
that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the
facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein are made subject to the penalties of
18 Pa. C.S. 4904 relating to unworn falsification to authorities.
Date:
ALL that certain messuage, tenement and tract of land situate in the Township of Lower
Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and
described as follows, to wit:
BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth
between parallel lines 120 feet in Block "B", as shown on Plan No. 4 of Highland Estates
Development, drawn by D. P. Raffensperger, Registered Surveyor, revised March 9,
1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's
Office in and for Cumberland County at Carlisle, Pennsylvania.
HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive
Camp Hill, PA 17011
UNDER AND SUBJECT to all existing easements, restrictions and conditions of record.
Parcel #13-23-0547-167
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OF TT
f'
110 ,
-S6 Al?
lPd
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
OF tCE OF ? c SnERIFF
OF THE
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
Fannie Mae
vs.
Harpreet S. Guleria
2009 JUL 22 PH 2: 28
Cis{?k? `,'., i' 'zV 3 S
!
i v r ?. Ja=;
Case Number
2009-4679
SHERIFF'S RETURN OF SERVICE
07/17/2009 11:41 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant to wit: Harpreet S. Guleria, but was unable to
locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the
defendant Harpreet S. Guleria. The request for service at 1920 Kent Drive Camp Hill, PA 17011 is vacant
The Camp Hill Postmaster has advised the defendant has moved and left no forwarding address. An
exact address is not available.
07/17/2009 11:41 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant to wit: OCCUPANTS, but was unable to locate
them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the
defendant OCCUPANTS. The request for service at 1920 Kent Drive Camp Hill, PA 17011 is vacant. The
Camp Hill Postmaster has advised the defendant has moved and left no forwarding address. An exact
address is not available.
SHERIFF COST: $67.50
July 17, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
GOLDBECK McCAFFERTY & MCKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
for Plaintiff
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
No. 09-4679
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTMfOR SUBSTITUTED SERVICE
- UNDER PA R C P 430(a)
Plaintiff, by and through its attorney, Michael T. McKeever, Esq., in support of its
Motion for Substituted Service, represents-as follows: -
1. Plaintiff is th • f the premises 1920 Kent Drive, Camp Hill, PA; V014OW
pursuant to a deed from the Sheriff of Cumberland County.
2. Plaintiff filed a Complaint in Ejectment on July 14, 2009 .
Sheriff has been unable to effect service of the Complaint upon Defendants despite
numerous attempts and despite the fact that Plaintiffs inspection of the premises indicates it is occupied.
4. As this is an action for possession, further investigation is unnecessary.
5. Defendants have no right, title or interest in the premises, 1920 Kent Drive, Camp Hill,
PA, 17011. Plaintiff believes and therefore avers that Defendants are deliberately avoiding service.
Plaintiffs inability to affect personal service upon Defendants has deprived, and
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
continues to deprive Plaintiff of the use and enjoyment of which it is the lawful owner.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to
serve the Complaint/Writ upon Defendants by posting the premises and certified and regular mail to the
Defendants' last known address.
Respectfully submitted,
G
.?
Ail
BY: chael T. McKeever, Esq.
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY.
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
No. 09-4679
VERIFICATION
I, Michael T. McKeever, Esq., Attorney for Petitioner do hereby verif3?that the facts set forth in
the foregoing Motion for Substituted Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein are made subject to the penalties of 18
Pa. C.S. 4904 rely unworn falsification to authorities.
BY: 'Michael T. McKeever, Esq.
GOLDBECKMcCAFFERTY & WEEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916"
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
09-4679
Term
No.
MEMORAMUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.RC.P. 430(a)
Plaintiff has filed a C laint in Ejectment, against Defendants which the Sheriff7has
been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a
good faith attempt to ascertain Defendants whereabouts without success. Accordingly, the Court may
approve alternative means of service s-0-Pa.R.C.P. 430(a).
CONCLUSION
For reasons stated above and in the attached Motion, the Court should enter an order
allowing Plaintiff to serve the Complaint in Ejectment upon Defendants by posting the premises and
certified mail and regular mail to the Defendants' last known address.
Respectfully submitted,
C Ld
Michael T. McKeever, Esq.
'mil
in- - _ ?? _?
