Loading...
HomeMy WebLinkAbout13-4484 4 t Supreme Cm." Hof Pennsylvania COur , C mm0 Pleas For Prothonotary Use Only: f T' Cl it VC,S eet Docket No: s Cu gland County 3 ( `�1 / N / The information collected on this form is used solely court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons rl Petition Transfer from Another Jurisdiction Q Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Federal Home Loan Mortgage Corporation Robert W. Kohut, Janice M. Kunkle, and /or Occupants T Dollar Amount Requested: Qwithin arbitration limits I Are money damages requested? CI Yes Flc No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? [I Yes iX. No Is this an MDJAppeal? Yes Ell No A, Name of Plaintiff /Appellant's Attorney: Richard J. Nalbandian, III, Esquire Check here if you have no attorney (are a Self- Represented [Pro Se] 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 you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional M Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution El Debt Collection: Credit Card 0 Board of Assessment Motor Vehicle M Debt Collection: Other r� I Board of Elections Nuisance �' Dept. of Transportation rl Premises Liability Statutory Appeal: Other S rl Product Liability (does not include mass tort) Q Employment Dispute: E 0 Slander/Libel/ Defamation Discrimination � Employment Dispute: Other Q Zoning Board C 0 Other: � Other: , I M Other: O MASS TORT n Asbestos N 0 Tobacco Toxic Tort - DES Q Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS C 1 Toxic Waste ix' Ejectment M Common Law /Statutory Arbitration B Other: M Eminent Domain /Condemnation 0 Declaratory Judgment El Ground Rent rl Mandamus M Landlord /Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial Q Quo Warranto ®' Dental r_,1 Partition Q Replevin M Legal 0 Quiet Title l Other: 0 Medical Other: Other Professional: Updated 1/1/2011 Lk"J- OFF p- POWERS, KIRN & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 LF�,� ; Il i MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 CUMBERLAND COUN1 - SEAN P. MAYS, ESQUIRE Id No. 307518 P ENNSYLVANIA RICHARD J. NALBANDIAN, III, ESQUIRE Id No. 312653 1310 INDUSTRIAL BOULEVARD 2 FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215 ) 942 -2090 ATTORNEYS FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court of Common Pleas 8200 Jones Branch Drive McLean, VA 22102 Civil Division Plaintiff vs. Cumberland /County f Robert W. Kohut No. Janice M. Kunkle And/Or Occupants COMPLAINT IN EJECTMENT 1363 Kiner Boulevard Carlisle, PA 17013 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. 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249 -3166 n (800) 990 -9108 POWERS, KIRN & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE ID No. 55669 MARY F. KENNEDY, ESQUIRE ID No. 77149 MEGHAN K. BOYLE, ESQUIRE ID No. 201661 SEAN P. MAYS, ESQUIRE ID No. 307518 RICHARD J. NALBANDIAN, III, ESQUIRE ID No. 312653 1310 INDUSTRIAL BOULEVARD 1 sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942 -9690 ATTORNEYS FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court of Common Pleas 8200 Jones Branch Drive McLean, VA 22102 Civil Division Plaintiff Cumberland County VS. No. Robert W. Kohut Janice M. Kunkle COMPLAINT IN EJECTMENT And /Or Occupants 1363 Kiner Boulevard Carlisle, PA 17013 Defendants COMPLAINT - CIVIL ACTION 1. Federal Home Loan Mortgage Corporation (hereinafter referred to as "Plaintiff') is a Corporation conducting business under the laws of the Commonwealth of Pennsylvania and brings this action against Robert W. Kohut, Janice M. Kunkle, and /or Occupants (hereinafter referred to as "Defendants "). 2. Defendants Robert W. Kohut and Janice M. Kunkle are adult individuals presently residing and occupying the premises at 1363 Kiner Boulevard, Carlisle, PA 17013, more fully described in the legal description as Exhibit "A ". 3. Plaintiff is the owner of the aforesaid premises, which real estate is fully described in Exhibit "A ". 4. Plaintiff purchased the aforesaid premises at the March 6, 2013 Sheriff s sale. 5. Plaintiff is the owner of the premises where Defendants reside by virtue of a Sheriffs Deed recorded May 7, 2013, a copy of which is attached as Exhibit `B ". 6. Defendants have no valid legal right to possession and title to the premises. 7. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants. WHEREFORE, Plaintiff, respectfully requests that this Court enter judgment for Possession against Defendants Robert W. Kohut, Janice M. Kunkle, and Occupants with respect to the aforesaid premises at 1363 Kiner Boulevard, Carlisle, PA 17013. ❑Gregory Javardian, Esquire Id. No. 55669 ❑Mary F. Kennedy, Esquire Id. No. 77149 ❑Me an 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" ALL THAT CERTAIN tract of with the improvements thereon situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a nail in the centerline of Township Road No. 564 (Kiner Boulevard), on the Western line of a private right -of -way; thence along the latter, South 11 35 55 East, a distance of 590.33 fat to an iron pin on the line of land now or formerly of Dennis B. Gotthard; thence along the latter, South 80010' 00 West, a distance of 180.00 feet to an iron pin on the line of land now or formerly of Elmer R. Reed; thence along the latter, North 1133 58 West, a distance of 597.13 feet to a nail in the centerline of said Township Road; thence along the latter, North 82 20 02 East, a distance of 180.00 feet to a nail, the place of BEGINNING. CONTAINING 2.4500 acres and being described according to a survey for Lester I. Smith,, et ux, by Eugene A. Hockensmith, R.S., dated December 8, 1978. BEING KNOWN AS: 1363 Kiner Boulevard, Carlisle, PA 17013 PARCEL #22 -25- 0047 -014 ...u.•. •.•.• w ww ..�. w ...- .......�+. ..r. -w .�. ww -r Y• w-.•. • w •r M• w - .r •..•....r•...+.... . EXHIBIT "B" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY i 1 COURTHOUSE SQUARE °- CARLISLE, PA 17013 717- 240 -6370 - Instrument Number - 201314817 Recorded On SnI2013 At 8:44:51 AM * Total Pages - 5 * Instrument Type - DEED- SHERIFF'S Invoice Number - 136157 User ID - BMM * Grantor - KOHUT, ROBERT W * Grantee - FEDERAL HOME LOAN MTG CORP " Customer - SHERIFF FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING PEES - $12.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $10.00 of this legal document. FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND 'VALLEY SCHOOL $0.00 DISTRICT MONROE TOWNSH $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA o� ouga 0 ° RECORDER O D .EDS �s6o • - Informntion denoted by an a sterisk may change during; the verification process and may not be reflected on this page. 012YIU III III11NlIIIII�N�I�I I1 l.I 1� •a� my su Tax Parcel No. 22-25.0047 -014 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 S 1.00 (One Dollar) to me in hand paid, do hereby grant and convey Federal Home Lose Mortgage Corporation 2011.8505 C1vn Term Suntrust Mortgage, Inc. F/K/A Crestar Mortgage Corporation Vs Robert W. Kohut Janice M. Kuakle ALL THAT CERTAIN tract of with the improvements thereon situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a nail in the centerline of Township Road No. 564 (Kiner Boulevard), on the Western line of a private right -of -way; thence along the latter, South 11 35 5S East, a distance of 590.33 feet to an iron pin on the line of land now or formerly of Dennis B. Gotthard; thence along the latter, South 80019 00" West, a distance of 180.00 feet to an iron pin on the line of land now or formerly of Elmer R. Reed; thence along the latter, North 1133 58 West, a distance of 597.13 feet to a nail in the centerline of said Township Road; thence along the latter, North 82 20 02 East, a distance of 180.00 feet to a nail, the place of BEGINNING. CONTAINING 2.4500 acres and being described according to a survey for Lester E. Smith, et ux, by Eugene A. Hockensmith, R.S., dated December S. 1979. BEING THE SAME PREMISES which Harold S. Davis, Jr. and Linda L. Davis, husband and wife, by Deed dated May 8, 1997 and recorded May 15, 1997 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book Volume 157, Page 669, granted and conveyed unto Robert W. Kohut and Janice M. Kunkle, joint tenants with the right of survivorship. BEING KNOWN AS: 1363 Kiner Boulevard, Carlisle, PA 17013 PARCEL #22 -25 -0047 -014 The same having been sold by me to the said grantee on the Gtb day of March Anno Domini Two Thousand and Thirteen (2013) aft due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 1st of October Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eleven (2011) Number 8505 at the suit of Santrust Mortgage, Inc. F/IUA Crestar Mortgage Corporation —vs- Robert W. Kohut Janice M. Kunkle In witness Whereof, I have hereunto affixed my signature this 9th d of April Am Dontini Two Thousand and Thirteen (2013) 74 — '— nny Anderson, Sheri ff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, peasonally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due farm 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 9th day of April Anno Domini'Iwvo Thousand and Thirteen (2013) Pro otary tort 2M i hereby certify that the residence And Post Office address of the Within Grantee is `t`rlrrttr 8200 Jones Branch Drive %%N �G ,����i McLean, VA 22102 SM ::... • •; �; •� :� r :: Richard W. Stewart ���' ^ �;'.•` Solicitor nEwua EX(oi•16) RECORDERS USE ONLY REALTY TRANSFER TAX Soft Ta FOG awnwtvanta STATEMENT OF VALUE ahh�.aertaaTe > PO BOX trPA a98-0oa See reverse for instructions. .. Complete each section and Ale in dupneate with Recorder of Deeds when (t) the full valu%cnslderation is not set forth in the deed, (2) the deed is without consideration or by ^ or (3) a tax exemption D claimed. A statement of Value is not required If the transfer Is wholly exempt from tax based on famly retattonshtp or pubpc utinty easemg. V more apace is needed, attach additional sheets. A. CORRESPONDENT— All Inquiries may be directed to the foUohhring Parse Numb Nam Powers, IQm S Javardian. LLC 1 942-9600 NOM Addren Qh State ZIP Code 1310 industrial Blvd Ste 101 soulftempton I PA 18888 B. TRANSFER DATA C. Date of Aete gWm of Doetmsent Gutor(s)/ Wor(s) Grantee(SyLessee(s) Sheriff of Cumberland Fedwal Home Loan Mortgage COMOT81110n WMq res Mal9ng one Courthouse Square 8200 Jonas Branch Drive State 11P Sete ZIP Code Carme PA 117013 McLean I VA 22102 D. REAL ESTATE LOCATION Address Qtr, T"Mhip, Borough 1383 Kim Boulevard SdhoW oavlct lfahr Parcel rpanoer Cumberland Cumberland Vall Z2 25.0047 -014 rla L VALUATION DATA • WAS TRANSACTION PART OF AN ASSIGN14 NT OR RELOCATION? 1. Acsual Cash CoralderStIwh 2. Other cord ersaft 3.1bbd Consideration 1.328.35 +0.00 = 1.328.35 4. County Assessed ue S. Common Level RAW Pacbor 6. fair Market VVA 228 X 1..00 a 228.400.00 F. EXEMPTIOIIIOATA is. Amount of E mnptlon Oatmed lb. Percentage of Grantors (ntarast in Real &lobe It Oe"eantage of Geahhtars Interest Canreyad 100.00 100 100 Check Appropriate Box Below for Exemption Claimed. [j win or intestate succession. ease Q Transfer to a trust. (Attach complete copy of trust agreement Identifying all beneficiaries.) E3 Transfer from a trust. Date of transfer into the trust If trust was amended attach a copy of original and a e (3 Transfer between principal and agent/straw party. (Attach complete Copy of agency/straw party agreanent) Q Transfers to the commonwealth, the U.S. and Instrumentalities by gift, dedication, condemnation or In lieu of con- demnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) 0 Transfer from mortgagor to a holder of a mortgage in default (Attach copy of mortgage and note/assigrtment) Q Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) Q Statutory corporate consolidation, merger or dividon. (Attach copy of articles.) ® Other (Please explain exemption dalr ted.) transfer tax Is not assessable as the grantee h a g overnment agency. the � of my itnewladpedend and to b is ave true, l and complete. Date including aocompanyln9 laforatatlon, or Pa Date 03=13 FAILURE O O�� L ST TO�RECORD THE PROPERLY OR REQUESTEQ DOCUMENTATION MAY RESULT IN VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: Q Name: Title: Ellzc�beth T + r j r Asslsll r' Federal Home Loan Mortgage Corporation Elizabeth. TaylOr-Cou s Assi a.n Tr ri r 1363 Kiner Boulevard, Carlisle, PA 17013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r E' rt, Sheriff 'THE t' C7 ]�Klit-i Jody S Smith �``���,�$33 �� Chief Deputy 12013 G 12 AN j0= �1 Richard W Stewart C,1JM8EKLAHD COUN `r Solicitor Orr: E CrTt4E WERIFr PENNSYLVANIA Federal Home Loan Mortgage Corporation vs. Case Number Robert W. Kohut(et al.) 2013-4484 SHERIFF'S RETURN OF SERVICE 08/05/2013 07:06 PM- Deputy Jeff Kolodzi, 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: Janice M. Kunkle at 400 Independence Court, Silver Spring Township, Mechanicsburg, PA 17 0. JEF DZI, DEPUTY 