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HomeMy WebLinkAbout13-6742 Supreme Co W nnsylvania Coll f f 11lI0 leas For Prothonotary Use Only: C 11 �� � y t Docket No: Cu tlan County �a The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint 0 Writ of Summons Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Nationstar Mortgage, LLC et. al William B. Goetz and Any /All Tenants /Occupants T Dollar Amount Requested: El within arbitration limits I Are money damages requested? 0 Yes 0 No (check one) ®x outside arbitration limits O N Is this a Class Action Suit? Yes El No Is this an MDJAppeal? Yes El No A Name of Plaintiff /Appellant's Attorney: Kevin P. Diskin, 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 Intentional Buyer Plaintiff Administrative Agencies Q Malicious Prosecution Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle D Debt Collection: Other Board of Elections 0 Nuisance Q Dept. of Transportation Q Premises Liability rl Statutory Appeal: Other S ® Product Liability (does not include © Employment Dispute: E mass tort) ® Slander/Libel /Defamation Discrimination C 0 Other: Employment Dispute: Other Zoning Board ®Other: I Q Other: O MASS TORT ® Asbestos N Q Tobacco Toxic Tort - DES Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Other: 0 Ejectment [] Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation Declaratory Judgment D Ground Rent Mandamus Landlord/Tenant Dispute 0 Non - Domestic Relations Q Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial 13 Quo Warranto Q Dental Partition El Replevin ® Legal ® Quiet Title ® Other: Medical n Other: Other Professional: Updated 1/1/2011 Richard M. Squire & Associates, LLC Attorneys for Plaintiff - - By: Richard M. Squire, Esquire r �- S.!.,_.''1 1 i. p.f ' Kevin P. Diskin, Esquire ' F,Lr'�� Url;ft i `t Craig Oppenheimer, Esquire F PIN!S`r`L.Y ANIA ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215 - 886 -8790 Fax: 215 - 886 -8791 Nationstar Mortgage, LLC f /k /a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. � � Y V NO: William B. Goetz Any /All Tenants /Occup.ants CIVIL ACTION 375 St. John Drive Camp Hill, PA 17011 -1328 EJECTMENT DEFENDANTS. COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE C - 1 6 9 - 1 69 C 9p DOCUMENT2LC NOTICE AVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, Le han demandado a usted en la corte. Si usted you must take action within twenty (20) days after quiere defenderse de estas demandas expuestas en this complaint and notice are served, by entering a las paginas siguientes, usted tiene veinte (20) dias written appearance personally or by attorney and de plazo al partir de la fecha de la demanda y la filing in writing with the court your defenses or notificacion. Hace falta asentar una comparencia objections to the claims set forth against you. You escrita o en persona o con un abogado y entregar a are warned that if you fail to do so the case may la corte en forma escrita sus defensas o sus proceed without you and a judgment may be objecciones a las demandas en contra de su entered against you by the court without further persona. Sea avisado que si usted no se defiende, la notice for any money claimed in the complaint or corte tomara medidas y puede continuar la for any other claim of relief requested by the demanda en contra suya sin previo aviso o plaintiff. You may lose money or property or other notificacion. Ademas, la corte puede decidir a favor rights important to you. del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR LLEVE ESTA DEMANDA A UN ABOGADO CANNOT AFFORD ONE, GO TO OR TELEPHONE THE INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO OFFICE SET FORTH BELOW TO FIND OUT WHERE TIENE EL DINERO SUFICIENTE DE PAGAR TAL YOU CAN GET LEGAL HELP. SERVICIO VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 - 249 -3166 and 800 - 990 -9108 DOCUMENT2LC Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215 - 886 -8790 Fax: 215 - 886 -8791 Nationstar Mortgage, LLC f /k /a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO: V. William B. Goetz CIVIL ACTION Any /All Tenants /Occupants 375 St. John Drive EJECTMENT Camp Hill, PA 17011 -1328 DEFENDANTS. COMPLAINT 1. Plaintiff, Nationstar Mortgage, LLC f /k /a Centex Home Equity Company, LLC (hereinafter "Nationstar Mortgage, LLC f /k /a Centex Home Equity Company, LLC'), is a corporation, DOCUMENULC partnership, limited partnership, limited liability company, federal savings bank, federal credit union, or national banking association under and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. § 1 et seq.) with an address at 350 Highland Drive, Lewisville, TX 75067. 2. Defendants are William Goetz a /k /a William B. Goetz, an adult individual, and Any /All Tenants /Occupants, residing at 375 St. Johns Drive, Camp Hill, PA 17011 -1328. 3. At all times material hereto, plaintiff was, and still is, the owner in fee simple of the real estate situated at 375 St. Johns Drive, Camp Hill, PA 17011 - 1328( "Property "). 4. Plaintiff was conveyed fee simple ownership of the Property by virtue of the Sheriff's Deed, which also contains the legal description of the Property, has been delivered and dully recorded in the Recorder of Deeds' Office. A true and correct copy of the Sheriff's Deed is attached hereto, made part hereof and marked has Exhibit "A." 5. At all times material hereto, Defendants have unjustifiably withheld and continue to unjustifiably withhold possession of the Property from Plaintiff. 6. No landlord- tenant relationship exists between Plaintiff and Defendant and no such relationship was created as a result of the mortgage foreclosure. 7. Plaintiff has complied with the Protecting Tenants at Foreclosure Act of 2009 (P.L. 111- 22) at all material times hereto and in all respect to the extent it is applicable. 8. Defendants are occupying the Property illegally. 9. As the legal owner of the Property, Plaintiff is entitled to immediate possession and immediate enjoyment thereof. DOCUMENT2LC WHEREFORE, plaintiff respectfully requests that this Honorable Court enter judgment in its favor and against defendants, William Goetz a /k /a William B. Goetz, and Any /All Tenants /Occupants found in possession of the Property for immediate possession thereof, for immediate ejectment of Defendants, for an award of Plaintiff's attorneys' fees, and for such other relief that this Court deems just and proper. Respectfully submitted, RICHARD M. SQUIRE & ASSOCIATES, LLC By: // ichard M. Squire, Esq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215 - 886 -8790 215 - 886 -8791 (fax) rsquire @squirelaw.com kdiskin @squirelaw.com coppenheimer @squirelaw.com Attorneys for Plaintiff Dated: l i� DOCUMENT2LC Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215 - 886 -8791 Nationstar Mortgage, LLC f /k /a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. NO: William B. Goetz Any /All Tenants /Occupants CIVIL ACTION 375 St. John Drive Camp Hill, PA 17011 -1328 EJECTMENT DEFENDANTS. VERIFICATION Kevin P. Diskin, Esquire, hereby states that he is one of the attorneys for the Plaintiff, a corporation unless designated otherwise; that he has personal knowledge of the facts averred in the foregoing pleading insofar as the foregoing pleading is predicated upon a public DOCUMENULC record (i.e. Sheriff's