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HomeMy WebLinkAbout09-5855• ti Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 ,Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 Fannie Mae P.O. Box 650043 Dallas, TX 75265-0043 V. Viktor Krapov or occupants 1793 Cessna Street Carlisle, PA 17013 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No. e 9 CIVIL ACTION - EJECTMENT **This firm 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 discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement 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 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. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (888)-990-9108 PHS #: 214248 1. Plaintiff is Fannie Mae. 2. Defendant is Viktor Krapov or occupants. 3. Plaintiff is the record owner of premises located at 1793 Cessna Street Carlisle, PA 17013, a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of Cumberland County, on August 5, 2009, as evidenced by the Sheriiff's deed recorded August 18, 2009 in the Office of the Recorder of Cumberland County in instrument # 200827958. 5. Plaintiff, by virtue of the above, is the record 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. By: _1?? Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 /Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 698,19 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a final subdivision plan of Heritage Court, dated July 9, 1976, and recorded in Cumberland County Plan Book 28, Page 71, as follows: BEGINNING at a point on the Southerly line of Cessna Street (50 feet wide) at the Northwest corner of Lot No. 6 on the abovementioned Plan of Lots; thence by the Southerly line of Cessna Street by a curve to the right having a radius of 225 feet, a distance of 74.776 feet to a point at the Northeast corner of Lot No. 8 on the abovementioned plan of Lots; thence by said Lot No. 8 South 0 degrees 38 minutes 40 seconds East 129.77 feet to a point; thence South 81 degrees 14 minutes East 131.63 feet to a point at the Southwest corner of said Lot No. 6; thence by said Lot No. 6 North 19 degrees 41 minutes West 173.07 feet to a point, the Place of BEGINNING. CONTAINING 14,623 square feet more or less and being numbered Lot No. 7 on the abovementioned Plan of Lots. BEING the same premises which Robert S. McKee and Ralph v. McKee, McKee Brothers Masonry, a Partnership, by Deed dated June 14, 1988, which Deed is recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 33-D, Page 530, granted and conveyed to Kay M. Grogan, single person, Grantor herein. VERIFICATION I hereby state that I am the attorney for the Plaintiff in this eviction 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 Attorney for Plaintiff n?n 1 rye/ 2009 AUG 26 Al"110: 06 GUME* l'>yr s7? 36 ,ems ga- 9 7 Yr & Sheriffs Office of Cumberland County R Thomas Kline L? Sheriff Vj?'Jv of 'u,r,Grrl r?' Ronny R Anderson ? t Chief Deputy Jody S Smith Civil Process Sergeant OFFICE of T"E `-"ERIFF Edward L Schorpp Solicitor Fannie Mae Case Number vs . Viktor Krapov 2009-5855 SHERIFF'S RETURN OF SERVICE 09/01/2009 07:57 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 1, 2009 at 1957 hours, he served a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Viktor Krapov, by making known unto himself personally, at 1793 Cessna Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to hirr personally the said true and correct copy of the same. SHERIFF COST: $33.40 September 02, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By? Deputy Sheriff Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Attorney for Plaintiff Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Fannie Mae COURT OF COMMON PLEAS CIVIL DIVISION vs No. 09-5855 Civil Term Viktor Krapov Or Occupants Cumberland County 1793 Cessna Street Carlisle, PA 17013 PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Fannie Mae and against the Defendant(s) Viktor Krapov and Or Occupants for possession of premises 1793 Cessna Street, Carlisle, PA 17013 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 co copy of which is attached hereto. Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Default Judgment entered as indicated above Chrisovalante P. Fliakos, Esq., Id. No. 94620 DATE Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Fannie Mae vs Vilctor Krapov Or Occupants 1793 Cessna Street Carlisle, PA 17013 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 09-5855 Civil Term Cumberland County VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have 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 Viktor Krapov Or Occupants Or occupants, .