08/07/2013 03:54 PM- Deputy Jason Kinsler, 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: Robert W. Kohut at 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17015. JASON KINSLER, DEPUTY 08/07/2013 03:54 PM- Sheriff Ronny R Anderson, 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 Served"at 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17013. Deputies were advised that there are no other occupants other than the defendent. JASON KINSLER, DEPUTY SHERIFF COST: $78.54 SO ANSWERS, V August 08, 2013 RbNW R ANDERSON, SHERIFF Vic)CountySuite Sheriff,Tcleosoft Inc. 1- POWERS, KIRN & JAVARDIAN, LLC ' GREGORY JAVARDIAN, ESQUIRE ID No. 55669 , ' JILL MANUEL-COUGHLIN, ESQUIRE ID No. 63252 ;CM rn r MARY F. KENNEDY, ESQUIRE ID No. 77149 Cn i ry c MEGHAN K. BOYLE, ESQUIRE ID No. 201661 SEAN P. MAYS, ESQUIRE ID No. 307518 RICHARD J.NALBANDIAN, III, ESQUIRE ID No. 312653 1310 INDUSTRIAL BOULEVARD °} -; 2nd FLOOR, SUITE 202 SOUTHAMPTON,PA 18966 ~ (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division VS. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kunkle And/Or Occupants Defendant(s) PRAECIPE FOR JUDGMENT OF POSSESSION TO THE PROTHONOTARY: Kindly enter judgment for Possession of the premises 1363 Kiner Boulevard, Carlisle,PA 17013 in favor of Federal Home Loan Mortgage Corporation against Robert W. Kohut, Janice M. Kohut, and Occupants due to Defendants' failure to file an Answer within twenty(20) days from Service of the Complaint in Ejectment. Date: �d O G g Javardian, Esquire ID 55669 ill anuel-Coughlin, Esquire I o. 63252 O Mary F. Kennedy, Esquire ID No. 77149 O Meghan K. Boyle, Esquire ID No. 201661 []Sean P. Mays,Esquire Id.No. 307518 ORichard J.Nalbandian, III, Esquire ID No. 312653 Attorney for Plaintiff $1 .50 pf1T l eq ISa e a459 s d Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kunkle And/Or Occupants Defendant(s) VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is the attorney for the Plaintiff in the above- captioned matter, and that on information and belief, he/she has knowledge of the following facts,to wit: (a) Plaintiff is unable to determine if Defendant Robert W. Kohut, Janice M. Kohut are in the Military of Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C.S. Appx. §§501 et seq., because it is unaware of the date of birth or social secutiry number of the Defendant. (b) Defendant, Robert W. Kohut and Janice M. Kohut is over 18 years of age, and resides at 1363 Kiner Boulevard,Carlisle,PA 17013. (c) Plaintiff, Federal Home Loan Mortgage Corporation, is an institution conducting business under the Laws of the Commonwealth of Pennsylvania with an address o£ 8200 Jones Branch Drive,McLean,VA 22102. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: (!W ❑qtr ry Javardian, Esquire 5669 ill anuel-Coughlin, Esquire ID No. 63252 ❑Mary F. Kennedy, Esquire ID No. 77149 ❑Meghan K. Boyle, Esquire ID No. 201661 El Sean P. Mays,Esquire Id. No. 307518 ❑Richard J.Nalbandian,III, Esquire ID No. 312653 Attorney for Plaintiff POWERS, KIRN & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE ID No. 55669 JILL MANUEL-COUGHLIN, ESQUIRE ID No. 63252 MARY F. KENNEDY, ESQUIRE ID No. 77149 MEGHAN K. BOYLE, ESQUIRE ID No. 201661 SEAN P. MAYS,ESQUIRE ID No. 307518 RICHARD J.NALBANDIAN, 111, ESQUIRE ID No. 312653 1310 INDUSTRIAL BOULEVARD 2nd FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kunkle And/Or Occupants Defendant(s) CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default was mailed to the Defendants and to his/her/their attorney of record, if any, after the default occurred and at least ten(10)days prior to the date of the filing of the Praecipe. Said notice was sent on the date set forth in the copy of said notice attached hereto and marked Exhibit "A." Date: rego Ja ardian, Esquire ID No 5669 ill Manuel-Coughlin, Esquire ID N . 63252 ❑Mary F. Kennedy, Esquire ID No. 77149 ❑Meghan K. Boyle, Esquire ID No. 201661 ❑Sean P. Mays, Esquire Id.No. 307518 ❑Richard J.Nalbandian,111, Esquire ID No. 312653 Attorney for Plaintiff s EXHIBIT `A' Federal Horne Loan Mortgage Corporation Court of Common Pleas Plaintiff' Civil Division vs. Cumberland County Robert W. Kohut Janice M. Kohut No. 2013-4484 And/Or Occupants Defendants TO: Robert W. Kohut Janice M. Kohut Occupants 1363 Kiner Boulevard 1363 Kiner Boulevard 1363 Kiner Boulevard Carlisle, PA. 17013 Carlisle, PA 17013 Carlisle, PA 17013 DATE OF NOTICE: August 28,201.3 NOTICE, RULE 237.1 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 objections to the claims se 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. IfyOU 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. Cumberland County.Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717)249-3166 (800)990-9108 Richard .l. Nalbandian, 1.11, Esquire 1310 Industrial Boulevard 21 id Floor, Suite 202 Southampton, Pa 18966 (215)942-2090 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez(10) dias de esta notification, el tribunal podra, sin necesidad de compararecer Listed en torte o escuchar prueba alguna, dictar sentencia en su contra, Listed puede perder bienes y otros derechos importantes. Debe llevar esta notification a Lin abogado immediatemente Si Listed no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. ATTORNEY FILE COPY OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: Robert W. Kohut 1363 Kiner Boulevard Carlisle, PA 17013 Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kohut And/Or Occupants Defendant(s) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. _Judgment by Default _Money Judgment Judgment in Replevin X Judgment for Possession by Default _Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Gregory Javardian, Esquire at this telephone number: (215) 942-2090. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: Janice M. Kunkle 1363 Kiner Boulevard Carlisle, PA 17013 Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division vs. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kohut And/Or Occupants Defendant(s) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. _Judgment by Default Money Judgment _Judgment in Replevin X Judgment for Possession by Default _Judgment on Award of Arbitration Judgment on Verdict _Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Gregory Javardian, Esquire at this telephone number: (215) 942-2090. A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: Occupants 1363 Kiner Boulevard Carlisle,PA 17013 Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division VS. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kohut And/Or Occupants Defendant(s) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. _Judgment by Default _Money Judgment Judgment in Replevin X Judgment for Possession by Default _Judgment on Award of Arbitration _Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Gregory Javardian,Esquire at this telephone number: (215)942-2090. POWERS, KIRN & JAVARDIAN, LLC GREGORY JAVARDIAN, ESQUIRE ID No. 55669 �- JILL MANUEL-COUGHLIN, ESQUIRE ID No. 63252 MARY F. KENNEDY, ESQUIRE ID No. 77149 x M r r, MEGHAN K. BOYLE, ESQUIRE ID No. 201661 , SEAN P. MAYS,ESQUIRE ID No. 307518 r–= RICHARD J.NALBANDIAN, III, ESQUIRE ID No. 312653 ° c --; 1310 INDUSTRIAL BOULEVARD - c 2nd FLOOR, SUITE 202 r Y SOUTHAMPTON,PA 18966 � ' (215) 942-2090 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation Court Of Common Pleas Plaintiff Civil Division VS. Cumberland County Robert W. Kohut No. 2013-4484 Janice M. Kunkle And/Or Occupants Defendant(s) PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Please issue a WRIT OF POSSESSION in the above matter, for possession of: 1363 Kiner Boulevard Carlisle, PA 17013 Date: 3 0, ]]A O Grego avar ian, Esquire ID No. 55 6 Pp P vi ll M el-Coughlin, Esquire ID No. 6 2 X616•bO ❑Mary F. Kennedy,Esquire ID No. 77149 q8.s CBS ❑Meghan K. Boyle,Esquire ID No. 201661 ❑Sean P. Mays, Esquire Id.No. 307518 ❑Richard J.Nalbandian, III, Esquire ID No. 312653 aa`1.029 pA �7 N Attorney for Plaintiff 01..025 �� area J lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION VS. No. 13-4484 Civil Term_ ROBERT W.KOHUT JANICE M. KUNKLE And/Or OCCUPANT Costs Attorney's $ 227.29 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 HOME LOAN MORTGAGE CORPORATION being: (Premises as follows): 1363 KINER BOULEVARD, CARLISLE,PA 17013 (see attached legal 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. David D.Buell,Prothonotary, Common Pleas Court of Cumberland County, PA Date 9/20/13 E (Seal) f 2 of 2 No 13-4484 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA FEDERAL HOME