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Home My WebLink About01-0597Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: O!-- ,~? CIVIL ACTION - EJECTMENT NOTICE AVISO 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 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 by the court without further notice for any money claimed in the complaint or 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. Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas an las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a santar una comparencia escrita o en persona o con un abogado y entregar a la corte en fonna escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted, LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERV1CIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIC1NA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR AS1STENCIA LEGAL. DAUPHIN COUNTY LAWYER REFERRAL SERVICES 213 NORTH FRONT STREET, HARRISBURG, PA 17101 (717) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.Q. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - EJECTMENT 1. Plaintiff, Federal National Mortgage Association, is the owner of premises known as 175 Church Road, Carlisle, PA 17013, more fully described in the legal description attached hereto as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriff's sale held on October 4, 2000, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, No. 95-4074 Civil Term, where mortgagee was the successful bidder, and whereby plaintiff, as guarantor of the mortgage, became the owner of the said property. 3. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The defendants Jennifer L. Troutman and or Occupant are occupying the said premises without right, and so far as the plaintiff is informed, without claim of title. premises. WHEREFORE, plaintiff brings this suit and seeks/~/recover possession of said M~, Vo,, Rosenstiel ttomey for Plaintiff VERIFICATION I verify that the Statements made in the foregoing Docket(s)in Ejectment are true and correct. I understand that false statements herein are made subject to penalties of t8 Pa C.S, Section 4904 relating to unsworn falsification to authorities. DF_,~ CRIPTION ALL THE following described piece, parcel or tract of land situated in the Township of Penn, County of Ctunberland, State of Pennsylvania, bounded and described as follows: BEGINNING at a post in the public road comer of l~nds now or formerly of I~vi Kissinger; thence by said road, North eighty-two (82) d~grees West, nine and five tenths (9.5) perches to a post, comer of lands now or formerly of J. H. Bosler; thence by said lands now or formerly of $. H, Bosler, North twenty-eight (28) degrees East, twelve (12) perches to a post; thence by the same, South eighty-two (82) degrees East, nine and frye tenths (9.5) perches to a post; thence by lands now or formerly of Levi Kissinger, South twenty-eight (28) degrees West, twelve (12) perches to the place of BEGINNING. CONTAINING one hundred six (106) perches, be the same more or less. BEING COUNTY TAX PARCEL NUMBER 31(120332)19 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Federal National Mortgage Association 1900 Market Street Suite 800 Philadelphia PA 19103 PLAINTIFF VS. Jennifer L. Troutman and or Occupant 175 Church Road Carlisle, PA 17013 DEFENDANTS Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY NO: 2001-597 Civil Term MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Writ of Possession, and all subsequent notices upon the above captioned defendant(s) by posting of the premises and in support thereof avers the following: 1. The Sheriff has been unable to serve the Writ of Possession. The Sheriff's Return of Service is attached hereto as Exhibit I. 2. Pursuant to Pennsylvania Rules of Civil Procedure 430, plaintiff has made a good faith effort to locate the defendant. 3. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefore is attached hereto as Exhibit II. WHEREFORE, plaintiff respectfully requests this Honorable Court enter an Order to Pennsylvania Rule of Civil Procedure 430 directing service of the Writ of Possession by posting of the premises. / /A~. Von Rosenstiel ttorney for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 (610) 623-2660 Attorney I.D.