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HomeMy WebLinkAbout12-1337Phelan Hallinan & Schmieg, LLP By: 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 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 Peter J. Mulcahy, Esq., Id. No. 61791 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 A tjrney for Plaintiff I ' con' 2.9 - ,4 L I>'_1 BERLAND COUNTY PENNSYL A'NIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 11 I 1 POLARIS PARKWAY COLUMBUS, OH 43240 V. ANTHONY M. VOGELSONG or Occupants 11 SOUTH ENOLA. DRIVE ENOLA, PA 17025 Court of Common Pleas Civil Division CUMBERLAND County No. c ro I a - 33 7 CIVIL ACTION - EJECTMENT "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 # 258049 a ('rv,.k % CK # RVr- a77M I/ Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION. 2. Defendant is ANTHONY M. VOGELSONG or Occupants. Plaintiff is the record owner of premises located at 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025, a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of CUMBERLAND County, on 09/08/2010, as evidenced by the Sheriffs deed recorded 11/09/2010 in the Office of the Recorder of CUMBERLAND County in 201032595, a true and correct copy of which is attached hereto, made part 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. LawrenEe T. Phelan, Esq., Id. No. 32227 Francis S man, Id. No. 62695 -AJaaJel . Schmieg, Esq., l d). No. 62205 Michele . Bradford, Esq. d. No. 69849 Judith T. Romano, Es No. 58745 Sheetal R. Shah-Ja ., sq., Id. No. 81760 Jenine R. Day , Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Cou ay 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 Attorney for Plaintiff EXHIBIT "A" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1. COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201032595 Recorded On 11/9/2010 At 9:14:25 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 76347 User ID - MBL * Grantor - VOGELSONG, ANTHONY M * Grantee - JPMORGAN CHASE BANK N A * Customer - CUMBERLAND COUNTY SHERW * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 EAST PENNSBORO SCHOOL $0.00 DISTRICT EAST PENNSBORO TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA K n REC011DER O U .,I;I)s 2n PW * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. ui?iiH?M'11iauflir 3-as s4 Know all Men by these Presents `??"" All?IIiIIIV Tax Parcel No. 09-15-1291-030 That T, Ronny R. Anderson, Sheriff of the County of Cumberland, in (he 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 J'PMorgan Chase Bank, National Association Writ No. 2009-3288 Civil Term JPMorgan Chase Bank, National Association Vs Anthony M. Vogelsong ALL, 'THA`I' CERTAIN TRACT OR PARCEL OF LAND SITUATE iN THE TOWNSITTP OF EAST PENINSBORO, COUNTY OF CUMBERLAND, AND S-IATE OF PENNSYLVANTA BOUNDED AND DESCRIBED AS FOLLOWS, TO Wl"I': BEGINNING AT A POINT ON THE SOUTHWEST CORNER OF PYNE STREET AND BRICK CHURCH (STATE) ROAD; THENCE SOUTHWARDLY ALONG TT-IE WESTERN SIDE OP BR CK CHURCH ROAD, FIFTY 950) FEET TO A POINT ON LINE OF LOT NO. 18 ON THE HEREINAFITR INTENTIONED PLAN OF LOTS AND ALSO BEING LANDS NOW OR LATE OF HERMAN A WAGGONER, THENCE WESTWARDLY ALONG SAME AND THROUGH THE CENTER OF A PARTITION WALT. AND BEYOND IN A LINE AT RIGI-i F ANGLES TO BRICK CHURCH ROAD, ONE HUNDRED AND TWENTY-FIVE' FEET TO A POINT ON THE EASTERN LINE OF A SIXTEEN FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG SAME FIF'T'Y FEET TO A POINT ON TFII SOUTHERN LINE OF PYNE STREET; THENCE EASTWARDLY ALONG SAME IN A LINE AT RIGHT ANGLES TO BRICK CHURCH ROAD ONE HUNDRED AND TWENTY- DIVE FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 19 AND 20 ON PLAN OF MOLT7' S ADDI'T'ION, RECORDED IN '111E OFFICE OF THE RECORDER OF DEEDS, CUMBERLAND COUNTY IN PLAN BOOK I PAGE 2. 