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Home My WebLink About10-5825GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF RED-nCE F TH 7r` TORY Q ?p I0 P 2: t2 NTY CUM PENSSYCVANIA FANNIE MAE International Plaza II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Defendants NOTICE CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 10 -58o2,S ?iv i 1TP,Nh 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 the 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 claim in the Complaint of 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 4 gA.00 PO PLFF 8 Irvine Row, Carlisle, PA 17013 P*54433a 717-243-9400 O a'/8 05' AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is FANNIE MAE, International Plaza II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916. 2. Defendants are MICHAEL F. MORAN, and OCCUPANTS. Plaintiff is the owner of property located at 500 Thomas Road, Camp Hill, PA 17011, by virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on 7/8/2010 at Instrument # 201018327. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, MICHAEL F. MORAN and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for p2*§siyn of the Property. By: MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 /bavid Fein Pa. ID 82628 / Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff VERIFICATION I, John N. Whitehead, on behalf of the Plaintiff corporation within named, do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: 0 P100735 500 Thomas Road, Camp Hill, PA 17011 99333EJ 90ran Fannie Manager REO Fulfillment SCHEDULE C ALL THAT CERTAIN #ract or parc:ei of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: IN ACCORDANCE with the Amended Final Subdivision Plan No. I entitled "1"'0=0ff", PmPared by Michael C. IYAngelo, R.S., dated August 7, 1981, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan gook "46,., Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. C-9 set at the dividing line between Lots Nos. C-9 and C-8 where said dividing line interseft with line of land designated as F.H.O.A. #2; thence along line of F.H.O.A. #2, North 61 degren 49 minutes 47 seconds East, a distance of 60.26 feet to a Pow thence continuing along line of land South 09 degrees 26 n*x tes 16 seconds East a dfstanoe of designated 5.03 feet to a?• Point thence continuing along F.H.OA #2, South 61 degrees 49 minutes 47 seconds West, a distance of 29.74 feet to the dhrfding rive between Lots Nos. C-9 and C-8; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, at distance of 90 feet to a point, the Place of BEGINNING. BEING Lot No. C-9 on the above Plan; also being known and numbered as 500 Thomas Road. 13E7NG the same premises which Mariellen Carpenter Lee, Execuhirc of the Will of Lois Jane Carpenter Wa Jame B. Carpenter, by her Deed dated September 20, 2001 and recorded October 2, 2001 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 248, Page 3057, granted and conveyed unto Wheel F. Moran, in fee. 8K 178311163430 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?y?tr etEe?t1bF? f??? QFF C4 gMC P" n. _ a 1 f'rr^r r- t ti C J li `t ° ^r [n nn 1 f f I;UJr"1 a Fannie Mae vs. Michael F. Moran Case Number 2010-5825 SHERIFF'S RETURN OF SERVICE 10/11/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on October 11, 2010 at 0855 hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Michael F. Moran. After several attempts the Complaint in Ejectment has expired. 10/11/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on October 11, 2010 at 0855 hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Occupant of 500 Thomas Road, Camp Hill, PA 17011. After several attempts the Complaint in Ejectment has expired. SHERIFF COST: $84.50 SO ANSWERS, October 11, 2010 RON R ANDERSON, SHERIFF re°, GourtySWte She!rff. Teiebsott, Irc. GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE International Plaza II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 vs. MICHAEL F. MORAN & OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW EJECTMENT COMPLAINT Term No. 10-5825 Civil PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. c? C t ot-- r°` x? By: GOL CK CAFFERTY MCKEEVER Michael Mc 9 Gary McCafferty Pa. ID 423 86 ,L.?' Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff N PQ } C71 A!d D 44? DD ? 