//52634 Federal National Mortgage Association 1900 Market Street Suite 800 Philadelphia PA 19103 PLAINTIFF VS. Jennifer L. Troutman and or Occupant 175 Church Road Carlisle, PA 17013 DEFENDANTS Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY NO: 2001-597 Civil Term MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A sheriff's return of "Not Found" or the fact that a Defendant bas moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polls, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended ad option mailed to last known address required a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the Defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examination of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Sheriff's Return of Service, marked Exhibit I, the Sheriff has been unable to serve the Writ of Possession. A good faith effort to discover the whereabouts of the defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit II. WHEREFORE, plaintiff respectfully requests service of the Writ of Possession and all subsequent notices by certified and regular mail and by posting of the premises by the Sheriff. ttorney for Petitioner Martha E. Von Rosenstiel, P.C. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 (610) 623-2660 Attorney I.D. #52634 Attorney for Plaintiff Federal National Mortgage Association 1900 Market Street Suite 800 Philadelphia PA 19103 PLAINTIFF VS. Jennifer L. Troutman and or Occupant 175 Church Road Carlisle, PA 17013 DEFENDANTS COURT OF COMMON PLEAS Cumberland COUNTY NO: 2001-597 Civil Term AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, being duly sworn according to law deposes and says that she is the attorney for the plaintiff in the foregoing action; that she is duly authorized to take this affidavit; that she is fully familiar with the facts in this matter; and that the statements made in the foregoing ~on for Service of the / Writ of Possession and all subsequent Notices Pursuant to Special O/der of Court are true and 1 correct to the best of her knowledge, information and belief. Sworn to and Subscribed p~r~. Von Rosenst~el -- ~/(J N°tarY PublicU ~ By virtue of this writ, on the __ day of __ I caused the within named have possession of the premises described with the appurtenances, and , to WrSt of Possession returned Not Served os per Attorney on 5/16/01 at 2:00 p.m. requested by Doina Pi]iD, REO Man~gor ~ ?Sheriff's Costs: $ 37.10 Refund $ l 17.90 :h ~worn and:subscribed to before me this ~]~y of Prothonotary WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) Federal National Mortgage Association No. IN "['HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-597 Civil Term vs. Todd Rowland, Occupant 175 Church Road Carlisle, PA 17013 No. Term Costs Att'y. _ $ 13_9.08 Pl'ff (s) $ $ t.Oo Prothy. __ 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: Federal National Mortgage Association Plaintiff (s) being: (Premises as follows): 175 Church Road Carlisle, PA 17013 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date April 24, 2001 (SEAL) Curtis R. Long Profl]onolmsg Common Pleas Coun of Cumberland County, Pennsylvani~ Deput CPS Culverwood Professional Services P.O. Box 24711, Philadelphia, PA 19111 215-331-6984 FEDERAL NATIONAL MORTGAGE ASSOCIATION -VS- JENNIFER L. TROUTMAN OR OCCUPANTS : COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : 2001-597 CIVIL TERM AFFIDAVIT OF GOOD FAITH INVESTIGATION Re: Troutman PROPERTY ADDRESS: 175 Church Road, Carlisle, PA 17013-9360 SEARCH OF LOCAL TELEPHONE AND AT&T DIRECTORIES A search shows that there is a listing for this address of Todd Rowland (717) 486-8410. A call to this numbered was answered by a male who identified himself as Mr Rowland and stated that Ms. Troutman does still live at the property. NEIGHBOR CONTACTS: Enquiries with the neighbors confirmed that the property is occupied by a male and female but was unsure of the name. BROKER INFORMATION: Enquiries with the Broker of Record confirmed that the property is occupied by Ms. Troutman. l VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF GOOD FAITH INVESTIGATION ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTrlORITIES.. By: RI~.~Johns File #8181 Search Results - InfoSpace Page 1 of I [ previoqs ] Results 11 - 15 of 24 Rhoads~ P~a~l R ~ 16 Ch~ch Rd ~lick 8*m for ~m ~A~out ~Rh~ Rowland, Todd ~ 175 Ch~ch Rd Find T~d ~ow!an~m ~lassMates,com Ma~ New [dendst [ next~] u_~dateLremov~e u~d~ate/r~em~o~ve_ *DDm I~,-~ ~t-Ciiek Sync'" R_odol~h~Nancy ~ 1 g Ch~ch Rd C~k Here for Mor~ About Na~Rudo[ph F~ N~R~Pdplph a}C~Mete~ ~date/remove Mak~ N~w Fri~0d;~ Thumma, Alvin R ~ ] 0 Ch~ch Rd CI~~ ~Thumma Find Alvin R Th~ma at ~ N.