Deed); and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 12013 n Title: Attorney for Plaintiff File #: Name: William B. Goetz Any /All Tenants /Occupants 375 St. John Drive Camp Hill, PA 17011 -1328 DOCUMENTM Exhibit "A" DOCUMENT2LC C 0)3217 Tax Parcel No. 10-20- 1846 -175 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 Nationstar Mortgage LLC Vk/a Centex Home Equity Company, LLC 2009.6749 Civil Term Nationstar Mortgage LLC f /k/a Centex Home Equity Company, LLC Vs William B. Goetz ALL THAT CERTAIN TRACTOR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF HAMPDEN, IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE EASTERN SIDE OF ST. JOHNS DRIVE (FORMERLY POINT RIDGE DRIVE) AT THE CORNER OF LANDS NOW OR LATE OF KURVIN W. LAUER: THENCE NORTH 64 DEGREES 59 MINUTES EAST ALONG THE SAME 206.40 FEET TO A POINT; THENCE NORTH 25 DEGREES 01 MINUTE WEST, 7.6 FEET ALONG SAME, TO A POINT; THENCE NORTH 64 DEGREES 59 MINUTES EAST ALONG LOT NO. 64, REVISED PLAN OF SECTION NO.3, POINT RIDGE FARMS, 88.28 FEET TO A POINT; THENCE SOUTH 29 DEGREES 39 MINUTES EAST, ALONG LANDS NOW OR LATE OF BARBARA ROGERS, 232.35 FEET TO A POINT; THENCE SOUTH 55 DEGREES 58 MINUTES WEST, ALONG SAME AND LANDS NOW OR LATE OF WATTS, 257.89 FEET TO A POINT; THENCE NORTH 33 DEGREES 17 MINUTES WEST, ALONG THE EASTERLY SIDE OF ST. JOHNS DRIVE (FORMERLY POINT RIDGE DRIVE) 102.65 FEET TO A POINT; THENCE NORTH 40 DEGREES 7 MINUTES WEST, ALONG SAME 168.80 FEET TO THE PLACE OF BEGINNING. Title to said Premises vested in William B. Goetz by Deed from William B. Goetz and Linda L. Goetz, h/w dated May 10, 2002 and recorded on May 20, 2002 in the Cumberland County Office of the Recorder of Deeds in Book 251, Page 3712. Being known as 375 St. Johns Drive, Camp Hill, PA 17011 Tax Parcel Number: 10 -20- 1846 -175 The same having been sold by me to the said grantee on the 10th day of July 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 25th of September Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 6749 at the suit of Nationstar Mortgage LLC f/k/a Centex Home Equity Company, LLC —vs- William B. Goetz In Witness Whereof, I have hereunto affixed my signature this 9th day of August Anno Domini Two Thousand and Thirteen (2013) 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 9 th day Of August Anno Domini Two Thousand and Thirteen (2013) Prothonotary Z)a44 �' . "' • ! ! ., Nothonota Cumberland County, Carlisle, PA ry. C" Expi the First Mond of fan 2014 F� My Commission +;n I hereby certify that the residence �'• ' �'� r And Post ff1C O a address of the �n '•.-� �,.�,` `� Within Grantee is 350 Highland Drive Lewisville, TX 75067 Ric and W. Stewart Solicitor REV _ 1113 EX (0410) RECORDER'S USE ONLY REALTY TRANSFER TAX COMMONWEALTH OF PENNSYLVANIA STATEMENT OF VALUE STATE TAx PAID DEPARTMENT OF REVENUE BWCK NUMBER BUREAU OF INDIVIDUAL TAXES POST OFFICE BOX 280603 PAOE NUMBER HARRISBURG, PA 17128.0603 SEE REVERSE FOR INSTRUCTIONS DATE RECORDED COMPLETE EACH SECTION AND FILE IN DUPLICATE WTTH RECORDER OF DEEDS WHEN ()) THE FULL VALUE/CONSIDERATION IS NOT SET FORTH IN THE DEED, (2) WHEN THE DEED IS WI MOUT CONSIDERATION, OR BY GIFT, OR (3) A TAX EXEMTION IS CLAIMED_ A STATEMENT' OF VALUE IS NOT REQUIRED IF THE TRANSFER IS WHOLLY EXEMPT FROM TAX BARES ON 1 FAMILY RELATIONSHIP FO R 2 PUBLIC UTILTY EASEMENT. IF MORE SPACE IS NEEDED ATTACH ADDITIONAL SHEET(S). A CORRESPONDENT -ALL INQUIRIES MAY BE DIRECTED TO THE FOLLOWING PERSON: NAME TELEPHONE NUMBER Amelia Torres 856 -482 -1400 MAILING ADDRESS CrrY/STATE W CODE 220 Lake Drive Eas Suite 301 Cherry Hill, NJ 08002 B TRANSFER DATA C. DATE OF ACCEPTANCE OF DOCUMENT: 7/2443 