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HomeMy WebLinkAbout13-3954 Supreme Con u 10,111"'Pe nsylvania Court ffCoihmo Pleas For Prothonotary Use Only: x 4 �y Y 7 f � Ct r Sheet � rt--�� Docket No: Cumberland County .. The information collected on this is used solely for court administration purposes. This form does not supplement or replace the and service ofplea o r other papers as required by law or rules of court. Commencement of Action: S [x Complaint ! - � Writ of Summons 0 Petition Q Transfer from Another Jurisdiction O Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: Federal National Mortgage Association a /k/a Fannie Mae Sutatip Grundon and /or Occupants T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? ❑ Yes ❑ No (check one) E] outside arbitration limits O N Is this a Class Action Suit? Yes ID No Is this an MDJAppeal? ❑ Yes l No i A Name of Plaintiff /Appellant's Attorney: Gregory Javardian, Esquire Check here if you have no attorney (are, Self- Represented (Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that i you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional fJ Buyer Plaintiff Administrative Agencies Q Malicious Prosecution [J Debt Collection: Credit Card _! Board of Assessment ❑I Motor Vehicle Debt Collection: Other E] Board of Elections _i Nuisance Dept. of Transportation LJ Premises Liability Q Statutory Appeal: Other S =J Product Liability (does not include mass fort) Dispute: F. Discrimination E3 Slander/Libel /Defamation C 3 Other: � Employment Dispute: Other Q Zoning Board � Other: , I Other: O MASS TORT © Asbestos N _ Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS IJ Toxic Waste El Ejectment El Common Law /Statutory Arbitration B Other: Eminent Domain /Condemnation 0 Declaratory Judgment C+ Ground Rent Mandamus Ci Landlord /Tenant Dispute _ Non- Domestic Relations f 3 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY LJ Mortgage Foreclosure: Commercial ? Quo Warranto Dental 0 Partition r1j Replevin -1 Legal [] Quiet Title Other: Q Medical ❑ Other: C'+ Other Professional: Updated 1 /1/2011 POWERS, KIRN & JAVARDIAN, LLC �NrT,, GREGORY JAVARDIAN, ESQUIRE ID No. 55669 JUL IQ ��,�• MARY F. KENNEDY, ESQUIRE ID No. 77149 .��: MEG MAYS,, ESQUIRE Ids I 307518 01661 i � 1R SEAN C© RICHARD J. NALBANDIAN,111, ESQUIRE Id. No. 312653 AFJ1 1310 INDUSTRIAL BOULEVARD 2nd FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215) 942 -2090 ATTORNEY FOR PLAINTIFF Federal National Mortgage Association Court of Common Pleas a/k/a Fannie Mae International Plaza II Civil Division 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254 -2916 Cumberland Coounnity Plaintiff No. I S- D ✓ VS. COMPLAINT IN EJECTMENT Sutatip Grundon And/Or Occupants 2001 Chestnut Street Camp Hill, PA 17011 Defendants COMPLAINT - CIVIL ACTION 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 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 defense 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 NOTICE 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. Cumberland County Bar Association 32 S. Bedford Street v Carlisle, PA 17013 (717) 249 -3166 Q,ux ASP , a qaq 3`( COMPLAINT IN EJECTMENT 1. Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION A /K/A FANNIE MAE, International Plaza II, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254 -2916. 2. Defendants are Sutatip Grundon and OCCUPANTS. 3. Attached hereto is a true and correct copy of the Deed from the Sheriff of Cumberland County in the possession, custody or control of Plaintiff, which reflects that Plaintiff is the owner of the property located at 2001 Chestnut Street, Camp Hill, PA 17011. 4. Plaintiff contends that it is entitled to immediate possession of the Property. 