1-IAVTNG ERECTED THF•,REON THE NORTHERN HALF OF A TWO STORY DOUBLE FRAME DWELLING HOUSE KNOWN AND NUMBERED AS NO. I I SOU'llf ENOLA DRIVE (FORMERLY NO. 11 BRICK CIIURCH ROAD). HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS I I SOU'T'H ENOLA DRIVE, ENOLA, PA, 17025. BEING THE SAME PREMISES WHICH MARLIN S. VOGELSONG, EXECUTOR OF TlT ESTATE OF MINNIE M. VOGELSONG, BY DEED DATED SEPTEMBER 21, 1998 AND RECORDED SEPTEMBER 24, 1998 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 185, PAGE 972, GRANTED AND CONVEYED UNTO ANTHONY M. VOGFLSONG. TAXMAPNO.: 09-15-1291-030. The same having been sold by me to the said grantee on the 8th day of September Anno Domini Two Thousand and Ten (2010) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 7th of May Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 3288 at the suit of JPMorgan Chase Bank, National Association vs- Anthony M. Vogelsong In Witness Whereof, I have hereunto affixed my signature this 5th Anno Domini Two Thousand and Ten (2010) Commonwealth of Pennsylvania, ss. County of Cumberland day of November Before the undersigned, David D, Buell, Prothonotary of the Court of Commolr 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 ill order that Said. deed might be recorded. Witness my hand and seal of said Court, this 5 th day of November Anno Domini Two Thousand and Ten (21010) ,.. co 11 4r) onotarv ??4Ot1td????l " 0 f)do'1 4 1 hereby certify that the residence And Post Office address of the Within Grantee is 7255 Baymeadows Way Jacksonville, FI 32256 Richard W. Stewart Solicitor LIMN VERIFICATION _ hercbv :states that he- X l cE ?'?irSLD?l1j {Marie 1 tltld } of'.) Port 4an Chase Bank, National Association for Plaintiff in this matter, that her authorised to make this Ve.r;*ication, and that the statements made in the f weguing Civil Action in Ft, meat are true and co c t €c the hest of his1bzf?knowIedge, information and helie 'he undersigned understands that this staterne= in made srahject to the penalties of' 13 Pa. C S -49(14 relating to, pan-",mn fal>if cation to a??rl?t?:•itie ; IPI •lorgan Chase Bank, National Association ? f 19 13y: Lll-Cj -sl Name: itlae: Vice Pres,den! 0 2- 2 7- 2?i 2 Ke_urn to Phelan IIallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1440, One Penn Center Plaza Philadelphia, PA 19103 Attn: Eviction Department 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 Attorney for Plaintiff 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 n; Wi " T -1D T Allison F. Wells, Esq., Id. No. 309519 = 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 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 83921 „ 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Court of Common Pleas Plaintiff Civil Division VS. No. 2012-1337-CIVIL ANTHONY M. VOGELSONG Or occupants Defendant CUMBERLAND County PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with referen a to the above captioned matter. Lawrence T. Phelan, q., Id. No. 227 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 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 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 83921 Attorney for Plaintiff Date: April 2, 2012 PHS # 258049 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - d4=- Sherifft., r, L' T(Ul Jody S Smith 1 7 2 Chief Deputy Richard W Stewart CUM5EP%L.A1'Z COGS TYY Solicitor PENti5Y .ti'AMA JP Morgan Chase Bank Case Number vs. 2012-1337 Anthony M. Vogelsong SHERIFF'S RETURN OF SERVICE 04/09/2012 04:40 