3U 39ia r, .?n C"a' "i FANNIE MAE International Plaza. II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 10-5825 Civil MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 AND NOW, this 013rd ORDER day of May 2011, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Ejectment upon Defendants by posting a copy of the Complaint upon the premises 500 Thomas Road, Camp Hill, PA, 17011, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 500 Thomas Road, Camp Hill, PA, 17011 , and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Writ of Possession pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: -4 ".L- 11 - Distribution list: / Goldbeck, McCafferty & McKeever, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 MICHAEL F. MORAN, 500 Thomas Road Camp Hill, PA 17011 Supreme Pennsylvania Pleas county z For Pr Batir : U" on)r _ Dochat-No ro-5845 el 5'.. The information collected on this form is used solely for court administration purposes. This form does not Sunnlement nr rvnlnrc tho 171;- ..y,.1 , -7 __ _ u L"U7lTL. Commencement of Action: X Complaint ? Writ of Summons ? Petition ? Notice of Appeal ? Transfer from another Jurisdiction ? Declaration of Taking Lead Plaintiff Name: Lead Defendant's Name: FANNIE MAE MICHAEL F. MORAN and Occupants ? Check here if you area Self-Represented (Pro Se) Litigant Name of Plaintiffiappellant's Attorney: GOLDBECK McCAFFERTY & McKEEVER Are money Damages requested?: El Yes X No Dollar Amount Requested within arbitration limits (Check one) _X _outside arbitration limits is this a Class Action Suit? ? Yes X NO -Nature of the Case..Place, .an 'X' to the left of the ONE case category: that most accurately describes,your PRIMARYCASE.. If you are making more than one type of claim, check the one that _ you consider most important :'. . _. .: : _ TORT (do not include Mass Tort) ? Intentional ? Malicious Prosecution ? Motor Vehicle ? Nuisance CONTRACT ? Buyer Plaintiff ? Debt Collection: Credit Card ? Debt Collection: Other _ CIVIL APPEAL Administrative Agencies ? Board of Assessment ? Board of Elections ? Dept of Transportation ? Premises Liability ? Zoning Board ? Product Liability (does not include mass tort) ? Sl d / i ? Employment dispute: Discrimination ? Statutory Appeal: Other er an L bel Defamation ? Oth ? Employment Dis ute: Othe er p r Judicial Appeals ? MDJ - Landlord/Tenant ? MDJ -Money Judgment MASS TORT ? Asbestos ? Other ? Other: ? Tobacco ? Tonic Tort - DES ? Toxic Tort - Implant ? Toxic Waste ? Other gEAj, PROPERTY X Ejectment ? Eminent Domain/Condemnation ? Ground Rent MISCELLANEOUS ? Common Law/Statutory Arbitration ? Declaratory Judgment ? Landlord/Tenant Dispute ? Mandamus ? Mortgage Foreclosure ? N D i PROFESSIONAL LIABILITY ? Dental ? Legal ? Medical ? Other Professional: ? Partition ? Quiet title ? Other on- omest c Relations Restraining Order ? Quo Warranto ? Replevin ? Other Pa.RC.P. 205.5 212010 GOLDBECK MCCAFFERTY & McKEEVER BY: MICHAEL T. McKEEvER, EsQuIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PRUADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE International Plaza 11 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff vs. MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Defendants NOTICE Term No. 16 -S89S CiuilTer%- 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 the 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 claim in the Complaint of 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 g HEREBY Q`F-M'!F A 4 HIS IS ATRUE AND 64PE T COPY OF THE ORIGINAL FINED C- C: z 2 w IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO PAMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA. DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is FANNIE MAE, International Plaza. 11, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916. 2. Defendants are MICHAEL F. MORAN, and OCCUPANT'S. 3. Plaintiff is the owner of property located at 500 Thomas Road, Camp Hill, PA 17011, by virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on 7/8/2010 at Instrument # 201018327. A true and correct copy of the legal description of the Property is attached to this Complaint 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, MICHAEL F. MORAN and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANT'S, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for p? of the Property. By: BECK MCCAFFERTY & MCKEEVER chael McKeever Pa_ ID 56129 Crary McCafferty Pa- ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff VERIFICATION I, John N. Whitehead, on behalf of the Plaintiff corporation within named, do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 2A John itehead Evictio Manager REO Fulfillment Fannie ae P100735 500 Thomas Road, Camp Hill, PA 17011 99333EJ l? ar) SCHEDULE C ALL THAT CERTAIN tract or Partsj of and hang and being in the BMMO of WOUd and P?Cumb dand e, and Comntajeaittr of PermsyWania, re ??y desaibed of Gun as blaww ,? ACCORDANCE with the