HomeMy WebLinkAbout12-6945SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411
The Bank of New York Mellon, f/k/a The
Bank of New York as successor to
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF
vs.
Johnnie L. Gillon and Erika M. Nelson and
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
_. ~~ -~
-~ I
!r
. ._ ~
~,
I~ .,.
• ,.
~~ ~~,,
:.J l P'S i-W r 1 1
COURT OF COMMON PLEAS
CUMBERLAND COUNTY ~ . I
No.: ~ ~ _ l~~ ~-I S v ~
CIVIL ACTION EJECTMENT 21000
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH. TO DEFEND AGAINST "CHE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN
TWENTY (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 ANY 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.
a~--} ~!u3.~S~ d ~~
C.k..~ ~ ~o0 3~ (~ ~
~~~ o~s'3a S8
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
NOTICIA
LE HAN DEMANDADO A LISTED EN LA CORTE. SI US"TED
QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS
SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA
DE LADEMANDA Y LA NOTIFICACION. LISTED DEBE PRESENTAR UNA
APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA
CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS
ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI LISTED NO SE DEFIENDE,LA
CORTE TOMARA MEDIDAS Y PtIEDE ENTRAR UNA ORDEN CONTRA LISTED
SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUF,
ESPEDIDO EN LA PETICION DE DEMANDA. LISTED PUEDE PERDER DINERO OSUS
PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA LISTED.
LLEVE ESTA DEMANDA A UN ABODAGO I:NMEDIATAMENTE. SI NO
TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARR AVERIGiJAR DONDE SE
PUEDECONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY LD. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411
The Bank of New York Mellon, f/k,~a The COURT OF COMMON PLEAS
Bank of New York as successor to ~ CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular ; NO,:
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF
vs.
Johnnie L. Gillon, Erika M. Nelson and
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
;
;
CIVIL ACTION EJECTMENT
Plaintiff hereby complains against Defendants as follows:
Plaintiff, The Bank of New York Mellon, f/k/a The Bank of New York as
successor to JPMorgan Chase Bank, as Trustee for the Benefit of the Certificateholders of
Popular ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-4 ("Plaintiff'), a
corporation, has an office located at c/o Ocwen Loan Servicing, LLC, 1661 Worthington Road,
West Palm. Beach, FL 33409, and is properly conducting business in the Commonwealth ol~
Pennsylvania.
2. Defendants are Johnnie L. Gillon and Erika M. Nelson and Occupants
("Defendants") and they reside at 318 East North Street, Carlisle, PA 17013 ("the Premises")
3. The Premises, which is where the ejectment is to take :place, is located at 3 18 East
North Street, Carlisle, PA 17013. A true and correct copy of the legal description of the
Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A."
4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County,
Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of
Execution issued to satisfy a Judgment In Mortgage Foreclosure entered in the Court of Common
Pleas of Cumberland County, Pennsylvania, at the suit of: The Bank of New York Mellon, f/k/a
The Bank of New York as successor to JPMorgan Chase Bank, as Trustee for the Benefit of the
Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-4 v.
Johnnie L. Gillon and Erika M. Nelson.
5. The case number of said Judgment is: 2010-2237.
6. The sale was held on: July 11, 2012.
7. Plaintiff purchased the Premises at the Sheriffs sale.
8. The Plaintiff acquired. valid title to the Premises on the date of and by virtue of
said Sheriffs sale.
9. Plaintiff is still the real owner of said Premises and is entitled to immediate
possession of the Premises.
10. The Deed in favor The Bank of New York Mellon, f/k/a The Bank of New York
as successor to JPMorgan Chase Bank, as Trustee for the Benefit of the Certificateholders of
Popular ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-4 was recorded with the
Cumberland County Department of Records as Document ID# 201226380, on August 28, 2012.
11. Said Deed is a matter of State public record and therefore, is hereby incorporated
by reference herein as if fully set forth at length. A true and correct copy of the Sheriff s Deed,
is attached hereto, incorporated herein by reference, and marked as Exhibit "B."
I2. The persons in possession of the Premises are believed to be the Defendants in
this action who are occupying the Premises without right and without claim to title.
