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Home My WebLink About11-5518<< L,ro-Ui EiCE POWERS KIRN & JAVARDIAN LLC L ?? t jQ?4NO?AR' GREGORY JAVARDIAN, ESQUIRE - ID No. 55669 n .. ? PM 12. 51 MARY KENNEDY, ESQUIRE - ID No. 77149 ?'J?` MEGHAN BOYLE, ESQUIRE - ID No. 201661 VjMSERLANC COUNT-' 1310 INDUSTRIAL BOULEVARD, SUITE 101 PENKSYLVA" SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation 8200 Jones Branch Drive McLean, VA 22102 Plaintiff vs. Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers And/Or Occupants 518 Katrina Court Mechanicsburg, PA 17050 Defendants Court of Common Pleas Civil Division Cumberland County No. I I- ss T &- COMPLAINT IN EJECTMENT COMPLAINT - CIVIL ACTION 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 this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 TAKE THIS NOTICE 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 anw} °?a• co p?I a POWERS, KIRN, & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE - ID No. MARY KENNEDY, ESQUIRE - ID No. 77149 MEGHAN BOYLE, ESQUIRE - ID No. 201661 1310 INDUSTRIAL BOULEVARD, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-2090 55669 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation 8200 Jones Branch Drive McLean, VA 22102 Plaintiff vs. Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers And/Or Occupants 518 Katrina Court Mechanicsburg, PA 17050 Defendants Court of Common Pleas Civil Division Cumberland County No. COMPLAINT IN EJECTMENT COMPLAINT - CIVIL ACTION Federal Home Loan Mortgage Corporation (hereinafter referred to as "Plaintiff ') is a Corporation conducting business under the laws of the Commonwealth of Pennsylvania and brings this action against Patrick K. Myers, Loraine K. Myers a/k/a Loraine Kline Myers, and/or Occupants (hereinafter referred to as "Defendants"). 2. Defendants Patrick K. Myers and Loraine K. Myers a/k/a Loraine Kline Myers are adult individuals presently residing and occupying the premises at 518 Katrina Court, Mechanicsburg, PA 17050, more fully described in the legal description as Exhibit "A". 3. Plaintiff is the owner of the aforesaid premises, which real estate is fully described in Exhibit "A". 4. Plaintiff purchased the aforesaid premises at the April 6, 2011 Sheriff's sale. 5. Plaintiff is the owner of the premises where Defendants reside by virtue of a Sheriffs Deed recorded May 9, 2011, a copy of which is attached as Exhibit "B". 6. Defendants have no valid legal right to possession and title to the premises. 7. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants. WHEREFORE, Plaintiff, respectfully requests that this Court enter judgment for Possession against Defendants Patrick K. Myers, Loraine K. Myers a/k/a Loraine Kline Myers, and Occupants with respect to the aforesaid premises at 518 Katrina Court, Mechanicsburg, PA 17050. ]Gregory Javardian, Esquire Id. No. 55669 XMary F. Kennedy, Esquire Id. No. 77149 EJMeghan K. Boyle, Esquire Id. No. 201661 Attorneys for Plaintiff EXHIBIT "A" ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Katrina Court at the dividing line between Lots 9 and 10 as shown on the hereinafter mentioned plan of lots; thence along the northern line of Katrina Court by a curve to the left having a radius of 100.0 feet an arc distance of 57.28 feet to a point at the dividing line between Lots 10 and 11; thence along the dividing line between Lots 10 and 11 North 28 degrees 28 minutes 14 seconds West a distance of 120.09 feet to a point on the south eastern line of the other lands of Sleepy Hollow P.R.D.; thence along the last mentioned line North 51 degrees 35 minutes 55 seconds East a distance of 161.84 feet to a point at the southwestern line of Pedestrian/Bikeway; thence along the southwestern line of said Pedestrian/Bikeway South 35 degrees 34 minutes 00 seconds East a distance of 40.00 feet to a point at the dividing line between Lots 9 and 10; thence along the dividing line between Lots 9 and 10 South 12 degrees 45 minutes 40 seconds West a distance of 168.20 feet to a point on the northern line of Katrina Court, said point being the place of beginning. BEING all of Lot No. 10 as shown on the final subdivision plan of Sleepy Hollow P.R.D. Phase 1, recorded in Plan Book 55, Page 44. CONTAINING 0.398 acres THEREUPON erected a two story brick and vinyl-sided