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HomeMy WebLinkAbout10-5300t Phelan, Hallinan & Schmieg, LLP 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 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 Federal Home Loan Mortgage Corporation 8200 Jones Branch Drive, Mail Stop 202 McLean, VA 22102 V. Steven W. Johnson Or Occupants 132 Goodyear Road Carlisle, PA 17013-9407 CIVIL ACTION - EJECTMENT Cumberland County 1 No. ' 6„ ?3 6 6 c N" I ?I e lfi **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 PHS #: 241971 (888)-990-9108 s9?-°DP'Ly C-0:? ffrf 717 /-4" at 7R ?u E O 12 PM 24-T3 Attorney for Plaintiff Court of Common Pleas Civil Division s 4 , 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is Steven W. Johnson Or Occupants. 3. Plaintiff is the record owner of premises located at 132 Goodyear Road, Carlisle, PA 17013-9407, 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 June 2, 2010, as evidenced by the Sheriff's deed recorded July 8, 2010 in the Office of the Recorder of Cumberland County in instrument 201018322, 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 recovervssession of said By: Phe , Hallinan & Schmieg, LLP La nce T. Phelan, Esq. Id. No. 3 227 F c S. Hallinan, Esq., Id. No. 62 95 Dan 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. 817,90 Jenine R Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 9333 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 l , EXHIBIT "A" 000330 Tax Parcel No. 46-07-0479-024 Know all Men by these Presents 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 Federal Home Loan Mortgage Corporation Writ No. 2009-8018 Civil Term Chase Home Finance, LLC Steven W. Johnson ALL THAT CERTAIN tract of land with improvements thereon erected, situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point in the centerline of Mt. Rock-Bloserville Road, at line of land now or formerly of Chester Snyder; thence along said latter lands, North 57 3/4 degrees West, 155 feet to a stake; thence along lands now or formerly of Margaret Ker Goodyear, North 15 1/2 degrees East, 447.5 feet to a stake; thence by the same, North 63 1/2 degrees East, 177 feet to a point in the center of the aforesaid road; thence in said road, South 9 1/4 degrees West, 114 feet, more or less, to a point in the centerline of said road; thence by the center of said road, South 15 1/2 degrees West, 495 feet to a point, the Place of BEGINNING. BEING the same premises which Nancy Goodyear Baish and R. Robert Baish, wife and husband, by Deed dated September 27, 1958, and recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book V, Volume 18, Page 496, granted and conveyed unto Earl, J. Keck and Dorothy M. Keck, husband and wife. The said Dorothy M. Keck died on October 13, 2000, whereupon the entire fee simple interest in the premises herein conveyed became vested in the said Earl J. Keck as surviving tenant by the entirety. UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions and rights of record, to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES VESTED IN Steven W. Johnson, single person, by Deed from Sandy A. Keck, Executor of the Last Will and Testament of Earl J. Keck, Sr., dated 06/02/2006, recorded 06/06/2006 in Book 274, Page 4902. PREMISES BEING: 132 GOODYEAR ROAD, CARLISLE, PA 17013-9407 PARCEL NO. 46-07-0479-024. The same having been sold by me to the said grantee on the 2nd day of June 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 20`h of January Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 8016 at the suit of Chase Home Finance, LLC vs- Steven W. Johnson In Witness Whereof, I have hereunto affixed my signature this 23 day of June Anno Domini Two Thousand and Ten (2010) 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 23 day of June Anno Domini Two Thousand and Ten (2010) onvtary 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 : --- 4-& A I ?L Richard W. Stewart Solicitor ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Chase Home Finance, LLC -vs- Steven W. Johnson No. 09-8016 ASSIGNMENT OF BID RIGHTS UNDER sZJF" rS FmVWU770M SALE Chase Home Finance, LLC hereinafter called Assignor, for and in consideration of the sum of $1,065.56, receipt of which is hereby acknowledge do(es) hereby sell, assign, transfer and set over unto FEDERAL HOME LOAN MORTGAGE CORPORATION. all of its right, title and interest in and to the property more fully described in the list attached hereto, made a part hereof and marked Exhibit "A" under the bid knocked down to Assignor at the execution sale in the Court of Common Pleas of Cumberland County, Pennsylvania, on June 2, 2010, in the above captioned proceedings. IN WITNESS WHEREOF, the Assignor has hereunto set its hand and seal, this A day of June 2010 intending thereby to be legally bound. Wt-\&m -? Nora M. Ferrer (SEAL) COMMONWEALTH OF PENNSYLVAMA NOTARIAL SEAL NORA M. FERRER, Notary Public City of PhiladePhia, Phh- C=* Canmin 20f3 . ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201018322 Recorded On 7/8/2010 At 12:58:53 PM * Instrument Type - DEED-SHERIFF'S Invoice Number - 68759 User ID - JM * Grantor - JOHNSON, STEVEN W * Grantee - FEDERAL HOME LOAN MTG CORP * Customer - SHERIFF * FEES STATE WRIT TAIL $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 PEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 BIG SPRING SCHOOL $0.00 DISTRICT WEST PENNSBORO TOWNSHIP $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. RECORDER OF Dr * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 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 Plaintiff s 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 sheriff s 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. b -7 Date PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Federal Home Loan Mortgage Corporation COURT OF COMMON PLEAS CIVIL DIVISION vs No. 10-5300 Steven W. Johnson Or occupants Cumberland County CD 132 Goodyear Road ' Carlisle, PA 17013-9407 -? rncrj ---4 1 .? c 'v r-- a C) PRAECIPE FOR WRIT OF POSSESSION . P. • t a ' ' TO THE PROTHONOTARY: ;- Issue Writ of Possession in the above matter for possession of: 132 Goodyear Road, Carlisle, PA 17013-9407 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 132 Goodyear Road O an, H lhnan & chmieg, LLP ence T. Phelan, Esq., Id. No. 32227 7L F ncis S. Hal linan, , Esq., Id. No. 62695 *014 W PD Al-ry Daniel G. Schmieg, Esq., Id. No. 62205 Ajq 40 C8F" Michele M. Bradford, Esq., Id. No. 69849 CIA. 00 , Judith T. Romano, Esq. Id. No. 58745 14' 00 Sheetal R. Shah-Jani, Esq., Id, No. 8176p Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 # I?Q 40 PO ATT`I 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 *a.00 LUe l.p Attorney for Plaintiff •50 LL C# 100$980 0 a484af,- RE W?4&uud %-- J ALL THAT CERTAIN tract of land with improvements thereon erected, situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described, as follows: BtGINNING at a point in the centerline of Mt. Rock-Bloserville Road, at line of land now or formerly of Chester Snyder; thence along said latter lands, North 57 3/4 degrees West, 155 feet to a stake; thence along lands now or formerly of Margaret Ker Goodyear, North 15 1/2 degrees East, 447.5 feet to a stake; thence by the same, North 63 1/2 degrees East, 177 feet to a point in the center of the aforesaid road; thence in said road, South 9 1/4 degrees West, 114 feet, more or less, to a point in the centerline of said road; thence by the center of said road, South 15 1/2 degrees West, 495 feet to a point; the Place of BEGINNING. BEING the same premises which Nancy Goodyear Baish and R. Robert Baish, wife and husband, by Deed dated September 27, 1958, and recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book'R', Volume 18, Page 496, granted and conveyed unto Earl. J. Keck and Dorothy M. Keck, husband and wife. The said Dorothy M. Keck died on October 13, 2000, whereupon the entire fee simple interest in the premises herein conveyed became vested in the said Earl J. Keck as surviving tenant by the entirety. UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions and rights of record, to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES VESTED IN Steven W. Johnson, single person, by Deed from Sandy A. Keck, Executor of the Last Will and Testament of Earl J. Keck, Sr., dated 06/02/2006, recorded 06/06/2006 in Book 274, Page 4902. PREMISES BEING: 132 GOODYEAR ROAD, CARLISLE, PA 17013-9407 PARCEL NO. 46-07-0479-024. r. 10f2 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. 10-5300 Civil Term STEVEN W. JOHNSON or OCCUPANTS 132 Goodyear Road Carlisle, PA 17013-9407 Costs Attorney's $ 1'14.40 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): 132 GOODYEAR ROAD, CARLISLE, PA 17013-9407 (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. 6- 1 vid D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA Date 9/29/10 (Seal) 4 2 of 2 No 10-5300 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION vs. STEVEN W. JOHNSON or OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att' y $ '79.. 40 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: JENINE R. DAVEY, ESQUIRE - ID# 87077 PHELAN, HALLINAN & SCHMIEG, LLP ONE PENN CENTER @ SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of I caused the within named , to have possession of the premises described with the appurtenances, and _ Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy Phelan, Hallinan & Schmieg, LLP 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation vs Steven W. Johnson Or occupants 132 Goodyear Road Carlisle, PA 17013-9407 F11 FG-O FILE OF THE PRO HONG A"Y 22' 1 ?5 fiFP 29 A !' C,. t CUMBERLAN'D COt9N 1 V PENNSYLVANIIa Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 10-5300 Cumberland County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Federal Home Loan Mortgage Corporation and against the Defendant(s) Steven W. Johnson and Or occupants for possession of premises 132 Goodyear Road, Carlisle, PA 17013- 9407 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10- notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct c of ich is attached her o Ph an, Hallinan & Schmieg, I/LP L rence T. Phelan, Esq., Id. No. 32227 F cis 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. 81 60 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 Default Judgment entered as indicated above Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 414-00 P0 DATE Courtenay R. Dunn, Esq. Id. No. 206779 a It08%0 Andrew C. Bramblett, Esq., Id. No. 208375 P-* ays9a? Attorney for Plaintiff Mc4ce, A&&Ct Phelan, Hallinan & Schmieg, LLP 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq. Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation vs Steven W. Johnson Or occupants 132 Goodyear Road Carlisle, PA 17013-9407 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 10-5300 Cumberland County VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant Steven W. Johnson Or occupants, is over 18 years of age, and resides at 132 Goodyear Road, Carlisle, PA 17013-9407. This statement is made subject to the penalties of 18 PA. C..S 904 relating to un w falsification to authorities. Phelan, limn & Schmieg, LLP Lawre T. Phelan, Esq., Id. No. 2227 Francis . 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. 817?t1 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 PHS# 241971 Phelan Hallinan and Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation Plaintiff V Steven W. Johnson or occupants Defendant TO: Steven W. Johnson or occupants 132 Goodyear Road Carlisle, PA 17013-9407 Court of Common Pleas Civil Division :No. 10-5300 :.Cumberland County DATE OF NOTICE: Seytember 8, 2010 "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."* 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 (10) 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: OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6195 ?9t???,?I CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 L encX'P. Phelan. Esq.,1 No. 32227 F Ws S. Hallinan, Esq., 1 No. 62695 17 ic;l G. Schmieg, Esq., Id. No. 62205 ichcle M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 56745 Sheetal R. Shah-Jani, Esq., Id. No. 81 Jenine R. Davey, Esq., Id. No, 6707 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~aaxxa at +Gu~nb~rl;~fi~ ~ k 1~$4 ~d_ cs~rice aF rhE sh~R(~F i' ~ (;~-i~r t= i%~ ~~iD ~C ~ _g ~~~ 3~ ~ f a Federal Home Loan Mortgage Corporation Case Number vs. Steven W. Johnson 2010-5300 SHERIFF'S RETURN OF SERVICE 10/06/2010 03:50 PM - Ronny R. Anderson, Sheriff, who being duly swom according to law, states that on October 6, 2010 at 1550 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupant(s)s, of 132 Goodyear Road, Carlisle, Cumberland County, Pennsylvania 17013. The only resident of 132 Goodyear Road, Carlisle, Cumberland County, Pennsylvania 17013 is defendant Steven W. Johnson. Therefore, the within Writ of Possession is being returned with no service as the defendant, Occupant was NOT FOUND. 10/06/2010 03:50 PM -Stephen Bender, Deputy Sheriff, who being duly swom according to law, states that on October 6, 2010 at 1550 hours, he served a true copy of the within writ of possession, in the above entitles action, upon the within named defendant, to wit: Steven W. Johnson, by making known unto Steven W. Johnson, at 132 Goodyear Road, Carlisle, Cumberland County, Pennsylvania 17013, its contents and at the same.time handing to him personally the said true and correct copy of the same. SO ANSWERS, .~, ~-- October 07, 2010 RON R ANDERSON, SHERIFF ~~~~ St:eph n Bender, Deputy (c} CountySuite Sheriff, Teleosoft, Inc. .. ...~ ] of 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. IO-5300 Civil Term STEVEN W. JOHNSON or OCCUPANTS 132 Goodyear Road Carlisle, PA 17013-9407 Costs Attorney's $ I'74.~f0 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): 132 GOODYEAR ROAD, CARLISLE, PA 17013-9407 (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. Date 9/29/10 (Seal) Da id D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA ~~ TRUE COPY FROM RECORD In'Tbstirrwny wnereot, ~ hen unto set my lurid and the seal of said ~ , p~ Th//i__s,,`~ ay of gp /~ CIA. v. r J 2 of 2 No 10-5300 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION VS. Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of I caused the within named , to have possession of the premises described with the appurtenances, and STEVEN W. JOHNSON or OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ I~r4.yo Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: JENINE R. DAVEY, ESQUIRE - ID# 87077 PHELAN, HALLINAN & SCHMIEG, LLP ONE PENN CENTER @ SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy ~ l ALL THAT CERTAIN tract of land with improvements thereon erected, situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point in the centerline of Mt. Rock-Bloserville Road, at line of land now or formerly of Chester Snyder; thence along said latter lands, North 57 3/4 degrees West, 155 feet to a stake; thence along lands now or formerly of Margaret Ker Goodyear, North 15 1/2 degrees East, 447.5 feet to a stake; thence by the same, North 63 1/2 degrees East, 177 fcet to a point in the cemer of the aforesaid road; thence in said road, South 9 1/4 degrees Wcst, 114 fcet, more or less, to a point in the centerline of said road; thence by the center of said road, South 15 1/2 degrees West, 495 feet to a point, the Place of BEGINNING. BEING the samc premises which Nancy Goodyear Baish and R Robert Baish, wife and husband, by Deed dated September 27, 1958, and recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Book'R', Volume 18, Page 496, granted and conveyed unto Earl. J. Keck and Dorothy M. Keck, husband and wife. The said Dorothy M. Keck died on October 13, 2000, whereupon the entire fee simple interest in the premises herein conveyed became vested in the said Earl J. Keck as surviving tenant by the entirety. UNDER AND SUBJECT bo existing covenants, agreements, conditions, easements, restrictions and rights of record, to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES VESTED IN Steven W. Johnsam, single person, by Deed from Sandy A. Keck, Executor of the Last Will and Testament of Earl J. Keck, Sr., dated 06/0212006, recorded 06/06/2006 in Book 274, Page 4902. PREMISES BEING: 132 GOODYEAR ROAD, CARLISLE, PA 17013-9407 PARCEL NO.46-07-0479-024.