GRANTOR(S) LESSOR(S) GRANTENS)LBSSFE(S) Sheriff of Cumberland County Nationstar Mortgage LLC VWa Centex Home Equity Company, LLC STREEI ADDRESS STREET ADDRESS Cumberland County Courthouse 350 Highland Drive One Courthouse Square CITY STATE ZIP CODE CITY STATE ZIP CODE Carlisle PA 17013 Lewisville TX 75067 D. PROPERTY LOCATION STREET ADDRESS CITY, TOWNSHIP, BOROUGH 375 St. Johns Drive Camp Hill, PA 17011 (Hampden Townshi COUNTY SCHOOL DISTRICT TAX PARCEL NUMBER Cumberland Cumberland Valle 1 10-20 -1846 -175 E. I AULATION DATA — WAS TRANS ACTION PART OF AN ASSIGNMENT OR RELOCATION? El Y M N 1. ACTUAL CASH CONSIDERATION 2. OTHER CONSIDERATION 3. TOTAL CONSIDERATION 51.00 s0 $1.00 4 COUNTY ASSESSED VALUE 5 COMMON LEVEL RATIO FACTOR b, FAIR MARKET VALUE $538,400.00 0.9700 $522,248.00 F. EXEMPTON DATA Ia. AMOUNT OF EXEMPTION CLAIMED 1b. PERCENTAGE OF GRANTOR'S INTEREST IN REAL ESTATE I Ic.. PERCENTAGE OF GRANTOR'S INTEREST CONVEYED 100 100% 100% 2. CHECK APPROPRATE BOX BELOW FOR EXEMPTION CLAIMED ❑ WILL OR INTESTATE SUCCESSION (NAME OF DECEDENT) (ESTATE FILE NUMBER) ❑ 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 STATE AND INSTRUMENTALITIES BY GIFT, DEDICATION, CONDEMNATION 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 NOTElASSIGNMENT) ❑ CORRECTIVE OR CONFIRMATORY DEED. (ATTACH COMPLETE COPY OF THE PRIOR DEED BEING CORRECTED OR CONFIRMED.) ❑ STATUTORY CORPORATE CONSOLIDATION, MERGER OR DIVISON. (ATTACH COPY OF ARTICLES.) ❑ OTHER (PLEASE EXPLAIN EXEMPTION CLAIMED, IF OTHER THAN LISTED ABOVE.) UNDEF PENALTIES OF LAW, I DECLAIRE TJ - J#T I V£ EXAMINED THIS STATEMENT, INCLUDING ACCOMPANYING TION, AND TO THE BEST OF MY KNOW EDG AND BELIEF IT IS TRUE, CORRECT AND COMPLETE. IGNA'IMOF CORRESPO OR RESPONSIBLE PARTY DATE t `1 aC FAILLU TO COMPLETE THIS FORM PROPERLY OR ATTACH APPLICABLE DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED. ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717 - 240 -6370 Instrument Number - 201329991 Recorded On 9/10/2013 At 8:39:14 AM * Total Pages - 5 • Instrument Type - DEED - SHERIFF'S Invoice Number - 146684 User ED - KW • Grantor - GOETZ, WILLIAM B • Grantee - NATIONSTAR MORTGAGE LLC • 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 a e is now art PARCEL CERTIFICATION $15.00 P g P 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 HAMPDEN TOWNSHIP $0.00 TOTAL PAID $68 I Certify this to be recorded in Cumberland County PA RECORDER O �EDS r�so * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 003217 l IIIIIIIIIII�IIIIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson `�-� Sheriff ^ THE' PROTHONOTARY Jody S Smith 2313 NOY 25 PM �: 04 Chief Deputy Richard W Stewart 4w,. CUMBERL.AND COUNTY Solicitor OFF40Eof TIRE SHERIFF PENNSYLYANIA Nationstar Mortgage LLC Case Number vs. William B. Goetz 2013-6742 SHERIFF'S RETURN OF SERVICE 11/19/2013 06:22 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, butwas unable to locate the [defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served" at 375 Saint Johns Drive, Hampden Township, Camp Hill, PA 17011. There were no other Occupants other than the defendant William Goetz. 11/19/2013 06:22 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:"William B. Goetz at 375 Saint Johns Drive, Hampden Township, Camp Hill, PA 17011. 4 JASON KIMS E , D PUTY SHERIFF COST: $60.95 SO ANSWERS, November 20, 2013 RONNJY R ANDERSON, SHERIFF (c)countysuite Sheriff,Teleosoff,Inc. , Richard M. Squire&Associates,LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P.Diskin, Esquire Craig Oppenheimer,Esquire D.Nos. 04267/ 86727/313264 Nationstar Mortgage, LLC f/k/a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY, 350 Highland Drive PENNSYLVANIA Lewisville, TX 75067 ,_7 a ,,, c_. PLAINTIFF, DOCKET NO: 13-6742 Civil m@ ;h , 2, ..