ProVest, LLC
Affidavit of Good Faith Investgation
Client provided information:
File Number: 84235EJ
Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER
Subject Name: Harpreet S. Guleria a/k/a Harpreet Singh Guleria
Property Address:
Street: 1920 Kent Drive
City: Camp Hill State: PA
Skip Results:
Last Known
Street: 1920 Kent Drive
City: Camp Hill
Date of Birth: None Found
State: PA
Zip 17011
ProVest File Number: 1785818
Dates: As of 7/30/2009
Phone:
Zip: 17011
As of 7/30/2009, the Social Security Administration has no death record on file for Harpreet S.
Guleria a/k/a Harpreet Singh Guleria.
Social Security Number Search Completed.
Employment Search: Unable to verify current employer.
Creditor IMonnation: Creditors indicated the last reported address for Harpreet S. Guleria a/k/a Harpreet Singh
Guleria as 1920 Kent Drive, Camp Hill, PA 17011.
Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Harpreet S. Guleria
Vehicle Records: a/k/a Harpreet Singh Guleria from 1920 Kent Drive, Camp Hill, PA 17011.
Public Liosnses (Pilot, -Search performed provided no information.
Real Estate, aft):
Voter Registration The County Voters Registration Office has no listing for Harpreet S. Guleria a/k/a Harpreet
Inforrrretion: Singh Guleria.
National Postal Has no change for Harpreet S. Guleria a/k/a Harpreet Singh Guleria from 1920 Kent Drive,
Address Search: ' -Camp Hill, PA 17011.
Military Search: _ ..,*.,ere was no active military status found. Y.
Comments:
717-737-3790: Number listed to Harpreet Guleria at 1920 Kent Drive, Camp Hill, PA 17011, there was no answer.
717-737-2709: Called possible neighbor, Lester Arnold, answering machine answered, no message left.
717737=4019E Weds -poesibte neighbor, Peter Schnaithmann there wv is-m-Wnswr. On 7/30/2009, I, Tonya Hardin being duly swom according to the law, deposes and says: I am employed by ProVest,
LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my
investigation.
'07r"- ' -
Date: 7/30/2009
Sheriffs. Office of Cumberland County
R Thomas Kline
Sheriff ?s?ntr of +?awL?ty4??
Ronny R Anderson E'
Chief Deputy
Jody S Smith
Civil Process Sergeant oFFCE OF nd $hOW
Edward L Schorpp
Solicitor
Fannie Mae
VS.
HarpnW S. Guieria
Case Number
2009-4679
SHERIFF'S RETURN OF SERVICE
07/17/2009 11:41 AM - R. Thomas Kline, Sheriff, who being duty swum according to law, states that he made a
diligent search and inquiry for the within named defendant to wit Herpreet S. Gulerla, but was unable to
loci him in his baltwick. He therefore returns the within Complaint in Ejectment as not found as to the
defendant Harpreet S. Guleria. The request for service at 1920 Kett Drive Camp Hill, PA 17011 Is vacant
The Camp HUI Postmaster has advised the defendant has moved and left no forwarding address. An
exact address Is not available.
07/1712009 11:41 AM - R. Thomas Kline, SherK who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant to wk: OCCUPANTS, but was unable to locate
them In his baghwI& He therefore returns the within complaint in Ejectment as not found as to the
defendant OCCUPANTS. The request for service at 1920 Kent Drive Camp Hill, PA 17011 is vacant The
Camp Hill Postmaster has advised the defendant has moved and left no forwarding address. An exact
address Is not available.
SHERD COST. $87.80 04AWSWERS. ,.,.?
GOLDBECK McCAFFERTY & MCKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FANNIE MAE
International Plaza 11
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
of Cumberland County.
No.
09-4679
CERTIFICATE OF SERVICE
Michael T. McKeever, Esq., does hereby certify that true and correct copies of the foregoing
Motion for Substituted Service have been served upon the Defendants this 3RD day of August, 2009, by
first class mail, prepaid.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
BY: Michael T. McKeever, Esq.
OF THE , I'JTAVN?
2009 !3 -'v FN #
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FANNIE MAE
International Plaza H
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
VS.
