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Home My WebLink About09-7576GOLDBECK 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 H 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff VS. ANNETTE M. FETROW JOSEPH A. HILL and OCCUPANTS 385 Sherwood Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Defendants Term No. Oq - `15'1'(0 0NOTICE 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 further 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is FANNIE MAE, International Plaza. II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916. 2. Defendants are ANNETTE M. FETROW, JOSEPH A. HILL, and OCCUPANTS. 3. Plaintiff is the owner of property located at 385 Sherwood Drive, Carlisle, PA 17013, by virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on 10/5/2009 at Instrument # 200934137. 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, ANNETTE M. FETROW, JOSEPH A. HILL 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 By: ichael McKeever, q. VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date : JQ - ?Q - QC' - d tDPA.. l T. McKeeve Esquire #56129 #87899EJ ANNETTE M. FETROW and JOSEPH A. HILL 385 Sherwood Drive Carlisle, PA 17013 ALL THAT CERTAIN tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described in accordance with Final Subdivision Plan for Lynell W. Wolf prepared by Thomas Alvin Neff, Registered Surveyor, a copy of said Plan dated April 24, 1978 being recorded in the hereinafter named Recorder's office in Plan Book 33, Page 21, as follows: BEGINNING at a point in the original center line of Thirty-three (33) feet wide Township Road T-503 KNOWN AS Sherwood Drive at the dividing line between Lot No.2 and land formerly of W. Narehood, now or formerly of Dennis E. Major; thence from said point at the Place of Beginning along said dividing line between said Lot No. 2 and said land now or formerly of Dennis E. Major, South 22 degrees 54 minutes 50 seconds West, a distance of one Hundred Ninety-seven and Seven Tenths (197.7) feet to au Iron pin; thence still along said dividing line South 22 degrees 52 minutes 50 seconds West, a distance of One Hundred Seventy-two (172) feet to an iron pin at corner common to said land now or formerly of Dennis J. Major and said Lot No. 2 and Lot NO.3; thence along the dividing line between said Lots 2 and 3, North 14 degrees 06 minutes 05 seconds West, a distance of Two Hundred Forty-one and Five Hundredths (241.05) feet to a stake; thence still along said dividing line between said Lots Nos. 2 and 3, North 17 degrees 35 minutes 20 seconds East, a distance of Two Hundred Five and Eight Tenths (205.8) feet to a point in the original center line of Thirty-three (33) feet wide Township Road T -503 known as Sherwood Drive; thence along said original center line of Thirty- three (33) feet wide Township Road T -503 known as Sherwood Drive, South 57 degrees 30 minutes 20 seconds East, a distance of One Hundred Sixty-six and Forty-four Hundredths (166.44) feet to a point at the Place of BEGINNING. BEING all of Lot No.2 as shown on said Final Subdivision Plan for Lynell W. Wolf dated April 24, 1978, recorded as aforesaid. TAX PARCEL# 21-05-0431-020 BEING KNOWN AS: 385 Sherwood Drive, Carlisle, PA 17013 0 RLE F: 11 IS LE' OF THE )T f 2009 NOV -2 Pty 3: 37 $'18. ,s3D PD AIW ?`1F 5039(0 ? P-T # a3a 879 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY r ~ r, r~C ' 1- .. , _ ~. Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor DNS;, o~ ~ii~i~br~,~9 ~ *~.~ ~~~ r , .. n . r'~ _ .. Fannie Mae vs. Annette M. Fetrow Case Number 2009-7576 SHERIFF'S RETURN OF SERVICE 11/06/2009 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 at 385 Sherwood Drive Carlisle, PA 17013, 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. Request for service at 385 Sherwood Drive Carlisle, PA 17013 is vacant. An exact address is not available. 11/06/2009 02:55 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: Annette M. Fetrow, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Annette M. Fetrow. Request for service at 385 Sherwood Drive Carlisle, PA 17013 is vacant. An exact address is not available. 11/06/2009 02:55 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: Joseph A. Hill, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Joseph A. Hill. Request for service at 385 Sherwood Drive Carlisle, PA 17013 is vacant. An exact address is not available. SHERIFF COST: $80.40 November 09, 2009 SO ANSWERS,,,,,., _w .. R THOMAS KLINE, SHERIFF iC) ~~Otl >.l~f,E;? ;~hE t, E x(30 ~~. I':i;. KML L.AW (:CROUP, P.C. Suite 5000 - I~NY Mellon lndependence Center 701 M~~r•ket tit:reet Philadelphia. PA 19106-1532 215-6~' -1.;~:' Attornti~ fir l~laintitf F/~NNIF, MAE International Plaza II 14221 Dallas Parkway, Suite 1000 Dallas. TX 7>254-2916 Plaintiff ,; ,,,._ -- ,, ~ IN T'HE COURT OF COMMON PLEAS OF CUMBERLAND CO[;NTY vs. ANNI: [~TE M. FETROW JOSEPH A. HILL and OCCUPANTS 385 Sherwoc>d Drive Carlisle. P~ 1701 No. 09-75?6 PRAECIPE TO DISCONTINUE AND END TO TIIE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of ~~otrr posts only. "~ .. ~ ~ (; ~y ~ ~ j~ -- KML Y: OU , P.C. Jay E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ~Jil! P. Jenkins Pa. 1D 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 BNY 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. T:X 75254-2916 Plaintiff vs. ANNETTE M. FETROW JOSEPH A. HILL And OC(~UPANTS ,85 Sherwood Drive Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CI`JIL ACTION -~ L.AW ACTION IN EJEC'i~~'V1ENT~ Term No. 09-7571; CERTIFICATE OF SERVICE Angela. M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on _~ ~ o~ - ~ ANNETTE M. FETROW 385 Sherwood Drive Carlisle. F'A 17013 JOSE:Pf f A. HILL. 385 Sherwood Drive Carlisle, P'A 17013 OCCUPANTS 385 Sherwood Drive Carlisle, PA 1701 l ~ ~'7 % /~'`~ ~ ~ KML Law roup, P.C. Angela M. Smith ,Legal Assistant asmith@kmllawgroup.com 215--825-6325 (Direct Phone)