5. Upon information and belief, the Defendants, Sutatip Grundon and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. ❑Gregory Javardian, Esquire Id. No. 55669 ❑ Mary F. Kennedy, Esquire Id. No. 77149 ❑Me , ghan K. Boyle, Esquire Id. No. 201661 ❑ an P. Mays, Esquire ID No. 307518 Richard J. Nalbandian, III, Esquire ID No. 312653 Attorneys for Plaintiff "EXHIBIT A" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE ' CARLISLE, PA 17013 717 -240 -6370` ' Instrument Number - 201318645 Recorded On 6/6/2013 At 11 :06:56 AM * Total Pages - 5 * Instrument Type - DEED - SHERIFF'S Invoice Number - 138696 User ID - KW * Grantor - GRUNDON, SUTATIP * Grantee - FEDERAL NATIONAL MTG ASSOC * Customer - SHERIFF * FEES STATE WRIT TAR $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $13.50 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 CAMP HILL SCHOOL $0.00 DISTRICT CAMP HILL BORO $0.00 TOTAL PAID $64.00 I Certify this to be recorded in Cumberland County PA RECORDER O D EDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 002YSX II(fll(IIII�II III I IIII III Tax Parcel No. 01 -22 -0536 -152 002YSX 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 Federal National Mortgage Association 2012 -4316 Civil Term Bank of America, N.A. Vs Sutatip Grundon ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT POINT ON THE WEST SIDE OF PENNSYLVANIA AVENUE (80 FEET WIDE) AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS AT THE DIVIDING LINE BETWEEN LOTS NOS. 180 AN D181, SECTION "D "; THENCE NORTH 78 52' WEST, 114.57 FEET TO LOT NO. 183, SECTION "D "; THENCE ALONG SAID LOT NO. 183, SECTION "D ", NORTH 11° 28' EAST, 135.07 FEET TO THE SOUTHERN LINE OF CHESTNUT STREET; THENCE SOUTH 85° EAST, ALONG THE SOUTHERN LINE OF CHESTNUT STREET, 97.63 FEET (ERRONEOUSLY WRITTEN ON PLAN OF RECORD AS 103.49) FEET TO A POINT; THENCE ALONG A CURVE TO THE RIGHT HAVING A RADIUS OF. 15 FEET, AN ARC DISTANCE OF 26.96 FEET TO A POINT ON THE WESTERN LINE OF PENNSYLVANIA AVENUE; THENCE ALONG THE WESTERN LINE OF PENNSYLVANIA AVENUE, SOUTHWARDLY 129.97 FEET TO A POINT THE PLACE OF BEGINNING. BEING LOT NOS. 181 AND 182, SECTION "D" IN THE PLAN OF COLLEGE PARK, RECORDED IN PLAN BOOK 4, PAGE 108, CUMBERLAND COUNTY RECORDS. BEING KNOWN AS: 2001 CHESTNUT STREET, CAMP HILL, PA 17011 PROPERTY ID NO.: 01 -22- 0536 -152 TITLE TO SAID PREMISES IS VESTED IN SUTATIP GRUNDON, A MARRIED WOMAN BY DEED FROM THOMAS R. GRUNDON AND SUTATIP GRUNDON, HUSBAND AND WIFE DATED 08/11/2005 RECORDED 09/15/2005 IN DEED BOOK 270 PAGE 4827. The same having been sold by me to the said grantee on the 3rd day of April Anno Domini Two Thousand and Thirteen (2013) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 19` of October Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Twelve (2012) Number 4316 at the suit of Bank of America, N.A. -vs- Sutatip Grundon In Witness Whereof, I have hereunto affixed my signature this al7day,April Anno Domini Two Thousand and Thirteen (2013) R y . Anderson, heriff 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 17 day of April Anno Domini Two Thousand and Thirteen (2013) thonotary I hereby certify that the residence ~ ,�_� . ,•�•;:� „ �, And Post Office address of the Within Grantee is 1900 Market Street ;'� ��.••� Suite 800 Philadelphia, PA 19103 l ' Richard W. Stewart Solicitor . .....rr:m ..... r ... •.Ir VMW.i1.wr•.: «aN.pF •r - _ .. . . i. n. gnu N %.'Y.1 -- ... .. .. ..y_. .. .� .. ._... .. _ t REV -183 EX (4.10) RECORDER'S USE ONLY p, REALTY TRANSFER TAX State Tax Paid ----- pennsyt4"rmE STATEMENT OF VALUE Book Number 'GkPARiNEHI Or HEVENU[ Bureau of Individual Taxes Page Number PO BOX 280603 Harrisburg PA 17128.0603 See Reverse for Instructions Date Recorded Complete each section and file in duplicate with Recorder of Deeds when (1) the full value /consideration is not set forth in the deed, (2) the deed is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach additional sheets. A. CORRESPONDENT — All inquiries may be directed to the following person: Name Telephone Number: UDREN LAW OFFICES, PC 856 -669 -5400 Street Address ity State ZIP Code 111 WOODCREST RD., STE 200 Y HILL J 08003 B. TRANSFER DATA Date of Acceptance of Document Grantor(s) /Lessor(s) Grantees) /Lessee(s) Sheriff of Cumberland County ederal National Mortgage Association Street Address treet Address One Courthouse Square 1900 Market Street Suitt 800 City State IP Code ity State ZIP Code Carlisle A 17013 Philadelphia A 9103 C. REAL ESTATE LOCATION Street Address Pty, Township, Borough 2001 Chestnut Street orou h of Cam hill County Pchool District rax Parcel Number Cumberland Lamp Hill SD 1 -22 -0536 -152 D. VALUATION DATA 1. Actual Cash Consideration 2. Other Consideration . Total Consideration $1.456.80 $1,456.80 4. County Assessed Value 5. Common Level Ratio Factor . Fair Market Value $197,900.00 X 1.00' 1 197,900.00 E. EXEMPTION DATA — WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? ® Y N 1a. Amount of