dwelling known as 518 KATRINA COURT, MECHANICSBURG, PA 17050 PARCEL No. 10-18-1316-088 EXHIBIT "B" ?335b C_ IN0029? Know all Men by these Presents Tax Parcel No. 10-18-1316-088 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 Home Loan Mortgage Corporation Writ No. 2009-6652 Civil Term U.S. Bank, NA Vs Patrick K. Myers Loraine K. Myers, a/k/a Loraine Kline Myers ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Katrina Court at the dividing line between Lots 9 and 10 as shown on the hereinafter mentioned plan of lots; thence along the northern line of Katrina Court by a curve to the left having a radius of 100.0 feet an arc distance of 57.28 feet to a point at the dividing line between Lots 10 and 11; thence along the dividing line between Lots 10 and 11 North 28 degrees 28 minutes 14 seconds West a distance of 120.09 feet to a point on the south eastern line of the other lands of Sleepy Hollow P.R.D.; thence along the last mentioned line North 51 degrees 35 minutes 55 seconds East a distance of 161.84 feet to a point at the southwestern line of Pedestrian/Bikeway; thence along the southwestern line of said Pedestrian/Bikeway South 35 degrees 34 minutes 00 seconds East a distance of 40.00 feet to a point at the dividing line between Lots 9 and 10; thence along the dividing line between Lots 9 and 10 South 12 degrees 45 minutes 40 seconds West a distance of 168.20 feet to a point on the northern line of Katrina Court, said point being the place of beginning. BEING all of Lot No. 10 as shown on the final subdivision plan of Sleepy Hollow P.R.D. Phase 1, recorded in Plan Book 55, Page 44. CONTAINING 0.398 acres THEREUPON erected a two story brick and vinyl-sided dwelling known as 518 KATRINA COURT, MECHANICSBURG, PA 17050 BEING THE SAME PREMISES which Patrick K. Myers by Deed dated July 17, 2002 and recorded July 19, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 252, Page 3787 granted and conveyed unto Patrick K. Myers and Loraine Kline Myers, husband and wife. PARCEL No. 10-18-1316-088 The same having been sold by me to the said grantee on the 6th day of April 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 9th of September Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 6652 at the suit of U.S. Bank, NA -vs- Patrick K. Myers and Loraine K. Myers, a/k/a Loraine Kline Myers In Witness Whereof, I have hereunto affixed my signature this 2nd day of May Anno Domini Two Thousand and Eleven (2011) 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 2 n d day of Ma y Anno Domini Two Thousand and Eleven (2011) ,?tittititl??, P thonotary ?. ,......., r I hereby certify that the residence And Post Office address of the 5 .•??•??. Within Grantee is 14. ???!> .••'?'? ?? 8200 Jones Branch Drive ,• ,gip '.?-.. 5? \ w a?t?Mail Stop 202 McLean, VA 22102 --Al 11' -- Richard W. Stewart Solicitor REALTY TRANSFER TAX State Tax RECORDER'S ONLY pennsytvania STATEMENT OF VALUE DEPARTMENT OF REVENUE ?'11) 3 3 ?s Bureau of Individual Taxes ber PO BOX 280603 Harrisburg, PA 17128-0603 See reverse for instructions. Date Recorded - Complete each section and file in duplicate with Recorder of Deeds when (1) the full value/consideration is not set forth in the deed, (2) the deed is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach additional sheets. A. CORRESPONDENT - All inquiries may be directed to the following person: Name Telephone Number: Powers Kim & Javardian, LLC (215) 942-9690 Mailing Address City State I ZIP Code 1310 Industrial Blvd Ste 101 1 Southampton PA 18966 _ B. TRANSFER DATA C. Date of Acceptance of Document 04/16/1.1 Grantor(s)/Lessor(s) Grantee(s)/Lessee(s) Sheriff of Cumberland County Federal Home Loan Mortgage Corporation Mailing Address Mailing Address One Courthouse Square 8200 Jones Branch Drive I State ZIP code City State ZIP Code City Carlisle PA 117013 McLean j VA j22102 D. REAL ESTATE LOCATION Street Address 518 Katrina Court County Cumberland E. VALUATION DA 1 Actual Cash Consideration 1.00 4. County Assessed Value 281,780.00 City, Township, Borough Mechanicsburg ( School District TA - WAS TRANSACTION PART OF AN 2. Other Consideration +0.00 5. Common Level Ratio Factor X 1.00 F. EXEMPTION DATA Ia. Amount of Exemption Claimed 1b. Percentage of Grantor's Interest in Real Estate 100.00 100 Check Appropriate Box Below for Exemption Claimed. ? Will or intestate succession. Tax Parcel Number 10-18-1316-088 NT OR RELOCATION? ? Y ? h 3. Total Consideration = 1.00 6, Fair Market Value = 281,780.00 1c. Percentage of Grantor's Interest Conveyed 100 (Name of Decedent) (Estate File Number) ? Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ? Transfer from a trust. Date of transfer into the trust If trust was amended attach a copy of original and amended trust. ? Transfer between principal and agent/straw party. (Attach complete copy of agency/straw party agreement.) ? Transfers to the commonwealth, the U.S. and instrumentalities by gift, dedication, condemnation or in lieu of con- demnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of mortgage and note/assignment.) ? Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ? Statutory corporate consolidation, merger or division. (Attach copy of articles,) ? Other (Please explain exemption claimed.) Transfer tax is excempt as that grantee is a government agency Under penalties of law, I declare that I have examined this statement, including accompanying information, and to the best of my k ledge and belief, it is true, correct and complete. _ Signature of Corr o or Responsible Party - Date / " -*-1- 1 04116/11 FAILURE TOAOMPLETE THIS FORM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW U.S. BANK, N.A. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. No.: 09-6652 CIVIL "PERM PATRICK K. MYERS LORAINE K. MYERS A/K/A LORAINE KLINE ASSIGNMENT OF BID RIGHTS UNDER SHERIFF'S EXECUTION SALE Gregory Javardian, Esquire, Attorney for U.S. Bank, N.A. kindly request that the bid on the above matter be assigned to FEDERAL HOME LOAN MORTGAGE CORPORATION whose address is 8200 Jones Branch Drive McLean, VA 22102-0110 as they are the investor in this matter. ,4nww ak?gp MEGI AN K. BOYLE, ESQ IRE %REGORY JAVARDIAN, ESQUIRE ATTORNEY FOR PLAINTIFF ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201113356 Recorded On 5/9/2011 At 10:58:05 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 86558 User ID - MSW * Grantor - MYERS, PATRICK K * Grantee - FEDERAL HOME LOAN MTG CORP * Customer - GREGORY JAVARDIAN * 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 " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. udiiiiiii?uu VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. Date: - Name: za<beth Taylor,C Title: 'Assistant Treasur r Federal Home Loan Mortgage Corporation 518 Katrina Court, Mechanicsburg, PA 17050 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4? ?S o' C7uljj x'/4110 FlL?G-C? 0 y?y ?j Ti f1',: r h r5 R t iJthAR l?/ l Jody S Smith Chief Deputy Richard W Stewart Solicitor PM 1:20 CUM RLA1U ("OUi i Y ENS 13Y+ t J; Federal Home Loan Mortgage Corporation Case Number vs. Patrick K. Myers (et al.) 2011-5518 SHERIFF'S RETURN OF SERVICE 07/13/2011 09:05 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2011 at 2105 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Patrick K. Myers, by making known unto himself personally, at 518 Katrina Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. ? ' TIM LACK, DEPUTY 07/13/2011 09:05 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2011 at 2105 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Loraine K. Myers, by making known unto himself Patrick Myers, Husband of Defendant at 518 Katrina Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. TIM BLAC,1 , DEPUTY 07/14/2011 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 518 Katrina Court, Mechanicsburg, Pennsylvania 17050, 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 518 Katrina Court, Mechanicsburg, Pennsylvania 17050 is only occupied by Patrick and Loraine Myers, Husband and Wife. SHERIFF COST: $75.00 July 14, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF C'/ ,'nfvsu 5hf';f. TC 09O!i Inc =iLE-U-OFFICE Y:. HE PROTHONOTARY POWERS, KIRN, & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE - ID No. 55669 !911 AUG 19 PH 3' 14 MARY F. KENNEDY, ESQUIRE - ID No. 77149 s rL???Q COUNTY MEGHAN K. BOYLE, ESQUIRE - ID No. 201661'LNFdSYLVANIA 1310 INDUSTRIAL BOULEVARD, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers No. 11-5518 Civil And/Or Occupants Defendants PRAECIPE FOR JUDGMENT OF POSSESSION TO THE PROTHONOTARY: Kindly enter judgment for Possession of the premises 518 Katrina Court, Mechanicsburg, PA 17050 in favor of Federal Home Loan Mortgage Corporation, and against Patrick K. Myers, Loraine K. Myers a/k/a Loraine Kline Myers, and Occupants due to Defendants' failure to file an Answer within twenty (20) days from Service of the Complaint in Ejectment. Date: 8/17/11 []Gregory Javardian, Esquire ID No. 55669 []Mary F. Kennedy, Esquire ID No. 77149 )dMeghan K. Boyle, Esquire ID No. 201661 Attorneys for Plaintiff Q.?