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Home My WebLink About10-7784• M Phelan Hallinan &Schmieg, LLP 13y: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FEDERAL HOME LOAN MORTGAGE CORPORATION Court of Common Pleas 8200 Jones Branch Dr., Mailstop 202 McLean, VA 22102 Civil Division v. NATHANIEL J. COOPER or Occupants CUMBERLAND County 53 BROAD STREET NEWVILLE, PA 17241-1522 No. ~ (1 ~'"~~ g`l~ CIVIL ACTION -EJECTMENT 1 w.. ~ ~.~ t ~„ p --~; ~~ rn ~ o c ~ rat ~ r-- -C ~' g^ s^ O ~- O .... ~ ~f y ~!'~ ~~ ~ ~ ~-ry ::.a **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 # 251533 oo ~1 p a "~ ~~q~. QC~,~ ~byb s Q,~,a s ~- 1. Plaintiff is FEDERAL HOME LOAN MORTGAGE CORPORATION . 2. Defendant is NATHANIEL J. COOPER or Occupants. 3. Plaintiff is the record owner of premises located at 53 BROAD STREET, NEWVILLE, PA 17241-1522, 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 09/08/2010, as evidenced by the Sheriff's deed recorded 10/12/2010 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201029001, 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. La ence`I :Phelan, Esq., Id~ No. 32227 Fr n is S. Hallinan, Esq., Id. No. 62695 Da i l G. Schmieg, Esq., Id. No. 62205 Mic ele 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. 8707 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 Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff 3Tax Parcel No. 28-21-0361-044 001YEE `~~ ~ 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. 2010-1953 Clvll Term Bank of America, N.A. Vs ~\ Nathaniel J, Cool7er ALL that certain tract of land with the improvements thereon erected, situate in the South Ward of the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a p.k. nail set in the concrete sidewalk along Broad Street, and at the dividing line between the within described premises and property now or formerly of Leslie J. Fickes, at or near a division line in the concrete pavement, and which point is South 70 degrees 32 minutes 49 seconds West 38.75 feet from the curb line of Pennsylvania Avenue; thence along line of land now or formerly of Leslie J. Fickes, South 19 degrees 45 minutes 16 seconds East 80.67 feet to a p.k. nail set in a concrete sidewalk at the rear of the within described premises at line of land now or formerly of Floyd A. Hurley and Annie C. Hurley; thence along line of land now or formerly of Floyd A. Hurley and Annie C. Hurley, South 70 degrees 32 minutes 49 seconds West 31.01 feet to an iron pin at line of land now or formerly of Raymod R. Heckman and Kathleen B. Heckman; thence along line of land now or formerly of Raymond R. Heckman and Kathleen B. Heckman, North 19 degrees 45 minutes 16 seconds West 80.67 feet to a p.k. nail set in the concrete sidewalk along Broad Street; thence in said sidewalk along Broad Street, North 70 degrees 32 minutes 49 seconds East 31.01 feet to the point and place of BEGINNING. CONTAINING 2,501 square feet and being described according to a survey by Eric L. Diffenbaugh, R.S., dated December 17, 2002, revised December 18, 2002, prepared for Douglas Jeffries, a copy of which is recorded in Deed Book 255, Page 710. TITLE TO SAID PREMISES IS VESTED IN Nathaniel J. Cooper, single person, by Deed from Staci A. Summers, dated 12/02!2005, recorded 12/06/2005 in Book 272, Page 1181. PREMISES BEING: 53 BROAD STREET, NEWVILLE, PA 17241-1522 PARCEL NO. 28-21-0361-044 28000192 The same having been sold by me to the said grantee on the 8th day of September 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 1st of June Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Ten (2010) Number 1953 at the suit of Bank of America, N.A. vs- Nathaniel J. Cooper In Witness Whereof, I have hereunto affixed my signature this 20th ~,erfj September Anno Domini Two Thousand and Ten (2010) Anderson, 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 20th day of September Anno Domini Two Thousand and Ten (2010) 1 othonotary I hereby certify that the residence ,st~;~ltr And Post Office address of the i~ -~ lr, ~ t ~ Within Grantee is , ,, , . : ~, • r `- ~ ~' J ~'~ ~ '' '~ ~' ~ r ' ~ ~ ~ ~,.,~ -:. 8200 Jones Branch Drive, ~,~ , ,. ~` ' '~~ ~ `' ~ ~: ~ Mail Stop 202 '; `'.' =~ w tom''. ~ ~~ ~ f McLean, VA 221.02 ~ ~ f ~ ~. L r f 1 M, , , ~ , , ~ ; ~~ , ;`~ Richard W. Stewart r , , -~ ~~ ar,,r~ -~ -~'~ ' ~~' ~ ~ Solicitor '~~lf}'7)i~l~. ROBERT P. ZIEGLER RECORDER OF DEED5 CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201029001 Recorded On 10/12/2010 At 10:17:42 AM * Instrument Type -DEED-SHERIFF'S Invoice Number - 74449 User ID - MSW * Grantor -COOPER, NATHANIEL J * Grantee -FEDERAL HOME LOAN MTG CORP * Customer -SHERIFF OFFICE * FEES STATE WRIT 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 BIG SPRING SCHOOL $0.00 DISTRICT NEWVILLE BOROUGH $0.00 TOTAL PAID $63.00 * Total Pages - 6 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 O * -Information denoted by an asterisk may change during the verification process and may not be reflected on tbis page. IIIAInI1111N1119 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 l 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. ~ 1 b~ Date L rence T. Phelan, Esq re F ncis S. Hallinan, Esq re D iel G. Schmieg, Esqui e Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquf're Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r' ILrEyO-OF i ICr Sheriff THE Jody S Smith ?1100FC 3Q Pit Chief Deputy Richard W Stewart `,UMBELAHI ? j {..a. Solicitor Federal Home Loan Mortgage Corporation I Case Number vs. 2010-7784 Nathaniel J. Cooper SHERIFF'S RETURN OF SERVICE 12/27/2010 08:40 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 27, 2010 at 2040 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Nathaniel J. Cooper, by making known unto himself personally, at 53 Broad Street, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. RO ERT BITN R, DEPUTY SHERIFF COST: $38.80 December 28, 2010 SO ANSWERS'` RONN R ANDERSON, SHERIFF