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HomeMy WebLinkAbout13-5521 Supreme Court of Pennsylvania Count f Commoia Pleas - - - - 't ' lk.- \ ` For Pt Lase 01111': Gn° Co_er Sheet Cumbeirlall f' , county Docket No: - The information collected on this form is used solely for 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: X Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: C FEDERAL NATIONAL MORTGAGE ASSOCIATION JAMESON E. CHRISTOPHER T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO Name of Plaintiff/appellant's Attorney: KML LAW GROUP, P.C. ❑ Check here if you 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 APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination C ❑ Employment Dispute: Other ❑ Other ❑ Other: 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort -Implant ❑ Toxic Waste ® Ejectment ❑ Common Law /Statutory B ❑ Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent 1 ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ❑ Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin • Medical • Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 FUlm too KML LAW GROUP, P.C. �=,, Suite 5000 BNY Mellon Independence Center X 701 Market Street c , - Philadelphia, PA 19106 CD (215) 627 -1322 >I r µ' co Attorney for Plaintiff' FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254 -2942 Plaintiff IN THE COURT OF COMMON PLEAS vs. OF CUMBERLAND COUNTY JAMESON E. CHRISTOPHER CIVIL ACTION - LAW and OCCUPANTS 131 East Louther Street ACTION OF EJECTMENT Carlisle, PA 17013 Defendants Term No. i3' `J) �IVtI �P� 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 the 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 claim in the Complaint of 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 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 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC � i o3. q.6 PA Am 8 Irvine Row, Carlisle, PA 17013 e 7�B-jza- 717- 243 -9400 1�#495 8q5 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238 -6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717 - 243 -9400 COMPLAINT IN EJECTMENT 1. Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION, with an address of 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254 -2942. 2. Defendants are JAMESON E. CHRISTOPHER, and OCCUPANTS. 3. Attached hereto as Exhibit A 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 the Plaintiff is the owner of the property located at 131 East Louther Street, Carlisle, PA 17013. 4. Plaintiff contends that it is entitled to immediate possession of the Property. 5. Upon information and belief, that Defendants, JAMESON E. CHRISTOPHER and OCCUPANTS are occupying the property without right, and so far as the Plaintiff is informed, without claim of title. 6. Attached hereto as Exhibit B is a true and correct copy of letter reflecting that 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. By: '�k V� LA GROUP, P.C. Jay E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff VERIFICATION I. Christopher Wolfe on behalf of Plaintiff corporation withilinanied do hereby verify that the factual allegations set forth iii tl foregoing Complaint are true and correct to the best of my knowledge or information and belief based On corporate sources and information. I understand that false statenients therein are made subject to the penalties of 18 P.S. §4904 relating to unsworn. falsification to authorities. Date: 8/8/2013 FEDERAL NATIONAL MORTGAGE ASSOCIATION Printed Nal /e.. Christopher Wolfe Tifle/Depaitinent: Asset Recovery Manager Company: Fannie Mae FILE#': 123044EJ REO 11)14: P13058P PROPERTY: 131 East Louthef Street Carlisle PA 17013) DEFENDANT: CHRISTOPHER., JAMESON E. EXHIBIT "A" SHERIFF'S DEED FILE #: 123044EJ PROPERTY: 131 East Louther Street Carlisle PA 17013 , p ✓ a� 0030PU Tax Parcel No. 02 -21- 0318 -206 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 to Federal National Mortgage Association 2009 -736 Civil Term JPMorgan Chase Bank, N. A., As Acquirer of Certain Assets and Liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation Acting as Receiver F /K/A Washington Mutual Bank F.A. Vs Jameson E. Christopher ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Louther Street; on the East by property now or formerly of John Wardecker and now or formerly of John D. Meck; on the North by Locust Alley; and on the West by property now or formerly of George N. Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. TAX PARCEL #: 02 -21- 0318 -206 BEING PREMISES: 131 EAST LOUTHER STREET, CARLISLE PA 17013 MUNICIPALITY: BOROUGH OF CARLISLE IMPROVEMENTS consist of a residential dwelling. BEING the same premises which Scott S. Hencb, married man by deed dated 7/30/1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher SOLD as the property of JAMESON E. CHRISTOPHER The same having been sold by me to the said grantee on the 5th day of June 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 11th of December Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 736 at the suit of JPMorgan Chase Bank, N. A., As Acquirer of Certain Assets and Liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation Acting as Receiver F/K/A Washington Mutual ,Bank F.A. --vs- Jameson E. Christopher i In Witness Whereof, I have hereunto affixed my signature this 3rd of July Anno Domini Two Thousand and Thirteen (2013) Ronn R. Anderson, Sheriff 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 3rd day of July Anno Domini Two Thousand and Thirteen (2013) i - 4Pr ono tar p avS t I `t• Wothoeotary Cumberimsd County, Ca�rHsk,.PA My Commission Expires the First M-dxy d m. M4 I hereby certify that the residence And Post Office address of the Within Grantee is 14221 Dallas Parkway Suite 1000 Dallas, TX 75254 Richard tewart Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS L T. CUMBERLAND COUNTY 1 COURTHOUSE SQUARE - tC- y CARLISLE, PA 17013 717 -240 -6370 - Instrument Number - 201324170 Recorded On 7/23/2013 At 4:36:31 AM * Total Pages - 5 * Instrument Type - DEED - SHERIFF'S Invoice Number - 142625 User ID - BMM * Grantor- CHRISTOPHER, JAMESON E * Grantee - FEDERAL NATIONAL MTG ASSOC * Customer - 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 This page is now part PARCEL CERTIFICATION $15.00 FEES of this legal document. 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 $68.00 I Certify this to be recorded in Cumberland County PA �y a p c vAr�� RECORDER OF D ED •ryao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0030PU 1111I f II1 IlII1411111 I1 III EXHIBIT "B" NOTICE TO VACATE • KML LAW GROUP, P.C. SUITE 5000 TINY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 W W W. KM LLA W GROUP. COrI August 5, 2013 NOTICE TO VACATE PROPERTY TO: JAMESON E. CHRISTOPHER and all Occupants 131 East Louther Street Carlisle, PA 17013 KML File #: 123044EJ NOTICE IS HEREBY GIVEN THAT FEDERAL NATIONAL MORTGAGE ASSOCIATION, purchased the property located at 131 East Louther Street Carlisle, PA 17013 (the "Property ") at a foreclosure sale held on Wednesday, June 05, 2013, and that a Sheriff's Deed to FEDERAL NATIONAL MORTGAGE ASSOCIATION was recorded on July 23, 2013. NOTICE IS FURTHER GIVEN THAT: 1. Within ten (10) days after service on you of this Notice, if you were the mortgagor and/or previous owner of the Property or any person who is not a bona fide tenant or subtenant; or 2. Within ninety (90) days after service on you of this Notice, in the event that you are a bona fide tenant or a subtenant of the mortgagor and/or prior owner of the Premises, or a bona fide tenant or subtenant of a successor in interest to said mortgagor and /or prior owner: You are required to vacate and surrender possession of the Property, or the portion of the Property in which you reside, to FEDERAL NATIONAL MORTGAGE ASSOCIATION through ANDREW SAFT, it's agent, who can be reached at 717 - 761 -6300 0107 during normal business hours, unless you provide evidence to this office that you are a bona fide tenant pursuant to Section 702(a)(2)(A) of the federal "Protecting Tenants at Foreclosure Act of 2009" ( "PTFA ") or are protected by Section 703 of the PTFA. Please see page 2, the Addendum to this Notice, for instructions on how to deliver this evidence. If within the applicable period as set forth above, EITHER you fail to surrender possession OR if you fail to provide evidence that you are a bona fide tenant pursuant to Section 703 (a)(2)(A) of the PTFA or are protected under Section 703 of the PTFA, FEDERAL NATIONAL MORTGAGE ASSOCIATION will commence ejectment proceedings against you to recover possession of the Premises. Fannie Mae previously delivered its "Knowing Your Options" document to you. Fannie Mae has either not received a response from you or has not received information that you are entitled to additional protections under the