The URL can be used to link to this page

Home My WebLink About13-1010Phelan Hallman, LLP By: Jonathan Lobb, Esq., Id. No.312174 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. Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County ~--, r„~. -ra - cn --c ~` ,.~.:. .~ceWx c-n c ---~ ~; r~ c; -,~ tv ..,.,. r.:; ~-~ =, -c~ ,_~t - `a ~p _:,' c:.: -: , :~ -; ~:~~ MAX G. MANWARING or Occupants 623 GLENDALE STREET No. ~ 3J ~ (~~ D CARLISLE, PA 17013 Defendant 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 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 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 PHS # 314319 ~~ agc~g~a 1. Plaintiff is Federal National Mortgage Association. 2. Defendant is MAX G. MANWARING or Occupants. 3. A true and correct copy of the Recorder of Deeds Index Display is in the possession, custody or control of Plaintiff which reflects that a Sheriffs deed was recorded 02/07/2013 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201304177, and further reflects Plaintiff s ownership of the property at 623 GLENDALE STREET, CARLISLE, PA 17013 (hereinafter the "Premises") is attached hereto, made part hereof, and marked as Exhibit "A". 4. 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. 5. The legal description of the Premises is attached hereto, made part hereof, and marked as Exhibit ..B.. 6. 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 "C". WHEREFORE, Plaintiff seeks to recover possession of the Premises. i~/~ J athan Lobb, Esq., Id. No.312174 ttorney for Plaintiff Phelan Hallinan, LLP EXHIBIT "A" PI-IS # 314319 LANDEX Document Data Instrument #: Recorded Date: Instrument Type: County: Municipality: Recording Status: 201304177 FEB 7, 2013 10:15:41 AM DEED-SHERIFF'S CUMBERLAND CARLISLE BOROUGH - 3RD WARD VERIFIED Book: Page: Total Pages: Parcel Numbers: 5 04220481030 Notes: 623 GLENDALE ST LOT 65 GRANTOR GRANTEE MANWARING,MAX G FEDERAL NATIONAL MTG A5SOC MANWARING,JANET B Page 1 of 1 http: //w ww.landex. com/webstore/j sp/cart/DocumentSeazchResults. j sp?LastName=MANW... 2/ 14/2013 EXHIBIT "B" PHS # 314319 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground known as Lot 65 of Plan of Section B of Heatherlands, with the improvements thereon erected, located on the Eastern side of Glendale Street of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the East side of Glendale Street, which point is 105.07 feet South of a second point on the East side of Glendale Street, which second point is in the line dividing Lots 66 and 67 as shown on the Plan of Section B of Heatherlands recorded in Cumberland County, Pennsylvania, in Plan Book 12, Page 36; thence along the Eastern side of Glendale Street in a Southerly direction, 100 feet to a point; thence South 88 degrees 52 minutes, 30 seconds East, 150 feet to a point; thence North 02 degrees 19 minutes 40 seconds East 92.77 feet; thence North 86 degrees 06 minutes 50 seconds West, 150 feet to the Place of BEGINNING. TITLE TO SAID PREMISES VESTED IN Max G. Manwaring and Janet B. Manwaring, by Deed from Reed S. Rusniak and Janice P. Rusniak, his wife, dated 10/26/2006, recorded 10/27/2006, in Deed Book 227, page 1543. PREMISES BEING: 623 GLENDALE STREET, CARLISLE, PA 17013 PARCEL N0.04-22-0481-030 EXHIBIT "C" PHS # 314319 r~ 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX #: 215-563-4491 Email: VIOLETA.PATORI@fedphe.com February 14, 2013 MAX G. MANWARING or Occupants 623 GLENDALE STREET CARLISLE, PA 17013 RE: 623 GLENDALE STREET CARLISLE, PA 17013 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 12/05/2012. 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. Very truly yours, Phelan Hallin~~i`'" P at an Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP PHS # 314319 ` ~ERIF~I~~A'rl(~~N 1, ._ _V Christopher Wolfe any ennployed by the Plaintiff cnrparatan as ttn asset Rc~;avery Manager and da hereby verify that the factual allegations set Earth in the fare~3n~; Cc~rnptaint are; true and correct to the best of my knowledge ax information and belief btiseei car ~;carpc~rate s~~ure:es caf information. 