~ F~nd~ ~date~emove ] 5 Church Rd E~onfia ~ ~h~mma at GJ~ssMates.c~m Make New Fden~ .../0Z&MinKS= c cZ 1Fve_0&MaxKS= d ca 1FwS_0&CurKS= c cZ 1Fve_4SxKJ&QI=10~5/21/01 Search Results - InfoSpace Page 1 of 1 Searching for: Church Rd Carlisle PA US Click a name for phone number, full address, map, directionsand more! Listings marked with an asterisk (*) are registered with InfoSpace.com [ previous J Resul~ 1 - 5 of 24 29 Ch~ch Rd [ next ] u~odate/remove 33 Church Rd Clic~k Here for More Details About[Paul CleYee~e_r F~nd P~ui D~lev~e£at ~Mates.~om update/remove ~ake New FriendsJ Clickart Mo~ De~lls Abo~ C~er Find Jan E Custe~ia~_~ undate/remnv~{ Make ~.F~ds~ Custer, Stephen C ~ 70 Ch~ch Rd Click ~ for M~r~ ~ About S~hen G~ter Find St~he~ G Custer at ClassMates,corn ~ake N~w Friends~ Grou~Paul E 23 Ch~ch Rd Click 9~ for ~o~la Abo~aul ~[n~ Paul E Greuo at~as~M~s.e~m Make New F~enOs~ .../kevdb?KCFG=US&OTMPL=%2Fres%2Fr 1 .htmI&QFM--A&QK=5&QHN=&QST=Church+I5/21/01 Return ,ansdow~e, P~. Lq05(, OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE Date No. CARLISLE, PENNSYLVANIA ~,/~?/0'.' Atty. Mar~:~: a Yon ~oser S ? ~.el Exemption has [has not] been waived. [Delete Word Not Applicable] o:-':,9~ ~-~k~ Term, 19 No, Advance Cost Paid $ Plaintiff Term, 19 ].%0.00./ / ':~ed~:a' ~'s.a,~r~onal Morkgage Assoc. Defendant vs. i'~5 Chur¢'h Road, Ca:clis]e, AMOUNT DUE INTEREST ATTY. COM. ATTY, WRIT COST PLAINTIFF MISC. SHERIFF COST DOCKETING POUNDAGE ADVERTISING LAW LIBRARY PROTHONOTARY SERVICE MlSC. SURCHARGE LEVY Served on Address Date Time Twp./Boro Phone PHONE (610) 623-2660 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 May 29, 2001 FAX (610) 623-2745 Office of the Prothonotary Cumberland Courthouse Court House Carlisle, PA 17013 175 Church Road, Carlisle, PA 17013 Docket #2001-597 Civil Term Our File #8181 Dear Sir/Madam: Enclosed please fred a Motion for Alternate Service in the above Ejectment matter. Kindly present this motion alon~ with the Order to the Judge of Duty and return the Order as soon as possible, so that writ can be vosted and eviction scheduled. I appreciate your prompt consideration. Please feel free to call if you have any questions. Enclosure Sincerely yours, Doina Filip REO Manager Martha E. Von Rosenstiel, P.C. FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff JENNIFER L. : TROUTMAN and/or : OCCUPANT, : Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-0597 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT BEFORE OLER, J. ORDER OF COURT AND NOW, this 5th day of June, 2001, after careful consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, and it appearing that Plaintiff engaged in a reasonable effort to locate and serve Defendant under Pennsylvania Rules of Civil Procedure 430(a), Plaintiff may make service by (1) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland county; (2) by ordinary mail and certified mail, restricted delivery, return receipt requested, service to be deemed complete upon mailing; and (3) posting on the most public part of the property located at 175 Church Road, Carlisle, PA 17013. ~ BY THE COURT, Martha E. Von Rosenstiel, Esq. Martha E. Von Rosenstiel, P.C. 16 South Lansdown Avenue P.O. Box 457 Lansdowne, PA 19050 Attorney for Plaintiff Jennifer L. Troutman and/or Occupant 175 Church Road Carlisle, PA 17013 Defendants, Pro Se :re WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) Federal National Mortgage Association No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 0t-597 Civil Term vs. Todd Rowland, Occupant 175 Church Road Carlisle, PA 17013 No. Term Costs Att'y. $ Pl'ff (s) $ Prothy. $ 1t9.08 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Curaberland 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: Federal National Mortgage Association being:(Premises as follows): 175 Church Road Carlisle, PA 17013 Plaintiff (s) (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date April 24, (SEAL) Curtis R. Long Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy By virtue of this writ. on the ___ da3 ol I caused the within named have possession of the premises described with the appnrtenunces, and ____ · tO Wri ~ of Possession returned Not Served as Der Attorney On 5f!6_/Q!__ap 2'-00 _D_.m_._ ...... rem]ested bv Doina Pi]iD, REO Manager ~ ,-~Sheriff's Costs: $ 32.10 ~worn and:subscribed to before me this 45 ~y of/. ~ , .3~v / Prothonotary Refund: $ I l 7.90 fi.:., Sheriff By (\..[[;-~,,(tt:', }.