Protecting Tenants at Foreclosure Act of 2009. If you did not receive Fannie Mae's "Knowing Your Options" document or you believe you are entitled to additional protections under state or federal law, please contact this office immediately. If you are a Servicemember or a Dependent, as defined under Section 101 of the Servicemembers Civil Relief Act (SCRA), you may be entitled to additional protections. Please provide us with proof that you are a Servicemember or a Dependent immediately, so that your eligibility for additional rights may be determined. • This Notice is given pursuant to the provisions of PTFA. KML LAW GROUP, P.C. Valerie Merritt — Legal Assistant, Eviction Department mailto:vmerritt@kmllawgroup.com 215- 825 -6319 (Direct Phone) 215- 825 -6419 (Fax) Barbara Groark — Manager mailto:bgroark@kmllawgroup.com 215- 825 -6314 (Direct Phone) 215- 825 -6441 (Fax) ADDENDUM TENANT INFORMATION IF YOU ARE A TENANT of the prior owner, you must provide the following documents within 10 days: • A copy of your lease or rental agreement • A return phone number and the best time to reach you • The receipt (or other proof) for the last six (6) payments made to the landlord for the residence by mail, fax, or in person to: Attn: Valerie Merritt / Barbara Groark KML LAW GROUP, P.C. Suite 5000, BNY Independence Center 701 Market Street Philadelphia, PA 19106 215- 825 -6419 (Fax) For any questions, please call 215- 825 -6319 PARA ASISTENCIA EN ESPANOL LLAME AL (215) 825 -6344. IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS: PROTECTIONS UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT If you are a servicemember on "active duty" or "active service," or a dependent of such a servicemember, you may be entitled to certain legal rights and protections, including protection from eviction, pursuant to the Servicemembers Civil Relief Act (50 USC .App. §§ 501 -596), as amended, (the "SCRA ") and, possibly, certain related state statutes. Eligible service can include: 1. active duty (as defined in section 101(d)(1) of title 10, United States Code) with the Army, Navy, Air Force, Marine Corps, or Coast Guard; 2. active service with the National Guard; 3. active service as a commissioned officer of the National Oceanic and Atmospheric Administration; 4. active service as a commissioned officer of the Public Health Service; or 5. service with the forces of a nation with which the United States is allied in the prosecution of a war or military action. Eligible service also includes any period during which a servicemember is absent from duty on account of sickness, wounds, leave, or other lawful cause. If you are such a servicemember, or a dependent of such a servicemember, you should contact David Fein, Esquire at (215) 825 -6318 to discuss your status under the SCRA. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff =c J I ?' vitv;11Xr 4St t;artP!"llp Jody S Smith -J 1 3 OCT 17 All n: Chief Deputy Richard W Stewart r-LIM ?cr i_,` i"ii LLFI_,a Solicitor orKF o Frw:E - PENNSYLVANIA Federal National Mortgage Association vs. Case Number Jameson E. Christopher 2013-5521 SHERIFF'S RETURN OF SERVICE 09/30/2013 10:26 AM- Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representin themselves to be t r ? //3/ BRIAN GR :O%1IDEPUTY 10/15/2013 03:17 PM-Served the requested Complaint in Ejectment b " n r resenting themselves nt to wit: RYA dip D, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, October 16, 2013 RONNY R ANDERSON, SHERIFF tc)Cou t,Su,e Sherif`"To eosof .u. KML LAW GROUP,P.C. FILED-OFFICE Suite 5000-BNY Independence Center OF THE PROTHONOTARY 701 Market Street ����DEC � � P� �• 23 Philadelphia,PA 19106-1532 215-825-6319 CUMBERLAND COUt� Attorney for Plaintiff TY A FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway,Suite 1000 IN THE COURT OF COMMON Dallas,TX 75254-2942 PLEAS Plaintiff vs. of Cumberland County JAMESON E. CHRISTOPHER CIVIL ACTION-LAW and OCCUPANTS 131 East Louther Street ACTION OF EJECTMENT Carlisle,PA 17013 Defendants Term No. 2013-05521 PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff,FEDERAL NATIONAL MORTGAGE ASSOCIATION and against the Defendants JAMESON E. CHRISTOPHER and OCCUPANTS for failure to file an Answer in the above action within(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 Defendants,a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is FEDERAL NATIONAL MORTGAGE ASSOCIATION, 14221 