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Home My WebLink About10-3113Phelan, 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 t-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 Federal Home Loan Mortgage Corporation 8200 Jones Branch Drive, Mailstop 202 McLean, VA 22102 OF THE PROTI=OVITAAY WO MAY 12 PM 2, 59 CUMBL'i"'L -4 -'D 1'-'10UNTY PCNNSaMa NA, Attorney for Plaintiff Court of Common Pleas Civil Division V. Nicholas G. Rodites, Jr. Or Occupants 909 Old Silver Spring Road Mechanicsburg, PA 17055-2884 Cumberland County No. 10 - 3113 l?lV l C-FerM 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 O (888)-990-9108 f?? .?ta.oo P? PHS #: 233816 0C1g49%&f 04g19sz 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is Nicholas G. Rodites, Jr. Or Occupants. 3. Plaintiff is the record owner of premises located at 909 Old Silver Spring Road Mechanicsburg, PA 17055-2884, 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 # 201007325, 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 premises. By.. Phelan, Hallinan & Schmie P 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 Ju ith T. Romano, Esq. Id. No. 58745 eetal 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff EXHIBIT "A" a 001 MY ?l Tax Parcel No. 18-22-0519-001-U-L909 #ol?? e a e, -moo' P'dC& -7&? /Vo Know all Men by these Presents That 1, 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 Federal Home Loan Mortgage Corporation Writ No. 2009-3339 Civil Term Wells Fargo Bank, NA Vs Nicholas G. Rodites, Jr. ALL THAT CERTAIN unit in the property known, named and identified in the Declaration referenced to below as `Walnut Villas Condominium' located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 58 Pa. Cons. Stat. An. 3101 et seq., (Purdon Supp. 1985), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated July 30, 1985, and recorded on August 14, 1985 in Miscellaneous Book Vol. 308, Page 147, and all of said Declaration amendments referred to in prior deeds. AND BEING DESIGNATED as Unit No. 909 with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as so amended and as further amended by any further amendments thereto hereafter recorded in the aforesaid office. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record, including (but not limited to) those contained in the instruments recorded in the aforesaid office in Miscellaneous Book Vo. 304, Page 227, Miscellaneous Book Vol. 304, Page 566. TITLE TO SAID PREMISES IS VESTED IN Nicholas G. Rodites, Jr., a single person, by Deed from Charles L. Miller, Jr., a single person, dated 08/10/2007, recorded 09/04/2007 in Instrument Number 200734411. PREMISES BEING: 909 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055-2884 PARCEL NO. 18- 22-0519-001.-U-L90 - The same having been sold by me to the said grantee on the 3rd 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 3339 at the suit of Wells Fargo Bank, NA -vs- Nicholas G. Rodites, Jr. In Witness Wereof, I have hereunto affixed my signature this 17 day of March Anno Domini Two Thousand and Ten (2010) 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) `titi' •< M/Ir ,.W FA Voliftow I hereby certify that the residence And Post Office address of the Within Grantee is 8200 Jones Branch Drive, Mail Stop 202 McLean, VA 22102 Solicitor ' ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201007325 Recorded On 3/24/2010 At 11:00:20 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 62783 User ED - AF * Grantor - RODITES, NICHOLAS G JR * Grantee - FEDERAL HOME LOAN MTG CORP * Customer - SHERIFF * FEES STATE SPRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 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 MECHANICSBURG SCHOOL $0.00 DISTRICT MECHANICSBURG BOROUGH $0.00 TOTAL PAID $63.00 * 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 I? 1) * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111111111111 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 Plainti SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronn R Anderson Y ,~- ~~ ~'`~~•-I"' r ', t... ~ , ~,",~sRY T~~ F~'` ( : r Sheriff gtr ct ~'u~nbrrf ~ . , .:,. Jody S Smith ~au ~~~ ~ ~ i fl ,~ _~, ~ I 1°~ " ~ ~ ~ ~ r~ Chief Deputy G ' ~`' "~ Richard WStewart ° ~~`" ~UPr!~ +"- `' '~' ~'~ ,1 Solicitor F i~E ~~ F , NE s~~aIFF - ~. ,~.~~• ` ;'~`~ Federal Home Loan Mortgage Corporation Case Number vs. Nicholas G. Rodites, Jr. 2010-3113 SHERIFF'S RETURN OF SERVICE 06/16/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Nicholas G. Rodites Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Nicholas G. Rodites Jr. Request for service at 909 Old Silver Spring Road, Mechanicsburg, PA 17055 is vacant. 06/16/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 909 Old Silver Spring Road, Mechanicsburg, PA 17055, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 909 Old Silver Spring Road, Mechanicsburg, PA 17055 is vacant. SHERIFF COST: $63.00 June 16, 2010 SO ANSWERS, ~--""" RON R ANDERSON, SHERIFF (c) GountySuile Sheriff, Teleosoft, Inc. o C uM David-D. Buell- e, Renee IC Simpson Prothonotary 1 Deputy Prothonota"J a ti�_run;.;s 2�irkS. Sofionage, ESQ Irene E. Morrow Solicitor 1750 Tar Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania An — 3/13 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fax(717)240-6573