- r,, , v. CIVIL ACTION ( ` ' (1)C3.' N t Cry f 7p c.3..11 William Goetz a/k/a William B. Goetz IN EJECTMENT 2 c-) Any/All Tenants/Occupants x� 375 St. Johns Drive '` r Camp Hill , PA 17011-1328, DEFENDANTS. PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER TO THE PROTHONOTARY: Kindly enter judgment for possession in favor of the Plaintiff and against William Goetz a/k/a William B. Goetz and Any/All Tenants/Occupants. I hereby certify that(1)the addresses of the Plaintiff and Defendants are as shown above, and (2)that notice has been given in accordance with Rule 237.1, copies attached. 'chard M. Squire, Esq. (PA I.D.#04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Craig Oppenheimer, Esq. (PA I.D.#313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) civx; GAD.SOf C644 rsquire@squirelaw.com Mc.lei l ba►N kdiskin @squirelaw.com co 1R#. a l q 3S coppenheimernsquirelaw.com pp 1)V Ma led Attorne yili for P ' tiff I . 0 .• iii"') Dated: GI' - - 43 PROTHONOTARY Richard M. Squire&Associates,LLC Attorneys for Plaintiff By: Richard M. Squire,Esquire Kevin P. Diskin,Esquire Craig Oppenheimer,Esquire ID.Nos. 04267/86727/313264 Nationstar Mortgage, LLC f/k/a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, v. DOCKET NO: 13-6742 Civil William Goetz a/k/a William B. Goetz CIVIL ACTION Any/All Tenants/Occupants 375 St. Johns Drive EJECTMENT Camp Hill , PA 17011-1328, DEFENDANTS. VERIFICATION OF NON-MILITARY SERVICE Richard M. Squire hereby verifies that he is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) at 375 St. Johns Drive, Camp Hill , PA 17011-1328. This statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. and M. Squire,Esq. (PA I.D.#04267) Kevin P.Diskin,Esq. (PA I.D.# 86727) Craig Oppenheimer, Esq. (PA I.D.#313264) 115 West Avenue, Suite 104 Jenkintown,PA 19046 215-886-8790 215-886-8791 (fax) Attorneys for Plaintiff Dated: la - Richard M. Squire&Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire I.D.Nos. 04267/86727/313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Nationstar Mortgage, LLC f/k/a Centex IN THE COURT OF COMMON PLEAS Home Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, v. DOCKET NO: 13-6742 Civil William Goetz a/k/a William B. Goetz Any/All Tenant/Occupants CIVIL ACTION 375 St. Johns Drive Camp Hill, PA 17011-1328, IN EJECTMENT DEFENDANTS. TO: William B. Goetz 375 St.John Drive Camp Hill,PA 17011-1328 DATE OF NOTICE: December 17.2013 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 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. If you do not have a lawyer or cannot afford once, go to or telephone the following office to find out where you can get legal help: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 717-249-3166 and 800-990-9108 F:\Clients\ALD-Aldridge Connors\Goetz-077E\10 day notice.wpd Richard M. Squire&Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire I.D.Nos. 04267/ 86727/ 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Nationstar Mortgage, LLC f/k/a Centex IN THE COURT OF COMMON PLEAS Home Equity Company, LLC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, v. DOCKET NO: 13-6742 Civil William Goetz a/k/a William B. Goetz Any/All Tenant/Occupants CIVIL ACTION 375 St. Johns Drive Camp Hill,PA 17011-1328, IN EJECTMENT DEFENDANTS. TO: Any/All Tenant/Occupants 375 St.John Drive Camp Hill,PA 17011-1328 DATE OF NOTICE: December 17,2013 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 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. If you do not have a lawyer or cannot afford once, go