Dallas Parkway, Suite 1000,Dallas, TX 75254-2942 and that the names and last known address of the Defendants are JAMESON E. CHRISTOPHER and OCCUPANTS 131 East Louther Street,Carlisle,PA 17013. By: 'w KML LAW GRO P P.C. i Jay E.Kivitz Pa.ID 26769 Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 2761.5 Salvatore Filippello Pa.ID 313897 Attorneys for Plaintiff a fo 1b,_-ZpJa I d7 Lw KML LAW GROUP,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-825-6319 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION IN THE COURT OF COMMON 14221 Dallas Parkway,Suite 1000 PLEAS Dallas,TX 75254-2942 Plaintiff of Cumberland County VS. CIVIL ACTION-LAW JAMESON E.CHRISTOPHER and OCCUPANTS ACTION OF EJECTMENT 131 East Louther Street Carlisle,PA 17013 Term Defendants No. 2013-05521 CERTIFICATION PURSUANT TO PA R.C.P.NO.237 I, Bethany Stewart, an employee of KML LAW GROUP, P.C., counsel for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail,postage prepaid: JAMESON E. CHRISTOPHER 131 East Louther Street Carlisle,PA 17013 OCCUPANTS 131 East Louther Street Carlisle,PA 17013 By K L LAW O ,P.C. Bethany SteNkarf,Legal Assistant 215-627-1322(Main Phone) DATED: /,T e4,2D43 KML LAW GROUP,P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARKET St*ti iF'jr PHILADELPHIA,PA 1.9106 (215)627-1322 ATTORNEX FOH PLAINTIFF FEDERAL NATIONAL MORTGAGE ASSOCIATION IN THE COURT OF COMMON PLEAS 14221 Dallas Parkway,Suite 1000 OF Cumberland COUNTY Dallas,TX 75254-2942 Plaintiff CIVIL ACTION-LAW vs. JAMESON E.CHRISTOPHER ACTION OF EJECTMENT and OCCUPANTS 131 East Louther Street Term Carlisle,PA 17013 No.2013-05521 Defendants DATE OF THIS NOTICE: October 25,2013 TO: OCCUPANTS 131 East Louther Street Carlisle,PA 17013 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 SET FORTH AGAINST YOU. UNLESS YOU ACT WITFJJN TEN(10) DAYS I 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Library Avenue t Carlisle,PA 17013 i LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 f. By: !pVAjLAWW;R0UP,P.C. I ay E.Kivitz Pa.ID 26769 I Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff i i KML LAW GROUP,P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARICT STREET PIHLADELPIIIA,PA 19106 (215)627-1322 ATTORNEY FOR PLAINTITT FEDERAL NATIONAL MORTGAGE ASSOCIATION IN THE COURT OF COMMON PLEAS 14221 Dallas Parkway,Suite 1000 OF Cumberland COUNTY Dallas,TX 75254-2942 Plaintiff CIVIL.ACTION-LAW VS. JAMESON E.CHR[STOPIIER ACTION OF EJECTMENT and OCCUPANTS 131 East L.outher Street Term Carlisle,PA 17013 No.2013-05521 Defendants DATE OF THIS NOTICE: November 15,2013 TO: JAMESON E.CHRISTOPEER 131 East Loutller Street Carlisle,PA 17013 IlAPORTANT 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 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 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 HIRNG 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 By: 42-ti/. LAW GROUP,P. Jay E.Kivitz Pa.ID 26769 Michael McKeever Pa.ID 56129 Lisa Lee Pa,ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Salvatore Filippello Pa.ID 313897 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. JAMESON E.CHRISTOPHER NO.2013-05521 Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appi/scra/scraHome.do) for the following individual(s): JAMESON E. CHRISTOPHER, has a last known residence of 131 East Louther Street, Carlisle,PA 17013. The following information was used to search the DMDC (check all that apply): • Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date Z By: ` KML LAW GROUP,P.C. Michael McKeever Pa. 1 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. 1D 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Dec-03-201311:55:35 SCRA 3.0 StatuRepoit Pbrswnt to Sffvicemembm Civil.Relief fact Last Name: CHRISTOPHER First Name: JAMESON Middle Name: E Active Duty Status As Of: Dec-03-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA _ `No NA _ F This response reflects the individuals'active duty status based on the Active Duty Status Date r Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA + NA =t ' '-No 1t.�D ' NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA YA NA This response reflects whether the individual or his/her nit has received eady notification to report for active duty Upon searching the data banks of the Department of Defense Manp er Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defense link.