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
No. 09-4679
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEB OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P. 430(a)
Plaintiff, by and through its attorney, Michael T. McKeever, Esq., in support of its
Motion for Substituted Service, represents as follows:
1. Plaintiff is the legal owner of the premises 1920 Kent Drive, Camp Hill, PA, 17011 pursuant to a
deed from the Sheriff of Cumberland County.
2. Plaintiff filed a Complaint in Ejectment on July 14, 2009
3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Michael
McKeever, Esquire, hereby certify that no judge has ruled on any other matters in this case. I
further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the
nature of this motion, it was not possible to locate or contact the Defendant to request his
concurrence.
4. Sheriff has been unable to effect service of the Complaint upon Defendants despite numerous
s
attempts and despite the fact that Plaintiffs inspection of the premises indicates it is occupied.
5. As this is an action for possession, further investigation is unnecessary.
6. Defendants have no right, title or interest in the premises, 1920 Kent Drive, Camp Hill, PA,
17011. Plaintiff believes and therefore avers that Defendants are deliberately avoiding service.
7. Plaintiff s inability to affect personal service upon Defendants has deprived, and continues to
deprive Plaintiff of the use and enjoyment of which it is the lawful owner.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to
serve the Complaint/Writ upon Defendants by posting the premises and certified and regular mail to the
Defendants' last known address.
BY:
Page 1 of 3
Barbara Roach
From: Failor, Tricia [tfailor@ocpa.net]
Sent: Monday, August 10, 200910:31 AM
To: Barbara Roach
Subject: RE: Failure to Comply with Local Rules 208.3 - AMENDMENT REQUIRED
You will need to file an original in the Prothonotary s office.
Thank you!
Trish Failor
Administrative Coordinator
--Original Message----
From: Barbara Roach [maatD:BRoach@gokJbeddaw.com]
Sent: Malay, August 10, 200910:10 AM
To: Fal or, Trida
Subject: RE: Failure to Comply with Local Rules 208.3 - AMENDMENT REQUIRED
Tricia:
Please see attachment. Please advise if you will need signal also.
Thank you.
GOLDBECK McCAFFERTY i McKEEVER
Barbara Roach
Eviction Department
Direct Number 215-8256319 (fax 6419)
Main Number 215627-1322 (fax 7734)
Evictions@Goldbecklaw.com
Escalation Contact: problems@goldbecklaw.com
All requests for eviction malBen can be sent to evlcilonsftQ1dbecldaw com
From: Michael T. Mdteever
Seat: Friday, August 07, 2009 3:18 PM
To: Failor, Tricia; M .can.; Evictions; Service Group
Subject: Re: Faikue to Comply with Loral Rules 208.3 - AMENDMENT REQUIRED
Thank you, we will comply with role 208.3 immediately.
Michael McKeever
Goldbeck McCafferty & McKeever
mmckeever@goldbecklaw.com
610-662-4798 (cell)
215-825-6303
Sent from my Verizon BlackBerry
From: "Failor, Tricia"
Date: Fri, 7 Aug 2009 14:38:45 -0400
To: <MMcKeever®goldbeck]aw.com>
Subject: Failure to Comply with Local Rules 208.3 - AMENDMENT REQUIRED
RE: Failure to Comply with Cumberland County Local Rule 208.3(a)
Motion for Substituted Service under PA.R.C.P. 430(x)
(2009-4679 Fannie Mae v. Guleria)
Dear Mr. McKeever,
Please note that due to your failure to comply with Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(x)(9), your motion will be held in the Court
Admimistrator's Office until an amendment containing the missing informal= is filed in the Prothonotary's Office. If after two notices no amendment has been filed, you
motion will be sent back to the Prothonotary's office and placed in the file and no father action will be taken.
Rule 208.3(a). Motions.
(2) The motion shall state whether or not a Judge has ruled upon any other issue in the same or related matter, and, if so, shall specify the judge and the issue.
(9) All motions and petitions shall contain a paragraph indicating that the concurrence ofany opposing counsel of record was sought and the response of said counsel,
provided, that this requirement shall not apply to preliminary objections, motions for judgment on the pleadings, motions for summaryjudgment, petitions to open or strike
judgments, and motions for post-trial relief.
