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HomeMy WebLinkAbout01-1923 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION. 2. Defendant is MICHAEL j. LONG OR OCCUPANTS. 3. Plaintiff is the owner of premises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011, a legal description of which is attached. 4. Plaintiff became 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). 5. 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 clairn 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. Attorney for Plaintiff ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described accordin~ to survey of D. p. Raffensper~er, Registered Surveyor, dated 7 April 1959, as follows. BEGINNING at a point on the Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18~h Street and Second Street, also bein~ at the dividin~ line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) de~rees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Eastern line of a twenty feet wide alley; thence North thirty- two (32) de~rees thirty (30) minutes West alon~ same, twenty (20) feet to a point :' at the dividin~ line between Lo~s Nos. 132 and 133 on said Plan; thence North fifty-seven (57) de~rees thirty (30) minutes East o through the center line of a partition wall between Lots Nos. 132. and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly alon~ same, twenty (20) feet to a point, the place of BEGIAR~ING. · BEING Lot No 133 on Plan of J L Hyde, said Plan recorded in Plan Book 1, Pa~e 65, Cumberland County Records. .~. FIAVING THEREON ERECTED a two and one-half story frame dwellin~ house known as No. 134 South 18th Street. BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, ~ranted and conveyed unto Michael j. Lon~.. , · VERIFICATION ROBERT CHESTER Hereby states that he/she is the is the of CORPORATION Mortgage servicing agent for the Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectmcnt 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 unswom falsification to authorities. Date:~ ~ ~ SHERIFF'S RETURN - NOT FOUND CASE NO- 2001-01923 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS LONG MICHAEL j R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LONG MICHAEL j but was unable to locate Hi_~m in his bailiwick. He therefore returns the COMPLAINT _ EJECTMENT , NOT FOUND as to the within named DEFENDANT , _LONG MICHAEL j ! DEFENDANT MOVED HOUSE IS VACANT NO FORWARDING ADDR Sheriff,s Costs. Docketing 18.00 So answers. Service 9.30 Affidavit .00 omas K1 ine Surcharge 10.00 Sheriff of Cumberland County _ .00 3 7.3 0-- FEDERMAN & PHELAN 04/19/2001 Sworn and subscribed to before me this _~~%~ day of · ¥ __ FEDERMAN AND PHELAN By: Frank Federman, Esquire Identification No. 12248 Attorney fbr Plaintiff One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION : Court of Common Pleas 3415 VISION DRIVE COLUMBUS, OH 43219-6009 : Civil Division v. : CUMBERLAND County :Term MICHAEL J. LONG OR 0CCUPANTS 'No./,/-. /q ')"3 134 SOUTH 18TH STREET CAMP HILL, PA 17011 : CIVIl, ACTION- E.IECTMENT- 3020 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 fights 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 TRUE (.,OPT FROM RE ' (717) 249-3166 Testimony t I tmte ,,_ ___: . un/o, flly ham 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION. 2. Defendant is MICHAEL J. LONG OR OCCUPANTS. 3. Plaintiff is the owner ofpremises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011, a legal description of which is attached. 4. Plaintiff became 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). 5. 