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Home My WebLink About12-6163Phelan Hallman & Schmieg, LLP By: Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 14011 Qne Penn. Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff v. RODNEY E. YOUNG or Occupants 783 LONGS GAP ROAD CARLISLE, PA 17013-8556 Defendant Attorney for Plaintiff c-~ ~ -.a c~ +:< .,.; Court of Common Pleas - xrn wZ "~ ~ ""~ ~ -~ r"1 Civil Division ter- ~ ao~_-, -G ~'' tv CUMBERLAND Coun Cp ~ -~,~ t '~ tv CIVYL ACTION -EJECTMENT **This firm is a debt collector attempting to collect a debt and arty information obtained will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not rea#ffirrrted, 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 procoed 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. Yoa s~nkl trite this paper to your lawyer at once. If you ds ast have a bwyer or cannot afford sue, go to or tekphsae the office set forth beiw to And oat where you can get legal help. I! yon caauet afford to hire s lawyer, this otllce aEay be abk to provide you with is#ormstion abeat agencies that may offer legal service to eligible persons at a redaced fee or no fee. Cumberland County Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 PHS # 310253 Q 6~,,~ ~,d Q~l c.~.~ ia3u~a8 ~2~ ;181 ~tl~"1 Plaintiff is WELLS FARGO BANK, N.A.. 2. Defendant is RODNEY E. YOUNG or Occupants. 3. Plaintiff is the record owner of premises located at 783 LONGS GAP ROAD, CARLISLE, PA 17013-8556, 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 07/11/2012, as evidenced by the Sheriffs deed recardcd 09/10/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201227468, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 5. 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 anti 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 fob. Cusick, Esq., Id. No.80193 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP E~~HIIT "A" PHS # 310253 a~a~~ C.~ Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Perin ylvania, for and in consideration of the sum of S 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to WeUa Fargo Bank, N.A. Wrtt No. 2011-2338 Civtl Ttrm Wells Fargo Bank, N.A. Vs Rodney E. Young ALL THAT CERTAIN lot or piece of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Thomas A. Neff, Registered Surveyor dated December 20, 1973, as follows: BEGINNING at a point in the center line of Long's Gap Road, Pennsylvania, Legislative Route No. 21072, said point being 120 fcet south of the southern line of Hillcrest Avenue; thence extending along land of Wayne Coleman, being Lot No. 12 on the hereinafter mentioned plan of lots North 72 degrees 30 minutes East 160 feet to a point by line of land of Robert Carpenter; thence along said land South 17 degrees 30 minutes East 60 feet to a comer of land of James Eberly; thence along said land being No. 14 on said plan, South 72 degrees 30 minutes West 160 feet to a point in the center line of Long's Gap Road aforesaid; thence along said center line North 17 degrees 30 minutes West 60 feet to the point and place of BEGINNING. BEING Lot No. 13 on a Plan of Lots laid out by Amos D. Keck which said plan is recorded in Plan Book 4, Page 52, Cumberland County Records. HAVING thereon erected aone-story frame dwelling. TITLE TO SAID PREMISES IS VESTED IN Rodney E. Young, a married ma15, by Deed from Richard L. Burkholder, a single individual, dated 04117/2009, recorded 04/29/2009 in Instrument Number 200913627. PREMISES BEING: 783 LONGS GAP ROAD, CARLISLE, PA 17013-8556 L Tax Parcel No. 29-15-1247-D09 ~,~ PARCEL N0.29-15-1247-009 The same having been sold by me to the said grantee on the 11th day of July Arno Domini Two Thousand and Twelve (2012) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 1st of December Anno Domini 2011 out of the Court of Conunon Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eleven (2011) Number 2338 at the suit of Wells Fargo Bank, N.A. -vs- Rodney E. Young in Witness Whereof, I have hereunto affixed my signature this Anno Domini Two Thousand and Twelve (2012} Commonwealth of Pennsylvania, ss. County of Cumberland 30th day of Augus t Before the undersigned, David D. Buell, Prothonotary of the Court of Common 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 in order that Said deed might be recorded. Witness my hand and seal of said Court, this 30th day of August Anno Domini Two Thousand and Twelve (2012) ~- 'Q , +~ ~' ~ " `~ t .i '. ~c'~ ' , .,r .fib . ~1, ~,,~ ~ ~ A,~ ••..... :~ ,, ,~ ~a..-~M.w.~-.~r..~. I hereby certify that the residence And Post Office address of the Within Grantee is 3476 Stateview Boulevard Fort Mill, SC 29715 ~~~ _____ :Ric W. Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CLTNIBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240.6370 Inatrameat Nnisber - 201227468 Recorded Oa 9/10/2012 At 9:17:02 AM * Inatra~ett Type -DEED-SHERIFF'S Invoice Ntmber -116845 User ID - JM * Grauttor -YOUNG, ROHNEY E * Graiatee -WELLS FARGO BK N A * Cnsto~ter -CUMBERLAND COUNTY SHERIFF * ~S STA'PS 'iiRIT TAY $0.50 STATL JCS/ACCESS TO $23.50 JUSTICE REtDIN6 FEZS - $12.50 RECORDER OF DEiDB PARCEL CERTIFICATION $10.00 FEES AFFOLE HOUSIliCi $11.50 COUNTY ]1RCHIVEB FEE $2.00 ROD ARCHIVES FEE $3.00 CARLISLE ARE71 SCHOOL $0.00 DISTRICT NOR'7.'H D[IDDLETORQ TOWNSH IP $0.00 TOTAL PAID $63.00 I Certify this to be recorded is Cumberland County PA * TotAi Pa~ea - S Certification Page DO NOT DETACH This pine is now part of this legal dae~tent. " - Ioformatbo deaebd by as arterbk may chaaSe ~urhy the verifleadon proceM and e~ay not be roMetrd oa the page. ii i VERIFICATION I hereby state that I am 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 Plaintiff s predecessor. in interest in the underlying foreclosure action. I am with the law f rm 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. T'he undersigned understands that this statement Pa.C.S. §4904 relating to orn falsification to ~b~,11 Date to the penalties of 18 R rt W. C Esq., Id. No.89i93 Attorn or Ptaintiff Phetan Hallinan & Schmieg, LLP PHS # 310253 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~, Ronny R Anderson ~~t ~ r~ ~-~ Sheriff f '~ . ,~,~,, ~ ~::,kiat¢ry,~ '~ ~'Rp~-~~~~,. Jody S Smith "'~~~~~ ~~~' ~Q~~~~ ~r~;~~~~ Chief Deputy L'U r ~3 P~ 2. Richard W Stewart MBfRL Solicitor ~~NN~ YL AN U~~Y ~A Wells Fargo Bank, N.A. Case Number vs. Rodney E. Young 2012-6163 SHERIFF'S RETURN OF SERVICE 10/11/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rodney E. Young, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Rodney E. Young. Request for service at 783 Longs Gap Road, Carlisle, Pennsylvania 17013 is vacant. SHERIFF COST $39.00 SO ANSWERS, r"1` , October 11, 2012 RONI~IY R ANDERSON, SHERIFF