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HomeMy WebLinkAbout14-0811 Supreme Co nnsylvania COUP leas For Prothonotary Use Only: a i; • z ,. � Docket No: r County 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 IM Complaint ® Writ of Summons O Petition ® Transfer from Another Jurisdiction © Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T John Doe and /or Tenant Occupant _ N onuWL Dollar Amount Requested: ©within arbitration limits I Are money damages requested? (� Yes No (check one) ®outside arbitration limits 0 N Is this a Class Action Suit? 0 Yes 13 No Is this an MDJAppeal? ® Yes 19 No A Name of Plaintiff/Appellant's Attorney: UDREN LAW OFFICE, P.0 ® 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 Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment ® Motor Vehicle E3 Debt Collection: Other ® Board of Elections ® Nuisance ® Dept. of Transportation ® Premises Liability ® Statutory Appeal: Other S ® Product Liability (does not include E mass tort) 13 Employment Dispute: ® Slander/Libel/ Defamation Discrimination C ® Other: E3 Employment Dispute: Other E3 Zoning Board T ® Other: I ® Other: 0 ' MASS TORT ® Asbestos ® Tobacco ® Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: 13 Ejectment [3 Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation ® Declaratory Judgment © Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non- Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial ® Quo Warranto ® Dental ® Partition 13 Replevin ® Legal 13 Quiet Title ® Other: ® Medical ® Other: 0 Other Professional: Updated 111/2011 _ SR C ! tlui' 0 ;k Oi : This is a non -jury matter 20 1 4 ��`i ��, Assessment of Damages Hearing not required CUMBE L ANO COUNTY Not arbitration matter UDREN LAW OFFICERFNWN- ,,VANIA ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856 - 669 -5400 pleadings@udren.com Federal National Mortgage =COURT OF COMMON PLEAS Association :CIVIL DIVISION 1900 Market Street, Suite 800 :Cumberland County Philadelphia, PA 19103 Plaintiff No � A Ut V. John Doe and /or Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) CIVIL ACTION COMPLAINT IN EJECTMENT YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are.served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9107 04XI S I�✓ AVISO Le han demandado a usted la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9107 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises ") which address is set forth on the caption. 3. Premises, a legal description of which is attached hereto, was sold at Sheriff's Sale in accordance with law on December 4, 2013, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. A true and correct copy of the deed in favor of Plaintiff is attached hereto as Exhibit "A ". 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant(s) who have refused to deliver up the possession thereof. WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAW OFFICES, P.C. AT Of2NEY FOR PLAINTIFF I Eric.Kishbaugh, Esquire PA I D 33078 VERIFICATION The undersigned an attorney for the Plaintiff and is authorized to make this verification. I verify that the facts set forth in the foregoing pleading are true and correct to the best of my 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. UDREN LAW OFFICES, P.C. I Eric Kishbaugh, Esquire PA ID 33078 DATED: February i� 2014 ©034NB VJ10 Tax Parcel No 25 -25 -0006 -239 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 2013 -2110 Civil Term Fulton Bank, N.A. Vs Arthur Clark ALL THAT CERTAIN PIECE OF PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED ACCORDING TO A SURVEY MADE BY GERRIT J. BETZ, R.S., DATED 30 MARCH, 1973, AS FOLLOWS, TO WIT: BEGINNING AT A DRILL HOLE ON THE SOUTH SDE OF RENO AVENUE (60 FEET WIDE) AT CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, BEING HOUSE NO. 222, SAD PONT BEING MEASURED ALONG THE SAID SIDE OF RENO AVENUE, FIFTY -NINE (59) FEET TO THE SOUTHEAST CORNER OF RENO AVENUE AND TAYLOR AVENUE; THENCE EXTENDING FROM SAD PONT OF BEGINNING AND ALONG RENO AVENUE, SOUTH FIFTY-ONE (5 1) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18) FEET TO A DRILL HOLE AT THE CORNER OF LANDS NOW OR LATE OF DERWIN SALTER, BEING HOUSE NO. 216; THENCE ALONG LANDS NOW OR LATE OF DERWIN SALTER, SOUTH THIRTY - EIGHT (38) DEGREES THIRTY (30) MINUTES WEST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO A PK NAIL ON THE NORTH SIDE OF CHERRY ALLEY; THENCE ALONG CHERRY ALLEY, NORTH FIFTYONE (5 1) DEGREES THIRTY (30) MINUTES WEST,THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18.00) FEET TO A HUB AT THE CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, NORTH THIRTY -EIGHT (38) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO THE POINT AND PLACE OF BEGINNING. BEING 3 FEET OF LOT NO.35 AND 15 FEET OF LOT NO, 36, BLQCK B ON THE GEORGE W. BUTTORFF'S ADDITION TO NEW CUMBERLAND AND RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK M, VOLUME 5, AT PAGE 500. BEING KNOWN AND NUMBERED AS 220 RENO AVENUE, NEW CUMBERLAND, PA 17070. BEING KNOWN AS: 220 RENO AVENUE, NEW CUMBERLAND, PA 17070 PROPERTY D NO.: 25 -25 -0006 -239 TITLE TO SAD PREMISES IS VESTED IN ARTHUR CLARK BY DEED FROM TERRY W. BRUBAKER SR. AND PAULA K. BRUBAKER , HUSBAND AND WIFE DATED 06/14/2010 RECORDED 06/16/2010 IN DEED BOOK INSTRUMENT # 201015779. { The same having been sold by me to the said grantee on the 4th day of December 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 4th of September Anno Domini 2013 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Thirteen (2013) Number 2110 at the suit of Fulton Bank, N.A. —vs- Arthur Clark i In Witness Whereof, I have hereunto affixed my signature this 16th da o December Anna Domini Two Thousand and Thirteen (2013) Ro 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 16" day of December Anno Domini Two Thousand and Thirteen (2013) • offi notary : = �� VA I hereby certify that the residence And Post Office address of the Within Grantee is ���ti ►Y� + +j�, 1900 Market Street . CD��fi Suite 800 Philadelphia, PA 19103 ZU IftZ 1, •�' iJ C«r J" •' .