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Home My WebLink About12-4817Phelan Hallinan & Schmieg, LLP By: Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Federal Home Loan Mortgage Corporation 8200 Jones Branch Dr., Mailstop 202 McLean, VA 22102 Plaintiff V. NAHEED A. SAMAD or Occupants 316 SHERMAN AVENUE CARLISLE, PA 17013-1680 Defendant Attorney for Plaintiff "pRGTHONOTA ? ? 2012 AUG -2 Am 10: 26 Court of Common PletUMBERL AND COUNT'y Civil Division PENNS?(LVp?NiA CUMBERLAND ?CoF(', No. /? - (/J Y/ 7 / (i 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 # 302380 CvJ CM}'* Io3.7S?,d alb, ct? /a?yySB ? ti• 0 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is NAHEED A. SAMAD or Occupants. Plaintiff is the record owner of premises located at 316 SHERMAN AVENUE, CARLISLE, PA 17013- 1680, 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 06/06/2012, as evidenced by the Sheriffs deed recorded 07/17/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201221278. 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. Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Legal Description ALL that certain piece, parcel, or lot of land situate between Abrams Avenue and Sherman Avenue in North Middleton Township, Cumberland County, Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the western right-of-way line of Sherman Avenue at the southeast corner of Lot 11; thence along said right-of-way line S 35 degrees 26 minutes 41 seconds E a distance of 46.00 feet to a point at the northeast corner of Lot 13; thence along said lot S 54 degrees 33 minutes 19 seconds W a distance of 153.26 feet to a point on the eastern right-of-way line of Abrams Avenue; thence along said right-of-way line N 23 degrees 10 minutes 00 second W a distance of 47.08 feet to a point at the southwest corner of Lot 11; thence along said lot N 54 degrees 33 minutes 19 seconds E a distance of 143.25 feet to a point, the point of BEGINNING. CONTAINING 6,820 square feet and being Lot 12 of Keystone Arms. BEING PART OF THE SAME PREMISES which Dickinson College, a nonprofit corporation, by deed dated September 17, 2004 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Book 265, Page 2860, granted and conveyed unto Keystone Arms Associates, LLC, a Pennsylvania limited liability company, its successors and assigns, as a straw party. ALSO BEING the same premises identified as Unit 12 in the Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ('Declaration'). Premises: 316 SHERMAN AVENUE #6 • VERIFICATION ELIZABETH TAYLOR-COUNTS hereby states that he/she is ASSISTANT TREASURER (name) Critle) of FEDERAL HOME LOAN MORTGAGE CORPORATION Plaintiff in this matter, that he/she is authorized to make this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 'Pro I -Jr PHS # 302380 Return to: Phelan, Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department qA '."') Signature Elizabeth Taylor-Counts Assistant Treasurer PHS # 302380 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson . ;, -~ ~-~y ~- ~~•~. ~ ; Sheriff ~~~~. i'~~f~~~Q~A+t~ Jody S Smith ~~`~~~~~ ci ~a+nb~~.~~~ Chief Deputy ~. °'~~~: ~ ~~~~ ~~~ ~ ~ ~~ $~ ~~ ,~~ Richard W Stewart ~F, ~ ° -.+', ~~R~~~(a ~~~Y, Solicitor crF~cr ~F -, ~ .,~R~FF C~ENNSYI.VA~A '', Federal Home Loan Mortgage Corporation Case Numbe vs. Naheed A. Samad 2012-4817 SHERIFF'S RETURN OF SERVICE 08/13/2012 09:24 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 1 , 2012 at 2124 hours, he served a true copy of the within Complaint in Ejectment, upon the within name defendant, to wit: Naheed A. Samad, by making known unto Farkhanda Ghafoori, Daughter of Naheed A. Samad at 316 Sherman Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and a the same time handing to her personally the said true and correct copy of the same. DENNI'.g FRY, SHERIFF COST: $34.00 August 14, 2012 SO ANSWERS, RONNY R ANDERSON, SHERIFF jc) Coun;ySuite Sheriff, Teleosoft, In. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,~derson :-ttattiskr/ e~~ Cti~ 1 ft~ f~f\~ i iT~~v~~«~~~';~ J Smith ~ef Deputy ~~Z OC 23 AM 9~ p3 Richard W Stewart so~rcitor CUM~£RLANU COUNTY PENNSYLVANIA Federal Home Loan Mortgage Corporation Case Number vs. Naheed A. Samad 2012-4817 SHERIFF'S RETURN OF SERVICE 09/21/2012 05:32 PM -Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2012 at 1730 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Naheed A. Samad or Occupants, by making known unto Shedil Sohd, adult in charge, at 316 Sherman Avenue, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him/her personally the said true and correct copy of the same. 10122!2012 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 316 Sherman Avenue, Carlisle, PA 17013. SHERIFF COST: $84.81 October 23, 2012 SO ANSWERS, RON ~ R ANDERSON, SHERIFF ~•dS' ~~,~'~ . ~" a8,~ ~