13. Plaintiff is entitled to immediate possession of the Premises.
WHEREFORE, Plaintiffdemands judgment, in ejectment, 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,
SHAPIRO & DeNARDO, LLC
Date: ~ I ~ BY: ~~
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
VERIFICATION
The undersigned, an authorized representative of Plaintiffs servicing agent, Ocwen Loan
Servicing, LLC ("Ocwen"), is authorized to make this verification on behalf of Plaintiff and
hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best
of their knowledge; information and belief. Except where otherwise stated and/or based upon
public record, this verification is based upon a review of business records regularly created, kept
and maintained in the course of Ocwen's mortgage servicing business conducted on Plaintiff s
behalf.
I understand that false statements herein are made subject to the penalties of 18 PA.C.S
SECTION 4904 relating to unsworn falsification to a thorities.
DATE: ( ~
NA E:
TITLE: Contract Me~nager
Ocwen Loan Servicing, LLC as attorney-in-fact for
Plaintiff
~~
ALL THAT CERTAIN tract of ground situate in the Borough of Carlisle, County of
Cumberland and State of Pennsylvania, bounded and described as follows:
ON the North by East North Street; on the East by property now or formerly known of
Bryon H. Kitch; on the South by a sixteen (16) foot alley; and on the West by property
now or formerly of Harry B. Ruhl and wife; containing eighteen feet six inches (18'6")
more or less, in front on East North Street and extending in depth at an even width one
hundred twenty (120) feet, more or less, to said alley on the South; the eastern boundary
line being the center of the division wall between the house erected on this lot of ground
and the house on the lot of ground adjoining on the East.
THE above described tract of land has thereon erected the Western half of a double three-
story pressed brick dwelling house known as 318 East North Street.
BEING KNOWN AS: 318 East North Street Carlisle, PA 17013
PROPERTY ID NO.: 02-21-0318-139
,l , .L I'4~IRIIIIA
Tax Parcel No. 02-21-0318-139
Know all Men by these :Presents
That I, Ronny R. Andersoi.~, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for anal in consideration of the sum of $ ].00 (One Dollar), io me in hand
paid, do hereby grant and convey to The Bank of New York Mellon, i7k/a "I'he Bank of
New York as successor in interest to JPMORGAN Chase Bank, N.A., as Trustee for the Benefit
Oi'the Certiticateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-4
Writ No. 2010-2237 Civil Term
The Bank of New York Mellon, f/k/a The Bank of New York as successor to JPMORGAN Chase Bank, as
"Crastee for the Benefit Of the Certiflcateholders of .Popular ABS, Inc. Mortgage Pass/Through Certificates,
Series 2004-4
-vs-
Johnnie L. Gllfon
Erika M, Nelson
ALL. THAT CIR"1 ~qIN 'f I'tAC'T OF GROUND SITUATE 1N THE BOROUGH OF CARLISLE, COUN'T'Y OF
CUMBERLAND AND STATE OF PENNSYLVANIA, I30LNDED AND DESCRII3E.U AS FOLLOWS:
ON THE NORTI-I BY EAS"C NORTH STREET; ON TIIE F.,AST BY PROPER'I"Y Iv'OW OR FC)RMF.RLY OF
BRYON Ii. KITCI~I; ON TILE SOU"1'H BY A SIXTI?EN (.16} FOOT ALLEY: AND ON THE WEST BY
PROPERTY' NOW OR FORMERLY OF HARRI' B. RUHLANDWIFE; CONTAINING EIGHTEEN .FEET SIX
INCHES ('i 8' 6") MORE OR LESS, IN FRONT ON EAST NORTH S'T'REET AND EXTENDING .IN DEPTH A'T
AN EVEN WIDTH ONE HUNDRED TWEN"I'Y (120) FEET, MORE OR LESS, TO SAID AI.,LEY ON THE
SOt1TH; THE EASTERN BOUNDARY LINE BEING TIIE CENTER OF THE DIVISION WAIL. BETWEEN
THE HOUSE EREC"I'ED ON THIS LOT OF GI20UND AND TIIE HOUSE ON THE LOT OF GROUND
AD.TOINING ON TI-IE EAST.
THE P.I30VF. DESCRIBED 'T'RACT OF LAND I[AS T'HER_L;ON ERECTED .THE WESTERN HALF OF A
DOUBLE THREE-STORY PRESSED BRICK DWELLING HOUSE KNOWN AS 318 EAST NORTH STREET.