1 understaand that false statements therein are made subje~;t to th+~ penalties cif 1 l~ Pa.C:,S, 49(14 relating to unswarn falsif cation to authorities. ~a1e; 2/15/2013 Printed. Name; TitlelDelaartment: Asset Recovery Manager _ __ ___ Ca~npany. ___.Fanne. Mae......... 1'HS 31~~1'~ ;` R.P.C."") fit` P1ZOI~'l'K Return ta; Phelan Hallman, GLP t}ne Penn tenter, Suite i4gfl 1 ~ l 7.11~'K. ~~~ulovaxd Philadelphia, PA 19103 r'~ttn: l~victiat~ Department l'11S 314319 Phelan Hallinan, LLP Adam H. Davis, Esq.,Id. No.203034 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 c c C) Federal National Mortgage Association -a3 --4 Plaintiff COURT OF COMMON PLEAS xm =I. CIVIL DIVISION -vm vs No. 13-1010 CIVIL kc C:)Q MAX G. MANWARING Or occupants i X=' 623 GLENDALE STREET CUMBERLAND County a2 CARLISLE, PA 17013 -mot Defendant PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of Plaintiff, Federal National Mortgage Association and against the Defendant(s) MAX G. MANWARING and Or occupants for possession of premises 623 GLENDALE STREET, CARLISLE, PA 17013 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiff s intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP Default Judgment entered as indicated above. DATE: LA U 2w .� Phelan Hallinan,LLP Adam H. Davis,Esq.,Id. No.203034 1617 HK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Federal National Mortgage Association Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 13-1010 CIVIL MAX G. MANWARING Or occupants 623 GLENDALE STREET CUMBERLAND County CARLISLE, PA 17013 Defendant VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am the Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts,to wit: (a)That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant MAX G. MANWARING and/or occupant(s)resides at 623 GLENDALE STREET, CARLISLE, PA 17013. (c)It is unknown whether any other occupants are in the military or are over 18 years of age. This statement is made subject to penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. Date: April 8, 2013 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP PHS #314319 v Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 215-563-7000 Federal National Mortgage Association Court of Common Pleas Plaintiff Civil Division VS No. 13-1010 CIVIL MAX G. MANWARING or Occupants Defendant CUMBERLAND COUNTY TO: MAX G. MANWARING or Occupants 623 GLENDALE STREET CARLISLE, PA 17013 DATE OF NOTICE: March 22, 2013 ** 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. ** IMPORTANT NOTICE 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 of 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 or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP PHS # 314319 PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Federal National Mortgage Association Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 13-1010 CIVIL C, C n MAX G. MANWARING Or occupants rnr"n.._,,, 623 GLENDALE STREET CUMBERLAND County .;o p�'�- CARLISLE, PA 17013 Defendant PRAECIPE FOR WRIT OF POSSESSION X!, CP TO THE PROTHONOTARY: -< Issue Writ of Possession in the above matter for possession of: 623 GLENDALE STREET, CARLISLE, PA 17013 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTION" Being Known as No. 623 GLENDALE STREET Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP DATE: 3)� R. �0 I a 00 GAF C'54. 