� �1�. , Richard W. Stewart "�����.�,► ����'�,•`' Solicitor r' I TAMMY SHEARER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717- 240 -6370 - � a Instrument Number - 201401510 Recorded On 1/21/2014 At 11:34:51 AM * Total Pages - 5 • Instrument Type - DEED - SHERIFF'S Invoice Number - 155057 User ED - SW • Grantor - CLARK, AR'T'HUR • Grantee - FEDERAL NATIONAL MTG ASSOC • Customer - CUMBERLAND COUNTY SHERIFF * FEES - -^�- -- STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this Iegal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT NEW CUMBERLAND BOROUGH $0.00 TOTAL PAID $69.00 I Certify this to be recorded in Cumberland County PA RECORDER OF DEEDS naa Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0034NB III!!!(II(IIN!(IIJIIIIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson • L. rbt Sheriff .^.'. �� TU�;��/'' ��^ .�.` . .`�.`.°`.v,`` Jody S Smith Chief Depu Richard W Stewart Solicitor |:& APR -� PM k/ |n - PM . ,~ CBMPE0/\QD[JU':'-y PENNSYLVANIA Federal National Mortgage Association vs. Case Number 2014-811 SHERIFF'S RETURN OF SERVICE 03/18/2014 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 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Fourteen attempts at service were made but deputies were unable to make contact with any for service. There is several weeks worth of mail in the mailbox and there is a Notice from the Borough regarding Water & Sewer being shut off. Deputies were advised by a neighbor that the house is stiii occupied by a maie. 03/18/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. The Sheriff thenehorereturnothewithinrequestedComp|ointinBectmentas''NotSmmed^at23OReno Avenue. New Cumberland 8oruugh, New Cumberland, PA 17070. Fourteen attempts at service were made but deputies were unable to make contact with any for service. There is several weeks worth of mail in the mailbox and there is a Notice from the Borough regarding Water & Sewer being shut off. Deputies were advised by a neighbor that the house is still occupied by a male. SHERIFF COST: $140.05 SO ANSWERS, March 21, 2014 RONNYR ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsftdren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 CIVIL MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT r■-■ _ c5) Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Complaint in Ejectment upon Defendant(s), by regular mail and certified mail and also by posting the premises at which Plaintiff is seeking possession, and in support thereof avers the following: 1. Premises located at 220 Reno Avenue New Cumberland, PA 17070 was sold at Sheriff's Sale in accordance with law on December 4, 2013, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. 2. The person(s) in possession of Premises are either the former owners/ Defendant(s) or are unknown occupants, and are occupying Premises without right or claim to title. 3. Process was unable to be served upon named Defendant(s) /Occupants at the said Premises. A copy of the Return of Service is attached hereto as Exhibit "A ". 4. Plaintiff wishes to give notice by service of the Complaint in Ejectment as requested hereafter, to the named Defendant(s) and /or occupants, whoever they may be. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Ejectment by regular mail and certified mail upon said Defendant(s) and also by posting the premises at which Plaintiff is seeking possession. UDREN LAW OFFICES, P.C. ttorney for P J. Eric laintiff Kishbaugh, Esquire PA ID 33078 J. Eric K;- ".hay. ugh, Esquire .1 jl 78 Exhibit "A " Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE QF THE ;:+ERIFF Federal National Mortgage Association vs. John Doe (et al.) Case Number 2014 -811 SHERIFF'S RETURN OF SERVICE 03/18/2014 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 220 Reno. Avenue, New Cumberland Borough, New Cumberland, PA 17070. Fourteen attempts at service were made but deputies were unable to make contact with any for service. There is several weeks worth of mail in the mailbox and there is a Notice from the Borough regarding Water & Sewer being shut off. Deputies were advised by a neighbor that the house is still occupied by a male. 03/18/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Served" at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Fourteen attempts at service were made but deputies were unable to make contact with any for service. There is several weeks worth of mail in the mailbox and there is a Notice from the Borough regarding Water & Sewer being shut off. Deputies were advised by a neighbor that the house is still occupied by a male. SHERIFF COST: $140.05 SO ANSWERS, March 21, 2014 RONNS' R ANDERSON, SHERIFF 9' YL ) E - ,G i'J sl ...1J' EXHIBIT A (cy CountySuito Sheriff, Teleosoft Inc. VERIFICATION The undersigned is the Attorney for the Plaintiff in this action, is authorized to make this Verification, and the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of the knowledge or information and belief of the undersigned. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: April 10, 2014 UDREN LAW OFFICES, P.C. J. Eric.Kishbaugh, Esquire 'PA ID 33078 At '•-rne for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and /or Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14 -811 CIVIL MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) provides for alternate service by Order of Court when a Defendant cannot be served or found. In the usual circumstances, an Affidavit setting forth the efforts taken to locate the Defendant(s) accompanies this Motion. Here, however, in this Action in Ejectment, the concern is not so much to serve the named Defendant(s), but rather to serve the person(s) actually occupying the premises. Searching out and locating former owners could very well not accomplish the desired goal. Accordingly, Plaintiff has requested this Honorable Court to allow service by the means most likely to give notice to the named Defendant(s) /occupant(s), whoever they may be. WHEREFORE, Plaintiff respectfully request service of the Complaint in Ejectment upon Defendant(s) by regular mail and certified mail and also by posting the premises at which Plaintiff is seeking possession. UDREN LAW OFFICES, P.C. Attorney for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings @udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and /or Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14 -811 CIVIL VERIFICATION WITH REGARD TO GOOD FAITH REASONABLE INVESTIGATION 1. The present action is in Ejectment. Inability to effect service presents unique issues. 2. The Defendants that have been named may be the former owners /mortgagors who have been foreclosed upon. 3. The former owners /mortgagors may not be the present occupants of the foreclosed premises. 4. The Sheriff /process server has been unable to serve the present occupants of the premises. 5. Plaintiff wishes to give proper notice to the actual occupant and if former owner /mortgagor is not the occupant, obtaining a standard reasonable investigation will not serve the intended purpose. 6. Locating the former owner /mortgagor at a remote location does not solve the service problem in an Ejectment action with regard to the actual occupant. 7. If occupant is not the former owner /mortgagor, no name or social security number is available to Plaintiff to order a Reasonable Investigation. 8. The present whereabouts of the occupants of the premises can be nowhere else but at the premises itself and therefore, additional reasonable investigation of the whereabouts of the occupants would serve no purpose. For the reasons stated, verifier requests this Honorable Court to accept this Verification in place of a Reasonable Investigation. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. w./(A/ At :' ey for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings @udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and /or Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14 -811 CIVIL CERTIFICATE OF SERVICE The undersigned, hereby certifies that true and correct copies of the attached Motion for Special Service Pursuant to Special Order of Court were sent to the following person(s) named herein at their last known address or their attorney of record by: x Regular First Class Mail Certified Mail Other TO: John Doe Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Dated: April 10, 2014 UDREN LAW OFFICES, P.C. Attorney for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings @udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and /or Tenant /Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14 -811 CIVIL O R D E R mco r r < u c.a AND NOW, this day of , 20) 1 , upon consideration of Plaintiff's Motion For Special Service, it is hereby ORDERED that service of the Complaint in Ejectment and all subsequent pleadings on Defendant(s), shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Ejectment and all subsequent pleadings by certified mail and regular mail to the address at which Plaintiff is seeking possession, and also by posting the premises at which Plaintiff is seeking possession: 220 Reno Avenue New Cumberland, PA 17070 BY THE COURT: UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Federal National Mortgage COURT OF COMMON PLEAS Association CIVIL DIVISION 1900 Market Street, Suite 800 Cumberland County Philadelphia, PA 19103 Plaintiff -_ NO. 14-811 CIVIL rnm 7t V. r- John Doe -<>"'> r•.) o�and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 _ r"` ' Defendant (s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: June 25, 2014 UDREN LAW OFFICES, P. C. 1• ' /)4LO3L-7-- ATT•RNEY FOR PLAINTIFF 1\1:001(-1c I_. i Ea71r-;',_r) r‘ D , r21 0 4I(.15PDP et 04.18 ra# 3c 7795 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 CIVIL VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER Grrl CP —• cW - « cR r, (51 - Pursuant to the Court order issued in this matter a true and correct copy of the Complaint in Ejectment to Defendant(s), was sent by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: "} 'a- I i John Doe Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: April/® , 2014 UDREN LAW OFFICES, P.C. Atto ney for Plaintiff J. Eric Kishbaugh, Esquire PAID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 MM 12110529-2 TENANT/OCCUPANT 220 RENO AVENUE NEW CUMBERLAND, PA 17070 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 MM 12110529-2 U.S. POSTAGE» PITNEY BOWES r ZIP 0800.3 $ 000.69° 02 1lN 0001.387090JUL. 02.2014. JOHN DOE 220 RENO AVENUE NEW CUMBERLAND, PA 17070 U.S. POSTAGE» PITNEY BOWES I 4,00 - imahmonswsmo ZIP 0800.3 $ 000.69° 02 1 VN 0001.38.7090. JUL. 02. 