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Home My WebLink About13-1087Phelan Hallman, LLP By: Meredith Wooters, Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff v. KEITH HOCKENSMITH or Occupants 156 WEST NORTH STREET CARLISLE, PA 17013-2318 Defendant Attorney for Plaintiff Court of Common Pleas r ~~ ~. ~, ~, {~~ Civil Division ~ ~ ~ CUMBERLAND County ~ ~ , ~ °--- ° ..~ ~ 3_ ~ p~'~ Ciui~ ` ~ c c . _.j R`) ~ -t r-, 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 aze 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 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 Cazlisle, PA 17013 (717) 249-3166 PHS # 317759 a~.~ ~~U3.lsp~~y,~ Ck-~ I ~'xt~3q . ~.# agla4q 1. . Plaintiff is WELLS FARGO BANK, N.A.. 2. Defendant is KEITH HOCKENSMITH or Occupants. 3. Plaintiff is the record owner of premises located at 156 WEST NORTH STREET, CARLISLE, PA 17013-2318, 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 12/05/2012, as evidenced by the Sheriffs deed recorded 02/07/2013 in the Office of the Recorder of CUMBERLAND County in Instrument No. 201304176, 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. M redith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan, LLP EXHIBIT "A" PHS # 317759 . `~\ n `~ Q.1 uiHu Tax Parcel No. OS-20-1798-330 That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 2.00 (One Doltar) to me in hand paid, do hereby grant and convey Wells Fargo Bank, N.A. Writ No. 2008-7428 Civil Term Wells Fargo Bank, N.A. Vs Keith Hockensmith ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: ON the North by West North Street, on the East by the property now or formerly of W. Jackson; on the South by property now or formerly of Branson; and on the West by property now or formerly of Martha H. Keene; having a frontage on West North Street of 15 feet, more or less, and extending in depth 120 feet, more or less, and being improved with the eastern half of a double frame dwelling known and numbered as 156 West North Street. TTTLE TO SAID PREMISES VESTED IN Keith Hockensrnith, a single person, by Deed from Carlisle Housing Opportunities Corporation, a Pennsylvania not-for-profit corporation, dated 12/22/2003, recorded 12/29/2003 in Book 261, Page 38. PREMISES BEING: 156 WEST NORTH STREET, CARLISLE, PA 17013-2318 PARCEL NO. OS-20-1798-330 The same having been sold by me to the said grantee on the 5th day of December Arno Domini Two Thousand and Twelve (2012} after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 31st of August Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nfne (2009) Number 7428 at the suit of Wetls Fargo Bank, N.A. -vs- Keith Aockensmith In Witness Whereof, I have hereunto affixed my signature this 25th ~Y of January Anno Domini Two Thousand and Thirteen (2013} 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 might be recorded. Witness my hand and seal of said Court, this 2 5th day of January Arno Domini Two Thousand and Thirteen (2013) ,, • ` ~ , ;, thonotary Q pw s D ~ ~+ I hereby certify that the residence . And Post Office address of the Within Grantee is 3476 Stateview Boulevard Fort Mill, SC 29715 ~~~ Richard W. Stewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201304176 Recorded On 2/7/2013 At 10:14:2 0 AM * Instrument Type -DEED-SHERIFF'S Invoice Number -128754 User ID - BMM * Grantor - HOCKENSNIITH, KEITH * Grantee -WELLS FARGO BK N A * Customer -CUMBERLAND COUNTY * FEES STATE WRIT TAR $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 /o RECORDER O D DS * -Information denoted by an asterisk may change during the verification process and may not be reflected oo this page. hum~iMnM VERIFICATION I hereby state that I am the attorney for the Plaintiff in this eviction action and am authorized to make this verification. The statements made in the foregoing Civil Action - Ejectment are correct to the best of my information and belief. I was the attorney for the Plaintiff or Plaintiff s predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on the property at the sheriff s sale. I am making this verification rather than a representative of the Plaintiff because my firm has records regarding the purchase of this property at sheriff s sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 2 ~ ~~~~ Date M redith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan, LLP PHS # 317759 SHERIFF'S OFFICE OF CUMBERLAND C? lNF Ronny R Anderson THE PR07 {UN0 1, Sheriff gtq aS+:u�nGrxf�xr�} ? !3 MA►t 28 hti i 10: ru"1�7 Jody S Smith k Chief Deputy* CUMBERLAND C1E1NIi"t` Richard W Stewart PENNSYLVANIA OFFICE OF TPE VtGRIFF Wells Fargo Bank, N.A. Case Number vs. Keith E. Hockensmith 2013-1087 SHERIFF'S RETURN OF SERVICE 03/08/2013 09:34 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: Keith E. Hockensmith, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Found"at 156 West North Street, Carlisle Borough, Carlisle, PA 17013. Residence is vacant. 03/25/2013 11:21 AM- Deputy William Cline, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Keith E. Hockensmith at 911 Greenspring Road, North Newton, Newville, PA 17241. WILLIA CLINE, DEPUTY SHERIFF COST: $46.46 SO ANSWERS, March 26, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft Inc.