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 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. FRANK FEDERMAN ~-' Attorney for Plaintiff ALL TBLtT CERTAIN tract or parcel of land situate in the Borou?h of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described accordin~ to sur-¢ey of D. p. Raffensper~er, Registered Surveyor, dated 7 April 1959, as foi!cws. BEGIN~ING at a point on the Westerly side of South 18 Street, for~y (40) feet North of the Northwest COrner of the intersection · of South 18th Street and Second Street, also bein~ at the dividin~ line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) de~rees thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Eastern line of a twenty feet wide alley; thence North thirty_ two (32) de~re=s thirty (30) minutes West along same twenty (20) feet to a point ' at the dividing line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) de~rees thirty (30) minutes East . through the center line of a partition wall between Lots Nos. 132. and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point, the place of BEGI~ING. BEING Lot No. 133 on Plan of j. L. Hyde, said Plan recorded in S S Plan Book 1 Pa~e 65 Cumberland County Records. HAVING THEREON ERECTED a two and one-half story frame dwellin~ house known as No. 134 South 18th Street. · BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Michael j. Long. · . .:. VERIFICATION ROBERT CHESTER Hereby states that he/she is the is the Of CHASE M~ANHATTAN MORTGAGE CORPORATION_Mortgage servicing agent for the Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are tree 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 unswom falsification to authorities. STER '-'""- F~DEI~V/AN ~ND PHELAN .BY: MICHELE M. BRADFORD, ESQUIRE -Identification No. 69849 One Penn Center ~ Suburban Station ._ Suite 1400 1617 John F. Kennedy BOUlevard Philadelphia, PA 19103-1814 Attorney tbr Plaintiff (2 t s) s~3-~ooo 'CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DR/VE ' Court of Common Pleas COLUMBus, OH 432~9-6009 ' Civil Division CUMBERLAND County MICHAEL j. LONG OR OCCUPANTS .134 SOUTH 18TH STREET ' Term, CAMp HILL, PA 17011 ' No. 01-1923-CIVIL Action in Ejectment It is order this ~.q '/"day of ~ ,2001, that PlaintifFs Motion for Service of Complaint Pursuant to Special Order of Court ~s GRANTED, permitting service by- ~- First Class and Certified Mail to MICHAEL j. LONG OR OCCUPANTs at the property which is subject to tills Ejectment Action, Service mail is effective upon tl~e date of mailing.'by first class and certified ~ Posting of the property which is subject to this Ejectment ^ction* * the property at 134 SOUTH 18TH STREET, CAMp HILL, PA BY THE CO~ FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD ESQUIRE Identification No. 69849 ' One Penn Center ~ Suburban Station _ Suite 1400 1617 John F. Kennedy Boulevard Attorney for Plaintiff Philadelphia, PA 19103-1814 (2 ~ ~) $~-?000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE ' Court of Common Pleas COLUMBUS, OH 43219-6009 ' Civil Division vs. ' CUMBERLAND County MICHAEL j. LONG OR OCCUPANTS' · 134 SOUTH 18TH STREET ' Term, CAMP HILL, PA 17011 No. 01-1923-CIVIL · Action in Ejectment Plaintiff, by its counsel, Michele M. Bradford, Esquire moves this Honorable Court an Order directing service of the Complaint upon the above-captioned Defendant(s) by certif/ed mail and regular mail, and in support thereof avers as follows. 1. Plaintiff commenced this action by filing a Complaint in EJECTMENT. 2. Attempts to serve Defendant(s) with the Complaint have been unsuccessful. Plaintiff attempted to serve the Defendant(s) on APRIL 19, 2001, as indicated by the Affidavit of Service attached hereto as Exhibit A. · 3 Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defbndant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and ti~e results from there are attached hereto as Exhibit B. 4. Plaintiff submits that is has made a good faith effort to locate the Defi~ndant(s), but has been unable to do so. · 5. Plaintiff verified through property inspection on JUNE 15, 2001 that the property was occupied by an unknown person. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order , 'pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail and posting of the premises. DATE: MAY 15, 2001 _ ' ]~~ ~ · Attorney for Plaintiff FEDERMAN AND PHELAN BY: MICHELE M. BRADFO~ , ESQUIRE Identification No. 69849 One Penn Center ~ Suburban Station- Suite 1400 1617 John F. Kennedy Boulevard Attorney tbr Plaintiff · Philadelphia, PA 19103-1814 (2 ~ ~) -~6~-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE ' Court of Common Pleas COLUMBUS, OH 43219-6009 ' Civil Division vs. ' CUMBERLAND County MICHAEL j. LONG OR OCCUPANTS · Term, 134 SOUTH 18TH STREET ' No. 01-1923-CIVIL CAMP HILL, PA 17011 ' Action in Ejectment CERTIFICATION OF SERVICE I hereby certify that a tree and correct copy of the Motion for Service Pursum~t to Special Order was served by first class mail on the Defendant (s) on the date listed below: MICHAEL j. LONG OR OCCUPANTS 134 SOUTH 18TH STREET CAMP HILL, PA 17011 Michele M. Bradford, Esquire Attorney for Plaintiff EXHIBIT "A" ..... ,~ .o~ ~'F h-R CUMBERLAND CO SHERIFF?l? 240 639? TO 9121556717~? 'P 82.'82 ~Si'i~.Kj. l"'l-" ' :.5 .K.15'J.'UIW. iN - ~.~lt,,,.L i', u, uz~ · · · CASE NO: ~001-01923 ~ COMMONW~T~{ OF ~EATNSYLVANIA COUNTy OF CUMBmRLAND VS · LONG MIC~L j ' R. Thomas Klin~__.~~,Sheriff or Deputy Sheriff, who bein~ duly sworn acoordin~ to law, says, that he made a diligent search and inquiry for the within named defendant, D~RW. NDANT LONG MICHaeL j ------------------ but was unable to locate ~i.~m in his bailiwick. He therefore returns the COMPLAINT_ ~J~CTMENT , NOT FOUN/D , as the within named ~, LONG MI CF2LEL j T NO FORWARDING ADDR Sher~ff,s Costs: Docket in9 So answers. Servi ce Af fidavit . 9.30 '00 Kllne Surcharge 10.00 Sheriff of Cumberland County oo 04/~9/2001 Sworn and subscribed to before me this -- __ _ day of ~ . _ .... A.D. · Prothonotary ~ TOTAL PAGE. 02 >~.~ EXHIBIT "B" PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 01-1923-CIVIL Attorney Firm: TRACK STARS Case Number: Subject: MICHAEL J LONG A.K.A.: None Last Known Address: 134 S. 18TH STREET CAMP HILL, PA 17011 Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2. On 05/11/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: 191-60-4277 B. EMPLOYMENT SEARCH: Unable to locate a good employer for Michael. C. INQUIRY OF CREDITORS: The creditors indicated that Michael is living at 134 S 18th Street, Camp Hill, Pa. 17011 with no valid home phone number. Michael filed chapter 13 bankruptcy in February 2000 with no attorney listed. Case # 2000-782 with a release date of September 2000. INQUIRY OF TELEPHONE COMPANY- A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Michael Long. Contacted 814-472-8914 and spoke with a relative who confirmed that Michael Long is living at the last known address. INQUIRY OF NEIGHBORS- NIA INQUIRY OF POST OFFICE- A. NATIONAL ADDRESS UPDATE: As of May 9, 2001 the National Change of Address (NCOA) has no change for Michael from last known address. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Michael listed at last known address. OTHER INQUIRIES- A. DEATH RECORDS: As of May 9, 2001 the Social Security Administration has no death record on file for Michael J Long under his social security number. -" ' B. PUBLIC LICENSES ( PILOT. REAL ESTATE. ETC. ): None Found C. COUNTYVOTER REGISTRATION' The Cumberland County Voters Registration Office has Michael listed at last known address. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: 07167 ...... ,..,,,,-.--, ..... -~'-¥' ~,~, ~,.~ .'-'~. :~.' ,~',~ t_," ~, , %_. ' .' "-".~ '~., ..-,~..~, i ~,'.'" ~::~;" ' ~"~,,.'..,~ -~ ~. AFFIANT Michael K Gross ...,,~,,,, ,~ ~c ,,,.. ...... ~, · ~ ~ '"~' · ~*"~ .~.~ r ~ ~, ~ t~.'.' :.~? .'.:~. '"" ' "" ~.~ ~ St. Lot .... .' ~-..' i:'. .... : .,,~ . :~i~...::.: .:'..'"~"-': ~ ~'" -..~,'"'-."t':'~"-,I '~', ? ..... '." ' .... . ,..,,..-...~-o'  ,~ ~. t~;¥ .,.-.~' ........ . ............... .--,.