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Home My WebLink About12-6983Phelan Hallinan & 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 Federal National Mortgage Association P.O. Box 650043 Dallas, TX 75265 Plaintiff v. ALYSSA R. STATLER or Occupants 453 NORTH PITT STREET CARLISLE, PA 17013-1946 Defendant Attorney for Plaintiff Court of Common Pleas . Civil Division :'' A ~~ }, .~_ _. , C.(7 ~ (~1 ..-~ ` , ~~~ ~ ~ i cw; .. CUMBERLAND Co I No. `moo--~a~~ U~ 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 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 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 Baz Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 PHS # 309920 ~ ~g3~~~ 3.~spda~ ~ I~la'~lb Plaintiff is Federal National Mortgage Association. 2. Defendant is ALYSSA R. STATLER or Occupants. 3. A true and correct copy of the Sheriffs deed in the possession, custody or control of Plaintiff which reflects a recording date of 10/29/2012 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201233354 and further reflects Plaintiffs ownership of the property at 453 NORTH PITT STREET, CARLISLE, PA 17013-1946 (hereinafter the "Premises") is attached hereto, made part hereof, and marked as Exhibit "A". 4. The attached Deed reflects that Plaintiff became the owner of the Premises as a result of the foreclosure and judicial sale by the Sheriff of CUMBERLAND County on 09/05/2012. 5. The legal description of the Premises is contained in Exhibit "A". 6. Plaintiff, by virtue of the above, contends that it is the record owner of the Premises, and is entitled to possession thereof. Plaintiff is informed that the defendant is occupying the Premises without right and without claim of title. 7. A true and correct copy of Plaintiffs letter demanding possession of the Premises from the Defendants, who have refused to deliver possession of same, is attached hereto, made part hereof, and marked as Exhibit "B". WHEREFORE, Plaintiff seeks to recover possession of the Premises. Allison Ils, Esq., Id. No.309519 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP EXHIBIT "A" PHS # 309920 ~ 3~s¢ c Tax Parcel No, 06-20-179&29$ Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Federal National Mortgage Association Writ No. 2011-8995 Civil Term Nationstar Mortgage LLC Vs Alyssa R. Statler ALL that certain piece or parcel of land situate in the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: ON the West by North Pitt Street; on the North by property now or formerly of John Humes; on the East by a 16 foot alley; and on the South by property now or formerly of said Ada S. Rinesmith. Containing thirty feet in front on North Pitt Street and extending in depth 138 feet, more or less to said alley on the East. Having thereon erected a two story frame dwelling house and other improvements known as 453 North Pitt Street, Carlisle, Pennsylvania. TITLE TO SAID PREMISES VESTED IN Alyssa R. Statler, a married person, by Deed from Dawn E. Collins and James J. Collins, w/h, dated 04/1712007, recorded 04119/2007 in Book 279, Page 3299. PREMISES BEING: 453 NORTH PITT STREET, CARLISLE, PA 17013-1946 PARCEL N0.06-20-1798-298 The same having been sold by me to the said grantee on the 5th day of September Arno Domuu 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 Jnne Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eleven (2011) Number 8995 at the suit of Nationstar Mortgage LLC -vs- Alyssa R. StaNer In Witness Whereof, I have hereunto affixed my signature this 10th day of October Anno Domini Two Thousand and Twelve (2012) Anderson, 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 declazed 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 10th day of October Anno Domini Two Thousand and Twelve (2012) .~y'~'~'fr•r yy. >~ .....,.,, ~: ,,~ y , ,. 1~. ~.t ,l"~ .i~..l~ G~'~ ~'".> 7~ ~' x :.. ,~ . ,, sj, f t ~ . t7. •. ~ \ ~` 1, `t1 ~"t/~.1'Y~~,,'~ P-ahonotary~ tun,b.rand camy6 PA ro{y Commisdoe Expires thr qne o(pn. 201 I hereby certify that the residence And Post Office address of the Within Grantee is P.O. Box 650043 Dailss, TX 75265 T/~ R c}tard Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-b370 Instrument Number - 201233354 Recorded On 10/29/2012 At 10:40:53 AM * Instrument Type -DEED-SHERIFF'S Invoice Number -120786 User Ill - RZ * Grantor - STATI,ER, ALYSSA R * Grantee -FEDERAL NATIONAL MTG ASSOC * Customer -CUMBERLAND CO 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 * Totat 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 -~'/~' RECORDER O * -Information denoted by an asterisk may change during the verlflcation process and may not be reflected on this page. tlIIII~II~~NVN~ EXHIBIT "B" PHS # 309920 -. PH ELAN HALLINAN 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX #: 215-563-4491 Email: VIOLETA.PATORI@fedphe.com November 6, 2012 ALYSSA R. STATLER or Occupants 453 NORTH PITT STREET CARLISLE, PA 17013-1946 RE: 453 NORTH PITT STREET CARLISLE, PA 17013-1946 Dear Occupant: We represent Federal National Mortgage Association which became owner of the above premises as a result of foreclosure and judicial sale by the Sheriff of the County of CUMBERLAND on 09/05/2012. You are now in possession of the premises without authority or permission of our client and you must vacate immediately. Unless you immediately vacate the premises and make them available for possession, court action will be taken against you at once. Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Very truly yours, Phelan Hallinan ,LLP Allison F . No.309519 PHS # 309920 • .. VERIFICA'I'IQN I, Christopher Wolfe _ , am employed by the- Plaintiff corporation as an Asset Recouery Manager and do hereby verify that the factual allegations set forth in the foregoing Complaint are true and correct to the best of my knowledge or information and belief basaed an corporate sources of information. I understand that false statements therein are matte subject to the penalties of 181'a.C.S. 49Q4 relating to unswarn falsification to authorities. Date: 11/13/2012 Printed Name; Title.(Department: Asset Recovery Manager Company: Fannie Mae PHS # 309920 ! RE4 # P1209K(} Return to: Phelan, Haiiinan & Schtnieg, LLP Une P~ Center, Suite 1400 l b 17 3`FI~ Boulevard Fhi ladelphia, FA 1 ~ 103 Attn: Fuictivn Department p~-IS # 309820