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Home My WebLink About02-0190 FEDERMAN 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 3415 Vision Drive Columbus,OH 43219 Court of Common Pleas Civil Division v. Cumberland County Tenn Lillian E. Buckles Or Occupants 424 Burgner Road Carlisle, P A 17013 No. D~ - ,Q6 Cu~L'-r~ CNIT, ACTION - KTF.CTMF.NT _ 1020 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 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Chase Manhattan Mortgage Corporation. 2. Defendant is Lillian E. Buckles Or Occupants . 3. Plaintiff is the owner of premises located at 424 Burgner Road, Carlisle, PA 17013 legal description of which is attached. a 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 ofthe said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. cv------ Premises: 424 BURGNER ROAD, CITY OF CARLISLE 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 tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, and described as follows: BEGINNING at a point at the northern line of the public road leading from Burgner's Bridge to Heishman's Bridge at line of property now or formerly of David R. Black; thence by said property, North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W. Wogan, South 85-1/4 degrees East, 208.5 feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and numbered as 424 Burgner Road, Carlisle, Pennsylvania. , VERIFICATION TIMOTHY FlTZGI880N Hereby states that hel she is the is the ASSImNT SKlETAR\' Of CHASEMANHATTANMORTGAGE 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, infonnation 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: 11'1 !tJ:;- f I flTZGlBBOH ASSI5TANT SEClETART Ifl\ ~ ~ ~ ~ ~ CI) , & & ~ - --....J JU ~ I 0. I (' ~~ f"- - ~ J (") ~ urn mfl Z'" ;O;C. (h?.. -<'c",,: c:;. "' i>o ~(j )>c ~ o 1'-' c_ :<:: ~,~ Cl -'ft --! , ::lJ , r~-I CJ _.:~) . -"1 ;:iSF~ '::..; S; -< ...- -u :.r~ w W ...1 ..~. " . 10 PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Chase Manhattan Mortgage Corporation ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Lillian E. Buckles Defendant(s) No. 02-190 PRAECIPE TO THE PROTHONOTARY: X Please mark the above referenced case Discontinued and Ended without prejudice. _Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date:~ ~(1'D S 1J(i/;;. Francis S. Hallinan, Esquire Attorney for Plaintiff ~ r--' c.~ C..J 0' (/J p-, -0 N CP -0 ';Ji: (-:? o -n :r-n 1""11 F:: .-.-,lil ~(?~6 ;~,S~ '.:E,; '< o SHERIFF'S RETURN - NOT SERVED ~ CASE NO: 2002-00190 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATAN MORTGAGE CORP VS BUCKLES LILLIAN E R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: BUCKLES LILLIAN E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT SERVED , as to the within named DEFENDANT , BUCKLES LILLIAN E HOUSE IS VACANT. LILLIAN'S CURRENT ADDRESS IS 224 STATE ST. APT 1F WEST FAIRVIEW, PA 17025 Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.14 .00 10.00 .00 32.14 ~~/~-~->/ .' ~~~~ R. THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY FEDERMAN & PHELAN 01/18/2002 Sworn and subscribed to before me this .<'I'tf: day of ~ ;uo:u A.D. ~Qn.-,ip._ ,,'~ Pro h notary FEDERMAN 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 3415 Vision Drive Columbus,OH 43219 Court of Common Pleas Civil Division v. Cumberland County Term Lillian E. Buckles Or Occupants 424 Burgner Road Carlisle, P A 17013 No. 001 - 196 a~L~ CTVTT ACTION - F.TFCTMFNT _ 'l020 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, P A 17013 (717) 249-3166 TRUE COPY FROM RECORD IIIl..1 Lt.... ....-.r.....UIlloIlt..,... :..~...~,..., '- ~ ~ ;:?X~ 1. Plaintiff is Chase Manhattan Mortgage Corporation. 2. Defendant is Lillian E. Buckles Or Occupants. 3. Plaintiff is the owner of premises located at 424 Burgner Road, Carlisle, P A 17013 legal description of which is attached. a 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. > (iyl i< /F E ttorney fi tiff .yr:C.v- Premises: 424 BURGNER ROAD, CITY OF CARLISLE 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 tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, and described as follows: BEGINNING at a point at the northern line of the public road leading from Burgner's Bridge to Heishman's Bridge at line of property now or formerly of David R. Black; thence by said property, North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W. Wogan, South 85-1/4 degrees East, 208.5 feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and numbered as 424 Burgner Road, Carlisle, Pennsylvania. . . VERIFICA nON T1MOllfY FITZGIBBON Hereby states that he/ she is the is the liSSImIIT SECRETARY Of CHASEMANHATTANMORTGAGE CORPORA nON 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. FITZGIBBON ASSmIIT SECRETARY Date: 1/1 /tlJ- I I OFFICE OF TilE SHERIFF CUWc", !I;) COUNTY JAM IS /I 27 All '02 c~<: .. i ,,-,: ,,,.L PENNSYLVANIA w ~ W ~ tb!bn ~1 {OE.; Il:!!dl @2i