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2012 at 1640 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Anthony M. Vogelsong, by making known unto Adam Vogelsong, Brother of Defendant at 11 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $43.00 April 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF I of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION VS. No. 12-1337 Civil Term_ ANTHONY M. VOGELSONG OR OCCUPANTS 11 SOUTH ENOLA DRIVE ENOLA, PA 17025 Costs Attorney's $191,15 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)) ALLY FINANCIAL INC., f/k/a GMAC INC. being: (Premises as follows): 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025 (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. David D. Buell, Prothonotary, Common Pleas Court of Cumberland Coun , PA Date 5/16/12 (Seal) 2 of 2 No 12-1337 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION VS. ANTHONY M. VOGELSONG OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 194.25 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: ALLISON F. WELLS, ESQUIRE - ID#309519 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 1617 JFK Blvd., Suite 1400, One Penn Center Plaza 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 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs ANTHONY M. VOGELSONG Or occupants I 1 SOUTH ENOLA DRIVE ENOLA, PA 17025 Defendant COURT OF COMMON PLEAS CIVIL DIVISION No. 2012-1337-CIVIL CUMBERLAND County t.r ti ? sry a ??' ?- , 10*r _`AAA PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTION" Being Known as No. I 1 SOUTH ENOLA DRIVE DATE: a g sv pa a ao{ '.00 car- 10SAS It 14 Q? P ?, a s 2-a?5a?° iserr?el Id. No.109519 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP W"I 0f RGS J-ss jd ? I 176- 1111killill Bl-i 'Fax Parcel No. 09-1134,2P1AQP Know all Men by theso Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the Stat,, of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to rn-e in llat)d paid, do hereby grant and convey to J'PMorgan Chase Bank, National Association Writ No. 2009»3288 Civil Term JI'Morgan Chase Bank, National Association Vs Anthony M. Vogelsang ALI,'IHNF Cl; CrAIN TRACTOR PARCEL OT LAND SITUATF iN THE TOWNSHIP 1) EAST PENINSBORO, COUNTY OF CUMBERLAND, AND STATL OFf"ENNSYLVAN'11A BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BECY NNING AT A POINT ON 111h SOUTHWEST CORNER OIL PYNE STREET AND BRICK CHURCH (STATE) ROAD; THENCE SOUTHWARDLY ALONG TIME WES'TFRN SIDT? OF BRICK CHURCH ROAD, FTF1'Y 950) FEET TO A POiNT ON LINT, OF LOT NO, 18 ON THE HEREINAFTER ME'N'T'ION'ED PLAN Or LOTS AND ALSO BEING LANDS NOW OR LATE OF HERMAN A WAGGONER, THENCE WESTWARDLY ALONG SAME' AND TIIROUGIT THE CENTER OF A PARTITION WALT. AND BEYOND IN A LINE AT RIGAT ANGLES TO BRICK CHURCH ROAD, ONE HUNDRED ANT) TWFIti I'Y-I IV:r^ FEET TO A POINT ON THE EASTERN LINT: OF A SIXTEEN FEET WU)E ALLF' Y: THENCE NORTHWARDLY ALONG SAME FI11-Y FEET TO A POINT ON THE SOU'T'HERN LINE Or PYNB STREET; THENCE BASTWARDLY ALONG SAME IN A I.1N13 AT RIGHT ANGLES TO BRICK CHURCH ROAD ONE HUNDRED AND '1'W ENTY- FIVL FEET TO A POINT, THE PLACE OF BEGINNING TEEING LOTS NOS. 19 AND 20 ON PLAN OF MOLTZ'S ADDITION, R1 CORDFI) IN FI:E? OFFICE OF'T'HE. RECORDER OF DEEDS, CUMBERLAND COUNTY IN PLAN 1100K I PAGE 2. HAVING EItT?C I ED TTiI REON' THE NORTHERN HALF OF A TWO STORY D01. 1131-F DWELLING HOUSF, KNOWN AND NUMBERED AS NO. I I SOUTH 1:3NOLA DRIVE (FORMERLY NO. 11 BRICK CHURCH ROAD). HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND N-JMBERED AS I 1 SOUTH ENOLA DRIVE, ENOLA, PA, 17025, BRING THE SAME PREMISES WHICH MARLIN S, VOGELSONG, EAECUTOR OF THE ESTATE OF MINIM M. VOGELSONG, BY DEED DATED SEPTEMBER. 