~,...., [...x~: {~ l.' WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) Federal National Mortgage Association 1900 Market St., Ste 800 Philadelphia PA 19103 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-597 Civil Term No. Term vs. Costs Jennifer L. Troutman and or Att'y. $ 166.18 Occupant 175 Church Road PI'fi(s) Carlisle PA 17013 ~ Prothy. $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of CUMBERLDNMm 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: Federal National Mortgage Association being: (Premises as follows): 175 Church Road Carlisle PA 17013 Plaintiff (s) (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date June 15, 2001 (SEAL) CURTIS R. LONG Profiqonotary, Common Pleas Court of Cumberland County, Pennsylvania - Deputy By virtue of this writ, on the 16th clay' ol _ .July I caused the within named Pederal National Mortcjage Assoc... have possession of the premises described ~m.ot~:X~ 175 Church Road Carlisle, PA 17013, this writ is returned stayed. 200I , to Advance Costs: $ 150.00 Sheriff's Costs $ 82.46 Sworn a(cd~subscribed to ,~rje me this dayof 7,.,~_~ ~g~. t,~ Prothonotary Refund: $ 67.54. .. :Sheriff ' Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 2001-597 CIVIL TERM PRAECIPE FOR THE WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the above Ejectme~t matter. / 175 Church Road Carlisle,, PA 17013 y E. Von Rosenstiel ~ for Plaintiff Martha E. Von Rosenstiel, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.~ 52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. ~JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 2001-597 CIVIL TERM PRAECIPE TO EI~RJUDGMENT TO THE PROTHONOTARY: Enter judgment in the above captioned Ejectment action for failure of the above named defendants to file an answer within twenty days from date of servioe thereof. I hereby certify that Notice as provided in Rule 237.5 has been duly given, and that the time limits provided for in that no/%e have expired as evidenced by the attached Exhibit I. Mar h~E. Von Rosenstiel torney for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Federal National Mortgage Association 1900 Market Street Suite 800 Philadelphia, PA 19103 Plaintiff VS. Jennifer L. Troutman and or Occupant 175 Church Road Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 2001-597 Civil Term TO: Jennifer L. Troutman and or Occupant 175 Church Road Carlisle, PA. 17013 Date of Notice: February 26, 2001 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 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: / / US. POSTAL SERVICE CERTIFICATE OF MAILING of .m~l~i-poslage and g 0. 80;( 457 ' ' \-,~x, tstie~ Martha E. Von Rosenstiel, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.~ 52634 P.e. Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMA~ AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 2001-597 CIVIL TERM AFFIDAVIT OFNONMILITARY SF~IC~ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS¸ M~/~"~AE. VON ROSENSTIEL, being duly sworn according to law deposes and says that she is the attorney for the plaintiff herein; that she is duly authorized to take this affidavit in behalf of the plaintiff, and that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the-Soldiers' and S/~lors' Civil Relief Act of Congress of 1940, as amended; / / That Jennifer L. Troutman and or Occupant is/~re over 21 years old and reside(s) at 175 Church Road, CarliSle, PA 17013. ~RT ~}A NITIEL E. VON ~SE Sworn to and Subscribed Z Before me this ~. Day /2 , /7 ~ ~ Notary P~li~ Martha E. Von Rosenstiel, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lan.sdowne, PA 19050 610 623-2660 Attorney I.D.% 52634 FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE PHILADELPHIA PA 19103 PLAINTIFF VS. ~JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT m~c. 800 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 2001-597 CIVIL TERM PRAECIPE FOR THE WRIT OF POSSESSION TO THE PROTHONOTARY: matter. Kindly issue Writ of Possession in/ above Ejectment 175 Church Road / Carlisle, PA 17013 _ ! M~~h~. Von Rosenstiel~ torney for Plaintiff SHERIFF'S RETURN - CASE NO: 2001-00597 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS TROUTMAN JENNIFER L ET AL REGULAR DAWN KELL , Cumberland County,Pennsylvania, says, the within COMPLAINT - EJECTMENT ROWLAND TODD TERRE TENANT , at 0015:03 HOURS, on the at 175 CHURCH ROAD CARLISLE, PA 17013 TODD ROWLAND {CURRENT OCCUPANT) a true and attested copy of COMPLAINT - NOTICE Sheriff or Deputy Sheriff of who being duly sworn according was served upon the 31st day of January by handing to EJECTMENT together with to law, 2001 and at the same time directing His attention to the contents 5hereof. Sheriff's