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Home My WebLink About12-4818r r?,-- Phelan 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. MARK A. HANAWAY or Occupants 349 CARLISLE ROAD NEWVILLE, PA 17241-9545 Defendant Attorney for Plaintiff C. M w MOP r- = fT1 r . Court of Common Pleas Nr Q Civil Division D rrZ <'d N aW -Y` p" C-) =C c:) i = Z.., CUMBERLAND Coun C o ---4n; No. d n-4 I' 8th 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 # 302382 ors C? ?a ?N 7 u a'78?& 3 %. 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is MARK A. HANAWAY or Occupants. Plaintiff is the record owner of premises located at 349 CARLISLE ROAD, NEWVILLE, PA 17241-9545, 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 07/16/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201221090. 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. 6. 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. issa J. , sq., Id. No.308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Legal Description ALL THAT certain three tracts of land situate in the Township of West Pennsboro, Cumberland County, Pennsylvania, bounded and described as follows: TRACT NO. 1 BEGINNING at a point in the center of the concrete road, (Rte. 641); thence by lands now or formerly of Wayne Anthony and Mary Ellen Anthony, North 56 1/4 degrees, West 200 feet to an iron pin; thence along other lands now or formerly of J. Melvin and Mildred D. Bard, his wife, and parallel to the aforesaid public road, South 49 degrees, West 100 feet to an iron pin; thence by same South 56 1/4 degrees, East 200 feet to the center of the aforesaid concrete road; thence by the aforesaid concrete road, North 49 degrees, East 100 feet to the place of BEGINNING. CONTAINING approximately 1/2 acres. TRACT NO. 2 BEGINNING at point in Route No. 641 at the corner of lands now or formerly of Wayne and Mary Ellen Anthony and now or formerly of Glenn L. Anthony; thence in said road South 56 degrees 15 minutes West 65.22 feet to a point; thence by other lands now or formerly of the said Wayne and Mary Ellen Anthony, North 37 degrees 15 minutes 20 seconds West 185.12 feet to an iron pin, said line passing through an iron situate 13.27 feet from said point in Route No. 641; thence by lands now or formerly of the said Wayne and Mary Ellen Anthony, South 56 degrees 15 minutes East 200 feet to a point in Route No. 641. CONTAINING 0.138 acres and being described according to a survey of John C. Brilhart, R.S., dated September 17, 1966. TRACT NO. 3 BEGINNING at a point in the center of the Newville-Carlisle Road, (Pa. Route #641), at a common corner of lands now or formerly Wayne and Mary Ellen Anthony and land now or formerly of Lester E. Funk and wife; thence along lands now or formerly of Wayne and Mary Ellen Anthony, North 50 degrees 41 minutes West 200 feet to a point at lands now or formerly of J. Melvin Bard and wife; thence along lands now or formerly of J. Melvin Bard and wife, North 62 degrees 28 minutes East 60 feet to a stake at lands now or formerly of Lester E. Funk and wife; thence along lands now or formerly of Lester E. Funk and wife, South 33 degrees 19 minutes East 184.83 feet to the place of BEGINNING. CONTAINING .126 acres. Premises: 349 CARLISLE ROAD ,. VERIFICATION ELIZABETH TAYLOR-COUNTS hereby states that he/she is ASSISTANT TREASURER (name) (Title) 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 unswom falsification to authorities. DATE: V I L-)" I , I CJ PHS # 302382 Return to: Phelan, Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department Elizabeth Taylor-Counts Assistant Teeasurer PHS # 302382 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOiiCltOr Federal Home Loan Mortgage Corporation vs. Mark A. Hanaway ~a~~t~v at ~~r~t~6rrf~~~ ~ ,k G ? t-.e" y ~ ~ ~'``~` ,,r. a~~~;v-~ ~ -, .. ~~ s~~Rf~~ SHERIFF'S RETURN OF SERVICE Case Number 2012-4818 08/08/2012 02:22 PM -John Hanner, Deputy Sheriff, who being duly sworn according to law, states that on August 8, 2012 at 1422 hours, he served a true copy of the within Complaint in Ejectment, upon the within name defendant, to wit: Mark A. Hanaway, by making known unto himself personally, at 349 Carlisle Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. DEPUTY SHERIFF COST: $40.00 August 10, 2012 jc? CounrySuife F,herifl~.. Telecsoft, 1n. ~_ i ~' ..i~ i ft~~~~ ~, I n ~~~ f{[J t7 ~ ~ ~l~ EL.t' SO ANSWERS, RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ` Richard W Stewart Solicitor T ° -RJE z Federal Home Loan Mortgage Corporation Case Number vs. Mark A. Hanaway 2012-4818 SHERIFF'S RETURN OF SERVICE 09/19/2012 01:55 PM - Property was found to be vacant. Per post office, defendant has a post office box for an address. 10/11/2012 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: $58.39 SO ANSWERS, K?z az- October 11, 2012 RON R ANDERSON, SHERIFF rr1w, :r rn CD C-> -:Z1 --1 -a ` . r--.. _?. r-- *aa5 PO sH?? e# 8e5coa eoa818g9 ee She^ii. Te ersoit. Im.