*is over 18 years of age, and resides at 1793 Cessna Street, Carlisle, PA 17013. ), ,, ?.'ting to unworn falsification to authorities. This statement is made subject to the penalties of 18 PA. C- Phelan, 'FI in Schmieg, LLP Lawrence T-Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff PHS# 214248 Phelan Hallinan and Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Fannie Mae Plaintiff Court of Common Pleas Civil Division No. 09-5855 Civil Term Cumberland County V Viktor Krapov or occupants Defendant TO: Viktor Krapov or occupants 1793 Cessna Street Carlisle, PA 17013 DATE OF NOTICE: September 22, 2009 "THIS FIRM 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 DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A 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 (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: OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 By: NA Lawrence T. Phelan, Esq., J. No. 2227 Francis S. Hallinan, Esq., I . . 2695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 _-.Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 J"y11! Y ?l 4I.DD ?d-- IZ.? x31578 PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Fannie Mae COURT OF COMMON PLEAS CIVIL DIVISION vs No. 09-5855 Civil Term Viktor Krapov Or Occupants CumberlandCounty 1793 Cessna Street Carlisle, PA 17013 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession o£ 1793 Cessna Street, Carlisle, PA 17013 **PLEASE SEE THE ATTACHED LEGAL DESCRIP,?ION*** Being Known as No. 1793 Cessna Street Phelan, Hal$a6 & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff FILE"'YFICE OF THE PROTHONOTARY 2009 OCT -7 PM 2: 48 CUMI uf? PEINt,'IS`l ?.'V'AN;i -1ka. l(c) cap 14.Ob it ! ? . 90 • Pa 4-ny -*a.0O 1)0e 0,' CK-1 8LGy3 ? Q ?tJ2t SS 10f2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE VS. VIKTOR KRAPOV OR OCCUPANTS 1793 Cessna Street Carlisle, PA 17013 Attorney's Plaintiff s Prothonotary Costs No. 09-5855 Civil Term- $149.90 $ 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): 1793 CESSNA STREET, CARLISLE, PA 17013 (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. Cu is R. Long, Prothonotary, Common Pleas Court of Cumberland ty, PA Date 10/7/09 (Seal) 2of2 No 09-5855 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE VS. VIKTOR KRAPOV WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 149.90 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: V17VEK SRIVASTAVA, ESQUIRE PHELAN, HALLINAN & SCHMIEG, LLP ONE PENN CENTER @ SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 ID #202331 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy ALL THAT CERTAIN tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a final subdivision plan of Heritage Court, dated July 9, 1976, and recorded in Cumberland County Plan Book 28, Page 71, as follows: BEGINNING at a point on the Southerly line of Cessna Street (50 feet wide) at the Northwest corner of Lot No. 6 on the abovementioned Plan of Lots; thence by the Southerly line of Cessna Street by a curve to the right having a radius of 225 feet, a distance of 74.76 feet to a point at the Northeast corner of Lot No. 8 on the abovementioned plan of Lots; thence by said Lot No. 8 South 0 degrees 38 minutes 40 seconds East 129.77 feet to a point; thence South 81 degrees 14 minutes East 131.63 feet to a point at the Southwest corner of said Lot No. 6; thence by said Lot No. 6 North 19 degrees 41 minutes West 173.07 feet to a point, the Place of BEGINNING. CONTAINING 14,623 square feet more or less and being numbered Lot No. 7 on the abovementioned Plan of Lots. BEING the same premises which Robert S. McKee and Ralph V. McKee, McKee Brothers Masonry, a Partnership, by Deed dated June 14, 1988, which Deed is recorded in the office of the Recorder of Deeds in and for Cumberland County in Deed Book 33-D, Page 530, granted and conveyed to Kay M. Grogan, single person, Grantor herein. Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 4?4tit,p A L Itlfipy f OFFICE ;,F 'rE w' `ERWF FILM -FM OF 1K PA(1T j Fannie Mae vs. Viktor Krapov 1009 OCT 21 AM T- 00 IENNSYLVAN A Case Number 2009-5855 SHERIFF'S RETURN OF SERVICE 10/21/2009 03:04 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2009 at 1505 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Occupants, by making known unto Vera Krapov, Occupant and Adult in Charge, at 1793 Cessna Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/21/2009 03:04 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2009 at 1505 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Viktor Krapov, by making known unto Vera Krapov, Adult in Charge, at 1793 Cessna Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. So Answers, ,.' R. Thomas Kline, heriff By Deputy Sheriff