to or telephone the following office to find out where you can get legal help: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 717-249-3166 and 800-990-9108 F:\Clients\ALD-Aldridge Connors\Goetz-077E\10 day notice.wpd Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 Date Nationstar Mortgage, LLC f/k/a Centex Home Equity Company, LLC, PLAINTIFF, v. William Goetz a/k/a William B. Goetz 375 St. Johns Drive Camp Hill, PA 17011-1328 Any/All Tenants/Occupants 375 St. Johns Drive Camp Hill , PA 17011-1328, DEFENDANTS. NOTICE TO: William B. Goetz 375 St.John Drive Camp Hill, PA 17011-1328 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on I l a i l t,) , a judgment(decree) (order) was entered against you in this office in the proceeding as indic d above. ) 4.11 IR i. 4 ,,f)' Prothonotary Deputy Prothonotary Date Mailed: . — Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 Date Nationstar Mortgage, LLC f/k/a Centex Home Equity Company, LLC, PLAINTIFF, v. William Goetz a/k/a William B. Goetz 375 St. Johns Drive Camp Hill, PA 17011-1328 Any/All Tenants/Occupants 375 St. Johns Drive Camp Hill , PA 17011-1328, DEFENDANTS. NOTICE TO: Any/All Tenants/Occupants 375 St.John Drive Camp Hill, PA 17011-1328 Pursuant to requirements of Penns lvania Rules of Civil Procedure, Rule 236, notice is hereby given that on \a y , a judgment(decree) (order) was entered against you i this office in the proceeding as indicated above. gitole40,,)P Prothonotary Deputy Prothonotary Date Mailed: 13f1��i0i6' 1Ca G.. Richard M. Squire&Associates,LLC Attorneys for Plaintiff NQ jr ; s, By: Richard M. Squire,Esquire � �_ Kevin P.Diskin, Esquire 2 Craig Oppenheimer,Esquire C1JHc3ERLAND COU�1TY I.D. Nos. 04267/86727/313264 PENNSYLVANIA?'" One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Nationstar Mortgage,LLC f/k/a Centex Home IN THE COURT OF COMMON PLEAS Equity Company, LLC, CUMBERLAND COUNTY,PENNSYLVANIA PLAINTIFF, TERM DOCKET NO: 13-6742 Civil v. CIVIL ACTION William Goetz a/k/a William B. Goetz Any/All Tenant/Occupants IN EJECTMENT 375 St. Johns Drive Camp Hill ,PA 17011-1328, DEFENDANTS. PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue a Writ of Possession in the above matter for possession of the property located at 375 St. Johns Drive , Camp Hill , PA 17011-1328 and more particularly described on Exhibit "A" attached hereto and incorporated herein. Rich . Squire,Esq. (PA I.D.#04267) Kevin P.Diskin,Esq. (PA I.D. #86727) a \'C �� Q Craig Oppenheimer,Esq. (PA I.D.#313264) 115 West Avenue, Suite 104 (Q 0 °IS t F Jenkintown,PA 19046 ` O2� S `' 14 215-886-8790 so t` 215-886-8791 (fax) Attorneys for Plaintiff Dated: ,) j(i° 0 3 13a.a e_,L4 3ortS %% WA-c2cioist6 • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA DOCKET NO. 13-6742 Civil Nationstar Mortgage,LLC f/k/a Centex Home Equity Company,LLC, PLAINTIFF, v. William Goetz a/k/a William B. Goetz Any/All Tenant/Occupants 375 St.Johns Drive Camp Hill ,PA 17011-1328, DEFENDANTS. Richard M. Squire&Associates,LLC chard M. Squire,Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire I.D.Nos. 04267/86727/313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 JAN 03 014/FRI 12:07 PM Richard Squire Assoc FAX No, 215 886 8791 P. 002/002 Exhibit "A" ALL THAT CERTAIN TRACTOR PARCEL OF LAND AND PREMISES,SITUATE,LYING AND BEING IN THE TOWNSHIP OF HAMPDEN,N THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA,MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN ON THE EASTERN SIDE OF ST.JOHNS DRIVE (FORMERLY POINT RIDGE DRIVE)AT THE CORNER OF LANDS NOW OR LATE OF KURVIN W.LAUER:THENCE NORTH 64 DEGREES 59 MINUTES EAST ALONG THE SAME 206.40 FEET TO A POINT;THENCE