BEING KNOWN AS: 318 East North Street
Carlisle, PA 17013
PROPERTY ID NO.: 02-21-0318-139
TITLE TO SAID PREMISES IS VESTED ITV` JOHNNIE L. CiILLON, A SINGLE MAN AND ERKA iVt.
NELSON, A SINGLE WOMAN, AS JOINT TENANTS WI'T'H THE 12IC~HT OF SURVIVORSHIP, NOT AS
I"E.NAN'1"S IN COMMON BY DEED FROM ROGER J. PERSIK AND CAROLY?V A. PERSIK, HUSBAND AND
WIFE DATED 06/10/2004 RECORDED 06/17/2004 IN DEED BOOK 263 PAGE 302.7
~h;bik "g"
The same having been sold by me to the said grantee on the 11th day of July
Anno Domini `l'wo Thousand and Twelve (2012) after due advertisement according to
law, under and. by Virtue of a Writ of Execution issued on the 2~th of February Anno
Domini. 2Q12 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Tez-m, Two Thousand and Ten (201.0) Number 2237 at the suit o.f
The Bank of New York Melton, t7k/a T'he Bank of New York as successor to JPMOI2GAN Chase Bank, as
Trustee for the Benefit Of the Certificateholders of Popular ABS, Inc. Mortgage Pass/T'hrough Certificates,
Ser.~s 2004-4 -vs-Johnnie L. Gillon and Erika M. Neison
In Witness Whereof, I have hereunto affixed my signature this g th day of ;qu~us t ~-
Anno Donaini Two Thousand and Twelve (2012)
one R. Anderson, Sheriff _`'`~~
Commonwealth of Pennsylvania, ss.
County of Cumberland
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 r~~ight be recorded. Witness my hand and seal of said Court, this g th day
of August A.nno Domini Two Thousand and Twelve (2012)
Pr thonotary ~ ~1VLCJ . ~,~,t.EL~„
''-i
'; ,Prothsmotary, Cumberland County, Cariisk,.PA
> , My C~sfion Expires the First Monday of Jan. 2011
'r
,, I hereby certify that the residence
{
And Post Off ce address of the
t °~~~~
'' „ `" Within Grantee is
2001 Australian Avenue
-, ~ , ~ Bay l
Riviera Beach, FL 33404
f
`~~ j ~r~ F.
~•
Ric and W. Stewart`-~-
Solicitor
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717=240-6370
Instrument Number - 201226380
Recorded On 8/28/2012 At 2:37:39 PM
* Instrument Type -DEED-SHERIFF'S
Invoice Number -116134 User Ill - KW
* Grantor - GILLON, JOHNNIE L
* Grantee - JPMOKGAN CHASE BANK N A
* Customer -SHERIFF
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $12.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
CARLISLE AREA SCHOOL $0.00
DISTRICT
CARLISLE BOROUGH $0.00
TOTAL PAID $63.00
* Total Pages - 5
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
rot+ c°'Me
RECORDER O
»ao
* - [nformation denoted by an asterisk may change during
the verification process and may not be reflected on this page.
VI IuIIIIIVI~IiII'lllAl
SHAPIRO ~t DENARDO, LLC
ATTORNEYS AT LAW
3600 Horizon Drive, Suite 150, King of Prussia, Pennsylvania 19406
GERALD M. SHAPIRO
.Admitted in Illinois and Florida Only
DAVID S. KREISMAN
.Admitted in Illinois Only
CFIRISTOPHER A. UeNARUO
Managing Partner
MICHAEL J. CLARK +
LESLIE J. RASE
Also Licensed in New Jersey
Tel: (610) 278-6800, Fax: (610) 278-9980
90 DAY NOTICE PURSUANT TO PROTECTING TENANTS OF
FORECLOSURE ACT, PUBLIC LAW 111-22
TO: Tenants
318 East North Street
Carlisle, PA 17013
AND ALL OTHER TENANTS IN POSSESSION:
AT PREMISES KNOWN AS
318 East North Street
Carlisle, PA 17013
NOTICE IS HEREBY GIVEN, that The Bank of New Fork Mellon, f/k/a The
Bank of New York as successor to JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4 has purchased the above-described property at a foreclosure
sale and is the record owner of the Property.