- % 14. o3 ?a add Jot,?,,Q POWERS, KIRK, & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE - ID No. 55669 MARY F. KENNEDY, ESQUIRE - ID No. 77149 MEGHAN K. BOYLE, ESQUIRE - ID No. 201661 1310 INDUSTRIAL BOULEVARD, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Plaintiff vs. Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers And/Or Occupants Defendants Cumberland County No. 11-5518 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF BUCKS ss The undersigned, being duly sworn according to law, deposes and says this affidavit is made on behalf of the above plaintiff, being authorized to do so, and it is averred that: (a) Patrick K. Myers is an adult individual over 18 years of age with a last known address of 518 Katrina Court, Mechanicsburg, PA 17050, and is employed as an unknown at unknown. (b) Loraine K. Myers a/k/a Loraine Kline Myers is an adult individual over 18 years of age with a last known address of 518 Katrina Court, Mechanicsburg, PA 17050, and is employed as an unknown at unknown. Deponent further avers that none of the above is within the protection of the Servicemembers' Civil Relief Act of 1940, as amended, together with the amendments thereto. Date: 8/17/11 AAg*A=-'k1- 1?-& []Greg y Javardian, Esqu' e ID No. 55669 []Mary F. Kennedy, Esquire ID No. 77149 `6Meghan K. Boyle, Esquire ID No. 201661 Sworn to and subscribed Attorneys for Plaintiff before me this jl+h day of 4U9t-'St 2011. N-k,N" , ? ka 1 D MMO SEERRYMNAM No ry Public COLEEN SPEm SEAL Swftmplon won T N? Pubk UppK Cw* Carr 1, 2014 . Court Of Common Pleas Civil Division POWERS, KIRK, & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE - ID No. 55669 MARY F. KENNEDY, ESQUIRE - ID No. 77149 MEGHAN K. BOYLE, ESQUIRE - ID No. 201661 1310 INDUSTRIAL BOULEVARD, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers No. 11-5518 Civil And/Or Occupants Defendants CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default was mailed to the Defendants and to his/her/their attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. Said notice was sent on the date set forth in the copy of said notice attached hereto and marked Exhibit "A." Date: 8/17/11 w4wl??= ?:g- []Gregory Javardian, Esquire ID No. 55669 ? Mary F. Kennedy, Esquire ID No. 77149 Meghan K. Boyle, Esquire ID No. 201661 Attorneys for Plaintiff EXHIBIT "A Federal Home Loan Mortgage Corporation Court of Common Pleas Plaintiff vs. Civil Division Patrick K. Myers Cumberland County Loraine K. Myers a/k/a Loraine Kline Myers And/Or Occupants No. 11-5518 Civil Defendants TO: Patrick K. Myers Loraine K. Myers Occupants 518 Katrina Court a/k/a Loraine Kline Myers 518 Katrina Court Mechanicsburg, PA 17050 518 Katrina Court Mechanicsburg, PA 17050 Mechanicsburg, PA 17050 DATE OF NOTICE: August 4, 2011 NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims se forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 r t Grp ory J ard? Esquire 1310 Industrial ulevard I" Floor, Suite 101 Southampton, Pa 18966 (215) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en cort e o escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telpfono a la oficina, cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. i POWERS, KIRK, & JAVARDIAN, LLCO CIfONOTAR. GREGORY JAVARDIAN, ESQUIRE - ID No. 55669 1 AUG 1g PM 3: 14 MARY F. KENNEDY, ESQUIRE - ID No. 77149 MEGHAN K. BOYLE, ESQUIRE - ID No. 201661 ";?J gQERLAND COUNT 1310 INDUSTRIAL BOULEVARD, SUITE 101 PENNSYLVANIA SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Patrick K. Myers Loraine K. Myers a/k/a Loraine Kline Myers No. 11-5518 Civil And/Or Occupants Defendants PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a WRIT OF POSSESSION in the above matter, for possession of: 518 Katrina Court Mechanicsburg, PA 17050 Date: 8/17/11 Qom} 4-gU. 06 r) s.oa qa.c? 0 at? CBF U It 4.9 CD 61") ?Gregory Javardian, fso ID No. 55669 ary