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HomeMy WebLinkAbout01-1650FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAl, MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 NATHAN K. McNAUGHTON OR OCCUPANTS 4190KITTATINNYDRIVE MECHANICSBURG, PA 17055 Court of Common Pleas Civil Division CUMBERLAND County Term CIVIL ACTION - E.IECTMENT - ~020 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION. 2. Defendant is NATHAN K. McNAUGHTON OR OCCUPANTS. Plaintiff is the owner of premises located at 4190 KITTATINNY DRIVE, MECHAN1CSBURG, PA 17055, a legal description ofwhich is attached. Plaintiffbecame owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiffis informed, without claim of title. 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. ARACOR Search and Abstract Services, bzc. One Penn Center, 1617 J.F.K. Boulevard, &rite 305 Philadelphia, P~nnsylvatzia 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 2/16/2000 Order Number: A39313 Client Number: MCNAUGHTON Premises: 4190 KITTATINNY DRIVE, TOWNSHIP OF HAMPTON CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL THAT CERTAIN lot or tract of land and premises, Situate in the Township of Hampden, Cumberland County, Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #76 and Lot #77; said point also being located 781.28 feet West of the Northwest corner of Kittatinny Drive and Tussey Court. THENCE by the Northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #78 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot #76 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the Northern right-of-way line of Kittatiimy Drive, the place of beginning. CONTAINING 2,000 square feet. BEING Lot #77 on Final Subdivision Plan of Mountain View Village Phase IV recorded in Plan Book 60, page 87B. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392 page 787, Miscellaneous Book 393 page 557 and Miscellaneous Book 414, page 1102. Tax Parcel # 10-15-1285-127 VERIFICATION R01~RT C~STE~ Hereby states that he/she is the is the ~$1~'r~A~ Of CHASE MANHATT~ MORTGAGE CORPORATION Mortgage servicing agent for the Plaintiffin this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his/her knowledge, information and belief. The Undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: ~RO~RT CHESTER SHERIFF'S RETURN CASE NO: 2001-01650 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS MCNAUGHTON NATHAN K - REGUIJkR BRIAi~ M.BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT - EJECTMENT MCNAUGHTON NATHAN K DEFENDANT at 1810:00 HOURS, at 4190 KITTATINNY DRIVE MECHANICSBURG, PA 17055 Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 19th day of April , 2001 by handing to a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.06 Affidavit .00 Surcharge 10.00 .00 36.06 Sworn and Subscribed to before me this ~q ~ day of '~r ~] A.D. othonotary t v - So Answers: R. Thomas Kline 04/20/2001 FEDERMAN AND~By: ~ ~~ Deputy Sheriff FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEM1CAL RESIDENTIAL MORTGAGE CORPORATION COURT OF COMMON PLEAS VS NATHAN K. McNAUGHTON OR OCCUPANTS 4190 KITTAT1NNY DRIVE MECHANICSBURG, PA 17055 CIVIL DIVISION No. 01-1650-CIVIL CUMBERLAND County PRAECIPE FOR JUDGMENT lN E.W, CTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION and against the Defendant(s) NATHAN K. McNAUGHTON amd OR OCCUPANTS for possession of premises 4190 K1TTATINNY DRIVE , MECHANICSBURG, PA 17055 for failure to file an Answer within twenty (20) days of service. [ hereby certify that according to Rule 237.1, written 10 day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE FEDERMAN AND PHELAN Frank Federman. Esquire Identification Number 12248 ATTORNEY FOR PLAINTIFF One Penn Center ~ Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION, F/KJA CHEMICAL RESIDENTIAL MORTGAGE CORPORATION COURT OF COMMON PLEAS NATHAN K. MCNAUGHTON OR OCCUPANTS CIVIL DIVISION CUMBERLAND COUNTY No. 2001-01650-CIVIL TERM TO: NATHAN K. MCNAUGHTON OR OCCUPANTS 4190 KITTATINNY DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: MAV 10, 2001 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 1MPORTANTNOTICE 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: CUMBERLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN L.L.P. BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION COURT OF COMMON PLEAS CWIL DIVISION VS NATHAN K. McNAUGHTON OR OCCUPANTS 4190 KITTATINNY DRIVE MECHANICSBURG, PA 17055 No. 01-1650-CIVIL CUMBERLAND County VERIFICATION OF NON-MIl ,ITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has 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 NATHAN K. McNAUGHTON Or occupants, is over 18 years of age, and resides at 4190 KITTATINNY DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. Attorney for Rlai~ff PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION ¥S NATHAN K. McNAUGHTON OR OCCUPANTS 4190 KITTATINNY DRIVE MECHAN1CSBURG, PA 17055 COURT OF COMMON PLEAS CIVIL DIVISION No. 01-1650-CML CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession off 4190 KITTATINNY DRIVE, MECHANICSBURG, PA 17055 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 4190 KITTATINNY DRIVE ARACOR Search and Abstract Services, Inc. One Penn Cente~; 16I 7 J.F.K. Boulevard, Stdte 305 Philadelphia, P~nnsylvama 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 2/16/2000 Order Number: A39313 Client Number: MCNAUGHTON Premises: 4190 KITTATINNY DRIVE, TOWNSHIP OF HAMPTON CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL THAT CERTAIN lot or tract of land and premises, Situate in the Township of Hampden, Cumberland County, Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #76 and Lot #77; said point also being located 781.28 feet West of the Northwest corner of Kittatinny Drive and TUssey Court. THENCE by the Northern right-of-way line of'Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #78 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East i00.00 feet to a point; thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot//76 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the Northern right-of-way line of Kittatinny Drive, the place of beginning. CONTAINING 2,000 square feet, BEING Lot//77 on Final Subdivision Plan of Mountain View Village Phase IV recorded in Plan Book 60, page 87B. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392 page 787, Miscellaneous Book 393 page 557 and Miscellaneous Book 414, page 1102. Tax Parcel// 10-15-1285-127