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Home My WebLink About09-7763Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michelle 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., I.D. 208375 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000-7000 Federal Home Loan Mortgage Corporation 5000 Plano Parkway Carrollton, TX 75010 Attorney for Plaintiff Court of Common Pleas Civil Division V. Greig G. Altieri Or Occupants 305 Brook Meadow Drive Mechanicsburg, PA 17050-3140 No. 0q-'1q(03 CiV i (TeAv 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 Cumberland County PHS #: 216642 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is Greig G. Altieri Or Occupants. 3. Plaintiff is the record owner of premises located at 305 Brook Meadow Drive, Mechanicsburg, PA 17050-3140, 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 September 2, 2009, as evidenced by the Sheriff s deed recorded September 29, 2009 in the Office of the Recorder of Cumberland County in instrument 200933421 a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 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 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 She R. Shah-Jani, Esq., Id. No. 81760 Je ne R. Davey, Esq., Id. No. 87077 auren 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 EXHIBIT "A," ?3? a? c? P ?iLC° OOOBZC Tax Parcel No. 38-21-0291-110.U23 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 Home Loan Mortgage Corporation Sale No. 3 Writ No. 2008-6985 Civil Term GMAC Mortgage, LLC VS. Greig G Altieri Atty: Daniel Schmieg LEGAL DESCRIPTION ALL, that certain unit, as occupying the real estate as described hereafter; said parcel being located in the Township of Silver Spring, County of Cumberland, Commonwealth of Pennsylvania, described as follows: BEGINNING, at a point, said point being referenced from an iron pipe at the southeastern corner of 'The Brook Meadow Condominium', said comer being in con with the southwestern comer of the Ginger Fields, single family subdivision, Lot 75, said point also lying on the northern right-of- way line of Mulberry Drive; THENCE, along the northern right- of-way line of Mulberry Drive, South 49 degrees, 50 minutes, 00 seconds West, for a distance of 1241.58 feet to a point, thence, leaving said right-of-way and perpendicular to said right-of-way, North 40 degrees, 10 minutes, 00 seconds West, for a distance of 45.83 feet to a point, the POINT OF BEGINNING, said point of beginning, being the southeastern corner of Unit 23, as described herein, thence, along the southern wall of the herein described Unit 23, South 49 degrees, 50 minutes, 00 seconds, West, for a distance of 24.00 feet to a point, thence, along the western wall of the herein described Unit 23 and the common wall with Unit 22, North 40 degrees, 10 minutes, 00 seconds West, for a distance of 40.00 feet to a point; thence, continuing along the herein described Unit 23, North 49 degrees, 50 minutes, 00 s,$conds East, for a distance of 19.17 feet to a point; thence, along the same, South 40 degrees, 10 minutes, 00 seconds East, for a distance of 1.33 feet to a point; thence, along the same, North 49 degrees, 50 minutes, 00 seconds East, for a distance of 4.83 feet to a point; thence, along the same and the common wall with Unit 24, South 40 degrees, 10 minutes, 00 seconds East, for a distance of 38.67 feet to a point; the POINT OF BEGINNING. BEING the real estate containing Unit No. 23 of a seven (7) unit building in 'The Brook Meadow Condominium', as recorded in Plan Book 80, Page 132 and as described in the Condominium documents as recorded in Book 715, Page 4681 in Cumberland County Records. The improvements thereon being known as No. 305 Brook Meadow Drive. TITLE TO SAID PREMISES IS VESTED IN Grei G. Altieri, a married man, by Deed from Altieri Enterprises, Inc., dated 07/20/2007, recorded 10 5/200 m Instrument Number 200738645. PREMISES BEING: 305 BROOK MEADOW DRIVE, MECHANICSBURG, PA 17050-3140 PARCEL NO. 38-21-0291-1 10.