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HomeMy WebLinkAbout13-1494 r This is a non -jury matter Assessment of Damages Hearing not required Not arbitration. matter UDREN LAW OFFiCh6S�II 6 f+ ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856 - 669 -5400 pleadings @udren.com Federal Home Loan Mortgage €COURT OF COMMON PLEAS Corporation - CIVIL DIVISION Plaintiff :Cumberland County V. John Doe and /or N0. O N Tenant /Occupant 155 Ken -Lin Drive Carlisle, PA 17013 Defendant(s) CIVIL ACTION COMPLAINT IN EJECTMENT 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 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 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 2 C) AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises ") which address is set forth on the caption. Premises, a legal description of which is attached hereto, was sold at Sheriff's Sale in accordance with law on December 5, 2012, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. A true and correct copy of the deed in favor of Plaintiff is attached hereto as Exhibit "A ". 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant(s) who have refused to deliver up the possession thereof . WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAW OFFICES, P.C. TT R INTIFF HARRY B. ESE, ESQUIRE PAID 310501 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTS r - 1 COURTHOUSE SQUARE ! CARLISLE, PA 17013 a 717- 240 -6370 Instrument Number - 201306041 Recorded On 2/22/2013 At 2:16:01 PM Total Pages - 5 * Instrument Type - DEED- SHERIFF'S Invoice Number - 130058 User ID - SW *Grantor - THOMAS, RCIHARD C • Grantee - FEDERAL HOME LOAN MTG CORP • Customer - CUMBERLAND COUNTY SHERIFF FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT MONROE TOWNSHIP $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA C C' f o v ° I RECORDER O D EDS t7ao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. Illllllfl I III III�IIIIIIIIII 002W5E \ Tax Parcel No. 22 -09- 0535 -024 � That I, Ronny R. Anderson, Sheriff of the County Cumberland, In the State of J "ennsvieania, for and in consideration of the suin of $ 1.00 (One Dollar) to nie in hand paid, do hereby grant and convey Federal Home Loan Mortgage 1 Corporation Writ No. 2010 -3286 Civil Term PNC Mortgage, a Division of PNC Bank NA Ns Richard C. Thomas Kim B. Thomas AL I, THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, AND BEING LOT NO. 8 ON FINAL PLAN OF �IMA10R SUBDIVISION FOR KEN -LIN ESTATES AS RECORDED IN THE OFFICE OI? TH'- RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 56. PAGE 139, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERN SIDE OF LISBURN ROAD, L.R 21013. SR. 200 WI I1C1-1 POINT IS ON THE DIVIDING LINE BE'T'WEEN LOTS NOS. 8 AND 7 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 10 DEGREES 40 MIN i_'TES 10 SECONDS EAST A DISTANCE OF 343.73 FEET TO A POINT IN LINE OF LOT NO I; THENCE- ALONG LOT NO. 15 AS IT APPEARS ON SAID PLAN, NORTH 45 DEGREES 36 JAINU'TES 20 SECONDS EAST 101.61 FEET TO A POINT; THENCE ALONG THE WESTERN BOUNDARY LINE OF THE AFORESAID LOT NO. 16, NORTH 54 DEGREES 37 MINUTES 20 SECONDS WIEST 444.67 FEET TO A POINT ON THE SOUTHERN LINE OF KEN -LIN DRIVE AS IT APPEARS ON SAID PLAN: THENCE ALONG THE SOUTHERN LINE OF KEN -LIN .DRIVE, NORTH 35 DEGREES 22 MINUTES .45 SECONDS EAST 40 FEET TO A POINT ON THE EASTERN SIDE OF LOT NO. 14, SODUTH 54 DEGREES 37 MINUTES 20 SECONDS EAST 470.73 FEET TO A POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF SAID LOT NO. 14, NORTH 