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Home My WebLink About11-3161Phelan Hallinan & Schmieg, LLP ~ By: 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 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 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Federal National Mortgage Association Court of Common Pleas P.O. Box 650043 Dallas, TX 75265 Civil Division V. DORIS A. LITTLE or Occupants CUMBERLAND County 411 WEST MAIN STREET A WALNUT BOTTOM, PA 17266-9718 No. l'.3i l b CIVIL ACTION - EJECTMENT ' M03 r- y - cn r- N _e tv - CD Z -C) "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 # 266180 (:?.s ?Ak @L 00 Ny oi ?,??o?ayatp I-ILL f 1. Plaintiff is Federal National Mortgage Association. 2. Defendant is DORIS A. LITTLE or Occupants. 3. Plaintiff is the record owner of premises located at 411 WEST MAIN STREET, WALNUT BOTTOM, PA 17266-9718, 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 02/02/2011, as evidenced by the Sheriff's deed recorded 03/14/2011 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201108154. 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 L r nce T. Phelan, Esq., Icy No. 32227 Fr n is S. Hallinan, Esq., Id. No. 62695 Da 'el 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. 817 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 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 William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff r'f Legal Description ALL the following two tracts of land with the improvements thereon erected, located in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: TRACT NO. 1: BEGINNING at a point in the center line of the Walnut Bottom Road, State Highway Route No. 33; thence by the center line of said Road, North 64 degrees East 84 feet to a point; thence South 23 degrees 50 minutes East along land now or formerly of Robert H. Frehn et ux, 125 feet to a stake; thence by the same, South 64 degrees West 84 feet to a stake at line of land now or formerly of Raymond E. Ott; thence by the same, North 23 degrees 50 minutes West 125 feet to a point in the center line of the Walnut Bottom Road, the place of BEGINNING. CONTAINING .195 an acre more or less. TRACT NO. 2: BEGINNING at an iron pin in the line of the right of way of the Philadelphia and Reading Railroad Company and lands now or formerly of Charles W. Meily and Violet L. Meily; thence along the said right of way, South 54 degrees 52 minutes West 48.48 feet; thence by land now or formerly of Rehoboth Methodist Church, North 23 degrees 35 minutes 40 seconds West 290.04 feet to an iron pin and land of the John W. Brannan and Faye L. Brannan, his wife; thence by the said land, North 63 degrees 55 minutes 10 seconds East 84.10 feet to an iron pin and land now or formerly of Charles W. Meily and Violet L. Meily; thence by the same, South 24 degrees 00 minutes 20 seconds East 16.05 feet to an iron pin; thence by the same, South 65 degrees 18 minutes West 2.19 feet to an iron pin; thence by the same, South 16 degrees 16 minutes East 270.10 feet to an iron pin, the place of BEGINNING. Prepared pursuant to a survey of Carl D. Bert, R.S., dated September 6, 1973. BEING that same property that John W. Brannan and Faye Brannan, by their deed dated March 18, 2000 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book Volume 218 at Page 53, conveyed to, John W. Brannan, Jr. Grantor herein. Premises: 411 WEST MAIN STREET r i 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 I 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. Date T. Phelan, Esquire an is S. Hallinan, Esiluire Da ' 1 G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Es ire Jenine R. Davey, Esqui Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire William E. Miller, Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor n,e;: OF THE PROTHONOTARY 2011 MAR 28 PM 2: 18 CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Case Number Doris Ann Little 2011-3161 SHERIFF'S RETURN OF SERVICE 03/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Doris Ann Little, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Doris Ann Little. Request for service at 411 W. Main Street, Walnut Bottom, Pennsylvania 17266 is vacant. SHERIFF COST: $47.00 SO ANSWERS, March 25, 2011 RON R ANDERSON, SHERIFF is t!1 i U re,:tt. ?e .. ft. If--, David -D. Buell- Protkonotasy Office of the Prothonotary Cum6erfancfCounty, Tennsyfvania 7(irkS. So hong?, ESQ Solicitor -3/Lf CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY.THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 0 CarCasfe, PA 0 Phone 717 240-6195 0 ¶FaX 717 240-6573