-,--' .... . ~'~ Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 FEDERMAN AND PHELAN BY: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center ~ Suburban Station - Suite 1400 1617 John F. Kennedy Boulevard Attorney for Plaintiff 'Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION ' Court of Common Pleas 3415 VISION DRIVE ' Civil Division COLUMBUS, OH 43219-6009 vs. ' CUMBERLAND County MICHAEL J. LONG · OR OCCUPANTS ' Term, 134 SOUTH 18TH STREET ' No. 01-1923-CIVIL 'CAMP HILL, PA 17011 ' Action in Ejectment Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Although Plaintiff has attempted to serve Defendant(s) with the Complaint, .Plaintiff's attempts have been unsuccessful. A true and correct copy of the Affidavit of ~'~ .!. No Service is attached hereto, made part hereof, and marked Exhibit A. Accordingly, Plaintiff ordered an investigation into the whereabouts of Defendant(s). A true and correct copy of the Affidavit of'Reasonable Investigation is attached hereto, make part hereof, and marked Exhibit B. The Affidavit reflects that Plaintiff's investigator has make at least three types of inquiries listed under Rule 403.1 (B)(1). Copies of any written responses obtained are attached to the Affidavit. The Affidavit also specifies the inquiries made, responses made, and dates .thereof,, in accordance with Rule 430.1(B)(2). As Plaintiff's within motion and its affidavit are both in compliance with the applicable Pennsylvania and local rules, Plaintiff respectfully requests that its motion be granted. WHEREFORE, Plaintiff respectfully requests permission to serve the Complaint by certified mail and regular mail and posting of the premises. Respectfully submitted. DATE'MAY 15. 2001 ~ Attorney for Plaintiff V~ERIFICATION Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this verification, and that the statements made in the tbregoing Motion for Service of the Complaint Pursuant to Special Order of Court are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ~vficnele M. Bradford, Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 Attorney for Plaintiff ONE PENN CENTER ~ SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD Philadelphia, PA 19103-1814 (215) S63-7000 Chase Manhattan Mortgage Corporation · COURT OF COMMON PLEAS Plaintiff vs. ' CIVIL DIVISION · TERM. Michael J. Long ' NO. 01-1923-civi! Or occupants Defendants ' Cumberland COUNTY TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. Attorney for Plaintiff Date: FEDERMAN AND PHELAN cz ..... .:-, By: Frank Federman, Esquire "c.,.,: .' ...~ Identification No. 12248 Attorney for Plaintiff :...:.c .-.-... 5..--L' [:l.. !, One Penn Center at Suburban Station · , 1617 John F. Kennedy Boulevard ~-- .... Suite 1400 Philadelphia, PA 19103-1814 >.'.c " -,'..'._' (215) 563-7000 :.:,,~...'/2 --< .... CHASE MANHATTAN MORTGAGE CORPORATION · Court of Common Pleas 3415 VISION DRIVE COLUMBUS, OH 43219-6009 · Civil Division v. · CUMBERLAND County · Term MICHAEL J. LONG OR OCCUPANTS · No. 6~t- J ~ 1.3 L:., °'~/t?-.L'''Sj 134 SOUTH 18TH STREET CAMP HILL, PA 17011 ' CIVIl, ACTION- E.IECTMENT- 3020 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 fights 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 FEDEFIMAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN .... : 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION. 2. Defendant is MICHAEL J. LONG OR OCCUPANTS. 3. Plaintiffis the owner ofpremises located at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011, a legal description of which is attached. 4. Plaintiff became owner of said premises by a Deed fi'om the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 5. 