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Home My WebLink About12-0383SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ? „IV OFFICE 0 '?ERIFF r ' { t t A'M `? 12 ?U PENNSYB'"N A' i I Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Donald A. Maurice Case Number 2012-383 SHERIFF'S RETURN OF SERVICE 01/30/2012 05:50 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2012 at 1750 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Donald A. Maurice, by making known unto himself personally, at 1519 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 February 01, 2012 `a;zxr ?l TIM K, DEPUTY SO ANSWERS, RON Y R ANDERSON, SHERIFF ?i CeuntySuito Shenff, Ie'eosofl. Ir.c. Puelan Hallinan & Schmieg, LLP Robert W. Cusick, Esq:, Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE COMPANY, INC., S/B/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY Plaintiff vs DONALD A. MAURICE Or occupants 1519 TERRACE AVENUE CARLISLE, PA 17013-9368 Defendant Attorney for Plaintiff COUNTY ,`I;;`SY! `?A??IA COURT OF COMMON PLEAS CIVIL DIVISION No. 12-383-CIVIL TERM CUMBERLAND County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of Plaintiff, CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE COMPANY, INC., SB/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY and against the Defendant(s) DONALD A. MAURICE and Or occupants for possession of premises 1519 TERRACE AVENUE, CARLISLE, PA 17013-9368 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, writte notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defe ant(s), a tr a and correct copy of which is attached hereto. .. Default Judgment entered as indicated above. DATE: Robe . Cusick, Esq., Id. No.80193 rney for Plaintiff Phelan Hallinan & Schmieg, LLP p wkk U 16 s0 Pd ate., C ? ? 11 ? S SAS I P lk- d7alsy V?k>hU* itiIa? ted Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia„ PA 19103 215-563-7000 CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE COMPANY, INC., S/B/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY Plaintiff VS DONALD A. MAURICE or Occupants Defendant DONALD A. MAURICE or Occupants 1519 TERRACE AVENUE CARLISLE, PA 17013-9368 DATE OF NOTICE: February 22, 2012 Court of Common Pleas Civil Division No, 12-383-CIVILTERM CUMBERLAND COUNTY •" 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 Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 1-19 4 t06 By: Phelan (lallinan & Schimieg LLP ttk No. 32227 Lawrence T. Ph <t, i iartrneis S-IAO)in i, Esq., IdAdNo. .62695 Daniel G. Schmie gq„ Id. 62205 Michele M. Bradford, Lsq, 69849 Judith T. Romano, F:sq.,Id. No. 58745 Jenine R. Davey, Fstl., 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 C ourtenay 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., ld. No. 308877 PBS # 289364 Phelan Hallinan & Schmieg, LLP Robert W. Cusick,' E'sq.; Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE COMPANY, INC., SB/M CITIFINANCIAL, MORTGAGE CONSUMER DISCOUNT COMPANY Plaintiff vs DONALD A. MAURICE Or occupants 1519 TERRACE AVENUE CARLISLE, PA 17013-9368 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 12-383-CIVIL TERM 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. (b) That defendant DONALD A. MAURICE and/or occupant(s) reside/s at 1519 TERRACE AVENUE, CARLISLE, PA 17013-9368. (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 ZS.S relating to unsworn falsification to authorities. Date: March 6. 2012 Ro rt usick, Esq., Id. No.80193 y for Plaintiff Phelan Hallinan & Schmieg, LLP PHS # 289364 • PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA ' COUNTY OF CUMBERLAND SB/M CITIFINANCIAL INC. CITIMORTGAGE -' , , INC., SB/M MORTGAGE COMPANY , CITIFINANCIAL MORTGAGE CONSUMER N "? f o DISCOUNT COMPANY r = c_ Plaintiff COURT OF COMMON PLEAS cry CIVIL DIVISION -? -- vs No. 12-383-CIVILTERM C -V DONALD A. MAURICE Or occupants -- , 1519 TERRACE AVENUE CUMBERLAND County CARLISLE, PA 17013-9368 Defendant: PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 1519 TERRACE AVENUE, CARLISLE, PA 17013-9368 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION* Being Known as No. 1519 TERRACE AVENUE R e \ usick, Esq., Id. No.80193 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP DATE: ? I aa.?s Ia c?-? 