Please note that you do not need to file an additional proposed order or provide additional envelopes for service. Your amendment will be attached to the original motion.
Please feel free to contact me if you have any questions or concerns regarding this matter.
Sincerely,
Trish Failor
Administrative Coordinator
8/10/2009
FLEL.. f(
OF THE" 'Y
2099 AUG I I A 10: J 0
y
AUG 0 7 2009 y
FANNIE MAE
International Plaza H
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
vs.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
ORDER
AND NOW, this
No. 09-4679
/ 3' day of 1q J 8" 2009, upon
consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to
the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants has been
unsuccessful, it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in
Ejectment upon Defendants by posting a copy of the Complaint upon the premises 1920 Kent Drive,
Camp Hill, PA, 17011, and Plaintiff is directed to serve the Complaint by certified and regular mail to the
Defendants' last known address at 1920 Kent Drive, Camp Hill, PA, 17011, and that all further service of
legal papers mclu ut not limited to motions, petitions and rules be made ' rtified and regular
mail to Defendants' last known address and that Writ of Possession pursuant to Pennsylvania Rule of
Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last
known address by certified and regular mail and by posting the premises.
BY THE COURT:
J. '
Distribution list:
Michael T. McKeever, Esquire uite 5000 - Mel n Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
HARPREET S. GULERIA & OCCUPANTS, 1920 Kent Drive Camp Hill, PA 17011
0
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
I MM-OFFICE
OF 7HE THOSOTAFiY
MAUG13 P"2:04
C ?A O?Y?t
GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
Plaintiff
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
VS.
HARPREET S. GULERIA
& OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Defendant(s)
Term
No. 09-4679
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
EJECTMENT COMPLAINT
GOLDBECK, McCAFFERTY & McKEEVER
By: Michael T. McKeever, Esquire
Attorney for Plaintiff
Flti:s 'w! Ali
OF p7. • NJOTARY
2009 AUG 27 A 11 0
GOLDBECK WCAFFERTY &
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
EJECTMENT
McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
vs.
HARPREET S. GULERIA
& OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Defendant(s)
CERTIFICATE OF SERVICE
Term
No. 09-4679
MICHAEL T. McKEEVER, ESQUIRE hereby certifies that on August 13, 2009
he did serve upon Defendant(s) HARPREET S. GULERIA and OCCUPANTS a true and correct copy of
the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated
August 31, 2009. The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
• 06
IEC cCAFF TY & McKEEVER
BY Michael T. McKeever, ESQUIRE
a.
L E ^''
OF THE R"17'
2009 SL.1 - I PM 2: SO 3
EL._
T -Y
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
2009 SEP - I f` ;', L• 17
"iJ -Y
Fannie Mae
vs.
Harpreet S. Guleria
Case Number
2009-4679
SHERIFF'S RETURN OF SERVICE
08/29/2009 10:42 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
August 29, 2009 at 1042 hours, she served a true copy of the within Complaint in Ejectment, upon the
within named defendant, to wit: Harpreet S. Guleria, pursuant to order of court by posting the premises
located at 1920 Kent Drive Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct
copy according to law.
08/29/2009 10:42 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
August 29, 2009 at 1042 hours, she served a true copy of the within Complaint in Ejectment, upon the
within named defendant, to wit: Occupants, pursuant to order of court by posting the premises located at
1920 Kent Drive Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy
according to law.
SHERIFF COST: $69.50
SO ANSWER ,
August 31, 2009 R THOMAS KLINE, SHERIFF
tn?IjA`
De Sheriff
GOLDBECK MCCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney ID #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6319
Attorney for Plaintiff
FANNIE MAE
International Plaza 11
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
vs.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Plaintiff
IN THE COURT OF COMMON
PLEAS
Of Cumberland County
CIVIL ACTION - LAW
ACTION OF EJECTMENT.