NOTICE IS FURTHER GIVEN that, pursuant to the Protecting Tenants of
Foreclosure Act, Public Law 111-22, All Tenants are given ninety (90) day notice to
vacate the premises. If you fail to vacate the premises within the ninety (90) day period,
The Bank of New York Mellon, f/k/a The Bank of New York as successor to
JPMORGAN Chase Bank, as Trustee for the Benefit of the Certificateholders of
Popular ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-4 will proceed
to have an eviction and lockout scheduled to have you removed from the Property.
Pursuant to Protecting Tenants of Foreclosure Act, Public Law 111-22, if you
have apre-existing lease extending beyond ninety (90) days from the date of receipt of
this notice, you may choose to deliver a bona fide lease agreement to the attorney's office
listed below. If you choose to produce your lease agreement, you will be expected to pay
contractual rent monthly to the The Bank of New York Mellon, f/k/a The Bank of New
York as successor to JPMORGAN Chase Bank, as Trustee for the Benefit of the
Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates, Series
2004-4 for the rest of the period of your lease agreement to the attorney's office listed
below. If rent is not paid timely, The Bank of New York Mellon, f/k/a The Bank of
New York as successor to JPMORGAN Chase Bank, as Trustee for the Benefit of
the Certificateholders of Popular ABS, Inc. Mortgage Pass-Through Certificates,
Series 2004-4 will proceed with legal action for POSSESSION. ALL TENANTS ARE
REQUIRED TO DELIVER POSSESSION of the premises at the scheduled end of said
lease agreement.
Enclosed herewith is a copy of the recorded Deed declaring The Bank of New
York Mellon, f/k/a The Bank of New York as successor to JPMORGAN Chase
Bank, as Trustee for the Benefit of the Certificateholders of Popular ABS, Inc.
Mortgage Pass-Through Certificates, Series 2004-4 as the lawful owner of said
premises.
I suggest you consult an Attorney or contact the undersigned to discuss the actual
date you plan to vacate the premises or submit your lease agreement pursuant to
Protecting Tenants of Foreclosure Act, Public Law 111-22.
Christopher A. DeNardo, Esquire
Attorney for Purchaser
Shapiro &DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
(610)278-6800
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,-~
Sheriff f -~ ~'' `'
r t1~~ ~' ~' ' `~ r
Jody S Smith ~' ' o
;i ~
-- .rl
r
Chief Deputy ~
= ` "
-- ~ ~
~_
'"
,
~ ~
Richard W Stewart ~
';~~~ ~''~ ~~'~"'~~
Solicitor r--~~ _;.r
._
- ...__
~
_ .,
.;,.: -
.. _c-
-- ~-i
The Bank of New York Mellon, f/k/a The Bank of New York as successor ~ ~" -ti
vs.
Johnnie L Gillon (et al.)
Case Number
2012-6945
SHERIFF'S RETURN OF SERVICE
11/21/2012 03:23 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Johnnie L Gillon, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not
Found" at 318 East North Street, Carlisle Borough, Carlisle, PA 17013. Deputies were advised by
neighbors that defendant has not resided at this address since March or April, although he does stop by
to get his mail and his property is still located at this address, defendant is thought to reside with his
mother at a probable address of 157 W. North Street, Carlisle, Pennsylvania, 17013.
11/21/2012 03:23 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Erika M. Nelson, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not
Found" at 318 East North Street, Carlisle Borough, Carlisle, PA 17013. Deputies were advised by
neighbors that defendant has not resided at this address since March or April of this year.
11/26/2012 03:23 PM - 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, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 318
East North Street, Carlisle Borough, Carlisle, PA 17013.
SHERIFF COST: $76.00
November 26, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar# 78447 1 `,' j
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406 P ?8 Atl I I: f-'7
TELEPHONE: (610)278-6800 a s _ FItCOUNT'-'
S & D FILE NO. 12-042411 P DM,Y t VA I A
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through '
Certificates, Series 2004-4 ;
PLAINTIFF
VS.
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action Ejectment in the above-captioned matter.