2? a?al?Y 4# , -% Legal Description ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with survey of Stephen G. Fisher, registered surveyor, dated January 3, 1979, as revised January 9, 1979, as follows: BEGINNING at an iron pin on the northern side of Terrace Avenue, which point at Place of' Beginning is 24.75 feet East of the eastern line of Lot No. 193 on the hereinafter mentioned Plan of Lots; thence from said point at the Place of Beginning through Lot No. 192 on the hereinafter mentioned Plan of Lots, by land now or formerly of Stephen Davidock, North 25 degrees 30 minutes West 1.20.00 feet to an iron pin in the line of land now or formerly of Spurgeon Alsbaugh; thence by the same and by land now or formerly of Raymond Santee, North 64 degrees 30 minutes East 90.00 feet to an iron pin; thence by land now or formerly of Jerry L. Rudd, South 25 degrees 30 minutes East 120.00 feet to an iron pin on the northern line of Terrace Avenue; thence along the northern line of Terrace Avenue, South 64 degrees 30 minutes West 90.00 feet to an iron pin, the Place of BEGINNING. CONTAINING 90 feet in front along the northern line of Terrace Avenue and extending northwardly therefrom at an even width a distance of 120 feet, and being the eastern 57.75 feet of Lot No. 192 and the western 32.25 feet of Lot No. 191 as shown on the Plan of Lots known as Valley Meadows, as recorded in Cumberland Count Right-of-Way Book 1, Page 81. HAVING thereon erected a ranch-type dwelling house with attached garage known and numbered as 1519 Terrace Avenue, Carlisle, Pennsylvania 17013. BEING the same property which Four States Livestock Sales, Inc., a Maryland company, by its deed dated July 25, 1986, and recorded July 25, 1986 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book 'B', Volume 32, Page 234, granted and conveyed to James A. DeGaetano and Barbara G. DeGaetano, husband and wife. I of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE COMPANY, INC., S/B/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY VS. No. 12-383 Civil Term_ DONALD A. MAURICE OR OCCUPANTS 1519 TERRACE AVENUE CARLISLE, PA 17013-9368 Costs Attorney's $ 182.75 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)) CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE COMPANY, INC., S/B/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY being: (Premises as follows): 1519 TERRACE AVENUE, CARLISLE, PA 17013-9368 (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 Cumberland County, Date 03,'08/12 (Seal) „ 2 oft No 12-383 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE COMPANY, INC., SB/M CITIFINANCIAL MORTGAGE CONSUMER DISCOUNT COMPANY VS. DONALD A. MAURICE OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 182.75 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: ROBERT W. CUSICK, ESQUIRE ID#80193 PHELAN, HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 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 _ So Answers, Sworn and subscribed to before me this Day of _ Sheriff --- By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _ D'DFrcI(C Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Donald A. Maurice OFFit E : -"` -,-ERIFF SHERIFF'S RETURN OF SERVICE 1012 MAR 21 AM 9: 22 CUMBERLAND COWNITY PEWS ISYLVANIA Case Number 2012-383 03/20/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant(s), but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1519 Terrace Avenue, Carlisle, PA 17013. Property was found to be vacant. 03/20/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Donald A. Maurice, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1519 Terrace Avenue, Carlisle, PA 17013. Property was found to be vacant. Per the post office, defendant has moved and left no forwarding address. SO ANSWERS, March 20, 2012 RON R ANDERSON, SHERIFF (ci GountySulte Shenff, ieleosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY .onny R Anderson Sheriff ????1` 5I 4f RC!r£.F?y ?' Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Donald A. Maurice SHERIFF'S RETURN OF SERVICE Case Number 2012-383 03/20/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Donald A. Maurice, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1519 Terrace Avenue, Carlisle, PA 17013. Property was found to be vacant. Per the post office, defendant has moved and left no forwarding address. 03/20/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant(s), but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1519 Terrace Avenue, Carlisle, PA 17013. Property was found to be vacant. 04/17/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $52.73 SO ANSWERS, April 18, 2012 RON R ANDERSON, SHERIFF rrj= rn = i r- "< r -4c= r -n =C Cj ea7403y