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Home My WebLink About11-6839SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ? p+?Vtt4? Gt Lltliif/pf?t? v r? ,?F? F uc ?u?R4FR' "E PRO H? ? i `+: 2P 1 i SEP 30 Pf' 2: n OIUMBERLAINL> PENtr SYL%! ?"1A US Bank National Association Case Number vs. Eugene M. Campbell 2011-6839 SHERIFF'S RETURN OF SERVICE 09/29/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 29, 2011 at 1025 hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Eugene M. Campbell. After several attempts the Complaint In Ejectment expired before the Deputies were able to reach anyone at home. SHERIFF COST: $58.00 SO ANSWERS, September 29, 2011 RON R ANDERSON, SHERIFF ci GounrySuae She?ft. 7eleso't. Inc U.S. BANK NATIONAL ASSOCIATION as Trustee for RASC 2005KS1, PLAINTIFF V. EUGENE M. CAMPBELL OR OCCUPANTS 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 *00 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT NO. 2011-6839 CIVIL TERM IN RE: MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT ORDER OF COURT AND NOW, this '2? y of January, 2012, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court, it is ordered and directed that service of the Complaint in this case upon the Defendant, Eugene M. Campbell or occupants at the property located at 5257 Meadowbrook Drive, Mechanicsburg, Pennsylvania 17050-6833, may be made (1) by first-class and certified mail at the last known address, 5257 Meadowbrook Drive, Mechanicsburg, Pennsylvania 17013, service to be deemed complete upon mailing; (2) by posting the Complaint on the most public portion of the property located at 5257 Meadowbrook Drive, Mechanicsburg, Pennsylvania 17013; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid Meadowbrook Drive address with service to be deemed complete upon mailing. • r •. BY JtJ T M"g Thoma . Placey, C.P.J. Distribution: Allison F. Wells, Esq. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, Pennsylvania 19103 Eugene M. Campbell 5257 Meadowbrook Drive Mechanicsburg, PA 17050-6833 Occupants of the Residence at u 5257 Meadowbrook Drive . j Mechanicsburg, PA 17050-6833 GP y m , lei Phelan Hallinan & Schmieg, LLP ". Lawrence T. Phelan, Esq., Id. No. 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS I Plaintiff vs. EUGENE M. CAMPBELL Or occupants Defendant Attorney for Pla k ?- a_z - i h ROTHONOTARf 2012 FEB -6 AM 9: 10 CUt?,BENNSYLVANIANTY r Court of Common Pleas Civil Division No. 11-6839 CIVIL CUMBERLAND County PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above Law ence T. helan, Esq., Id. N .32227 Frftmeis S. n, Esq., I . o. 62695 Daniel G. Schmieg, Es ., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 son F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Attorne for Pl 'nt'ff Date: February 2, 2012 PHS # 275909 y ai ? CkM+*.u.-I SP4 60 IJ ?a?io V LL od? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F iLE1)-01 1' ' 1ri Sheriff ?. IH(- PROTHONOTARY Jody S Smith Chief Deputy 2012 FED 16 PH Z: a 7 Richard W Stewart CUMBERLANU COUNITY Solicitor PENNSYLVANIA US Bank National Association Case Number vs. Eugene M. Campbell 2011-6839 SHERIFF'S RETURN OF SERVICE 02108/2012 04:24 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 8, 2012 at 1624 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Eugene M. Campbell, pursuant to order of court by posting the premises located at 5257 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 with a true and correct copy according to law. G " NOAH CLINE, DEPUTY SHERIFF COST: $47.00 February 14, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 vs. Plaintiff s J! p7 =FI 2012 FEB 21 PAS 3: 03 CUMBERLAND COUNTY PENNSYLVANIA Court of Common Pleas Civil Division CUMBERLAND County No. 11-6839 CIVIL EUGENE M. CAMPBELL Or occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Defendant AFFIDAVIT OF SERVICE VIA REGULAR AND CERTIFIED MAIL I hereby certify that a true and correct copy of the Complaint in Ejectment in the above captioned matter was sent by Regular and Certified Mail, to the following person(s): EUGENE M. CAMPBELL or Occupants at 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833 in accordance with the Order of Court dated January 24, 