Amended Finial SubdMn Plan No. I last revised on J - IXMxM f by lWchael C. DR my IT. 1984 and recorder! in the Ofrwe of tha ?r 7' teed, in and for Gtimberkmd County "ROWS: , Pence in Plan gook, onleof Deeds page 110, as "EGINNUM bobat a set at the d Port at the item conW of Lot No. C-9 divides line n Lets Nos. C-9 and C-8 where said divld' F.Ft.O with f§re of ! designated as F.H.OA. #2; thence a Una #2, North 61 degrees 49 minutes 47 seconds. lie of feet to a Point thence continuing along rms of land ' a distar of 60.26 dedgnated as F.N.OA #2, ?? ? mkwtes 16 seconds East a dteimnce of f 95.03 few to a seconds W slang F N.OA #2, South 61 degrees 49 mnwfes 47 esf, a distWa of 29'.r4 fea to the dint ' and "I thence along said diVid'stg line and ? Veen [.ors Nos. G9 Nord 28 degrees 70 minutes 13 P?i??9 dough a Parf?an wall, the Plane of BEGINNING. seconds West, at t stance of 9p feet to a point. BEING Lot No, numbered as 50p TfKxnas C-9 on the above also being known and I3 Dad. gE1NG the same ExecLft of the premises which Ma"88en Carpente Lee win of Lois Jane Carpenter aWa Jame B. Deed dated unbar 20, 2001 and recorded ? ? by her fike the Recorder of Deeds in and for Cumberland Cy, 2, n2MI syl in the C? e of Book 248. Page 3W7, gmnted and conveyed unto 1Nichael F. Mortiaoran, in fee. BK 178 3PG33438 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 -- Prothonotary ba„c FANNIE MAE International Plaza II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff vs. MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Defendants N O T I C E Term No. 10-5825 Civil Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: -Cezrg Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Goldbeck McCafferty & McKeever at the following telephone number: (215) 825-6319 5-60 (2) (Rev. 4/78)55 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 191001532 215-825-6319 Attorney for Plaintiff FANNIE MAE, International Plaza. H 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff vs. MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Defendants e- i- r 2111 JUL 22 AFB II : t? F (,ur-)tltHLAt PENNS YLW,WIA ¢ . IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 10-5825 Civil PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, FANNIE MAE and against the Defendants MICHAEL F. MORAN and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237.1, written 10 day notice of Plaintiff's intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is FANNIE MAE, International Plaza II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916 and that the names and last known address of the Defendants are MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road, Camp Hill, PA 17011. By: X-r- 0e?? G A6LD ECK MCC FFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ?Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff J L{. 0?) F d ' GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff FANNIE MAE International Plaza H 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 vs. MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Plaintiff Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 10-5825 Civil CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Valerie Merritt, an employee of Goldbeck McCafferty & McKeever, counsel for Plaintiff, certify that a tnie and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: MICHAEL F. MORAN OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 By: GOLDBECK MCCAFFERTY & MCKEEVE Valerie Merritt, Legal Assistant 215-825-6319 (Direct Phone) DATED: % ?.0/? GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHTLADELPHiA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE International Plaza II -142217Datla-PuMT, Dallas, TX 75254-2916 MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 vs. Plaintiff Defendants DATE OF THIS NOTICE: July 8, 2011 TO. OCCUPANTS 500 Thomas Road Camp Hill, PA 17011. R%dPORTANT NOTICE ACTION OF EJECTMENT Term No. 10-5825 Civil 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 OBJECTION'S 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SETFORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. CUNMFRL AND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES IIJC 8 ]wine Row Carlisle, PA 17013 By: _ GO BE t MCCAFF RT'Y & MCKEEVER Michael Mc Bever Pa ID 56124 -Gary McCafferty Pa_ ID 423 86 -Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa ID 82628 Thomas Puleo Pa. ID 27615 ?Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW GOLDBECK McCAFFERTY & McKEEVER SUTIE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF FANNIE MAE ---- ------luternatioiral-P-laz-a4[ --- 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 vs. DATE OF THIS NOTICE: July 8, 2011 TO: MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS - - ---- --OF- Cumberland COUNTY - __-- CIVIL ACTION - LAW Plaintiff ACTION OF EJECTMENT Tenn No. 10-5825 Civil Defendants 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 WIITIIN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR 'T'ELEPHONE THE OFFICE SET' FORTH BELOW- THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER 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 BAR ASSOCIATION 2 Liberty Avenue C r isle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 By: !il GO BE MCCAFF TY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 423 86 Lisa Lee Pa_ ID 78020 -Kristin Murtha Pa- ID 61858 David Fein Pa- ID 82628 Thomas Puleo Pa_ ID 27615 y Kivitz Pa- ID 26769 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA FANNIE MAE Plaintiff vs. MICHAEL F. MORAN Defendant(s) NO. 10-5825 Civil VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with Goldbeck McCafferty & McKeever, as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, MICHAEL F. MORAN, has a last known residence of 500 Thomas Road, Camp Hill, PA 17011. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is riot in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: 7/18/2011 By: G DB CK MCC FFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ?Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Attorneys for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jul-18-2011 13:05:13 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency MORGAN MICHAEL Based on the information you have furnished, the DMDC does not possess F any, information indicating the individual status. Upon searching the information. data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 1A jft*4+. - A01 f4- A(? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 'T'he Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. 'The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://wNvw.defenselink.mil/fag/`pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. htips://www.dmdc.osd.mil/appj/:;cra/popreport.do 7/18/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic: and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:5CS5HKPIG7 https://www.dmdc.osd.mil/appj/scra/popreport.do 7/18/2011 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA FANNIE MAE; et seq. Plaintiff (Petitioner) V. MICHAEL F. MORAN; et al. Defendant (Respondent) CASE and/or DOCKET No.: 10-5825 CIVIL Sheriffs Sale Date: AFFIDAVIT OF SERVICE Complaint Summons 11 Other: PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT I, RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that 1 attempted to serve OCCUPANTS the above process on the 13 day of June, 2011, at 11:45 o'clock, AM, at 500 Thomas Road Camp Hill, PA 17011 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: J By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of PA } SS: County of lk rtrt ) Before me. the undersigned 4tary public, this day, personally, appeared . Al - 1 _ to me known, who being duly sworn according 6? law, deposes the following: i hereby swear or affirm} the facts set forth in the foregoing Affidavit of Service are true and correct. of Affiant) File Number:99333EJ Subscribed and om to fore me this lit day of 6q% 20 l1 Notary Public COMMONWEALTH OF PMNMVANIA Notarial Seal Eric m. ARWbach, Notary Kok Mly Cam Washington nTwp., Berke County Expires NOV. 18, 2013 ?a ?u - o -- ( ' °? L 0o MN 61 _ W N U)i 5 o ?. O L Q U) _ (- ` N ? r C' l 0 Q? { 111 CQ 6 a 1 rn ? ? ti a b Lo d - c T `Z iNn o i c 0 Y c m E m Y Y U Q T U -U Er j N m c m .?l f1J?f ?' a d c 0 cc 7 (A m ?l C U t0 E c m 2 _ N? o m o cc 65 D 'o U N Q %U00 co m c N O D C m ao m o a E L m a) C C a) O m Z m o E d ° o O? vU R c? v m a m ? ? ni m Si' m m y - ???? E U m U C ? l rn j N E ? W-0o Ca F- 700 cc ~ 0 m U? E = Or- ?¢ O. - cnWQ E zH? c m m m U `n n- F" Na ? ro' S m mo w x°N 3s $ ? m - E_ Z m - E= a d a CL L) W.S z o= o= ????o a F- O m U E 0 - 2tooU OLoU o a o? dx is _ o a a E? a w u ~ j ~ 0 w z n WQ CL ¢ U) 'U) Q m v' ? m U °oYpWO. m a ` N LUOYJM ? o 0 ?LU M) ? ? Q E > `J F- J O v _ i 0 O= T r" N M oD o m T 0cntia? I C d a S O IL Itl m O .b c d 3 Q T m a E O U 0 N N 0 0 D m U) N T O C 3 O a -a CU E O ? Z' E Q U 0 ti LL- oo J C-7 -7 W W Q € m X: 0 co LL crc) U_ a rn Z> Form 3877 Page: 2 Mai lees Name an Address: Permit Number: MAC Cert. Ver. Num. Goldbeck McCafferty & McKeever 969005937 SendSuite - MAC v6.25.6.25.L 701 Market Street Sequence Number: PHILADELPHIA, PA 19106 0001186 Pc ID W Addressee Name Postage ES ES Insured