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 2618N2504053Z30 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith - b Chief Deputy :s Richard W Stewart `•� ? Solicitor OFFICE OF rN£SNERIFF Federal National Mortgage Association Case(Number VS. Jameson E. Christopher 2013-5521 SHERIFF'S RETURN OF SERVICE 09/30/2013 10:26 AM-Deputy Brian Grzyboski, being duly sworn according to law,served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Tiffany Eiland,Tenant, who accepted as"Adult Person in Charge"for Occupant at 131 East Louther Street, Borough of Carlisle, Carlisle, PA 17013. BRIAN GR OS EPUTY 10/15/2013. 03:17 PM-Served the requested Complaint in Ejectment by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit:Jameson E. Christopher at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. RYA W D, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, October 16, 2013 RON RANDERSON,-SHERIFF (c)CounlySulte Snorill,Teleosoft Inc. I 1 R' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Curt Long -- Prothonotary FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2942 Term Plaintiff No. 2013-05521 vs. JAMESON E. CHRISTOPHER and OCCUPANTS 131 East Louther Street Carlisle,PA 17013 Defendants N O T I C E Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: Prot onot c -- Judgment by Default Money Judgment Judgment in Replevin �+ X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KML Law Group, P.C. at the following telephone number: (215) 825-6319 5-60 (2) (Rev. 4/78)55 .;r C.P. 109—P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway,Suite 1000 IN THE COURT OF COMMON PLI�A$ . Dallas,TX 75254-2942 C, -- c �'�n; Plaintiff OF Cumberland COUNT d rn t--�� 2013-05521 JAMESON E.CHRISTOPHER and OCCUPANTS = 131 East Louther Street ' Carlisle,PA 170131 �. Defendants ' PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter,for possession of 131 East Louther Street Carlisle,PA 17013(describe property) SEE ATTACHED LEGAL DESCRIPTION By: KML LAW GROU .C. Jay E.Kivitz Pa.ID 6 69 Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 sod Plaintiff ,,eyss for Plainti / ( ? Ejectment sod V&J "r C.• 1 `j• `0 J Quiet Title A. 5—116 (Rev. 10/76) C Pda Ca �S '2OAV 7:539"96 f i�oi 93a�o WRIT OF POSSESSION(Ejectment Proceedings PRCP 3160-3165) FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway, Suite 1000 Dallas,TX 75254-2942 Plaintiff COURT OF COMMON PLEAS VS. Term JAMESON E.CHRISTOPHER and OCCUPANTS No. 2013-05521 131 East Louther Street Carlisle,PA 17013 WRIT OF POSSESSION 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 FEDERAL NATIONAL MORTGAGE ASSOCIATION,Plaintiff, being: (Premises as follows): 131 East Louther Street Carlisle,PA 17013 (2) To satisfy the costs against the defendants you are directed to levy upon any property of the defendants and sell his,her or their interest therein. Prothonotary, Court of Common Pleas Cumberland County By: Deputy Dated: z 0 H d U W a r- Z �• d � y Z U � � � o Ov H ay U x F o O U U a U °N° z a W UO 0 W ti o W � Q � W w N ALL that certain tract of land situated in the Borough of Carlisle,Cumberland County, Pennsylvania,bounded and described as follows: ON the South by East Louther Street;on the East by property now or formerly of John Wardecker and now or formerly of John D.Meek;on the North by Locust Alley;and on the West by property now or formerly of George N.Schuchman;CONTAINING 15 feet in front of said East Louther Street and extending back,at that width, 120 feet,and from thence at the width of 30 feet,the distance of 120 feet to said alley,the western line being straight. TAX PARCEL#: 02-21-0318-206 BEING PREMISES: 131 EAST LOUTBER STREET,CARLISLE PA 17013 lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. No. 13-5521 Civil Term JAMESON E. CHRISTOPHER AND OCCUPANTS 131 EAST LOUTHER STREET CARLISLE,PA 17013 Costs Attorney's $ 206.31 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): 131 EAST LOUTHER STREET, CARLISLE, PA 17013 ***PLEASE SEE THE 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. Davl D.Buell,Pr honotary, t Common Pleas Court of Cumberland County, PA Date Al 11-1.3 '(Seal) . 2of2 No 13-5521 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. JAMESON E. CHRISTOPHER AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 206.31 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s) attorney name and address: SALVATORE FIL IPPELLO, ESQUIRE- ID# 313897 KML LAW GROUP,P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARKET STREET, PHILADELPHIA, PA 19106 215-825-6319 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 L11111ir0' Jody S Smith t iF —8 i i Chief Deputy Richard W Stewart ' s I ''_tit ;;� i Solicitor .