21, 1998 AND RECORDED SEPTEMBER 24, 1998 IN AND FOR C;UMBF.RLAND COI1NI'Y, PENNSYINANIA, IN DEED BOOK VOLUME 185, PAGE 972, GRANTED AND CONVEYED UNTO ANTHONY M, VOGFLSON0, 'CAXMAPNO.; 09-15-1291-030. Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff t.?f Qt?OT;{r, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs ANTHONY M. VOGELSONG Or occupants 11 SOUTH ENOLA DRIVE ENOLA, PA 17025 Defendant COURT OF COMMON PLEAS f ;, ` . !T RL AND COUNT°r` &yr.j? ????? CIVIL DIVISION No. 2012-1337-CIVIL CUMBERLAND County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of Plaintiff, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION and against the Defendant(s) ANTHONY M. VOGELSONG and Or occupants for possession of premises 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025 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 corre w ich is attached hereto. , sq., Id. No.309519 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Default Judgment entered as indicated above. DATE: GM,} ? I le . SO ? Q ck#I/89LP9 )z007sa`iD Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff VS ANTHONY M. VOGELSONG or Occupants Defendant TO: ANTHONY M. VOGELSONG or Occupants 11 SOUTH ENOLA DRIVE ENOLA, PA 17025 DATE OF NOTICE: May 1, 2012 Court of Common Pleas Civil Division No. 2012-1337-CIVIL 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) 249-316 By: Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP PHS # 258049 Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 HK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs ANTHONY M. VOGELSONG Or occupants 11 SOUTH ENOLA DRIVE ENOLA, PA 17025 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 2012-1337-CIVIL CUMBERLAND County VERIFICATION OF NON-MELITARY 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 Plaintiff is without information sufficient to determine whether 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 ANTHONY M. VOGELSONG and/or occupant(s) reside/s at 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025. (c) That Plaintiff is without information sufficient to determine whether defendant, or occupants, is/are over 18 years of age. _ This statement is made subject to penalties of 18 PA. C.S.S 4904 re authorities. Date: May 15, 2012 falsification to AllisonY-WeRs, Esq., Id. No.309519 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP PHS # 258049 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SKRIFF 13 PM 1: P17-N NSYL VANIA JP Morgan Chase Bank vs. Case Number Anthony M. Vogelsong 2012-1337 SHERIFF'S RETURN OF SERVICE 06/12/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Anthony M. Vogelsong, but was unable to locate the Defendant in ME bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 11 South Enola Drive, Enola, PA 17025. There were 13 attempts at service with negative results. A neighbor told one of the deputies that he has seen somebody coming and going out of the house late at night, but not staying there. Also, the electric has been shut off as of 06-11-12. SO ANSWERS, June 12, 2012 RON R ANDERSON, SHERIFF (c) CountySuite Shenff. Teleosoft, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 44L?ttr of + rug ,,r Ito - 3- l- THE PP,0T1i0N'-' 2012 JUN 29 PM 3: 34 %UM?? :: ? tVANI xhu COUNTY JP Morgan Chase Bank vs. Case Number Anthony M. Vogelsong 2012-1337 SHERIFF'S RETURN OF SERVICE 06/12/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Anthony M. Vogelsong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 11 South Enola Drive, Enola, PA 17025. There were 13 attempts at service with negative results. A neighbor told one of the deputies that he has seen somebody coming and going out of the house late at night, but not staying there. Also, the electric has been shut off as of 06-11-12. 