The URL can be used to link to this page

Home My WebLink About11-8343Phelan 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 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 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 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 Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Court of Common Pleas 1000 TECHNOLOGY DRIVE O'FALLON, MO 63368 Civil Division MARISA A. STRAUB CUMBERLAND County A/K/A MARISA A. GRENKEVICH or Occupants n 208-210 9TH STREET No. V1'/ NEW CUMBERLAND, PA 17070-1609 CIVIL ACTION - EJECTMENT P-1 ?> C-) - :a x c? 3C: LD C) "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 # 267206 GFxW} 49a.c6 pd a ek.rki?a?oyv 12- 4- alob°?2? 1. ' Plaintiff is CITIMORTGAGE, INC.. 2. Defendant is MARISA A. STRAUB A/K/A MARISA A. GRENKEVICH or Occupants. Plaintiff is the record owner of premises located at 208-210 9TH STREET, NEW CUMBERLAND, PA 17070-1609, a legal description of which is attached. 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 Sheriffs deed recorded 04/11/2011 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201110686, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 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. 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 the Premises. Lawrence T. Phelan, Esq., . o. 32227 Francis S. Hallinan, Esq., Id. No. 95 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 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 / Melissa J. Cantwell, Esq., Id. No. 30891T' Mario J. Hanyon, Esq., Id. No. 203993 Andrew Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 Attorney for Plaintiff EXHIBIT "A" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201110686 Recorded On 4/11/2011 At 8:35:23 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 85105 User ID - ES * Grantor - GRENKEVICH, MARISA A * Grantee - CITIMORTGAGE INC * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT NEW CUMBERLAND BOROUGH $0.00 TOTAL PAID $64.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. 1 Certify this to be recorded in Cumberland County PA RECORDER O /D7EDS ' - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. ?iuiiA0028B?iAiin p, 10686 pW?s'YI ? IWIIb I??o Know all Men by these Presents Tax Parcel No. 26-24-0811-282 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 CITIMORTGAGE, INC. Writ No. 2010-4330 Civil Term CITIMORTGAGE, INC. Vs Marisa A. Straub, a/k/a Marisa A. Grenkevich ALL THAT CERTAIN tract or parcel of land, situate in the Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, designated and being known as Lots Nos. 160 and 161 in a certain Plan of Lots called Elkwood, which is duly filed among the records in the Recorder's Office of Cumberland County in Deed Book'M', Vol. 5, Page 498, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the corner formed by the intersection of the southerly side of Ninth Street and the easterly side of a ten-foot wide alley; thence in an easterly direction along the said southerly side of Ninth Street, seventy-four (74) feet to the dividing line between Lots Nos. 159 and 160; thence in a southerly direction along the said dividing line and at right angles with the said Ninth Street, on hundred thirteen (113) feet to a ten- foot wide alley; thence in a westerly direction along said ten-foot wide public alley, seventy-four (74) feet to the easterly side of said ten-foot wide public alley; thence in a northerly direction along the easterly side of a said ten-foot wide public alley, one hundred thirteen (113) feet to the southerly side of Ninth Street, the place of BEGINNING. HAVING THEREON erected a double two and one-half story brick dwelling house and garage known an numbered as 208 and 210 Ninth Street. TITLE TO SAID PREMISES IS VESTED IN Marisa A. Grenkevich, a single person, by Deed from Scott D. Heisey and Karen A. Heisey, his wife, dated 12/28/2000, recorded 01/04/2001 in Book 237, Page 245. PREMISES BEING: 208-210 9TH STREET, NEW CUMBERLAND, PA 17070-1609 PARCEL NO. 26-24-0811-282 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 27th of October Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Ten (2010) Number 4330 at the suit of CITIMORTGAGE, INC. -vs- Marisa A. Straub, a/k/a Marisa A. Grenkevich In Witness Whereof, l have hereunto affixed my signature this 30th day of March Anno Domini Two Thousand and Eleven (2011) ,?-R?nn .?. 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) „` •?. k ? 4'? ? J .qtr • .` ? ,1 ? ,y. r P thonotaiy, jj?}V7t. Q. BtlE' a? ?MALM I hereby certify that the residence And Post Office address of the Within Grantee is 5280 Corporate Drive, MS1011 Frederick, MD 21703 Richard W. Stewart Solicitor 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 Plaintiff's 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 sheriff's 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 sheriff's 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 Lawrence T. Phelan, ' e LZ Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Allison F. Wells, Esquire William E. Miller, Esquire Melissa J. Cantwell, Esquire Mario J. Hanyon, Esquire Andrew Marley, Esquire Robert W. Cusick, Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Marisa A. Straub Orf 'FILED-OFFICE C;? i E£ Pr 0THC°?UTA ?Y 2011 ` OV 16 A`1 C- w 14 P£NPiSYLVANlA Case Number 2011-8343 SHERIFF'S RETURN OF SERVICE 11/15/2011 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: Marisa A. Straub, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Marisa A. Straub. Request for service at 208-210 Nineth Street, Unit 21013, New Cumberland, Pennsylvania 17070 is vacant. 11/15/2011 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: Marisa A. Straub, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Marisa A. Straub. Request for service at 208-210 Nineth Street, Unit 20813, New Cumberland, Pennsylvania 17070 is vacant. SHERIFF COST: $58.00 November 15, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) COuntySuito Shenif, fe,eosotj In;_ OmCC Trothonotary Office of the Tr«th~y%{]fnyy -—'-g` _~"~ Solicitor �� ~~��~�°�=� CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28' 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 BY THE COURT, DAVID D.8UELL , PROTHONOTARY One Courthouse Square 0 Suite100 CanCis TA 0 (Phone 717240-6195 0 Ta,,c717240-6573