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Home My WebLink About11-3547 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Federal Home Loan Mortgage :COURT OF COMMON PLEAS Corporation :CIVIL DIVISION 5000 Plano Parkway :Cumberland County Carrollton, TX 75010 Plaintiff 6WI ?• -. V. MM ` John Doe ;r: _ no and/or Tenant/Occupant LO -<1? _ CD ; 607 5th Street New Cumberland, PA 17070 Defendant (s) ?-,C:) ?o CDi _ a CIVIL ACTION COMPLAINT IN EJECTMENT 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 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 any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 s aftX sqa oa pd atfi? ck* ,099 CT R#?sT7o8 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9107 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises") which address is set forth on the caption. 3. Premises, a legal description of which is attached hereto, was sold at Sheriff's Sale in accordance with law on January 5, 2011, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. The deed in favor of Plaintiff recorded on March 14, 2011 at Instrument #201108158. Pursuant to Pa. R.C.P. 1019(8), Plaintiff incorporates that document by reference herein. 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant (s) who have refused to deliver up the possession thereof. WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAW OFFICES, P.C. A EY FOR PLAINTIFF ar?ueriP ID L. Thomas, 204460 Esquire ALL THAT CERTAIN TRACT OR PIECE OF LAND, SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHERN LINE OF FIFTH STREET ONE HUNDRED (100) FEET EAST FROM THE NORTHEAST CORNER OF ROSEMONT AVENUE AND FIFTH STREET; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF LOT NO. 9, BLOCK "R", ON THE HEREINAFTER MENTIONED PLAN OF LOTS, ONE HUNDRED FORTY (140) FEET TO A POINT IN THE SOUTHERN LINE OF SMITH AVENUE; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF SMITH AVENUE FIFTY (50) FEET TO A POINT IN THE WESTERN LINE OF LOT NO. 6, BLOCK "R"; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF LOT NO. 6, BLOCK "R", ONE HUNDRED FORTY (140) FEET TO A POINT IN THE NORTHERN LINE OF FIFTH STREET; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF FIFTH STREET, FIFTY (50) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO 7 AND NO 8, BLOCK "R", ON THE PLAN OF GEORGE W. BUTTORFF'S ADDITION OF NEW CUMBERLAND AS RECORDED IN THE OFFICE FOR THE RECORDER OF DEEDS IN AND FOR THE COUNTY OF CUMBERLAND IN DEED BOOK "N", VOLUME 5, PAGE 498. BEING KNOWN AS: 607 5th Street New Cumberland, PA 17070 PROPERTY ID NO.: 25-24-0811-178 VERIFICATION The undersigned an attorney for the Plaintiff and is authorized to make this verification. I verify that the facts set forth in the foregoing pleading are true and correct to the best of my information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. ?d,Kmq r-rq4"rA Marg 04460 DATED: April 8, 2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com` Federal Home Loan Mortgage ?COURT OF COMMON PLEAS Corporation :CIVIL DIVISION 5000 Plano Parkway €,Cumberland County Carrollton, TX 75010 Plaintiff NO V. John Doe and/or Tenant/Occupant Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Mr ?0 .C C:j p„ ate. C? Tr ? C) r Tr ® Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Sherri J. Braunstein, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire; Heather Riloff, Esquire and Chandra M. Arkema, Esquire on behalf of the Plaintiff, Federal Home Loan Mortgage Corporation in the above-captioned matter. UDR BY: Margutrlte L. Thomas, E.q.,'. PA 10 204460 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff RLED-OFLI h , ?titrttr ta( Jody S Smith ?tttn?errh6 ldr THE PIR0 T HO'N3 Chief Deputy 2,311 PR 20 PM ?C; 0 0 Richard W Stewa Solicitor OFf?r S" R'Fr CUMBERLAND COUNT`` PENNSYLVANIA Federal Home Loan Mortgage vs. Case Number John Doe 2011-3547 SHERIFF'S RETURN OF SERVICE 04/14/2011 07:4 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 201 at 1941 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defe dant, to wit: Tim Sweeney, by making known unto himself personally, current occupant at 607 5th Stre t, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time han ing to him personally the said true and correct copy of the