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HomeMy WebLinkAbout10-2220 Phelan, Hallinan & Schmieg, LLP CT T!-" Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 2010 AR ' I AM I 1 * ( 1 Daniel G. Schmieg, Esq., Id. No. 62205 Michelle M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 V,?^ _ . U1 i'f Sheetal R. Shah-Jani, Esq., Id. No. 81760 r`, i, !. 'S Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ?ivek 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 1. 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 Attorney for Plaintiff Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Fannie Mae P.O. Box 650043 Court of Common Pleas Dallas, TX 75265 Civil Division V. Cumberland County Matthew Nink An Lg No. 10 -,W0 i ?arm Or Occupants 128 North 32nd Street Camp Hill, PA 17011-2919 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 S PHS #: 233409 (888)-990-9108 $ga.oo pA ATT%, Uc,? 93D5o3 ?.' amoa • 1. Plaintiff is Fannie Mae. 2. Defendant is Matthew Nink An Le Or Occupants. 3. Plaintiff is the record owner of premises located at 128 North 32nd Street, Camp Hill, PA 17011-2919, 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 March 3, 2010, as evidenced by the Sheriff's deed recorded March 24, 2010 in the Office of the Recorder of Cumberland County in instrument # 201007326, 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 said pi By: 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 EXHIBIT "A" • 40WIx Parcel No. 01-21-0273-157 ?gd) 99? Know all Men by these Presents 0005UE That I, Ronny R. Anderson, 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 Fannie Mae Writ No. 2009-3556 Civil Term First Horizon Home Loans, A Division of First Tennessee Bank National Association, F/K/A First Horizon Home Loan Corporation Vs Matthew Nink An Le Linda Louise Le F/K/A Linda L. Le All THAT CERTAIN lot of ground situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as follows: BOUNDED on the North by Lot No. 13 on the hereinafter Plan of Lots by Charles H. Sible; on the East by 32nd Street (formerly Oyster Point Avenue); on the South by Lot No. 11 on the hereinafter mentioned plan of lots owned now or formerly of Caleb S. Brinton; on the West by a fifteen (15) foot wide alley. CONTAINING fifty (50) feet in front on 32nd Street and extending in depth at an even width one hundred sixty (160) feet to the aforesaid fifteen (15) foot alley. And being Lot No. 12 on the Plan of Lots known as `Belvoir in the Borough of Camp Hill, which said plan is recorded in the Recorder's Office of Cumberland County in Plan Book 1, Page 16. TITLE TO SAID PREMISES IS VESTED IN Matthew Nink An Le and Linda L. Le, his wife, by Deed from Michael L. Stone and Kathy G. Stone, his wife, dated 07/29/1983, recorded 08/02/1983 in Book 30-H, Page 887. PREMISES BEING: 128 NORTH 32ND STREET, CAMP Hill PA 17011-2919 PARCEL NO. 01-21-0273-157 r . w The same having been sold by me to the said grantee on the 3`d day of March Anno Domini Two Thousand and Ten (2010) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 6th of October Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 3556 at the suit of First Horizon Home Loans, A Division of First Tennessee Bank National Association, F/K/A First Horizon Home Loan Corporation -vs- Matthew Nink An Le and Linda Louise Le F/K/A Linda L. Le In Witness Wereof, I have hereunto affixed my signature this 17 Anno Domini Two Thousand and Ten (2010) day of March Anderson, Sheriff Commonwealth of Pennsylvania, ss. / County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared, Ronny R. Anderson, 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 17 day of March Anno Domini Two Thousand and Ten (2010) 1%qI 111j If.., ?? r f? Prothonotary ... f, 012 4;1 'fi'r ?E,,.,...._•.r ?? ??? `ro rtltt{ti<< I hereby certify that the residence And Post Office address of the Within Grantee is P.O. Box 650043 Dallas, TX 75265-0043 Solicitor a a ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201007326 Recorded On 3/24/2010 At 11:00:31 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 62784 User ID - MSW Grantor - LE, MATTHEW NINK AN * Grantee - FANNIE MAE * Customer - CUMBERLAND SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CAMP HILL SCHOOL $0.00 DISTRICT CAMP HILL BORO $0.00 TOTAL PAID $64.00 * 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 OF I7 AD * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0005UE 111111111111111111111111 Y •i 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.