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 fight 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. FRANK FEDERMAN Attorney for Plaintiff FEDERMAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN ......, . · · ..i', '...;.,.,.. . ._..: .,, .... ,, · · · ALL TblAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described according to sur-¢ey of D. P. Raffensperger, Registered Surveyor, dated 7 April 1959, as fol!cws- BEGINNING at a point on the Westerly side of South 18 Street, forty (40) feet North of the Northwest corner of the intersection of South 18th Street and Second Street, also bein~ at the .... dividin~ line between Lots Nos. 133 and 134 on hereinafter mentioned Plan of Lots; thence South fifty-seven (57) de~rees .. thirty (30) minutes West through the center line of an eight-inch wall between Lots Nos. 133 and 134 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Eastern line of a .~. twenty feet wide alley; thence North thirty- two (32) degrees thirty (30) minutes West along same, twenty (20) feet to a point at the dividin~ line between Lots Nos. 132 and 133 on said Plan; thence North fifty-seven (57) degrees thirty (30) minutes East . · through the center line of a partition wall between Lots Nos. 132- and 133 on said Plan, and beyond, one hundred twenty (120) feet to a point on the Western line of South 18th Street; thence Southwardly along same, twenty (20) feet to a point the place of BEGINNING. ' BEING Lot No. 133 on Plan of J. L. Hyde, said Plan recorded in Plan Book 1, Page 65, Cumberland County Records. · HAVING THEREON ERECTED a two and one-half story frame dwelling ':' house known as No. 134 South 18th Street. .... , .. BEING THE SAME PREMISES which Francis X. Kuntz and Kathleen T' Kuntz, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland .. County, granted and conveyed unto Michael J. Lon~.· , FEDERIVIAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN VERIFICATION ROBERT CHESTER Hereby states that he/she is the is the Of CHASE ~TTAN MORTGAGE CORPORATION Mortgage servicing agent for the Plaintiff in 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. FEDERMAN AND PHELAN ATTORN~ FILE COpy PLEASE RETURN , } · ,-....? · · .. .., .., . , · FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE I.D. # 12248 ATTORNEY FOR PLAINTIFF SUITE 1400 ONE PENN CENTER ~ SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA. 19103-1814 (215) 563-7000 Chase Manha~ Mortgage Corporation · COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland COUNTY V. Michael J. Long or occupants · No. 01-1923-civil AFFIDAVIT OF SERVICE VIA REGIIIJAR & CERTIFIED MAlL I hereby certif3, that a true and correct copy of the Civil Action in Ejectment in the above captioned matter was sent by Regular and certified Mail, return receipt requested, to the Following person(s) In accordance with the Order of Court dated M~ 20:2001. The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. F rank Federman, Esquire Attorney for Plaintiff Date: June 13; 2001 SHERIFF ' S RETURN - REGULAR CASE NO. 2001-01923 p COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERIJtND CHASE MANHATTAN MO~RTGAGE CORP VS LONG M_~ICHAEL j GERALD W__ORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT _ EJE_CTMENT was served upon LONG M~ICHAEL j DEFENDANT the , at 1700-00 HOURS, on the 13th day of June , 2001 at 134 SOUTH 18TH ST ~ - ~ CD~4P HILL, PA 17011 by handing to P~ROPERTY POSTED a true and attested copy of COMPLAINT _ EJECTMENT together with and at the same time directing Hi~s attention to the contents thereof. Sheriff,s Costs. Docketing 15 00 So Answers. Service · Affidavit 9.3 0 Surcharge .00 Posting 10.00 R. Thomas Kline 6.00 43.30 06/18/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By- me this -20 ~- day of --_______A.D. FEDERMAN AND PHEL~ BY: FRANK FEDERMAN ATTORNEY FOR PLAINTIFF IDENTI~CATION NO. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1514 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION · COURT OF COMMON PLEAS · CIVIL DIVISION MICHAEL J. LONG ' No. 01-1923-CIVIL OR OCCUPANTS ' CUMBERLAND County 134 SOUTH 18TH STREET CAMP HILL, PA 17011 TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, CHASE MANHATTAN MORTGAGE CORPORATION and against the Defendant(s) MICHAEL J. LONG and OR OCCUPANTS for possession of premises 134 SOUTH 18TH STREET, CAMP HILL, PA 17011 for failure to file an Answer within twenty (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 Defendant(s), a tree 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 PLAINTI~ One Penn Center ~ Suburban Station _. 