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Home My WebLink About12-6877Phelan Hallman & Schmieg, LLP By: Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 1100 VIRGINIA DRIVE, P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff v. MARY JANE GUISE or Occupants 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 Defendant Attorney for Plaintiff ~ o ~ 3 c~ ,v --i ~ :~ ~' "~ ~rn cn r'-' -tom ..... ~~ ~ ~ r--.... -:c~ w ---+ca z-~, . Court of Common Pleas ~" o ' a ~ ~; ~ ~ _ z Civil Division ~ ~; _~ CUMBERLAND County 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 dischazge 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 appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You aze wazned 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 fmd 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 Baz Association 32 South Bedford Street Cazlisle, PA 17013 (717) 249-3166 5 ~ 103.75 P~ ATr~ ~,rayv~a9~ ~~'a8a ~~5 PHS # 310250 1. Plaintiff is THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6. 2. Defendant is MARY JANE GUISE or Occupants. 3. Plaintiff is the record owner of premises located at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362, 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 09/05/2012, as evidenced by the Sheriffs deed recorded 10/29/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201233347. 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 and so faz 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. Allison lls, Esq., Id. No.309519 Attorney 'ntiff Phelan Hallinan & Schmieg, LLP LEGAL DESCRIPTION ALL THAT CERTAIN PEKE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA BEING KNOWN AND DESIGNATED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST), WHICH POINT IS THE LINE DIVIDING LOTS NO. 167 AND 168 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SAID LINE NORTH 85 DEGREES 40 MINUTES EAST, ONE HUNDRED T'VVENTY (120) FEET TO THE LANDS OF W.R. KEELEYAND AND ANN L. KEELEY; THENCE ALONG THE SAID LANDS SOUTH 10 DEGREES 28 MINUTES EAST, SEVENTY-TWO AND FIFTY-TWO ONE HUNDREDTHS (72.52) FEET TO A POINT ON THE DIVIDING LOT NO. 167 AND LOT N0.82, OF A PREVIOUS PLAN; THENCE ALONG THE SAID LINE SOUTH 72 DEGREES 04 MINUTES 19 SECONDS WEST, ONE HUNDRED TWENTY-FOUR AND NINETY-ONE ONE HUNDREDTH (124.91) FEET TO A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST); THENCE ALONG PAMELA'S LANE (EAST) IN A NORTHERLY DIRECTION ON A CURVE TO THE RIGHT HAVING A RADIUS OF 202.34 FEET, AN ARC DISTANCE OF FIFTY AND SEVENTY-EIGHT ONE-HUNDREDTHS (50.78) FEET TO A POINT THENCE CONTINUING ALONG THE SAME NORTH 04 DEGREES 20 MINUTES WEST, FIFTY- ONE AND TWENTY-TWO ONE-HUNDREDTHS (S 1.22) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 167, PLAN N0.9, OF THE VILLAGE OF WESTOVER, WHICH PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE ON PLAN BOOK 30, PAGE 83, HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 800 PAMELA'S LANE (EAST). TITLE TO SAID PREMISES VESTED IN EARL R GUISE AND MARY JANE GUISE, HIS WIFE, AS TENANTS BY THE ENTIRETIES AND EARL GUISE, II, JOINTLY HELD AS TENANTS IN COMMON WITH THE RIGHT OF SURVIVORSHIP to EARL R GUISE AND MARY JANE GUISE, HIS WIFE dated 1289/99, recorded I/10!2000 in book 214 and page 763. EARL R. GUISE was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of EARL R. GUISE's death on or about 04/08/2005, his ownership interest was automatically vested in the surviving tenant by the entirety, Jane Guise. PREMISES BEING: 800 PAMELAS LANE, MECAAIVICSBURG, PA 17050-2362 PARCEL NO.10-18-1323-041 M ~ VERIFICATION }.K,D ~~ rrr.~~ t.~ri ~S hereby states that he/she is ~~D'~1L~,Q d ~'C t C P~ (name)(1 ~ '~ ~ (Title) of ~~~ ~! (.D ~~'+aG ~-~' servicing agent for THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6, 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. Signature DATE: ~ I '~ g~ 12-- PHS # 310250 Return to: Phelan, Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~tr o~ ~ ~„nt~rr~~~ ~. ~~°~ =~~ ~~ ~ ~ ~~~ 2 ~ ~~ ~`~ ~ ~J ~i GUMBERLAH~ ~~~~'~` PEMNSYLVAi'dIA The Bank Of New York Mellon Trust Company, National Association f/k!a Case Number vs. Mary Jane Guise 2012-6877 SHERIFF'S RETURN OF SERVICE 11/15/2012 05:25 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Mary Jane Guise at 800 Pamelas Lane, Hampden Township, Mechanicsburg, PA 17050. RYANl~~DEP~c U G , SHERIFF COST: $38.00 November 16, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF c; ~ ouniySude S!?eri!{, ~I~e;ecsofl. I^,c. ` SHERIFF'S OFFICE OF CUMBERLAND COUNTY ry R Anderson ariff xx F �,{Z"4l 1A 4 �xltjtg ff -' Jody S Smith 'i► 'E++,;;: Chief Deputy Richard W Stewart !f l � i `6 P 2 F J` Solicitor t : fs� f ' / " , � The Bank Of New York Mellon Trust Company, National Association f/k/a Case Number vs. Mary Jane Guise 2412-6877 SHERIFF'S RETURN OF SERVICE 01/10/2013 04:09 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Mary Jane Guise at 800 Pamelas Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland County, informed Defendant of contents of same. 01/11/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant of 800 Pamelas Lane, Hampden Township, Mechanicsburg, PA 17050, but was unable to locate the Defendant in his bailiwick. The only resident of 800 Pamelas Lane, Hampden Township, Mechanicsburg, PA 17050 is defendant Mary Jane Guise. The Sheriff therefore returns the within requested Writ of Possession as"Not Found"as to the occupant. 03/20/2013 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 800 Pamelas Lane, Mechanicsburg, PA 17050-2362, SHERIFF COST $97.62 SO ANSWERS, March 26, 2013 RbNW R ANDERSON, SHERIFF -_,f