Due Total Article # Delivery Address Type Fee Value Sender Charge 99333EJ-MM MORAN, MICHAEL F. 0.640 C 112.850 0.00 4.640 9171082133393932086031 500 Thomas Road ERR 111.150 Camp Hill, PA 17011 99333EJ-00 OCCUPANTS 0.640 C 112.850 0.00 4.640 9171082133393932086048 500 Thomas Road ERR 111.150 Camp Hill, PA 17011 Page Totals: 2 Cum Totals: 17 1.280 8.000 10.880 S7AI o,, 00 : a :RTIFIC r N Q?, a u ? i e Round Stamp: 9.280 78.880 USPS Total Number of Pieces Received: Off Signature of Receiving Employee Form 3877 (Facsimile) SendSuite - MAC v6.25.6.25.1- C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland FANNIE MAE International Plaza Il 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS Plaintiff vs. Defbndants PRAECIPE FOR WRIT POSSESSION C) C- r-I 10-5825 Civil G7 -- rrj M c C. e - :?D r Cl,r -C!M N N !:?c3 >C) 33. M r C3 Issue the Writ of Possession in the above matter, for possession of 500 Thomas Road Camp Hill. PA 17011 (describe property) SEE ATTACHED LEGAL DESCRIPTION By: WLEIBECK MCC'AFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 ?.?Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Ejectment Quiet Title A. 5 - 116 (Rev. 10/76) .)I.C ?, . U 5Y. sJ .00 /0 n' OF Cumberland COUNTY C ?Y WJ ?f -00 E)" C' WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160-3165) FANNIE MAE International Plaza 11 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 vs. MICHAEL F. MORAN and OCCUPANTS 500 Thomas Road Camp Hill, PA 17011 Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland To the Sheriff of Cumberland County, Pennsylvania. COURT OF COMMON PLEAS Term No. 10-5825 Civil WRIT OF POSSESSION (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to FANNIE MAE, Plaintiff, being: (Premises as follows): 500 Thomas Road Camp Hill, PA 17011 (2) To satisfy the costs against the defendants you are directed to levy upon any property of the defendants and sell his., her or their interest therein. Dated: a a . 020 / / 41 u bay;d 6 /-c;eIf Prothonotary, Court of Common Pleas Cumberland County By: Deputy AJ a -a-) 04,-,e el d w a a C H ?z W o O V z H z E OU w x H z z c ? ? o ?? z w o a a U =~ o ?. o o U ? U ! y ? O U W U U U I'D o v c" ? M " o o W °o x? Q? a? o ? c? SCHEDULE C ALL. THAT CERTAIN t W or Parcel of land tying arid nd Co being in the Borough ofyy?.ny Wburg in the ark prruRlb situafQ, a Of Pennsylvania, M. of Cumberland dY described as folFov?r? entitled rN ACCORDAMCE with ft Amended Final Subd-nn 0 ", Prepared by Michael C. CYAN, a S., d Aug s# Plan 19 f 81, last revised on July 17, 1984 and recorded in the Office of &a Recorder of Deeds in and for Cumberland County, Pennsylvania. in Plan tiler of Deeds foffows; Book W, page 110, as BEGINNING at a point at the northwestern set at the r of Lot No. C9 intersectswith with tg fine be4Keen lots Nos. C-9 and C.g where corner dividling if rte of 'WW desigttated as F_H.OA. line #2; ff F.H.O.A. #2, North 61 degrees 49 minutes 47 secon & Eases along late of feet to a Point; thence c on5nuing along ins ? laird ' a e of 60.28 0 o o to #2, South 09 degrees 26 mkxtes 16 $ec ands East a df? Hated .as F.HOA P'4?? ttrer c?nflnuing along F-ROA. #2 95.03 feet to a seconds West, a distance of 29.74 feet to the dividing degrees between Loft S 47 and C-8, thence along s84 dividing line and W ? ben Lots Nos. GJ NoM 28 degrees 10 minutes 13 seconds West, at distance of 90 feet point the Place of BEGf NNING. BEING Lot No. GS on the above pFan; also being kr3onan and numbered as sm Tbornas Road. BEING ft same premises which Marielien Ca Executrix of Me Will of Lois Jane Carpenter aWa .lame B. ?? Lee, Ca Deed dated S? 20, 2001 and Mcorded October 2 in # , her the Reorder of Deeds in and for Curnbedand county, • nsyl rr the jyl C Dee of Book 248, Page 3057, granted and conveyed unto Wiichaef Moran, in famed fime. BK t 783PGS3430 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _a Jody S Smith C Chief Deputy `-1r'ri r Richard W Stewart ,. Solicitor , }? Fannie Mae Case Nurmiter - vs. 2010-5825 Michael F. Moran SHERIFF'S RETURN OF SERVICE 07/28/2011 03:45 PM - Deputy Amanda Cobaugh, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 500 Thomas Road, Wormleysburg Borough, Camp Hill, PA 17011. 07/28/2011 03:45 PM - Deputy Amanda Cobaugh, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 500 Thomas Road, Wormleysburg Borough, Camp Hill, PA 17011. 12/05/2011 By virtue of this writ, Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 500 Thomas Road, Camp Hill, PA 17011. SHERIFF COST: $100.00 December 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 1 Amanda Cobuagh, RI uty ry) 4' 1`/ < L l_? ?/