2012. The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. DATE: February 16, 2012 Lawrence T. Phein, Esq., Id. o. -Ff-ftnei9 S. l4al4iuaa--t2q,- Id. No. 62695 Daniel G. Schmieg, Esq., I . o. 62205 Michele M. Bradford, Esq., Id. No. 6 Judith T. Romano, Esq., Id. No. 45 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 /Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 PHS # 275909 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Attorney for Plaintiff F'.11 0 ,40 A f{ Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Dana Ostrovsky, Esq., Id. No. 83921 1617 JFK Boulevard, Suite 1400 i'gc iCi itl D Cc?iJ i ;-- :'P??Y!_Vla 1! ATTORNEYS FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS 1 COURT OF COMMON PLEAS Plaintiff VS. CIVIL DIVISION CUMBERLAND COUNTY EUGENE M. CAMPBELL OR OCCUPANTS No. 11-6839 CIVII, Defendant(s) AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Ejectment was made in accordance with the Court Order dated 01/24/12 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)(1) in The Sentinel on 02/20/12 and The Cumberland County Law Journal on 02/24/12. Proofs of the said publications are attached hereto. PHS # 275909 JMG r The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: March 1, 2012 Phelan Hallinan & Schmieg, ,-Phelan Hallman & Schmieg, LLP Lawrence T. P e an, s ., o. 32227 sq., Id. No. 695 Daniel G. Schmieg, sq., Id. No. 6 05 Michele M. Bradford, Esq., Id. N .669849 Judith T. Romano, Esq., Id. N 8745 Jenine R. Davey, Esq., Id. o. 87077 Lauren R. 'Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 CRsovalante ew L. Spivack, Esq., Id. No. 84439 P. Fliakos, Esq., Id. No. 94620 enay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Dana Ostrovsky, Esq., Id. No. 83921 Attorneys for Plaintiff PHS # 275909 JMG I PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 20, 2012 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are tr Sworn to and subscribed before me this U_tjn 201) Notary Public My commission expires: NOTARIAL N HECKENDORN Notary Public Ly LISLE 130ROU( BOROUGH, CUMBERLAND CNTY Expires Jan 27, 201, BAMBI ANN SEA. Commission ?n&,r aa?oa PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V iz_ February 24, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject mattes- of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Li a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 24 day of February, 2012 d Notary ?NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN EJECTMENT In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 2011-6839 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KSl v. EUGENE M. CAMPBELL, or occupants NOTICE TO: EUGENE M. CAMPBELL or oc- cupants You are hereby notified that on AUGUST 31, 2011, Plaintiff U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 filed an Ejectment Complaint endorsed with Notice to Defend, against you in the Court of Common Pleas of CUMBERLAND County, Pennsylva- nia, docketed at 2011-6839. Wherein Plaintiff seeks to Evict all occupants at the property 5257 MEADOW- BROOK DRIVE, MECHANICSBURG, PA 17050 whereupon your property was sold by the Sheriff of CUMBER- LAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or Judgment will be entered against you. "This firm is a debt collector at- tempting 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. 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 appear- ance 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 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 Feb. 24 NOTICE 16 lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 VS. No. 11-6839 Civil Term EUGENE M. CAMPBELL OR OCCUPANTS 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Costs Attorney's $ 253.75 Plaintiff's $ Prothonotary $ 2.25 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)) U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS 1 being: (Premises as follows): 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833 (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. Common Pleas Court of gbmberland County, PA Date 4/3/12 (Seal) 2of2 No 11-6839 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 VS. EUGENE M. CAMPBELL OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 