06/29/2012 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: $112.92 SO ANSWERS, June 29, 2012 RON R ANDERSON, SHERIFF r s? zfr .2-S t, .i.irtv5u t aye-.*F tort WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION VS. No. 12-1337 Civil Term ANTHONY M. VOGELSONG OR OCCUPANTS 11 SOUTH ENOLA DRIVE ENOLA, PA 17025 Costs Attorney's $ 191.75 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)) ALLY FINANCIAL INC., f/k/a GMAC INC. being: (Premises as follows): 11 SOUTH ENOLA DRIVE, ENOLA, PA 17025 (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. David D. Buell, Prothonotary, P Common Pleas Court of Cumberland Cottqt Date 5/16/12 (Seal) TRUE-: COPY FROM -1 EC 'RD In Tentirnonywh~, I here unto set my hand and the seal of saW Cou at Carlisle, Pa. This _I tp day at 20 ro ftwtary ,? a. ;vim I*e 2 of 2 No 12-1337 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION vs. ANTHONY M. VOGELSONG OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 194.25 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: ALLISON F. WELLS, ESQUIRE - ID#309519 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 1617 JFK Blvd., Suite 1400, One Penn Center Plaza 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 So Answers, Sworn and subscribed to before me this Day of Sheriff By _ Prothonotary Deputy 314 Know all Men by these Presents 95,f•l6. 2, IIINAIIII 001 3BH 'Fax Parcel No. 09-15-1291-030 That 1, Ronny R. Anderson, Stwriff of the County of Cimiberland, 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 .IPMorgan Cbase Bank, National Association Writ No. 2009.32$8 Civil Term JPMorgan Chase Bank, National Association Vs Anthony M. Vogelsong ALL'1'HA:f CWtTAIN TRACT OR PARCEL OF LAND SITUATE iN THE TOWNS if E) OF EAST PENINSBORO, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVAN'I'A BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT A P01NT ON THE SOUTHWEST CORNER OF PYNE STREET AND BRICK CHURCH (STATE) ROAD; THENCE SOUTHWARDLY ALONG TIME WESTERN SIDE OF BRICK. CHURCH ROAD, FIFTY 950) FEET TO A POINT ON LINE OF LOT NO. 18 ON THE HEREINAFTER MENTIONED PLAN OF LOTS AND ALSO BRING LANDS NOW OR LATE OF HERMAN A WAGGONER, THENCE WLS-1'WAR.DLY ALONG SAME AND nIROUGH THE CENTER OF A PARTITION WALT. AND BEYOND IN A LINT: AT RIGHT ANGLES TO BRICK CHURCH ROAD, ONE HUNDRED AND TWE?ti T'Y-FIV E r13ET TO A POINT ON THE EASTERN LINE OF A SIXTEEN FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG SAME FIFTY FEET TO A POINT ON THE SOUTHERN LINE OF PYNE STREET; THENCE EASTWARDLY ALONG SAN4E IN A LINE AT RIGHT ANGLES TO BRICK CHURCH ROAD ONE HUNDRED AND TW ENf'Y- FIVE FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 19 AND 20 ON PLAN OF MOLTL'S ADDITION, RECORDFD 1N '1'1-113 OFFICE OF THE RECORDER. OF DEEDS, CUMBERLAND COUNTY IN PLAN 1300K 1 PAGE 2. HAVING ERECTED THEREON THE NORTHERN HALF OF A TWO STORY D01,131-F FRAME DWELLING HOUSE KNOWN AND NUMBER.1r1) AS NO. I 1 SOUTH ENOLA DRIVE (FORMERLY NO. 11 BRICK CHURCH ROAD). HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS I I SOUTH ENOLA DRIVE, ENOLA, PA, 17025. BEING THE SAME PREMISES WHICH MARLIN S, VOGELSONG, EXECUTOR OF TITS ESTA'T'E OF MINNTE M. VOGELSONG, BY DEED DATED SEPTEMBER 21, 1998 AN-D RECORDED SEP'TE-"vM dR 24, 1998 IN AND FOR. CUMBERLAND COUNIN, PENNSYLVANIA, IN DEED BOOK VOLUME 185, PAGE 972, GRANTED AND CONVEYED UNTO ANTHONY M, VOG)~LSONCi, TAXMAPNO.: 09-15-1291-030.