F. Kennedy, Esquire ID No. 77149 Meghan K. Boyle, Esquire ID No. 201661 Attorneys for Plaintiff Ck,& I(o9s e4k oos4-tB' ?y- 4 q em WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160-3165) Federal Home Loan Mort 8200 Jones Branch Drive McLean, VA 22102 Patrick K. Myers vs Loraine K. Myers a/k/a Loraine Kline Myers And/Or Occupants 518 Katrina Court Mechanicsburg, PA 17050 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF Bucks - To the Sheriff of Cumberland IN THE COURT OF COMMON PLEAS OF ,. _ Cumberland COUNTY, PENNSYLVANIA No. 11-5518 Civil XXffXXKEXXXXk0- . No Term 19 E.D. WRIT OF POSSESSION County, Penna. (1) To satisfy the judgment for possession in the above matter you are directed to deliver posses sion of the following described property to: Federal Home Loan Mortgage Corporation Plair--stiff (s) being: (Premises as follows): 518 Katrina Court Mechanicsburg, PA 17050 (See attached legal description) (2) To satisfy the costs against the defendant(s) you are directed to levy upon any property of the de- fendant(s) and sell his her (ortheir) interest therein. Prothonotary, Court of Common Pleasof Cumberland County, Pennsylvania Dated By: Deputy (SEAL) NOTE: If the judgment includes profits or damages, or if the attachment execution for costs is desired, the p&-l-liff may issue a separate Writ of Execution under Rule 3102. MP-11 91 N (D ro 1 W 0 I-- D p !SD ° m ° H W ? m ct H O ,I K rl p ? i W CD 1 ? C rL CL rt N or ?r roroln .. .. O c N N n Ul to W 10 10.0 P- ? rY N N O I I ? ?o N O? O to ?o ro to o a 0 .o ON ON t", ?ld ? I ?g 00 N o 7 a O W m n N O O 11 t7 0 lal rO a (D m w ° w :3 Fl to n ft O x ?y o a' n m OD Q Gd m ? w A o ?mm ° w r rt w m " CD N a Z W H l--\ ti % ? "? •? Ul 93 C ° OQ O 1w r ° w G r W 9 w (D r t p O C • I o n r m rt O c , N n ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Katrina Court at the dividing line between Lots 9 and 10 as shown on the hereinafter mentioned plan of lots; thence along the northern line of Katrina Court by a curve to the left having a radius of 100.0 feet an are distance of 57.28 feet to a point at the dividing line between Lots 10 and 11; thence along the dividing line between Lots 10 and 11 North 28 degrees 28 minutes 14 seconds West a distance of 120.09 feet to a point on the south eastern line of the other lands of Sleepy Hollow P.R.D.; thence along the last mentioned line North 51 degrees 35 minutes 55 seconds East a distance of 161.84 feet to a point at the southwestern line of Pedestrian/Bikeway; thence along the southwestern line of said Pedestrian/Bikeway South 35 degrees 34 minutes 00 seconds East a distance of 40.00 feet to a point at the dividing line between Lots 9 and 10; thence along the dividing line between Lots 9 and 10 South 12 degrees 45 minutes 40 seconds West a distance of 168.20 feet to a point on the northern line of Katrina Court, said point being the place of beginning. BEING all of Lot No. 10 as shown on the final subdivision plan of Sleepy Hollow P.R.D. Phase 1, recorded in Plan Book 55, Page 44. CONTAINING 0.398 acres THEREUPON erected a two story brick and vinyl-sided dwelling known as 518 KATRINA COURT, MECHANICSBURG, PA 17050 PARCEL No. 10-18-1316-088 10f2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION 8200 JONES BRANCH DRIVE MCLEAN, VA 22102 VS. No. 11-5518 Civil Term_ PATRICK K. MYERS, LORAINE K. MYERS a/k/a LORAINE KLINE MYERS AND/OR OCCUPANTS 518 KATRINA COURT MECHANICSBURG, PA 17050 Costs Attorney's $ 205.00 Plaintiff's $ Prothonotary $ 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 being: (Premises as follows): 518 KATRINA COURT, MECHANICSBURG, PA 17050 (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. CA2 David D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA Date AUGUST '2212011 (Seal) 2of2 No 11-5518 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION 8200 JONES BRANCH DRIVE, MCLEAN, VA 22102 vs. PATRICK K. MYERS, LORAINE K. MYERS a/k/a LORAINE KLINE MYERS AND/OR OCCUPANTS, 518 KATRINA COURT, MECHANICSBURG, PA 17050 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 205.00 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MEGHAN K. BOYLE, ESQ. 1310 INDUSTRIAL BLVD., SUITE 101 SOUTHAMPTON, PA 18966 215-942-2090 ID # 201661 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , So Answers, Prothonotary By Sheriff Deputy