Defendants I Term
No. 09-4679
PRAECIPE FOR JUDGMENT IN EJECTMENT
Kindly enter Judgment
Defendants in Ejectment in favor of the Plaintiff F ANNIE S. GULERIA and OCCUP 9 ANNIE M
within AE and against the
(20) days of service. ANTS for failure to file an I HEREBY CERTIFY THAT ACCORDING TO rule 237.1 Answer in the above action
intention to file a Praecipe for Entry of Default Jud
written 10 day notice of Plaintiff's
of which is attached hereto. gment was mailed to Defendants, a
I hereby certify that the above true and correct copy
judgment creditor is FANNIE MAE, names are correct and that the precise residence address of the
International
75254-2916 Plaza H, 14221 Dallas Parkway, Suite 1000, Dallas,
-2916 and that the names and last known address of the Defendants are
OCCUPANTS 1920 Kent Drive, Cam HARPREET S. GUI EIA and
p Hill, PA 17011.
GOLDB
ECK McCAFFERTY & McKEEVER
Michael T. McKeever, Esq.
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney ID #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6319
Attorney for Plaintiff
FANNIE MAE
International Plaza lI
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
vs.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Plaintiff
Defendants
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Term
No. 09-4679
CERTIFICATION PURSUANT TO PA R.C.P. NO. 237
I, Michael T. McKeever, Esquire, attorney for Plaintiff, certify that a true and correct copy of
the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid:
HARPREET S. GULERIA
OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
GOLDBECK McCAFFERTY & McKEEVER
BY:??
Michael T. McKeever, Esq.
Attorney for Plaintiff
DATED: October 6, 2009
GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL MCKEEVER, ESQ.
ATTORNEY I.D. #56129
SUITE 5000 MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
Plaintiff
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
VS.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Defendants
DATE OF THIS NOTICE: September 22, 2009
TO: HARPREET S. GULERIA
1920 Kent Drive
Camp Hill, PA 17011
IMPORTANT NOTICE
Term
No. 09-4679
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 RAPORTANT RIGHTS. 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
Y?
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL MCKEEVER, ESQ.
ATTORNEY I.D. #56129
SUITE 5000 MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
Plaintiff
vs.
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Defendants
DATE OF THIS NOTICE: September 22, 2009
TO: OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF EJECTMENT
Term
No. 09-4679
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 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever, Esq.
Attomey for Plaintiff
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff corporation within named do hereby
verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that
the facts set forth in the foregoing verification of Non-Military Service are true and correct to the
best of my knowledge, information and belief. I understand that false statements therein are made
subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, HARPREET S. GULERIA, is about unknown
years of age, that Defendant's last known residence is, 1920 Kent Drive Camp Hill, PA 17011, and
is engaged in the unknown business located at unknown address.
2. That Defendant is 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 Action of
Congress of 1940 and its Amendments.
Date: I'd'G /197 4XIt- 4;-c i ? ? A?
Sheriffs Office of Cumberland County
R Thomas Kline
SheriB?tr of fatdLrr/¢hd
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant OFFICE OF TA SNERIFF
Edward L Schorpp
Solicitor
Fannie Mae Case Number
vs. 2009-4679
Harpreet S. Guleria
SHERIFF'S RETURN OF SERVICE
0829/2009 10:42 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
August 29, 2009 at 1042 hours, she served a trite copy of the within Complaint in Ejectment, upon the
within named defendant, to wit: Harpreet S. Guleria, pursuant to order of court by posting the premises
located at 1920 Kent Drive Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct
copy according to law.
08/292009 10:42 AM - Amanda Cobaugh, Deputy Sheriff, who being duty sworn according to law, states that on
August 29, 2009 at 1042 hours, she served a true copy of the within Complaint in Ejectment, upon the
within named defendant, to wit Occupants, pursuant to order of court by posting the promises located at
1920 Kent Drive Camp Hill, Cumbedand County, Pennsylvania 17011 with a true and cared copy
according to law.
SHERIFF COST: $69.50 SO ANSWE,
August 31, 2009 R THOMAS KLINE, SHERIFF
W ff
0 F ?NE Fr^? "rn! lbTRFiY
2009 OCT -9 PM 12: 18
$ r4.oc Po A` W
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0151910
f)ckea. WaW
C.P. 109 - P Praecipe for Writ of Possession
(ACTION OF EJECTMENT)
THE COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
HARPREET S. GULERIA
and OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Plaintiff
VS.