SHAPIRO &DeNARDO, LLC
BY:
Christopher A. DeNardo, Esquire
12-042411 Attorney for Plaintiff
arat
SHERIFF'S OFFICE OF CUMBERLAND COU Kcy
Ronny R Anderson �'ILEOwfl
Sheri �ON�TARI
Sheriff t � PRO
�a n of ���fl � 013 APR t5 Ate 9% 23
Jody S Smith
Chief Deputy
0MBE
Richard W Stewart RLAHO COUt4T'
Solicitor PENNS`f LVPm A
The Bank of New York Mellon, f/k/a The Bank of New York as successor Case Number
vs.
Johnnie L Gillon (et al.) 2012-6945
SHERIFF'S RETURN OF SERVICE
04/03/2013 09:25 AM-Deputy Noah Cline, being duly sworn according to law, served the requested Complaint in
Ejectment upon the within named Defendant,to wit: Occupant, pursuant to Order of Court by'Posting"
the premises located at 318 East North Street, Carlisle Borough, Carlisle, PA 17013 a true and
correct copy according to law.
NOAH CLINE, DEPUTY
SHERIFF COST: $40.00 SO ANSWERS,
April 04, 2013 RONW R ANDERSON, SHERIFF
(r)CoumySuite Sheriff,7eleosoft..P c.
SHAPIRO& DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE,ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 «'
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D.NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406 C)
TELEPHONE: (610)278-6800 r '
S & D FILE NO. 12-042411 )>C-) C'
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEA
Bank of New York as successor to CIVIL DIVISION cry
JPMORGAN Chase Bank, as Trustee for the CUMBERLAND COUNTY
Benefit of the Certificateholders of Popular
ABS, Inc. Mortgage Pass-Through NO: 12-6945 Civil
Certificates, Series 2004-4
PLAINTIFF
VS.
Johnnie L. Gillon and Occupants
DEFENDANT
AFFIDAVIT OF SERVICE
I, Alicia DeMedio,the undersigned, being duly sworn according to law, hereby depose
and say that on the day of ADYd 2013, pursuant to the attached
Order of Court, attached as Exhibit "A", I served a true and correct copy of the Occpants in the
above captioned matter to the Defendant by certified and regular mail,to their last known
address of:
Occupants, 318 East North Street, Carlisle, PA 17013
SHAP O DeNARDO, LLC
BY:
Alicia 6eMedio
Legal Assistant to Attorney for Plaintiff
SWORN AND SUBSCRIBED
Before me this o`(.o day of
20
Notary Public
S & D FILE NO. 12-042411
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Denise L.Semetti,Notary Public
Upper Marion Twp.,Montgomery County
My Commission Expires Iuiy 22,2034
Member,Pennsvlvania Association of Notaries
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411 w .
The Bank of New York Mellon f/k/a The
COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY -
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil x^
ABS, Inc. Mortgage Pass-Through r �
Certificates, Series 2004-4
co
F_
PLAINTIFF
VS.
Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
PRAECIPE FOR JUDGMENT FOR POSSESSION
FOR FAILURE TO ANSWER
Enter Judgment for immediate possession of the Premises located at: 318 East North Street, Carlisle, PA
17013, in favor of Plaintiff and against the Defendants above captioned for failure to file an answer to Plaintiffs
Complaint within 20 days from service of the Complaint.
SHAPIRO & DeNARDO, LLC
Date: _ BY:
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
AND NOW,judgment for immediate possession of the Premises located at 318 East North Street,
Carlisle, PA 17013 is entered in favor of the Plaintiff and against the Defendant.
9�\ V�;) J90
Pro. P oth
'� f(p.So P13 iAl
SHAPIRO &DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 12-042411
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as.Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
1661 Worthington Road; Suite 100
P.O. Box 24737
West Palm Beach, Florida 33409 ;
PLAINTIFF
VS.
Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street ;
Carlisle, PA 17013
DEFENDANTS
CERTIFICATION OF ADDRESS
I hereby certify that the correct addresses of the judgment creditor(Plaintiff) and that the
last known address of the judgment Debtor(Defendant) are as above.
SHAPIRO &DeNARDO, LLC
Date: BY: L--
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
SHAPIRO &DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 12-042411
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF
VS. '
Johnnie L. Gillon ;
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the attached papers on
e15-P51;Z01�5 to all parties named herein at their last known address or upon their
attorney of record as below listed by regular mail, postage prepaid:
Johnnie L. Gillon, 318 East North Street, Carlisle, PA 17013
Occupants, 318 East North Street, Carlisle, PA 17013
SHAPIRO &DeNARDO, LLC
Date: A, BY: �_
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CIVIL DIVISION
JPMORGAN Chase Bank, as Trustee for the CUMBERLAND COUNTY
Benefit of the Certificateholders of Popular
ABS, Inc. Mortgage Pass-Through NO: 12-6945 Civil
Certificates, Series 2004-4
PLAINTIFF
VS. '
Johnnie L. Gillon and Occupants
DEFENDANT ;
CERTIFICATION OF MAILING NOTICE UNDER RULE 23 7.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for
the Entry of Default Judgment was mailed to the defendant (s) and to his,her, their attorney of
record, if any, after the default occurred and at least(10) days prior to the date of the filing of the
Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,
April 26, 2013, to:
Johnnie L. Gillon, 318 East North Street, Carlisle, PA 17013
Occupants, 318 East North Street, Carlisle, PA 17013
Alicig DeMedio, Legal ssistant
SH PIRO &DeNARDO, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411
The Bank of New York.Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CIVIL DIVISION
JPMORGAN Chase Bank, as Trustee for the CUMBERLAND COUNTY
Benefit of the Certificateholders of Popular ;
ABS, Inc. Mortgage Pass-Through NO: 12-6945 Civil
Certificates, Series 2004-4
PLAINTIFF
VS.
Johnnie L. Gillon and Occupants
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Occupants
DATE OF NOTICE: April 26,2013
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN(10)DAYS
FROM THE DATE OF THIS NOTICE;A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A.
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
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 Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
V
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION'DEBIDA DENTRO DE UN TERMINO DE DIEZ(10)
DIAS DE LA FECHA DE ESTA NOTIFICACION,EL TRIBUNA PODRA,SIN NECESIDAD DE COMPARARECER
USTED IN CORTE O ESCUCHAR PREUBA ALGUNA,DICTAR SENTENCIA EN SU CONTRA. LISTED PUEDE
PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Johnnie L. Gillon, 318 East North Street, Carlisle,PA 17013
Occupants, 318 East North Street, Carlisle,PA 1.7013
SHAPIRO&DeNARDO, LLC
Date:-
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
PA ID 310530
•R�
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 12-042411
The Bank of New York Mellon,f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CIVIL DIVISION
JPMORGAN Chase Bank,as Trustee for the CUMBERLAND COUNTY
Benefit of the Certificateholders of Popular ;
ABS, Inc. Mortgage Pass-Through NO: 12-6945 Civil
Certificates, Series 2004-4
PLAINTIFF
VS.
Johnnie L. Gillon and Occupants
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Johnnie L. Gillon
DATE OF NOTICE: April 26,2013
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS
FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
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 Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
ti
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUnMA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ(10)
DIAS DE LA FECHA DE ESTA NOTIFICACION,EL TRIBUNA PODRA,SIN NECESIDAD DE COMPARARECER
USTED IN CORTE 0 ESCUCHAR PREUBA ALGUNA,DICTAR SENTENCIA EN SU CONTRA. LISTED PUEDE
PERDER BIENES Y OTROS DERECHOS wpoRTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO>MMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRTTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASWENCIA LEGAL:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle,PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Johnnie L. Gillon,318 East North Street,Carlisle,PA 17013
Occupants,318 East North Street,Carlisle,PA 17013
SHAPIRO&DeNARDO, LLC
i
Date: BY:
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
PA ID 310530
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530
LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D.NO. 92357
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 12-042411
The Bank of New York Mellon, f/k/a The COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
c/o Ocwen Loan Servicing, LLC
1661 Worthington Road
West Palm Beach, FL 33409
PLAINTIFF
VS.
Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANT(S)
STATE OF:_PENNSYLVANIA_
COUNTY OF: MONTGOMERY
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen
years and competent to make this affidavit and the following averments are based upon
information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that
the above captioned Defendants last known address is as set forth in the caption and they are not
to the best of our knowledge, information or belief, in the Military or Naval Service of the
United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended.
SHAPIRO & DeNARDO, LLC
Date: S _ S - 1 BY: ^�
Attorneys for Plaintiff
Sworn to and subs gibed KASSIA FIALKOFF E
before me this day SQUIRE
o ,2013.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Denise L.Sernetti,Noltanj Public
Upper Merion Twp.,iryci.yE wry County
My Commission Expires Jury 22,2014
Member.Pennsvlvania Aesodation of Notaries;
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
David D. Buell, Prothonotary
TO: Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
The Bank of New York Mellon, f/k/a The ; COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF ;
VS.
