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Home My WebLink About11-7388?D ri; 4Yr kP; ; LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER PdD COUNT" 1719 NORTH FRONT STREET E " 'S YLVA N I A HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK, NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE CUMBERLAND COUNTY, PENNSYLVANIA AGENCY Plaintiff vs. CIVIL ACTION - LAW ERIN GARRISON CRAMER and NO. sn CtVt KEVIN L. CRAMER Defendant : IN EJECTMENT N 0 T I C E 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 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 ® a. Pd a a N 0 T I C I A Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar_ una. orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 46 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER. 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK, NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. ERIN GARRISON CRAMER and KEVIN L. CRAMER : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, CIVIL ACTION - LAW NO. Defendant IN EJECTMENT C O M P L A I N T PENNSYLVANIA 1. Plaintiff, U. S. Bank, National Association Trustee for the Pennsylvania Housing Finance Agency, pursuant to a Trust Indenture dated April 1, 1982, is a National Association with a servicing agent of Pennsylvania Housing Finance Agency with an office located at 211 North Front Street, Harrisburg, Pennsylvania 17102. 2. Defendants, Erin Garrison Cramer and Kevin L. Cramer, are adult individuals whose last known precise residence is 2751 Spring Road, Carlisle, Pennsylvania 17013. 3. Plaintiff avers that any person not set forth above, but in possession of the premises set forth in Paragraph 2 is, and shall become a Defendant to this action by virtue of Rule 410(b)(2) of the Pennsylvania Rules of Civil Procedure, upon identification by the Sheriff of Cumberland County in his Return of Service of such person, and upon Praecipe of the Plaintiff. 4. Prior to September 7, 2011, Defendant was the owner of certain real property known as 2751 Spring Road, Carlisle, Pennsylvania 17013. 5. Said premises were sold by the Sheriff of Cumberland County at a Sheriffs Sale held at the Cumberland County Court House on September 7, 2011, after due advertisement according to law, under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, No. 07-6838 Civil Term at the suit of U. S. Bank, National Association Trustee for The Pennsylvania Housing Finance Agency vs. Erin Garrison Cramer and Kevin L. Cramer. 6. The aforesaid property was purchased at sale by U.S. Bank, National Association Trustee for The Pennsylvania Housing Finance Agency, the said proceedings being incorporated herein by reference. 7. By virtue of the aforesaid Sheriffs Sale, Plaintiff acquired title to the said premises. 8. Defendants are presently in possession of the said premises, having come into said possession by virtue of their prior ownership. 9. Plaintiffs Abstract of Title is attached hereto as Exhibit "Bn WHEREFORE, Plaintiff demands judgment against Defendants in Ejectment for recovery of premises described in Exhibit "All attached hereto and made a part hereof, plus costs of suit. PURCELL, KRUG & By: Leon P. Ha er, FjkGire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: September 22, 2011 Towrwhip and ALL that certain tract of land situate des o bled ?? aleco dance with surveYerlmade County , Pennsylvania, bounded an by Thomas Alvin Neff, Registered Surveyor, on June 13, 1967, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a stake on the Eastern right of way line of the Carlisle-New ern Bloomfield Road (Pennsylvania R5 Elm No. 34) Avenue, along the Southemhlsne line of an unpaved street known a of said Elm Avenue, South 70 degrees 15 minutes East, a distance of 200 feet to a stake; thence South 19 degrees 45 minutes West along ling of aland long ow of formerly of Harold Hall, a distance of 75 feet to an iron pin; land now or formerly of M•L- = rO on ?astemQightodegrees of 15 minutes line of said Carlisfe- distance of 200 feet to an iron p 45 minutes East along said right New Bloomfield Road; thence North 19 degrees of way line, a distance of 75 feet to a stake, the place of BEGINNING. for 40 feet CONTAINING 75 feet in front extending Eastwa dly'therefrom at an even Pennsylvania Route No. 34 and width, a distarce of 200 feet, and having thereon erected a one and one-half story brick and aluminum siding covered house. EXHIBIT "A" PLAINTIFF'S ABSTRACT OF TITLE 1. Property acquired by Plaintiff at Cumberland County Sheriff's Sale conducted by Sheriff of Cumberland County on September 7, 2011. 2. Deed from William F. d'Happart and Catherine J. d'Happart, husband and wife, dated December 23, 2005 and recorded December 30, 2005, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 272, Page 2813, to Kevin L. Cramer and Erin Garrison Cramer. EXHIBIT "B" Re: Erin Garrison Cramer and Kevin L. Cramer Loan No. 1317866 Property: 2751 Spring Road, Carlisle, PA 17013 VERIFICATION I verify that the statements made in the foregoing Complaint in Ejectment are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.. Dated: q ['21? 1 1 U.S. BANK, NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE ACWNCY By: b iy-LLo-e S- 1-t'nc?n Title SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,iny R Anderson iheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor THE- FPCTif??i+? 2912 JAN 19 AN 8: 34 CUMBERLAM) COUNT" PENNSYLVANIA US Bank National Association Case Number vs. Kevin L Cramer (et al.) 2011-7388 SHERIFF'S RETURN OF SERVICE 11/28/2011 03:30 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: Kevin L. Cramer at 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania but was unable to locate him in his bailiwick he therefore returns the within Writ of Execution as NOT FOUND as to the defendant, Kevin L. Cramer. Deputies were advised that the residence has been vacant for approximately three weeks. 11/28/2011 03:30 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: OCCUPANT at 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania but was unable to locate him in his bailiwick he therefore returns the within Writ of Execution as NOT FOUND as to the defendant, OCCUPANT. Deputies were advised that the residence has been vacant for approximately three weeks. 01/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is being closed per request of plaintiffs attorney. SHERIFF COST: $52.02 January 18, 2012 a?fX?P?•Co. a6? yr-y 7 SO ANSWERS, RON R ANDERSON, SHERIFF tc Goun,ySuite Sher , Teieosoft, Inc.