Defendants
PRAECIPE FOR WRIT POSSESSION
09-4679
Issue the Writ of Possession in the above matter, for possession of 1920 Kent Drive Camp Hill. PA 17011 (describe
property)
SEE ATTACHED LEGAL DESCRIPTION
Ejectment
Quiet Title
A.
5 - 116 (Rev. 10/76)
GOLDBECK, McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
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ALL that certain messuage, tenement and tract of land situate in the Township of Lower
Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and
described as follows, to wit:
BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth
between parallel lines 120 feet in Block "B", as shown on Plan No. 4 of Highland Estates
Development, drawn by D. P. RafFensperger, Registered Surveyor, revised March 9,
1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's
Office in and for Cumberland County at Carlisle, Pennsylvania.
HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive
Camp Hill, PA 17011
UNDER AND SUBJECT to all existing easements, restrictions and conditions of record.
Parcel #13-23-0547-167
GOLDBECK WCAFFERTY &
MCKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
EJECTMENT
FANNIE MAE
International Plaza II
14221 Dallas Parkway, Suite 1000
Dallas, TX 75254-2916
vs.
HARPREET S. GULERIA
& OCCUPANTS
1920 Kent Drive
Camp Hill, PA 17011
Defendant(s)
CERTIFICATE OF SERVICE
Term
No. 09-4679
MICHAEL T. MCKEEVER, ESQUIRE hereby certifies that on August 13, 2009
he did serve upon Defendant(s) HARPREET S. GULERIA and OCCUPANTS a true and correct copy of
the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated
August 31, 2009. The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, ESQUIRE
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R I I
Form 3877
Domestic USPS Firm Mailing Book
Name and Address of Sender: Permit Number Sequence Number
JOSEPH A GOLDBECK JR 2570A
MELLON INDEPENDENCE CE NT
701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J
PHILADELPHIA, PA 19106
Piece ID Article N %elive:y Address SS Fee Postage Value Sender Charges
:addressee Name •"ype Insur./Register Due Total
84235EJ-HG 71114342363000680126 GULEP.IA, HARPREET S. C 2.80 0.61 4.51
1920 Kent Drive ERR 1.10
? art.p Hill, PA 17011
84235EJ-06/10 71114342363000687135 OCCUPANTS C 2.80 0.61 4.51
1920 KENT DRIVE ERR 1.10
CAMP HILL, PA 17011
82956EJ-05/04 71114342363000680142 Ccf:upants
616 South Summit Street
Derry, PA 15627
82956EJ-LH5/0471114342363000680159 HENNING, LISA A.
616 South Summit Street
Derry, PA 15627
82956EJ-HH5/0471114342363000680166 HENNING JR., HERBERT P.
616 South Summit Strect
Derry, PA 15627
81211EJ-03/24 71114342363000680173 Occupants
1531 East Elm Street
Scranton, PA 18085
81211EJ-AA3/2471114342363000680180 AUKSCUNAS, ALGRID F.
105 Little Spike May
Scranton, PA 18504
81211EJ-JS3/2471114342363000680197 STAPLES-STAHL, JILL
1531 East Elm Street
Scranton, PA 18505
C 2.80 0.61 4.51
ERR 1.10
C 2.80 0.61 4.51
ERR 1.10
C 2- 80 0.61 4.51
ERR 1.10
C 2.80 0.61 4.51
ERR 1.10 f
??