253.75 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: MELISSA J. CANTWELL, ESQUIRE - ID#308912 PHELAN, HALLINAN & SCHMIEG, LLP 1617 JFK BLVD., SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the - day of . I caused the within named to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy PRAECIPE. FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF' CUMBERLAND U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS 1 Plaintiff vs EUGENE M. CAMPBELL Or occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Defendant COURT OF COMMON PLEAS CIVIL DIVISION No. 11-6839 CIVIL CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTION" vLt-!i.l` 1- i -3 'N 10: 41. ,,jBEftLAN0 COEJNT'`' PENNSYLVANIA Being Known as No. 5257 MEADOWBROOK DRIV Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP DATE: ?a g. So 1, al? avk , NF 00 u., of CO II. 75 i U . SD It Q -3. ?r5 P as Legal Description ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the eastern line of Meadowbrook Drive at the northern line of Lot No. 33, Section A, on the hereinafter mentioned Plan of Lots; thence along the said eastern line of Meadowbrook Drive, North 23 degrees 40 minutes West, 100 feet to the southern line of Lot No. 35; thence along said line of Lot No. 35, North 66 degrees 20 minutes East, 279.85 feet to the western line of lands shown on the Plan now or late of Good Hope Terrace; thence along said land, South 01 degree 52 minutes East, 107.70 feet to the northern line of Lot No. 33; thence along said line, South 66 degrees 20 minutes West, 239.85 feet to a point, the place of BEGINNING. Being Lot No. 34, Section A, Plan 7, Good Hope Farms, which Plan is recorded in Plan Book 23, Page 21, Cumberland County Records. HAVING THEREON ERECTED a Colonial brick and aluminum bi-level with an attached two car garage known and numbered as 5257 Meadowbrook Drive, Good Hope Farms, Mechanicsburg, Pennsylvania. BEING THE SAME PREMISES which Carolyn B. Smolizer, widow, by Deed dated August 9, 1991 and recorded August 28, 1991 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book H, Volume 35, Page 56, granted and conveyed unto Byron A. Wiley. Carol Ann S. Wiley, wife of Byron A. Wiley, joins in this conveyance to divest all right, title and interest in said property. Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 Plaintiff vs EUGENE M. CAMPBELL Or occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Defendant: Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 11-6839 CIVIL CUMBERLAND County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: -RU COUNTv' + $?ieSY?."1A?1A Kindly enter Judgment in Ejectment in favor of Plaintiff, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS 1 and against the Defendant(s) EUGENE M. CAMPBELL and Or occupants for possession of premises 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Melissa J. Cantwell, Esq., Id. 12 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Default Judgment entered as indicated above. DATE: ?'t I U.:5b 0 al? Cv,r# 11-?q2S4o 12 g a73a97 Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR R.ASC 2005KS 1 Plaintiff vs EUGENE M. CAMPBELL Or occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Defendant COURT OF COMMON PLEAS CIVIL DIVISION No. 11-6839 CIVIL CUMBERLAND County VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am the Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. authorities. Date: April 2, 2012 PHS # 275909 (b) That defendant EUGENE M. CAMPBELL and/or occupant(s) reside/s at 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833. (c) It is unknown whether any other occupants are in the military or are over 18 years of age. This statement is made subject to penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to LA Melissa J. Cantwe , sq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR Court of Common Pleas RASC 2005 KS 1 Plaintiff Civil Division VS No. 11-6839 CIVIL EUGENE M. CAMPBELL or Occupants Term Defendant CUMBERLAND COUNTY TO: EUGENE M. CAMPBELL or Occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 DATE OF NOTICE: March 19, 2012 ** 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. ** 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 of objections to the claims set 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: Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street I Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 By: Me is . Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP PHS # 275909 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor - F t t yriz- P[,'0T , t'N' :,n2 MAY -4 PPS 3:21 CUMBERLAND t;OUN'r Y PENNSYLVANIA US Bank National Association vs. Case Number Eugene M. Campbell 2011-6839 SHERIFF'S RETURN OF SERVICE 05/04/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Eugene M. Campbell, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 5257 Meadowbrook Drive, Mechanicsburg, PA 17050. Attempts were made on the following dates/times: 04-13-12 @ 1618 hours 04-13-12 @ 2038 hours 04-16-12 @ 1826 hours 04-17-12 @ 1707 hours 04-17-12 @ 2109 hours 04-18-12 @ 1528 hours 04-19-12 @ 1800 hours 04-23-12 @ 2005 hours 04-24-12 @ 1750 hours 04-27-12 @ 1938 hours (Deputy noted there were dogs in the residence) 05-01-12 @ 1922 hours SHERIFF COST: $75.25 May 04, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF .' [ rua` atP :,hart r ,. i Pheh: n Hallinan & Schmieg, LLP yuh* Michael Kolesnik, Esq., Id. No.308877 P1617 A Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 Plaintiff VS. EUGENE M. CAMPBELL Or occupants 5257 MEADOWBROOK DRIVE MECHANICSBURG, PA 17050-6833 Defendant Attorney for Plaintiff Court of Common Pleas r 7 ?y Civil Division, s CUMBERLAND County= %c' No. 11-6839 CIVIL C'o < C=; AFFIDAVIT OF SERVICE VIA REGULAR MAIL I hereby certify that a true and correct copy of the Writ of possession in the above captioned matter was sent by Regular Mail, to the following person(s): EUGENE M. CAMPBELL or Occupants at 5257 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17050-6833 in accordance with the Order of Court dated January 24, 2012. The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. DATE: May 7, 2012 Esq., Id. No.308877 y for Plaintiff Hallinan & Schmieg, LLP PHS # 275909 W1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY c Anderson kYStt Di Lit119IhYt Mco M F- ,ody S Smith ? 4,?? ` -? ' Chief Deputy un . ; C-) t' _ Richard W Stewart ..p Solicitor C-, `_' US Bank National Association vs. Eugene M. Campbell Case Number 2011-6839 SHERIFF'S RETURN OF SERVICE 05/04/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Eugene M. Campbell, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 5257 Meadowbrook Drive, Mechanicsburg, PA 17050. Attempts were made on the following dates/times: 04-13-12 @ 1618 hours 04-13-12 @ 2038 hours 04-16-12 @ 1826 hours 04-17-12 @ 1707 hours 04-17-12 @ 2109 hours 04-18-12 @ 1528 hours 04-19-12 @ 1800 hours 04-23-12 @ 2005 hours 04-24-12 @ 1750 hours 04-27-12 @ 1938 hours (Deputy noted there were dogs in the residence) 05-01-12 @ 1922 hours 05/15/2012 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 5257 Meadowbrook Drive, Mechanicsburg, PA 17050. SHERIFF COST: $118.01 May 15, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF +a. as pa 01o of 810& ON a,15mo (c) GourtgSote She-ff. Teleosoft, hic_ Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff U.S. BANK NATIONAL Court of Common Pleas ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 Civil Division c Plaintiff c CUMBERLAND County X r-- vs ,,r ... No. 11-6839 CIVIL ?<- EUGENE M. CAMPBELL OR r-, OCCUPANTS Z---, c Defendant TO THE PROTHONOTARY: ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ? Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ® Ples7it ark the in rem judgment Satisfied and the action Discontinued and Ended. Date: .( P AN LLINAN & HMIEG, LLP Melissa J. Cantwell, Esq., o.308912 Attorney for Plaintiff PHS # 275909 rn ?_ ["r o a4: Phelan Hallinan & Schmieg, LLP Attorney For Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS1 Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County EUGENE M. CAMPBELL OR OCCUPANTS Defendant No. 11-6839 CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served regular mail to the person(s) on the date listed below: EUGENE M. CAMPBELL OR OCCUPANTS 5257 MEADOWBROOK DRIVE MECHA ICS1BURG, PA 17050-6833 Date: I Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff PHS # 275909