Exemption Claimed lb. Percentage of Grantor's Interest in Real Estate 1c. Percentage of Grantor's Interest Conveyed 100% 1009E 10090 2.Check Appropriate Box Below for Exemption Claimed Will or Intestate succession. ame o ec en a e i e Number El Transfer to Industrial Development Agency. ❑ Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ❑ Transfer From a trust. Date of transfer into the trust If trust was amended attach a copy of original and amended trust. ❑ Transfer between principal and agent/straw party. (Attach complete copy of agency /straw party agreement.) ❑ Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnatlon or in lieu of condemnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of Mortgage and note /Assignment.) ❑ Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ❑ Statutory corporate consolidation, merger or division. (Attach copy of articles.) ® Other (Please explain exemption claimed, If other than listed above.) Transfer from the Sheriff to a Government Agency, therefore, tax exem t. Under penalties o law, i declare that I examined is statement, linduding accompanying Inform ation, and to the best of my knowledge and belief, It Is true correct and complete 8 !3 FAILURE C LETE THIS FORM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED. .. -r. w.rrw., ✓..v.. ..w •..... .ruw ,.... w...••.- ...— yA,.,,y�� �.•i...R4M.1.i �.�.!�ry.►IANF.�Mn�+. ..,,. .. .. _- .s•.- r,�w.rM1t.MA....w..•F �M. . ,�-[ .,._ •. ..- ..w+– .'- \A.I.S!e.w.w'•n,ww+ew -. ... VERIFICATION 1. Christopher Wolfe on behalf of the Plaintiff corporation widlin named do hereby verify that the factual allegations set folill in the foregoing Comphunt are tnie and CO1TeCT TO the best of my knowledge or infonliation and belief based oil corporate sources of information. I tuiderstand that false statements there.111 are made subject to tile penalties of IS Pa. C.S. 4904 relating to wiswom falsification to authwities. Date: 7/1/2013 PRINTED NANIE: Christopher Wolfe TITLUDEPARTMENT: Asset Recovery Manager COMPANY: Fannie Mae RE04` P1302VZ p — 2oo1 Cliestt.lut Stj Cunp Hill, PA 17011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE O�OTH01�0 A 1)" p of Climber, Jody S Smith 7 Chief Deputy 7 5 -2 PM 3* 28 13 AUG Richard W Stewart CUMBERLA?4D CHMI'y Solicitor OF```E,S,4EP1FP PEWiSYLVANIA Federal National Mortgage Association vs Case Number . Sutatip Grundon 2013-3954 I SHERIFF'S RETURN OF SERVICE 0713112013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states this Complaint in Ejectment upon defendant Occupant is returned not served per request from attorney Richard J. Nalbandian, 111. 07/31/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states this Complaint in Ejectment upon defendant Sutatip Grundon is returned not served per request from attorney Richard J. Nalbandian, Ill. SHERIFF COST: $61.41 SO ANSWERS, July 31, 2013 RbNW R ANDERSON, SHERIFF (C)CountySufto Shentf,'reteosoft,Inc. FAX COVER SHEET 1310 Industrial Boulevard. I"Floor,Suite 101.Southampton,PA 18966 DATE: .July 24, 2013 TO: Sheriff's Office of Cumberland Co.-Attn: Sheri FAX NO. (717-240-639fl.. 63'-1 FROM: Naisha Keenan COMPANY: Powers, Kirn &c Javardian PHONE NO. (215) 942-9690 FAX NO: (215) 942-9695 NO. PAGES: 1 (Inel. Cover sheet) RE: Federal National Mortgage Association v. Grundon Property: 2001 Chestnut Street, Camp Hill, PA Cumberland County CCP, No. 13-3954 Dear Sheri: We have been notified by our-client that the above property is vacant. Please stop service of the Complaint in Ejectment for the above matter. It is my understanding that you have already made 2 attempts and will bill us for the services rendered thus far,but please forward any refunds due back to our office. If you should have any questions,please feel free to contact me. Thank you. Confidential This memo is intended only for the individual or entity to which it is addressed,and may contain information that is privileged,confidential or otherwise exempt from the disclosure under applicable law. If you are not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient,you are hereby notified that any dissemination,distribution,or copying of this communication is strictly prohibited. If you have received this communication in error,please notify us immediately by telephone and return the original message to us at the above address. 'Thank you.