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Home My WebLink About11-3957Rbefan 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 C-- Lauren R. Tabas, Esq., Id. No. 93337 --a CC) Vivek Srivastava, Esq., Id. No. 202331 . M 7 Jay B. Jones, Esq., Id. No. 86657 r-- tv Mt:i Peter J. Mulcahy, Esq., Id. No. 61791 cs? C) Andrew L. Spivack, Esq., Id. No. 8443 9 Chrisovalante P. Fliakos, Esq., Id. No. 94620 D C-) Joshua I. Goldman, Esq., Id. No. 205047 ca om: Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 c - 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. ANGELA L. RUSNOV KEIM or Occupants CUMBERLAND County 4909 17101 (!A ROAD , A 17050-3093 No. 1 • 5-1 ?? ?' MECHANIC BOURG CIVIL ACTION - EJECTMENT "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 # 267196 C rmk %9U0,pd Q? et# 10$91-3` 124 asQ sap 1. Plaintiff is Federal National Mortgage Association. 2. Defendant is ANGELA L. RUSNOV KEIM or Occupants. 3. Plaintiff is the record owner of premises located at 4909 DELBROOK ROAD, MECHANICSBURG, PA 17050-3093, 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 03/02/2011, as evidenced by the Sheriff's deed recorded 04/11/2011 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201110691, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 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 s, 2d Lawrence T. Phelan, Esq., Id. N-o-32227 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 Kur 1 R. Shah-Jani, Esq., Id. No. 81760 R. Davey, Esq., Id. No. 87077 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 EXHIBIT "A" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201110691 Recorded On 4/11/2011 At 8:39:16 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 85110 User ID - MSW * Grantor - KEIM, ANGELA L RUSNOV * Grantee - FEDERAL NATIONAL MTG ASSOC * Customer - PHELAN HALLINAN & SCHMIEG LLP * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT HAMPDEN TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O?D " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111111111 111111111111 )0 B4 Tax Parcel No. 10-21-0281-043 Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to Federal National Mortgage Association Writ No. 2010-5056 Civil Term PHH Mortage Corporation Vs Angela L. Rusnov Keim ALL THAT CERTAIN piece or parcel of land, situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of Del-Brook Road (60 feet wide) at the dividing line between Lots Nos. 14 and 15, Block A on the hereinafter mentioned Plan of Lots; thence Northwardly along said Lot No. 14, Block A, a distance of 85 feet to a point at Lot No. 13, Block A; thence Northwestwardly along said Lot No. 13, Block A, a distance of 68.23 feet to a point at Lot No. 17, Block A; thence Southwestwardly along said Lot No. 17, Block A, a distance of 68.23 feet to Lot No. 16, Block A; thence Southwardly along said Lot No. 16, Block A, a distance of 85 feet to the North side of Del-Brook Road; thence Eastwardly along the North side of Del-Brook Road, a distance of 65 feet to Lot No. 14, Block A, the place of BEGINNING. BEING Lot No. 15, Block A, Plan No. 1, of Del-Brook Manor, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and on-half story frame dwelling house. UNDER AND SUBJECT to covenants, conditions, reservations, restrictions, easements and right of ways of record. TITLE TO SAID PREMISES IS VESTED IN Angela L. Rusnov Keim, a married woman, by Deed from Harriet F. Gramm, widow, dated 09/26/2005, recorded 10/05/2005 in Book 271, Page 1553. PREMISES BEING: 4909 DELBROOK ROAD, MECHANICSBURG, PA 17050-3093 PARCEL NO. 10-21-0281-043, 10008149 The same having been sold by me to the said grantee on the 2"d day of March Anno Domini Two Thousand and Eleven (2011) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 4th of November Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Ten (2010) Number 5056 at the suit of PHH Mortage Corporation -vs- Angela L. Rusnov Keim i 1, In Witness Whereof, I have hereunto affixed my signature this 30th day of March Anno Domini Two Thousand and Eleven (2011) Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 30th day of March Anno Domini Two Thousand and Eleven (2011) 4Pr.onotary, Q U.L OwnrN c?on Expir Coft r?tlNondc?lkle, PA MY tlN H .Y of Jan. 2W4 I hereby certify that the residence And Post Office address of the Within Grantee is 1 P.O. Box 650043 Dallas, TX 75265 eldIIit` ? Richard W. Stewart Solicitor t 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 unswom falsification to authorities Date /.O? "'Lawrence T. Phelan, Esquir Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire FShental R. Shah-Jani, Esquire e R. Davey, Esquire en 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 at C11 1n6Ar1 tv;. ,y" OFFICE TWA S"ERI€F FILED-OFFICE ?t THE PROTh'O';OTp? R 2011 MAY 25 AM 5: 4 R CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Case Number Angela L. Rusnov Keim 2011-3957 SHERIFF'S RETURN OF SERVICE 05/24/2011 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: Angela L. Rusnov Keim, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Angela L. Rusnov Keim. Request for service at 4909 Delbrook Road, Mechanicsburg, Pennsylvania 17050 is vacant. SHERIFF COST: $43.00 SO ANSWERS, May 24, 2011 RON R ANDERSON, SHERIFF ,C CCUrtySuite Shenff. Tejecsoft Inc cDavidO. BueC Prothonotary Office of the Prothonotaiy Cum5er[ancfCounty, Qennsyfvania xirks. So€ionage, fSQ Solicitor ,I/ —.2QJ / 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 CarasCe, PA ® Phone 717 240-6195 0 'Fax 717 240-6573