Costs: Docketing 18.00 Service 5.58 Affidavit Surcharge 10.00 .00 33.58 Sworn and Subscribed to before me this ~ day of A.D. So Answers: R. Thomas Kline 02/0i/2001 MARTHA VON ROSENSTIEL Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2001-00597 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND FEDERAL NATIONAL MORTGAGE V$ TROUTMAN JENNIFER L ET AL R. Thomas Kline duly sworn according to law, says, that inquiry for the within named defendant, TROUTMAN JENNIFER L unable to locate Her COMPLAINT - EJECTMENT ,Sheriff or Deputy Sheriff, he made a diligent DEFENDANT in his bailiwick. He therefore returns who being search and but was the the within named DEFENDANT , NOT FOUND , as to TROUTMAN JENNIFER L DEFT. MOVED LEFT NO FORWARDING ADDRESS, CURRENT OCCUPANT STATES HE HAS LIVED HERE FOR A YEAR. Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sheriff of Cumberland County MARTHA VON ROSENSTIEL 02/01/2001 Sworn and this subscribed to before me day of A.D. Prothonotary Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: O ~ - ~-,c~ ~ CIVIL ACTION - EJECTMENT NOTICE AVISO 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 aider this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the cpurt your defenses or objections to the claims set forth against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the phtintiff. 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. Le hah dernandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, nsted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la nntificacion. Hace faits a santar una comparencia escrita o en persona o con un abogado y entregar a la corte en forms escrita sus defansas o sns objeeiones a las demandas an contra de su persona. Sea a visado que si usted no se defiende, la torte toms ra medidas y puede confmuar la demands an contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del dernandante y requiere que usted cumpla con todas las provisiones de esta demands. Usted puede perder dinern o sns propiedades o otros de rechos importantes para nsted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFIC1ENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIC1NA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGU1R ASISTENCIA LEGAL. DAUPHIN COUNTY LAWYER REFERRAL SERVICES 213 NORTH FRONT STREET, HARRISBURG, PA 17101 (717) 232~7536 TRUE COPY FROM RECORD Martha E. Von Rosenstiel, P,C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 1900 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 PLAINTIFF VS. JENNIFER L. TROUTMAN AND OR OCCUPANT 175 CHURCH ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: CIVIL ACTION - EJECTMENT 1. Plaintiff, Federal National Mortgage Association, is the owner of premises known as 175 Church Road, Carlisle, PA 17013, more fully described in the legal description attached hereto as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on October 4, 2000, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, No. 95-4074 Civil Term, where mortgagee was the successful bidder, and whereby plaintiff, as guarantor of the mortgage, became the owner of the said property. 3. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The defendants Jennifer L. Troutman and < Occupant are occupying the said premises without right, and so far as the plaintiff is informed, without claim of title. WHEREFORE, plaintiff brings this suit and seeks t~/recover premises. ~a~. V~,, ttorney for Plaintiff possession of said VERIFICATION I verify that the Statements made in the foregoing Docket(s)in Ejectment are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. BY~Ia~ C~~N m~an~/~~dX~~ DESCRIPTION A! .L THE following described piece, parcel or ~l'~ct of land situated in the Township of Penn, County of Cumberland, State of Pennsylva~aia, bounded and described as follows: BEGINNING at a post in thc public road comer of lands now or formerly of I_gvi Kissinger; thence by said road, North eighty-two (82) d~'grees West, nine and five tenths (9.5) perches to a post, comer of lands now or formerly of I. H. Bosle~; thence by said lauds now or formerly of J. H. Bosler, North tweu~7-ei§ht (28) degrees East, twetv¢ (12) perches to a post; thence by thc same, South eighty-two (82) degrees East, nine and fi','e tenths (9.5) perches to a post; thence by lands now or formerly of lgvi Kissinger, South twemy-~ight (28) degrees West, twelve (12) perches to the place of BEGINNING. CONTAINING one huudred six (106) perches, be ~he same more or less. BEING COUNTY TAX PARCEL NUMBER 31(120332)19