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Home My WebLink About04-4805FEDERMAN AND PHELAN By: Francis S. Halhnan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Federal Home Loan Mortgage Corporation Mail Stop 61, P.O. Box 5000 Vienna, VA 22183-5000 : Court of Common Pleas Civil Division Cumberland County Edward W. Orth Or Occupants 208 Bosler Avenue Lemoyne, PA 17043 · Term : No. CMT. ACTION- ~.J~.CTM~.NT - ~*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 ora 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is Edward W. Orth Or Occupants. 3. Plaintiff is the equitable owner of premises located at 208 Bosler Avenue, Lemoyne, PA 17043, a legal description of which is attached. 4. Plaintiff became equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County on September 8, 2004. 5. Plaintiff, by virtue of the above, is the equitable 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. WHEREFORE, plaintiff seeks to recover possession of said premises. ancis S Hallinan, Esquire Attorney for Plaintiff ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Suite 305 Phitade~ohia, Pent~'ylvania 19103 (215) 496-0900 FAX (215J 496-0904 .RECORD OWNER AND LIEN CERTIFICATE Effective Date: 5/8/2001 Order Number: A50088 Client Number: 40216731 Premises: 208 BOSLER AVENUE~ BOROUGH OF LEMOYNE CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hcretnat~er set forth. This Certificate does not constitute rifle insurance; liability hereunder is assumed hy the Company solely ia its capacity as an abstractor for its negligence, mistakes Or omissions in a sum not to exceed Two Thousand Dollars. ~)ESCRIF¥1ON Al.l. THAT CERTAIN lot or piece of ground wi~ thc huildiags a~.d improvements fltereon erected situate in the Borough of Lemoyne, Coun~' of Cumberland and Commonwealth of Pelmsylv~aJa, more particularly bouuded and described as follows, to wit, in accordance with survey of Ernest J. Walker, Registere~ Professional Engineer, dated tile 24th day of May, A.D., 1967: BEGINNING at a point o~ the Southwesterly line of Bosler Avenue, which point is 55 feet Westwardiy of ate Westerly line of Cherry Avenue; thence extending South 38 degrees, East 150 feet to a point on the Northeasterly line of Apple Alley; thence extending along the stone South 52 degrees, West 54 lbet to a point; thence extending North 38 degrees West 150 feet to a poiai on Snutheasterly line of Bosler Avenue Nor~ 52 degrees East 54 feet to the point of beginning. HAVING THEREON erected half of a double three story frame dwelling being kuown and numbered as 208 Bosler Avenue. TAX PARCEL ,9' 12-21-0265-298 Francis S. Hallinan hereby states that he is 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 Plaintiffs 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 sheriffs 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 sheriffs sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff Date Soptemher 30, 3004 SHERIFF'S RETURN CASE NO: 2004-04805 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND FEDEP~AL HOME LOAN MORTAGE CORP VS ORTH EDWARD W R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT ORTH EDWARD W unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT , ORTH EDWARD W , NOT FOUND , as to 208 BOSLER AVENUE LEMOYNE, PA 17043 208 BOSLER AVENUE LEMOYNE IS VACANT. Sheriff's Costs: Docketing 18.00 Service 11.84 Not Found 5.00 Surcharge 10.00 .00 44.84 So answe~'/~ " R. Th~as~iine Sheriff of Cu~rland County FEDER~ & PHEL~ 10/15/2004 Sworn and subscribed to before me this ~ FL day of P t y ~ FEDERMAN PHELAN, LLP By: Frank Federman, Esquire I.D. No. 12248 Lawrence T. Phelan, Esquire I.D. No. 32227 Francis S. Hallinan, Esquire I.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FEDERAL HOME LOAN MORTGAGE CORPORATION Plaintiff VS. EDWARD W. ORTH OR OCCUPANTS Defendant(s) Court of Common Pleas CUMBERLAND County No. 04-4805- CIVIL PRAECIPE TO WITHDRAW COMPLAINTf WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. Date Federrrefin, Esquire Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Attorneys for Plaintiff