LOAN MORTGAGE CORPORATION VS. ROBERT W.KOHUT JANICE M.KUNKLE And/Or OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 227.29 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: JILL MANUEL-COUGHLIN, ESQUIRE - ID#63252 POWERS,KIRK, &JAVARDIAN,LLC 1310 INDUSTRIAL BOULEVARD 2"D FLOOR, SUITE 202 SOUTHAMPTON, PA 18966 215-942-2090 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 w ALL THAT CERTAIN tract of with the improvements thereon situate in Monroe Township, Cumberland County,Pennsylvania,bounded and described as follows: BEGINNING at a no in the centerline of Township Road No.564(King Boulevard),on the Western line of a private right-of-way;thence along the latter,South It 35 55 East,a distance of 590.33 feet to as iron pin on the line of land now or formerly of Dennis B.Gotthard;thence along the latter,South 80010'00°West,a distance of 180.00 feet to an iron pin on the line of land now or formerly of Elmer R.Reed;thence along the latter,North 1133 58 West,a distance of 597.13 feet to a nail in the centerline of said Township Road;thence along the latter,North 82 20 02 East,a distance of 180.00 feet to a nail,the place of BEGINNING. CONTAINING 2.4500 acres and being described according to a survey for Lester E.Smith,et ux,by Eugene A.Hockensmith,R.S.,dated December 8, 1978. BEING KNOWN AS:1363 Kiner Boulevard,Carlisle,PA 17013 PARCEL#22-25-0047-014 •rr w.�• t ww w•�•�..�.•.w.wY.f•MwY••M.•w./f�..f•-rq•w wyw. • w . r.-..•r•.w•r+.. • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith bi t ai tar,� 4, Chief Deputy _ n13 OCT -3 PM 2: Li 2 Richard W Stewart Solicitor op c;,,,.r 14,E. , .ra :.;U iBERLr' to COUNT,"t PENNSYLVANIA Federal Home Loan Mortgage Corporation Case Number vs. Robert W. Kohut(et al.) 2013-4484 SHERIFF'S RETURN OF SERVICE 09/24/2013 07:39 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Janice M. Kunkle at 400 Independence Court, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 10/02/2013 10:05 AM- Deputy William Cline, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Robert W. Kohut at 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17015, Cumberland County, informed Defendant of contents of same. 10/03/2013 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 of 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17013, but was unable to locate the Defendant in his bailiwick. The only resident of 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17013 is defendant Robert W. Kohut. The Sheriff therefore returns the within requested Writ of Possession as"Not Found"as to defendant OCCUPANT. SO ANSWERS, October 03, 2013 RONR ANDERSON, SHERIFF (u)Cou^:tySui;o harit':"re,osot i..,,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 7 ' Jody S Smith Chief Deputy a A d 21013 NOV 25 PM 1: 25 a Richard W Stewart CUMBERLAND GQUN 1 Solicitor v, �c,Fr" `�' PENNSYLVANIA Federal Home Loan Mortgage Corporation Case Number vs. Robert W. Kohut(et al.) 2013-4484 SHERIFF'S RETURN OF SERVICE 09/24/2013 07:39 PM-Deputy Jamie DiMartle, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Janice M. Kunkle at 400 Independence Court, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 10/02/2013 10:05 AM- Deputy William Cline, being duly sworn according to law, served the requested Writ of Possession by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Robert W. Kohut at 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17015, Cumberland County, informed Defendant of contents of same. 10/03/2013 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 of 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17013, but was unable to locate the Defendant in his bailiwick. The only resident of 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17013 is defendant Robert W. Kohut. The Sheriff therefore returns the within requested Writ of Possession as"Not Found"as to defendant OCCUPANT. 11/18/2013 Possession scheduled for this date NOT GRANTED. Rescheduled for November 21, 2013. 11/21/2013 By virtue of this writ, Sheriff Ronny R.Anderson caused the within named Plaintiff to have possession of the premises described as 1363 Kiner Boulevard, Carlisle, PA 17015. SHERIFF COST: $120.06 SO ANSWERS, oZ, x November 22, 2013 RONRY R ANDERSON, SHERIFF a- Pa -�. X399 ;cu:ntySw:e Shenf,7c�eosefr. nc.