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Home My WebLink About12-7271Phelan 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 Federal Home Loan Mortgage Corporation 8200 Jones Branch Dr., Mailstop 202 McLean, VA 22102 Plaintiff v. LISA C. WELLS or Occupants 372 KERRSVILLE ROAD A/K/A 371 KERRSVILLE ROAD CARLISLE, PA 17015-9438 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. i~ ~-7~-~ C'1 c -~ 3 ~~ ~~ x~ ~ ~.' ...C D r ~= cc ~ c-, 0 ~. C', :~~: W_...r N rTt i W c~ .~' L~ r~ ~~`, --~r _~ _~ r :x7''~' c~ ~~ ~? ~' c., ~:,.. .;;~-• .'•! 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 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 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 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 d (717) 249-3166 ~ ~ /d 3 . ~ S ~ r PHS # 309254 c,~~r ~a-s~7~~" ,~~ ~5~3 7~fo 1. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is LISA C. WELLS or Occupants. 3. Plaintiff is the record owner of premises located at 372 KERRSVILLE ROAD A/K/A, 371 KERRSVILLE ROAD, CARLISLE, PA 17015-9438, 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. 201233358, 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 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. Alps F. Wells, Esq., Id. No.309519 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP EXHIBIT "A" PH5 # 309254 333Sg ~'' Know all Men by these Presents Tax Parcel No. 46-09-0521-088 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 Home Loan Mortgage Corporation Writ No. 2011-9373 Civil Term Branch Banking and Trust Company Vs Lisa C. Wells ii ALL THAT CERTAIN TRACT of land situate, lying and being in West Pennsboro Township, Cumberland County, Pennsylvania, being more fully bounded and described as follows, to wit: BEGINNING at a point in or near the center of Kerrsville Road (T-326); thence continuing in and along said roadway the following courses and distances: 1) South 22 degrees 22 minutes 13 seconds East; a distance of 86.050 feet to a point; 2) thence by a curve to the right having a radius of 1262.640 feet, an arc length of 199.584 feet and a chord bearing of South 17 degrees 50 minutes 31 seconds East, a distance of 199.376 feet to a point; 3) thence South 13 degrees 18 minutes 49 seconds East; a distance .Of39.929 feet to a point in said roadway; 4) thence leaving said roadway and extending along Lot NO.S of the hereinafter referred to subdivision Plan, South 69 degrees 29 minutes 43 seconds West, a distance of 547.640 feet to a point at Lot N0.3 of the hereinafter referred to subdivision plan; 5) thence along the last mentioned lands North 67 degrees 27 minutes 32 seconds West, a distance of 307.144 feet to a point at other lands N/F of Edgar C. Myers; 6) thence along the last mentioned lands North 61 degrees 08 minutes 12 seconds East; a distance of 791.975 feet to the point and Place of BEGIN1VIIVG. CONTAINING a gross area of 4.265 acres and s net area of 4.080 acres and being designated as Lot N0.4 on a final subdivision plan of Mandy Meadow, prepared by Shelly & Witter, Professional Land Surveyors, said Plan is recorded in the Cumberland county Recorder's Office in Plan Book 79 at page 44. UNDER AND SUBJECT, NEVERTHELESS, to all restrictions, easements, rights-of--way, conditions and/or set-back lines of record and to the deed restrictions more fully set forth in Cumberland County Deed Book 247 pages 1722 to 1723 TITLE TO SAID PREMISES VESTED IN Kevin W. Wells and Lisa C. Wells, his wife, by Deed from R Len Weller, Jr. and Virginia A. Weller, his wife, dated 06/29/2001, recorded 07/10/2001 in Book 247, Page 1720. KEVIN W. WELLS was a co-record owner of the mortgaged premises as a tenant by the entirety: By virtue of KEVIN W. WELLS's death on or about 02/2812009, his ownership interest was automatically vested in the surviving tenant by the entirety, Lisa C. Wells. PREMISES BEING: 372 KERRSVILLE ROAD A/K/A, 371 KERRSVILLE ROAD, CARLISLE, PA 17015-9438 PARCEL N0.46-09-0521-088 The same having been sold by me to the said grantee on the 5th day of September Anno Domini Two Thousand and Twelve (2012) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 1`~ of June Arno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eleven (2011) Number 9373 at the suit of Branch Banking and Trust Company -vs- Lisa C. Wells In Witness Whereof, I have hereunto affixed my signature this 10th Anno Domini Two Thousand and Twelve (2012 Commonwealth of Pennsylvania, ss. County of Cumberland day of October 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 10th day of October Arno Domini Two Thousand and Twelve (2012) .~' ''~ w « ;.~~t ~y 1 i"~:,, ~~ , rb > £ r e~ r ~ r, „, ~f~~~' ,. ~Q~.~ { ~fi:i ~ ~', ~ ~,, ; . ,,~. ;~,~ ~ ~ . ~~ ~r '~.~~ s ij ~ ~, „' ~ die wMond~~lan pt~i I hereby certify that the residence And Post Office address of the '°~ Within Grantee is 8200 Jones Branch Drive Mailstop 202 McLean, VA 22102 :Richard. W. Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQTJARE CARLISLE, PA 17013 717-240-637Q Instrument Number - 201233358 Recorded On 10/29/2012 At 10:43:18 AM * Instrument Type -DEED-SHERIFF'S Invoice Number -120789 User ID - MBL * Graator -WELLS, LISA C * Grantee -FEDERAL HOME LOAN MTG CORD * Customer - PHELAN HALLINAN & SCHMIEG LLP * FEES STATE ~iRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RSCORDEA OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 BIG SPRING SCHOOL $0.00 DISTRICT 1PEST PENNSBORO TON1dSHIP $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 ~~~/~ RECORDER O " -Information denoted by an aateriak may change during the verification proceaa and may not be reflected on this page. IIII~INIIIIIII VERIFICATION ELIZABETH TAYLOR-COUNTS hereby states that he/she is ASSISTANT (name) {Title) TREASURER of FEDERAL HOME LOAN MORTGAGE CORPORATLON 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 hismer 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 Elizabeth Taylor-Counts DATE: Il" 2q- ti0~v Assistant Treasurer PHS # 309254 Return to: Phelan Hallinan & Schmieg, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department PHS # 309254