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Home My WebLink About01-4880THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen J. DiPaolo, Esquire / I.D. No. 79992 Suite 100, 425 Commerce Drive Fort Washington, PA 19034 (215) 653-7450 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, MICHAEL L. HILLIARD, MICHELLE L. HILLIARD and OCCUPANTS OF 16 Hill Street, Mt. Holly Spring, PA 17065, Defendants. COURT OF COMMON PLEAS CUMBERLkND COUNTY CIVIL ACTION EJECTMENT NOTIC~ YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU 5~3ST TAKE ACTION WITHIN TWENTY (20} DAYS AFTER THIS COMPLAINT AND NOTICE kRE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSON~tLLY OR BY ATTORNEY A~D FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED T~LAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU A~D A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR A-NY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGKTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR i~WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAArNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CA~ GET LEGAL HELP. CAlmberland County Court Administrator 4th Floor Cu~berland County Court House 1 Courthouse Sq,/are Carlisle, PA 17013 (717) 240-6200 NOTICIA LE ~LAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO A PARTIR DE LA FECMA DE LA DEMAb!DA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOG~DO Y ARCHIVAR EN LA CORTE SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOM~ MEDIDAS Y PUEDE ENTR~ UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION 0 POR CJALQIER QUEJA O ;ALIVIO QUR ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES O OTROS DERECHOS IMPORTA~TES P~RA USTED. LLEVE ESTA DEM~A A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE P/~LA PAGAR TAL SERVICIO, VAYA EN PERSONA O Li~ME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ASAJO PARA A%~RIGUAR DO,DE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Court Administrator 4th Floor Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240 6200 CIVIL ACTION -- EJECTMENT 1. The Plaintiff, Federal National Mortgage Association, is a corporation organized and existing under the laws of The United States of American and the Commonwealth of Pennsylvania, and having its principal place of business at 1900 Market Street, Suite 800, Philadelphia, PA 19103. 2. (a) The Defendant, Michael L. Hilliard is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 16 Hill Street, within the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as the "Premises". (b) The Defendant, Michelle L. Hilliard is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 16 Hill Street, within the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as the "Premises". (c) The Defendant Unknown Occupants are individuals whom Plaintiff believes and therefore avers are residing at the Premises. 3. The Premises which are described at Exhibit "A" attached hereto and incorporated herein by reference, were sold at the Cumberland County Sheriff's Sale conducted on March 7, 2001, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment entered in the Court of Common Pleas for Cumberland County at the suit of PNC Bank, N.A. v. Michael L. Hilliard and Michelle L. Hilliard, as Court Docket Number 98-6140. 4. The Premises were purchased by the Plaintiff at the Sheriff's Sale, said sale results being a matter of public record. 5. The Plaintiff acquired title to the Premises on the date of and by virtue of said Sheriff's Sale, and is the real and current entitled owner of said Premises by virtue of a Cumberland County Sheriff's Deed Poll recorded in the Cumberland County Recorder of Deeds' Office on June 22, 2001 at Deed Book 247, Page 399 . 6. The persons in possession of the Premises are believed to be the Defendants in this action and are occupying the Premises without right and without claim to title. 7. The Defendants herein named were duly served with Notices of the Sheriff's Sale held on March 7, 2001. 8. Plaintiff has demanded possession of the Premises from the Defendants who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff, Federal National Mortgage Association, respectfully requests entry of judgment for immediate possession of the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. Respectfully Submitted, THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Barbara A. Fein, Esqu~e Attorney for Plaintiff Attorney I.D. No. 53002 - rmow all Men by these Presents That[ R. Thomas Kline Cum~fl~d ~ ~e$~ ofPe.my~a~ ~rm.nd ~ cnndd~ra~onotflm~um~ One ....... ~me~ ~y~t~n~ Pederal National Mortgage Association ~1 C~O , dolJan, REAL ESTATE SALE No. 32. Wdt No. 1998-6140 Civil Term PNC Bank, N,A. ¥$ Michael L.. Hilllard and Michelle L, Hilliard Arty: Frank Federman DESCR]Ft3ON ALL THAT CERTAIN r~ct o~' land with improvements thereon emoted $ituam in the Borough of Moant Holly Springs, Cumberland County, penn~Ivania, bounded mid d~l~cribed ~.¢, fOllOw.q: ON thc South by thc W~.~t by land now ~ fomlerly of TheOdore A. Tiehy and Annie Tichy.and Annie ~ Ticby, his wife; on the Noah by an alley and on the East by land now or formerly of - AJ*chia Murray and Anne Murray. his wife: having a frontage of (40) feel on Hill Street and e~mnding One Hundred Fifty-three (153) feat |a depth to the alley on the North. BEING all of Lot No. 8 of the Arthur R. Rupley Plan of'Late as recorded in thc Office o~ thc Recorder of Dccd$ for Cumbcrland County in Deed Book "Z", V~lumc 5, l~g~ 600. HAVIlgG thereon erected a single two story tYame and aluminam dwelling and said {/mmises being known and nambered as 16 Hill Street, Mount Holly Springs, Penn- ~ylvanla 17065, TAX PARCEL $~23-32-2336-353. TITLE TO SA[E) PREMISES 15 VESTED IN Michael L. l-lilllard and Michelin L Hilli~d, huaband and wife by Deed from Lucinda lC Hoffalan. single woman, dated 6/10/94, recorded 6/13/9~-, in Deed Book 106 page 955. 6th and one of Exe~mion issued on thc the same having been sold by me to the said grantee on the day o1" ..Tur~e Aono Domini two thousand ( 20 0 ,].. ) after duc advertJs~'ment according to law, under and by ~,irtue of a writ 13 th day of December Cumberland Counl~ Pcnnsylvania; ~ of Nine Hundrea (1998) Ninety-Eight X~ ) Anno Domini 20 0 0 out of the court of Common Pleas of Number s~ 1 ~. {3 , at the suit of again$1 Michael L. Hilliard and Miche~lP r,. ~l]_~a.~a VERIFICATION BARBARA A. FEIN, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Affidavit, and that the statements made in the foregoing Civil Action Complaint in Ejectment are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: August 15, 2001 THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Barbara A. Fein, Esqu~e Attorney for Plaintiff Attorney I.D. No. 53002 THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen J. DiPaolo, Esquire / I.D. No. 79992 Suite 100,425 Commerce Drive Fort Washington, PA 19034 (215) 653-7450 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, MICHAEL L. HILLIARD, MICHELLE L. HILLIARD and OCCUPANTS OF 16 Hill Street, Mt. Holly Spring, PA 17065, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 01-4880 PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARy: Kindly mark the above referenced matter settled, and ended without prejudice to Plaintiff. discontinued Dated: September 17, 2001 THE LAW OFFICES OF BARBARAJ FEIN, Barbara A. Fein, Esquire Attorney for Plain~ff Attorney I.D. No. ~002