nf
C 2.80 0.61 4.51
ERR 1 .10
C 2.80 0.61 4.51
ERR 1.10
----------------------------------------------------- ---------------------------------------------------------------------------
Page Totals: 8 31.20 4.88 36.08
Cumulative Totals: 8 31.20 4.88 36.08
------------------------------------------- -------------------------------------------------------------------------------------
USPS CERTIFICATION
Total Number of Pieces Received:
Round Stamp:
Signature of Receiving Employee
Form 3877 (Facsimile) Date of Manifest: 08/31/2009
Page 1
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717.240.6397
Plaintiffs: Court Number:
FANNIE MAE 09-4679
Expiration Date:
Type of Action:
Defendant/s:
HARPREET S. GULERIA and OCCUPANTS
Serve Upon:
HARPREET S. GULERIA
Address for Service:
1920 Kent Drive Camp Hill, PA 17011
Alternate Address for Service:
1920 Kent Drive Camp Hill, PA 17011
Type of Service:
r Personal jW Adult in Charge r- Deputize r Certified Mail r Posting (copy of
court order required)
Special Service Instructions:
**If service is to be made by deputized service to another county please specify which
County
POST PER COURT ORDER
Filing Attorney's Information:
Name: Goldbeck McCafferty & McKeever
Address: Mellon Independence Center
701 Market Street Suite 5000
Philadelphia, Pa 19106-1532
Telephone: 215-627-1322
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717.240.6397
Plaintiffs: Court Number:
FANNIE MAE 094679
Expiration Date:
Type of Action:
Defendant/s:
HARPREET S. GULERIA and OCCUPANTS
Serve Upon:
OCCUPANTS
Address for Service:
1920 Kent Drive Camp Hill, PA 17011
Alternate Address for Service:
1920 Kent Drive Camp Hill, PA 17011
Type of Service:
W Personal 17 Adult in Charge r Deputize r Certified Mail r Posting (copy of
court order required)
Special Service Instructions:
**If service is to be made by deputized service to another county pl ease specify which
County
POST PER COURT ORDER
Filing Attorney's Information:
Name: Goldbeck McCafferty & McKeever
Address: Mellon Independence Center
701 Market Street Suite 5000
Philadelphia, Pa 19106-1532
Telephone: 215-627-1322
FILED"+fiCE
OF THE PP'-)r?CNOTARY
2009 OCT -9 PM 12: 18
CUM ?. L;-?qu?d T Y
F`Erd?`:? i???l NIIA
.dqL
W2
2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FANNIE MAE
VS.
No. 09-4679 Civil Term
HARPREET S. GULERIA
and OCCUPANTS
Costs
Attorney's $ 256.00
Plaintiff's $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
FANNIE MAE
being: (Premises as follows):
1920 KENT DRIVE, CAMP HILL, PA 17011
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
C is R. Long, Prothonotary
,
Common Pleas Court of Cumbe County, PA
Date 10/9/09
(Seal)
2 of 2
No 09-4679 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FANNIE MAE
VS.
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the day of . I caused the within
named , to have possession of the premises described with the
appurtenances, and
HARPREET S. GULERIA
and OCCUPANT
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 256.00
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
MICHAEL T. McKEEVER, ESQUIRE
GOLDBECK, McCAFFERTY & McKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
215-627-1322
ID #56129
Sworn and subscribed to before me this
Day of ,
Prothonotary
So Answers,
Sheriff
By
Deputy
ALL that certain messuage, tenement and tract of land situate in the Township of Lower
Allen, County of Cumberland, Commonwealth of Pennsylvania, more fully bounded and
described as follows, to wit:
BEING Lot No. 32, with a 60 foot frontage on the North side of Kent Drive and a depth
between parallel lines 120 feet in Block "B", as shown on Plan No. 4 of Highland Estates
Development, drawn by D. P. Raffensperger, Registered Surveyor, revised march 9,
1949, and recorded March 21, 1941 in Plan Book No. 4, page 79, in the Recorder's
Office in and for Cumberland County at Carlisle, Pennsylvania.
HAVING THEREON erected a single dwelling house known as No. 1920 Kent Drive
Camp Hill, PA 17011
UNDER AND SUBJECT to all existing easements, restrictions and conditions of record.
Parcel #13-23-0547-167
Sheriffs Office of Cumberland County
R Thomas Kline `
Sheriff
r 9pti 1t ?5 qt 4CI1(!(/CT?,, ^ 1 -
Ronny R Anderson
Chief Deputy
l
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
Fannie Mae
vs.
Harpreet S. Guleria
SHERIFF'S RETURN OF SERVICE
Case Number
2009-4679
10/20/2009 08:08 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant, to wit: HARPREET S. GULERIA, but was
unable to locate defendant in his bailiwick at the address provided. Therefore, there is no service on this
writ of possession as the defendant was not found. House was vacant.
10/20/2009 08:08 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant, to wit: OCCUPANTS, but was unable to locate
any occupants in his bailiwick at the address provided. Therefore, there is no service on this writ of
possession as the defendant was not found. House was vacant.
So Answers
Thomas Kline, Sheriff