-U23 PROPERTY ADDRESS: 305 Brook Meadow Drive, Mechanicsburg, PA 17050 The same having been sold by me to the said grantee on the 2nd day of September, Anno Domini Two Thousand and Nine (2009) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 1't of April Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eight (2008) Number 6985 at the suit of GMAC Mortgage, LLC vs- Greig G. Altieri. In Witness Wereof, I have hereunto affixed my signature this 24 day of September Anno Domini Two Thousand and Nine (2009) Thomas Kline, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curtis R. Long, Prothonotary 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 24 day of September Anno Domini Two Thousand and Nine (2009) NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY CC !R'r'40V- MY COMMISSION EXPIRES JANUAR':' I hereby certify that the residence And Post Office address of the Within Grantee is 5000 Plano Parkway Carrollton, TX 75010 Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE. CARLISLE, PA 17013 717-240-6370 Instrument Number - 200933421 Recorded On 9/29/2009 At 10:04:26 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 53175 User ID - KW * Grantor - ALTIERI, GREIG G * Grantee - FEDERAL HOME LOAN MTG CORP * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT SILVER SPRING TOWNSHIP $0.00 TOTAL PAID $49.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D DS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. Aiuu?ii 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. \ J?' ? I AM Date OAAtt,,ney for Plaintiff FILL' 211A Nov -9 Af III LildiC', FJ',urry $19-So Po A7r`( ce 8'13 tp 39 '233,213 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ??4??tp at C1e111t)"'t4/14 Ella}-(YFICE OF TEE PRM'H;"NOTARY 2009 NOV 19 PM I : 00 PENt'41SY .VANA. Edward L Schorpp Solicitor Federal Home Loan Mortgage I Case Number vs. 2009-7763 Greig G Altieri SHERIFF'S RETURN OF SERVICE 11/17/2009 03:25 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2009 at 1525 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Greig G. Altieri, by making known unto Bruce Armstrong, current resident at 305 Brook Meadow Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 18, 2009 SO ANSWERS, 0000104embale 4440 R THOMAS KLINE, SHERIFF By Depu y Sheriff ci Gou, +ySultr' Shentt Teleosott Inc SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~f~E~_.; 3+~~=i~~ Sheriff 1F T ~ hn ~ ~! ~'n ~~Y ~~tittt~, ui' ~a~ntor,y,rr~~ M~- ~, tv~ ~~~;t' T Jody S Smith Chief Deputy __ ~ ZQ ~ ~ ~~{~ ~ ~ ~~ ~Q; ~ (~ Edward L Schorpp Solicitor ~~- . ~ CU~~+ .:. ,;,.~ .:''~ IY -,- ,,i_ ,~, '~ j°='`'V~~ ~ ~s ; Federal Home Loan Mortgage Case Number vs. Greig G Altieri 2009-7763 SHERIFF'S RETURN OF SERVICE AMENDED 11/17/2009 03:25 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2009 at 1525 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Occupant of 305 Brook Meadow Drive, Mechanicsburg, PA 17050, by making known unto Bruce Armstrong, current occupant at 305 Brook Meadow Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 November 18, 2009 SO A WERS .~ NY R ANDERSON, SHERIFF ~~~(~~ Deputy Shariff .. Gru~iipSuaF SFer't. Tr,!'sc't. i,~~:. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~~titr~ at ti~u+attrrr~~~4 ~ `~ ,' Federal Home Loan Mortgage vs. Bruce Armstrong (et al.) tl ~~ Ci L Z tiY X11 ~iQZ SHERIFF'S RETURN OF SERVICE 01/28/2010 Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1540 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupant, by making known unto Stevana Fewell, Adult in Charge anc Occupant, at 305 Brook Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. 01/28/2010 03:40 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1540 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Bruce Armstrong, by making known unto Stevana Fewell, Adult in Charge, at 305 Brook Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/19/2010 By virtue of this writ, on the 19th day of February, 2010, Sheriff Ronny R. Anderson caused the within named Federal Home Loan Mortgage Corporation to have possession of the premises described as 305 Brook Meadow Drive, Mechanicsburg, PA 17050-3140. SHERIFF COST: $88.44 February 24, 2010 i -„ - " _- ;., tai;; f ~ ,, ~ ,, n - - . t" ! s t~ ~ ~` J ~~.o i''t SO ANS S, RgNf~VP R ANDERSON, SHERIFF V ;' By .~ Case Number 2009-7763 ~ (,v l,~ ~3~1 Sharon R. Lantz (c} CcuntySuite Sheriff. Telen.=,ofL Inc. 2 of 2 No 09-7763 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION V S. GREIG G. ALTIERI, BRUCE ARMSTRONG or OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 190.50 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 215-563-7000 ID# 62695 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served 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 lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION VS. No. 09-7763 Civil Term_ GREIG G. ALTIERI, BRUCE ARMSTRONG or OCCUPANT Costs Attorney's $ 190.50 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)) FEDERAL HOME LOAN MORTGAGE CORPORATION being: (Premises as follows): 305 BROOK MEADOW DRIVE, MECHANICSBURG, PA 17050-3140 (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. ~. Da D. Buell, P onotary, Common Pleas Court of Cumberland County, PA Dare li Ul/10 (Sea;)