Johnnie L. Gillon
318 East North Street ;
Carlisle, PA 17013
i
Occupants
318 East North Street
Carlisle, PA 17013 ;
DEFENDANTS
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Default
[XX] Judgment for Possession
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE BY CALLING (610)278-6800
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
David D. Buell, Prothonotary
TO: Occupants
318 East North Street
Carlisle, PA 17013
The Bank of New York Mellon, f/k/a The COURT OF COMMON.PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF
VS.
;
Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary _jL4Ao0
[XX] Judgment by Default 4
[XX] Judgment for Possession
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE BY CALLING (610)278-6800
SHAPIRO &DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
2i
CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 1—
KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D.NO. 310530
LEONARD J. MUCCI 111, ESQUIRE, ATTORNEY I.D. NO. 92357 r
3600 HORIZON DRIVE, SUITE 150 )>C"')
=C�
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S &D FILE NO. 12-042411
The Bank of New York Mellon, fVa The COURT OF COMMON PLEAS
Bank of New York as successor to CUMBERLAND COUNTY
JPMORGAN Chase Bank, as Trustee for the
Benefit of the Certificateholders of Popular NO: 12-6945 Civil
ABS, Inc. Mortgage Pass-Through
Certificates, Series 2004-4
PLAINTIFF
VS. '
Johnnie L. Gillon
318 East North Street
Carlisle, PA 17013
Occupants
318 East North Street
Carlisle, PA 17013
DEFENDANTS
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindly issue a Writ of Possession in the above matter for property located at 318 East
North Street, Carlisle, PA 17013 as more fully described in the Complaint. pp ATT-1
4ae so p
76.00 CBF
(Costs to be added) 15.00 4!
x{0.00
1)6
)1, 175
Ito. so
SHAPIRO &DeNARDO, LLC aS QOM
Date: BY:
Attorneys for Plaintiff
KASSIA FIALKOFF, ESQUIRE
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THE BANK OF NEW YORK MELLON,
f/k/a THE BANK OF NEW YORK as
successor to JPMORGAN CHASE BANK,
as Trustee for the Benefit of the Certificateholders
of Popular ABS,Inc. Mortgage Pass-Through
Certificates, Series 2004-4
VS. No. 12-6945 Civil Term_
JOHNNIE L. GILLON
318 East North Street
Carlisle, PA 17013
OCCUPANTS
318 East North Street
Carlisle,PA 17013
Costs
Attorney's $ 363.25
Plaintiff's $
Prothonotary $2.25
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1)To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff(s))
THE BANK OF NEW YORK MELLON, f/k/a THE BANK OF NEW YORK as
successor to JPMORGAN CHASE BANK, as Trustee for the Benefit of the Certificateholders
of Popular ABS, Inc. Mortgage Pass-ThroughCertificates, Series 2004-4
being: (Premises as follows):
**318 East North Street, Carlisle, PA 17013**
(2)To satisfy the costs against the defendant(s)you are directed to levy upon any
property of the defendant(s) and sell his/her(or their) interest therein.
David D.Buell,Prothonotary,
Common Pleas Court of Cumberland County, PA
Date 12-6945
(Seal)
2 or 2
No 12-6946 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
THE BANK OF NEW YORK MELLON,
f/k/a THE BANK OF NEW YORK as
successor to JPMORGAN CHASE BANK,
as Trustee for the Benefit of the Certificateholders
of Popular ABS,Inc. Mortgage Pass-Through
Certificates, Series 2004-4
VS.
JOHNNIE L. GILLON and OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 363.25
Plff(s) $
Prothy $ 2.25
Sheriff $
Plaintiff(s)attorney name and address:
KASSIA FIALKOFF,ESQUIRE/ID#310530
SHAPIRO &DeNARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
Attorney for Plaintiff(s)
Where papers may be served
By virtue of this writ, on the day of I caused the within
named to have possession of the premises described with the
appurtenances, and
So Answers,
Sworn and subscribed to before me this
Day of ,
Sheriff
By
Prothonotary Deputy