NORTH 25 DEGREES 01 MINUTE WEST,7.6 FEET ALONG SAME,TO A POINT;THENCE NORTH 64 DEGREES 59 MINUTES EAST ALONG LOT NO.64,REVISED PLAN OF SECTION NO.3,POINT RIDGE FARMS,88.28 FEET TO A POINT;THENCE SOUTH 29 DEGREES 39 MINUTES EAST,ALONG LANDS NOW OR LATE OF BARBARA ROGERS,232.35 FEET TO A PONT;THENCE SOUTH 55 DEGREES 58 MINUTES WEST,ALONG SAME AND LANDS NOW OR LATE OF WATTS, 257.89 FEET TO A POINT;THENCE NORTH 33 DEGREES 17 MINUTES WEST,ALONG THE EASTERLY SIDE OF ST.JOHNS DRIVE(FORMERLY PONT RIDGE DRIVE) 102.65 FEET TO A PONT;THENCE NORTH 40 DEGREES 7 MINUTES WEST,ALONG SAME 168.80 FEET TO THE PLACE OF BEGINNING. Title to said Premises vested in William B.Goetz by Deed from William B. Goetz and Linda L. Goetz,h/w dated May 10,2002 and recorded on May 20,2002 in the Cumberland County Office of the Recorder of Deeds in Book 251,Page 3712. Being known as 375 St. Johns Drive,Camp Hill,PA 17011 Tax Parcel Number: 10-20-1846-175 loft WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE, LLC f/k/a CENTEX HOME EQUITY COMPANY, LLC VS. No. 13-6742 Civil Term WILLIAM GOETZ a/k/a WILLIAM B. GOETZ,ANY AND/ALL TENANT/OCCUPANTS 375 St. Johns Drive Camp Hill, PA 17011 Costs Attorney's $209.70 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)) NATIONSTAR MORTGAGE, LLC f/k/a CENTEX HOME EQUITY COMPANY, LLC being: (Premises as follows): 375 ST. JOHNS DRIVE, CAMP HILL, PA 17011 ***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. 12Am:ea .'"ALtale David D. Buell,Prothonotary, CoA/4 mm on Pleas Court of Cumberland County PA Date 1/2/14 � 0 (Seal) 2 of 2 No 13-6742 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NATIONSTAR MORTGAGE,LLC f/k/a CENTEX HOME EQUITY COMPANY,LLC VS. WILLIAM GOETZ a/k/a WILLIAM B. GOETZ,ANY AND/ALL TENANT/OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 209.70 P1ff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: RICHARD M. SQUIRE, ESQUIRE- ID# 04267 RICHARD M. SQUIRE&ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 215-886-8790 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 Ronny R Anderson Sheriff Jody 5 Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND ��d����� ~�" .~~"�." . �� ~°. . "~°~— =," .=~°.°.��u~o^~'�v"�~= COUNTY ° ^ ' � ^^-`^' �!L��-Ur�/�L L:r THE PROTHONA���� ^�����mm^u~ oF 2014 M=R 18 PM 21 5k ` CUMBERLANO COUNTY PENNSYLVANIA Nationstar Mortgage LLC vs. William B. Goetz Case Number �� SHERIFF'S RETURN OF SERVICE 01002014 01:16 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on January 8, 2014 at 1316 hours a true copy of the within wri of possession was attempted to be served upon the dehandont, to wit: occupant, of 375 Saint Johns Dhve, Camp HiU, Cumberland County, Pennsylvania 17011. The property was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the defendant, occupant, was NOT FOUND. Deputies went to the house; property appears to be vacant. There is nothing inside the residence and there were no tracks in the snow in the driveway. 0108/2014 01:16 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on January 8, 2014 at 1316 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: William B. Goetz of 375 Saint Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011, The property was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the defendant, William B. Goetz, was NOT FOUND. Deputies went to the house; property appears to be vacant. There is nothing inside the residence and there were no tracks in the snow in the driveway. 03/18/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED per request of plaintiffs attorney. SHERIFF COST: $68.54 SO ANSWERS, March 18, 2014 R N R ANDERSON, SHERIFF • =.~� *e� 9,s--se INA ~^-u'=