1 It • a � a .as C� iagyeo 9 W Legal Description ALL that certain lot of ground known as Lot 65 of Plan of Section B of Heatherlands,with the improvements thereon erected, located on the Eastern side of Glendale Street of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the East side of Glendale Street,which point is 105.07 feet South of a second point on the East side of Glendale Street, which second point is in the line dividing Lots 66 and 67 as shown on the Plan of Section B of Heatherlands recorded in Cumberland County, Pennsylvania, in Plan Book 12, Page 36; thence along the Eastern side of Glendale Street in a Southerly direction, 100 feet to a point; thence South 88 degrees 52 minutes, 30 seconds East, 150 feet to a point;thence North 02 degrees 19 minutes 40 seconds East 92.77 feet; thence North 86 degrees 06 minutes 50 seconds West, 150 feet to the Place of BEGINNING. AND BEING the same property which Alvin F. Bonawitz, single man, granted and conveyed to Reed S. Rusniak and Janice R. Rusniak,his wife, grantors herein,by deed dated January 30, 2006,and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 272 Page 4812 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. No. 13-1010 Civil Term MAX G.MANWARING OR OCCUPANTS 623 GLENDALE STREET CARLISLE,PA 17013 Costs Attorney's 182.75 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)) FEDERAL NATIONAL MORTGAGE ASSOCIATION being: (Premises as follows): **623 GLENDALE STREET,CARLISLE,PA 17013** **SEE ENCLOSED PROPERTY DESCRIPTION" (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. Davi D.Bu—eTl, oonotaryl Common Pleas Court of Cu ertand County, PA Date 4/9/13 (Seal) 2 of 2 No 13-1010 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. MAX G.MANWAR]NG OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att9y $ 182.75 Plff(s) $- Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: ADAM DAVIS,ESQUIRE ID#203034 PHELAN RALLINAN,LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 (215) 563-7000 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff U r L Jody S Smith:44a THE PR0THr'N0"1'1'%::'- Chief Deputy 2 5 013 APR 1 PM 3* Richard W Stewart G 6 Solicitor OFfICE OF THE S49RIFF CUMBERLAND COUNT Y PENNSYLVANIA Federal National Mortgage Association Case Number vs. Max G. Manwaring 2013-1010 SHERIFF'S RETURN OF SERVICE 04/1212013 02:06 PM-Dennis Fry, Deputy Sheriff,who being duty sworn according to law, states that on April 12, 2013 at 1406 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant,to wit: occupant,by making known unto Janet Manwaring,occupant, at 623 Glendale Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/1212013 02:06 PM-Dennis Fry, Deputy Sheriff,who being duly sworn according to law, states that on April 12, 2013 at 1406 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant,to wit: Max Manwaring, by making known unto Janet Manwaring, spouse of defendant and adult in charge, at 623 Glendale Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $55.25 SO ANSWERS, April 15, 2013 RONW R ANDERSON, SHERIFF (C)cauntysu!te sneriff.'Teiaosoft,im ' +~ SHERI��U��v�� U�� CUMBERLAND d��UU�� FF'S== ~~" " "=,�� ~m ~~��"°"��.^u�x�nn�� COUNTY Ronny RAnderson Sheriff ' ^ ~ 0— �A� oRD — ' °°~ . ^ � ' ^ ^� ' '`~ (UUM� //�O� JmdyS Smith =- I* 2013 MAY �� M1 Chief Deputy �"'�''�/ ' ' ,/ �` w , �uha�VVS#eart ��zs� CU T\/ Solicitor �pmE*+mewwsmp pENW�� ''' COMITY - . _.'`^~,` Federal National Mortgage Association ma. Case Number Max G. KAanwahng | 2013'1010 SHERIFF'S RETURN OF SERVICE 04/ 2/2013 O2:OGpyW-Dennis Fry, Deputy Sheriff,who being duly sworn according bm law, states that on April 12. 2013 at 1406 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant,to wit: occupant, by making known unto Janet Manwaring, occupant, at G23 Glendale Street, Carlisle, Cumberland County, Pennsylvania itocontenteandsdthooamodme handing to her personally the said true and correct copy nf the same. 04/12/2013 02:06 PM- Dennis Fry, Deputy Sheriff,who being duly sworn according to law, states that on April 12, 2013 at 1406 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant,to wit: Max Manwaring, by making known unto Janet Manwaring, spouse of defendant and adult in charge, at 623 Glendale Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 0505/2813 By virtue of this writ, Sheriff Ronny R.Anderson caused the within named Plaintiff to have possession of the premises described aeS23 Glendale Street, Carlisle, R417013. SHERIFF COST: $Q4.33 SO ANSWERS, May O7. 2O13 RONP;YR ANDERSON, SHERIFF " 444 �]w�t _�v�*�33 �� ~_�� (c)um"tySu/wn:erixryeow«/"c