� =, « v �: V L i.i 4 S Federal National Mortgage Association vs. Case Number Jameson E. Christopher 2013-5521 SHERIFF'S RETURN OF SERVICE 12/13/2013 05:24 PM - Deputy Dawn Kell, 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: Jameson E. Christopher at 821 Factory Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, informed Defendant of contents of same. NOTE: Defendant said that there was someone living at the 131 East Lougher Street address; he said he told them to be out by December 31, 2013. 01/08/2014 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 131 East Louther Street, Borough of Carlisle, Carlisle, PA 17013, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Writ of Possession as"Not Found"as to OCCUPANT. NOTE: Ten (10) attempts at service were made with the following results: 12-13-2013 1512 hours No one home (Deputy noted that there was mail in the mail box and she could see kids toys on the floow) 12-18-2013 1003 hours No one home 12-23-2013 1034 hours No one home 12-26-2013 1507 hours No one home 12-30-2013 1452 hours No one home 12-30-2013 2023 hours No one home 12-31-2013 1857 hours No one home 01-03-2014 1330 hours No one home 01-06-2014 2035 hours No one home(Deputy noted that he was unsure if vacant; there was still property in the house; spoke with a neighbor who stated that he hasn't seen anyone at the residence, but that there are lights on in the house sometimes) 01-07-2014 1850 hours No one home(Deputy noted that every room appears to be empty; there were 2-3 bags packed in the living room, and one end table). SHERIFF COST: $74.15 SO ANSWERS, January 08, 2014 RONIR ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r1 E -O F 1 1 Sheriff ,.;t THE FROTHONO ti -s \ ; C1100rF,. Jody S Smith Chief Deputy Richard W Stewart Solicitor ,w4 QFs7CE OF THE SHERIFF JUN I3 P11 12: 13 CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Jameson E. Christopher Case Number 2013-5521 SHERIFF'S RETURN OF SERVICE 12/13/2013 05:24 PM - Deputy Dawn Kell, 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: Jameson E. Christopher at 821 Factory Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, informed Defendant of contents of same. NOTE: Defendant said that there was someone living at the 131 East Lougher Street address; he said he told them to be out by December 31, 2013. 01/08/2014 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 131 East Louther Street, Borough of Carlisle, Carlisle, PA 17013, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" as to OCCUPANT. NOTE: Ten (10) attempts at service were made with the following results: 12-13-2013 1512 hours No one home (Deputy noted that there was mail in the mail box and she could see kids toys on the floow) 12-18-2013 1003 hours No one home 12-23-2013 1034 hours No one home 12-26-2013 1507 hours No one home 12-30-2013 1452 hours No one home 12-30-2013 2023 hours No one home 12-31-2013 1857 hours No one home 01-03-2014 1330 hours No one home 01-06-2014 2035 hours No one home (Deputy noted that he was unsure if vacant; there was still property in the house; spoke with a neighbor who stated that he hasn't seen anyone at the residence, but that there are lights on in the house sometimes) 01-07-2014 1850 hours, No one home (Deputy noted that every room appears to be empty; there were 2-3 bags packed in the living room, and one end table). 06/12/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED per request of plaintiffs attorney. SHERIFF COST: $80.73 SO ANSWERS, June 12, 2014 (c) CountySuite Sheriff, Teleosoft, inc. RONR ANDERSON, SHERIFF a�as'��-lam - 3 ©7a-yS' KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FEDERAL NATIONAL MORTGAGE ASSOCIATION 14221 Dallas Parkway, Suite 1000 Dallas, TX 75254-2942 Plaintiff vs. JAMESON E. CHRISTOPHER and OCCUPANTS 131 East Louther Street Carlisle, PA 17013 Defendant(s) H£ r,�0 THQN p r!; 1014,4 G ?.2 A �' 2 CUNBERL LVA NIA I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1, No. 2013-05521 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER I/(// '/ By: Michael McKeever Pa. ID 56 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 alvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff