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Home My WebLink About11-3390?! EO-O? r THE PROTTJONOTAR c' GOLDBECK McCAFFERTY & McKEEVER 2011 APR - I AM e0' 08 Suite 5000 Mellon Independence Center t;?BERLAND COUTY 701 Market Street PENNSYLVANIA Philadelphia, PA 19106 (215) 825-6314 Attorney for Plaintiff FANNIE MAE International Plaza. II 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2916 Plaintiff vs. MICHAEL T. CALAMAN and OCCUPANTS 35 Partridge Circle Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL, ACTION - LAW ACTION OF EJECTMENT Defendants Term No. ?J 33RO G Yi 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 twenty (20) days after the 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 claim in the Complaint of for any 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 BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO at*49aabPAa LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE W-5,10686Y CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE 9'467 ?37 USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER D1NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT Plaintiff is FANNIE MAE, International Plaza II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916. 2. Defendants are MICHAEL T. CALAMAN, and OCCUPANTS. 3. Plaintiff is the owner of property located at 35 Partridge Circle, Carlisle, PA 17013, by virtue of a Deed from the Sheriff of Cumberland County to FANNIE MAE recorded on 10/14/2010 at Instrument # 201029364. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, MICHAEL T. CALAMAN and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. By: NC--'K'5 & MCKEEVER Michael M e ?-Pary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Attorneys for Plaintiff VERIFICATION I, John Whitehead, Eviction Manager REO Fulfillment, on behalf of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 1.8 Pa. C.S. 4904 relating to unworn falsification to autherit°°s_ Date: ?? I 1 WO 14A fI UD 13OV/ awl?-O John tehead Evic ion Manager, REO Fulfillment Fannie Mae /Oiyas[,J' ALL THAT CERTAIN tact of land with the Improvements thereon erected, situate in the Township of North Middleton, Cumberland County, Pennsylvania, bounded and described, as follows: BEGINNING at a point on the northam right of way line of Partridge Cirde at the southwest comer of Lot No. 3C; thence along said right of way line North 59 degrees 24 minutes 23 seconds West 18.00 feet to a point being the southeast comer of Lot 30A; thence along Lot No. 3-A and partly through a partition wall and through a 10 feet emergency easement and through a 40 feet pipeline easement and through a 50 feet pipeline easement North 30 degrees 35 minutes 37 seconds East 242.95 feet to a point at line of lands now or formerly of George Shahs and Susan Burger, Deed Book 31-0, Page 568; thence along said lands South 68 degrees 55 minutes 58 seconds East 18.16 feet to a point being the northwest corner of Lot No. 3-C; thence along Lot No. 3-C and partly through a partition wall and through said 10 feet easement and through said 40 feet easement and through said 50 feet easement South 30 degrees 35 minutes 37 seconds West 245.33 feet to a point, being the place of BEGINNING. CONTAINING 4,395 square feet, more or less. HAVING thereon erected a two story dwelling known and numbered as 35 Partridge Circle, Carlisle, PA 17013. BEING LOT NO. 3-B on the Final Re-Subdivision Plan for Middleton Estates prepared by R. J. Fisher & A.ssaciates, Inc., and recorded in Cumberland County in Plan Hook 69, Page 48. SUBJECT, HOWEVER to such easements, restrictions and conditions that may apply to the afore-described tact of land, recorded or unrecorded. Parcel 29-15.1252-047 PROPERTY ADDRESS: 35 PARTRIDGE CIRCLE, CARLISLE RA 1701 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' O"'tp of citio""., C, 'iC'E OF S-:RIFF FILED-G FKvE C?r THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2311 APP 12 AM 9: 13 CUMBERLAND COUNTY PENNSYLVANIA Fannie Mae vs. Michael T Calaman Case Number 2011-3390 SHERIFF'S RETURN OF SERVICE 04/07/2011 06:23 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 7, 2011 at 1823 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Michael T. Calaman, by making known unto himself personally, at 35 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. DENNI, RY, DEPU) 04/08/2011 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: Occupant of 35 Partridge Circle, Carlisle, Pennsylvania 17013, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 35 Partridge Circle, Carlisle, Pennsylvania 17013 is only occupied by Michael T. Calaman. SHERIFF COST: $55.00 April 08, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (.C) CouniySuite Shenft. Teieosott. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE 4ti?5ti?'' of rr,r,Grr rr 1 THE PROTHON6T.AI Y Jody S Smith Chief Deputy - t 2011 JU1. 15 PM 2: 05 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNS YLVA H I A Fannie Mae Case Number vs. 2011-3390 Michael T Calaman SHERIFF'S RETURN OF SERVICE 06/15/2011 08:40 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in hi: bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 35 Partridge Circle, North Middleton Township, Carlisle, PA 17013. 06/15/2011 08:40 PM - Deputy Gerald Worthington, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Michael T Calaman at 35 Partridge Circle, North Middleton Township, Carlisle, PA 17013, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 07/14/2011 By virtue of this writ, Ronny R. Anderson, Sheriff caused the within named Plaintiff to have possession of the premises described as 35 Partridge Circle, Carlisle, PA 17013. Possession given to Plaintiffs representative Brad Boyer, Agent for Century 21. This Writ is returned STAYED. SHERIFF COST: $76.00 July 14, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF a & /5- 9? . 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