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHA~~ MORTGAGE CORPORATION · COURT OF COMMON PLEAS V. ' CIVIL DIVISION MICHAEL j. LONG ' CUMBERLAND COUN'I~ OR OCCUPANTS · NO. 01 - 1923-CIVIL TO: MICHAEL j. LONG OR OCCUPANTS 134 SOUTH 18TM STREET CAMP HILL, PA. 17011 DATE OF NOTICE: __Jl/I,¥ 6. 2001 TH/S NOT/CE IS SENT TO YOU IN AN ATTE~ TO COLLECT A DEBT AND ANY /NFO~TION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 fi'om the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important fights. 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 COUNI'y COUR ousE COURT ADMINISTRATOR 4Ti/ LOOR CARLISLE, PA 17013 (717) 240-6200 Attorney for Plaintiff FEDERMAN AND PHELAN L.L.P. ATTORNEY FOR PLAINTIFF 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 CHASE MANHATTAN MORTGAGE CORPORATION : COURT OF COMMON PLEAS : C1VIL DIVISION vs · No. 01-1923-CIVIL MICHAEL J. LONG OR OCCUPANTS · CUMBERLAND County 134 SOUTH 18TH STREET CAMP HILL, PA 17011 VERIFICATION OF. NON-MII.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 MICHAEL J. LONG Or occupants, is over 18 years of age, and resides at 134 SOUTH 18TH STREET, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. '--~/Attorney 1~ intiff PRAECIPE FOR WRIT OF POSSESSION cOMMONAVEALTH OF PENNSYLV A cOUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORPORATION · COURT OF cOMMON PLEAS · CIVIL DIVISION · No. 01-1923-CIVIL vs MICHAEL J. LONG . cUMBERLAND County OR oCCUPANTS 134 sOUTH 18TH STREET CAMP HILL, PA 17011 PRAECIPE FOR WRIT OF POSSESSION TO. THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 134 sOUTH 18TH STREET, CAMP HILL, PA 17011 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 134 SOUTH 18TH STREET Kun~ Court ~ .- .., , ~ ~ =-., .. ~ ' , , ~~.~ -- . " ~ ~ ' ~ , i - ~ ~ '' ~ ' '1 < ~. , , ~ . :.; ~ , : , .................... 'd'a ~' ,~.' - /. caused ~e wi~'~in nam=,d , ? ........ .-.- ........................ .~ 2001 k=,--~n/es~n of r.h~ pr .e~..is~..des~.;be4 · .. ' . _.Ie, IRIT IS Iq~-'ITIRNED ~ .IL::'I~A.'IIL'~f ..... 8TAY~, PROI~Frl'Y IS V/~AN~. -- Sheriff,s Costs- - ................. --~~i~j~ ....... -~--18.11g .......... Advance Costs: 150.00 _Poundage 3.00 .......................... gt~iff-,~ ~es~- -5t, ?f~ ........... ._S_u__r_c_Na._r_~e_ 20 00 -- 98.25 - p~ot~o=o~.ag- ........ 'l-~88 ......................................................................... ~ilage ....... 9"'2'"75 ...... /~ ................ :-5r;75 .................................... ~_funded to Att_v on 8/3/0]' "-~~ V t~-! ",s ^ q ! !~ ~! N 3 d .................................... '-~= :' :,,' ---~,~e_.__.~..~.~-=:. : .., .;,.~.ri i- ..... ~-. __~,.~,,._ ........ ._ ............ - . ~ :. · ' '-.- ...... ~_~__~ ....... ~ ~ ,~,_,~,,~.,-~ , , ~--- 'I~/{IT OF pO$SE$$IO-~' °.E]¢cnncn: Proceedings PRC P 3160 .... ~' ~~ COURT OF CO>.[5,[O~' PL~kS OF . ..................... T~ 20_ ..... ~- ' C~s , ......... ' .k::~v ....................... ~~EL J. LOnG Oa OCCUP~TS ' ' PU" 's' - ............................ . i 134 SOUTH 18TH STREET __ -- .... ..................... T .............. J P~mv .................. C~P HILL, PA 17011 C O.%~/O~VEALTrI OF C O U.'N-rY O F C L' .x £ B F_Pd_i2*'D: CUMBERLAND ....... Conn.-f: P.~..nz. ' To i~e 5he~ of ............................ C~SE ~N~TT~ MORTGAGE COR~O~IION ..... ' P~ndff s b~{=~ · ~ P~~ ~ foR~) ' 134 SOUTH 18TH STREET C~P HILL, PA 17011 '~' To '~-~'? i"-¢ c~sts ~ · " · '::':~.... "' . - ~u~- !_s_ ~.__~__na ............ · p~:honoca-~.'. C~-~r._.--c. r{ P:.~ Ceu.~ o~ C~ July 20, 2.001 ................................. ~.~.~J-) .