same. RYAN BURGETf, DEPUTY 04/14/2011 07:4 PM - 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: John Doe, but was unable to locate him in hi bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Joh Doe. Request for service at 607 5th Street, New Cumberland, Pennsylvania 17070 is currently occ pied by Tim Sweeney. SHERIFF COST: April 18, 2011 00 RYAN BURGETT, DE SO ANSWERS, RON R ANDERSON, SHERIFF ;c) CountySuito Shenif, Te;eosoft, iw; UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Federal Home Loan Mortgage =COURT OF COMMON PLEAS Corporation :CIVIL DIVISION 5000 Plano Parkway ":Cumberland County Carrollton, TX 75010 Plaintiff NO. 11-3547-Civil r v. -- John Doe 3 - and/or Tenant/Occupant 607 5th Street ?y, J New Cumberland, PA 17070 --t o Defendant (s) C-) n PRAECIPE TO INDEX DEFENDANT PURSUANT TO PA.R.C.P. 410(b)(2) TO THE PROTHONOTARY: Kindly index as a Defendant, pursuant to Pa. R. C. P. 410 (b) (2) , Tim Sweeney, who was found in possession of the real property subject of the within action in Ejectment. UDREN LAW OFFICES, P.C. Attorney for Plaintiff Chandra M. Arkema, Esquire PA ID 203437 / 0 0_30 92k-,?- I of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION VS. JOHN DOE TIM S WEENEY AND/OR TENANT/OCCUPANT 6075 T" STREET NEW CUMBERLAND, PA 17070 Attorney's Plaintiff's Prothonotary Costs No. 11-3547 Civil Term $ 196.00 $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) FEDERAL HOME LOAN MORTGAGE CORPORATION AT 5000 PLANO PARKWAY CARROLLTON, TX 75010 being: (Premises as follows): SEE ATTACHED DESCRIPTION (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Date May 18, 2011 (Seal) TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and tha aW of saki Court at CM116W Ps- This _1..drr a.7?--y /?&z 4? ALL THAT CERTAIN TRACT OR PIECE OF LAND, SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHERN LINE OF FIFTH STREET ONE HUNDRED (100) FEET EAST FROM THE NORTHEAST CORNER OF ROSEMON"T AVENUE AND FIFTH STREET; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF LOT NO. 9, BLOCK "R", ON THE HEREINAFTER MENTIONED PLAN OF LOTS, ONE HUNDRED FORTY (140) FEET TO A POINT IN THE SOUTHERN LINE OF SMITH AVENUE; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF SMITH AVENUE FIFTY (50) FEET TO A POINT IN THE WESTERN LINE OF LOT NO. 6, BLOCK "R"; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF LOT NO. 6, BLOCK "R", ONE HUNDRED FORTY (140) FEET TO A POINT IN THE NORTHERN LINE OF FIFTH STREET; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF FIFTH STREET, FIFTY (50) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO 7 AND NO 8, BLOCK "R", ON THE PLAN OF GEORGE W. BUTTORFF'S ADDITION OF NEW CUMBERLAND AS RECORDED IN THE OFFICE FOR THE RECORDER OF DEEDS IN AND FOR THE COUNTY OF CUMBERLAND IN DEED BOOK "N", VOLUME S, PAGE 498. BEING KNOWN AS: 607 5th Street New Cumberland, PA 1707C PROPERTY ID NO.: 25-24-0811-178 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff- tit s p i, Jody S Smith Chief Deputy JA, ^l 2 cU PH 2; 0 t Richard W Stewart Solicitor t:UMBERLANr,, COUNT`.' PE NS Federal Home Loan Mortgage Case Number vs. John Doe (et al.) 2011-3547 SHERIFF'S RETURN OF SERVICE 05/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2011, a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Occupant, at 607 5th Street, New Cumberland, Cumberland County, Pennsylvania 17070. The property was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the defendant, Occupant was NOT FOUND. 05/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2011, a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: Timothy M. Sweeney, at 607 5th Street, New Cumberland, Cumberland County, Pennsylvania 17070. The property was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the defendant, Timothy M. Sweeney, was NOT FOUND. 06/25/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2011, a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: John Doe, at 607 5th Street, New Cumberland, Cumberland County, Pennsylvania 17070. The property was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the defendant, John Doe was NOT FOUND. 01/25/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $82.45 SO ANSWERS, January 25, 2012 RON R ANDERSON, SHERIFF 71,d-/7