68 DEGREES 2', MINUTES 40 SECONDS EAST It 9.34, FEET TO A POINT INLINE OF LOT NO. !3z AS IT APPEARS ON SAID PLANT; THENCE ALONG SAID LOT NO. 13 BY THE SAM E COURSE. A DISTANCE OF 52.05 FEET TO A POINT IN LINE OF LAND NOW 9P, FORMERLY" OF DAVID M. KERCH; THENCE ALONG SAID I...AND OF KERCH, SOUTH 52 DEGREES 37 MINUTES 20 SECONDS EAST 171.67 FEET TO A PIPE; TIIENCE ALONG THE SAME, NORTH 83 DEGREES 22 MINUTES 10 SECONDS EAST 305.9 ; FEET TO A POINT ON THE RIGHT -OF -WAY LINE OF BOYER ROAD, T -553: THENCE ALONG SAID RIGHT -OF -WAY OF BOYER ROAD, SOUTH 27 DEGREES 00 MINUTES 35 SECONDS WEST 543.67 FEET TO A POINT; THENCE BY A CURVE TO TH RIGHT HAVING A RADIUS OF 50 FEET TO AN ARC DISTANCE OF 64.28 FEET TO A POINT ON THE ADOREMENTIONED LISBURN ROAD: THENCE ALONG THE SAID 1SBURN ROAD, MOTH 79 DEGREES 19 MINUTES 50 SECONDS WEST 488.09 FEET TO - POINT ON THE DIVIDING LINE BETWEEN LOTS NO.7 AND 8 AS IT APPEARS ON SAID PLAN, THE PLACE OF BEGINNING. BEING KNOWN AS: 155 KEN -LINE DRIVE CARLISLE, PA 170'.3 °R( , PERTY ID NO. 22 -09 -0535 -024 T17 TO SAID PREMISES IS VESTED IN RICHARD C. THOMAS AND KIM B. I IIOMAS, HUSBAND AND WIFE BY DEED FROM RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE DATED 1/26/1994 RECORDED 2/3/1994 IN DEED 001: 101 PAGE. 123. The same having been sold by me to the said grantee on the 5th day of December gnno Domiiii Two Thousand and Twelve (2012) after due advertisement according to under and bye Virtue of a Writ of Execution issued on the 30th of August A no Domi,ni 2012 out of the Court of Common Pleas of Cumberland County, Pernzsylvania. as of Civil Term. Two Thousand and Ten (2010) Number 3286 at the suit of PNC Mortgage. a Division of PNC Bank NA —vs- Richard C. Thomas And Kim B. Thomas In Witness VA'hereof. I have hereunto affixed my signature this 3�,th day o: anuary Anno Domini Two Thousand and Thirteen (2013) onn R. Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned. David D. Buell, Prothonotary of the coil-, of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson. Sheriff of Cumberland County aforesaid, and in due fonr_ of law declared that the facts Set forth in the foreLgoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. IN "itness my hand and sea] of said Court, this 30 th day of J a n u a r v Anno Domini Two Thousand and Thirteen (20I 3 j 1 P othonotary, Z)I;v , p, C31� E.ti. Prothonota r =. ry, Cumberland County, Carlisle, PA Commission Expires the First Monday of fan. 2014 ^ � v y Ut ?�� -- �� •'� c N , I hereby certify that the residence r - And Post Office address of the - 'thin Grantee Grantee is 1 8000 Jones Branch MSTP 202 McLean. VA 22102 f �rtr,ti�lt ° j Richard '\A Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND 1COUNTY Ronny R Anderson _ Sheriff TI PPCIi�iC�IJ + ' Jody S Smith ° . 20131118 28 A�11 5: Chief Deputy Richard W Stewart '' NMBERLASD Solicitor OFFICE OF T"E SHERIFF P ENNSY LVANI to Federal Home Loan Mortgage Corporation Case Number vs. 2013-1494 John Doe SHERIFF'S RETURN OF SERVICE 03/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Found"at 155 Ken-Lin Drive, Monroe Township, Carlisle, PA 17013. Residence is vacant and per neighbors has been so since January. 03/26/2013 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 in Ejectment as"Not Found"at 155 Ken-Lin Drive, Monroe Township, Carlisle, PA 17013. Residence is vacant and per neighbors has been so since January. SHERIFF COST: $60.00 SO ANSWERS, March 26, 2013 R-ONtrY R ANDERSON, SHERIFF p CounirySuile Sheriff,Teleosoft,lrc.