2014. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 MM 12110529-2 11 11 1 1 1 91 7199 9991 7034 0705 8369 JOHN DOE 220 RENO AVENUE NEW CUMBERLAND, PA 17070 U.S. POSTAGE»»PITNEY BOWES ZIP 08003 $ 0®5.340 02 1w 000138.7090JUL. 02.2014. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 MM 12110529-2 CERTIFIED MAIL 1 11 11 1 I I 91 7199 9991 7034 0705 8352 TENANT/OCCUPANT 220 RENO AVENUE NEW CUMBERLAND, PA 17070 ti U.S. POSTAGE» PITNEY BOWES 4 41:ZIP 0800.3 $ 005.34° 02 1w 0001.387090 JUL. 02. 2014. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'r: EI In jot, rr O FiGF F'F:F 4:N RIFF JUL -9 EN. iy . J `r3ERLAKD PENNSYLVi=',N1I-: Federal National Mortgage Association vs. John Doe (et al) Case Number 2014-811 SHERIFF'S RETURN OF SERVICE 06/27/2014 07:52 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint in Ejectment upon the within named Defendant, to wit: Occupant, pursuant to Order of Court by "Posting" the premises located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070 with a true and correct copy according to law. BRIAN GRZYB 06/27/2014 07:52 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Complaint in Ejectment upon the within named Defendant, to wit: John Doe, pursuant to Order of Court by "Posting" the premises located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070 with a true and correct copy according to law. RIAN GRZYBO SHERIFF COST: $69.21 SO ANSWERS, June 30, 2014 RONNY R ANDERSON, SHERIFF (c) Cou:^:tVSuite Sheriff, Teleosott. lr.c. UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff V. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: c7 -fl Kindly enter Judgment in Ejectment in favor of the Plaintiff and against the Defendant(s),John Doe, and/or Tenant/Occupant, for possession of the premises appearing in the caption, for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof. I hereby certify that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. Attorney tifor Plaintiff DEFAULT JUDGMENT ENTERED AS INDICATED DATE: %Boll q PRO FROTHY UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff V. John Doe and Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) TO: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil John Doe 220 Reno Avenue New Cumberland, PA 17070 DATE of Notice: July 18, 2014 XMPORTANT 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 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 TARE 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9107 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA, ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9107 ---11 4.• e WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 at UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856 669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v, John Doe and Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) TO: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 DATE of Notice: July 18, 2014 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 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9107 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9107 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL NEW JERSEY 08003-3620 UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff v. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 The Affiant lacks sufficient information to determine whether the Defendant(s) in this action are in active military service because Plaintiff cannot provide dates of birth and/or Social Security numbers for said Defendant(s) to enable a search. Defendant: John Doe Age: Over 18 Residence: As captioned above Employment: Unknown Affiant has not received notice from Defendant(s) that they are in active military service. This statement is made subject to the penalties of 18 Pa. C.S 4904 relating to unsworn falsification to authorities. DATED: July 29, 2014 U1:6?-,041NX6N— Attorney for Plaintiff UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff V. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 SIP OTh The Affiant lacks sufficient information to determine whether the Defendant(s) in this action are in active military service because Plaintiff cannot provide dates of birth and/or Social Security numbers for said Defendant(s) to enable a search. Defendant: Tenant/Occupant Age: Over 18 Residence: As captioned above Employment: Unknown Affiant has not received notice from Defendant(s) that they are in active military service. This statement is made subject to the penalties of 18 Pa. C.S 4904 relating to unsworn falsification to authorities. DATED: July 29, 2014 11\AVIAVIP Attorney for Plaintiff UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Federal National Mortgage Association 1900 Market Street, Suite 800 Philadelphia, PA 19103 Plaintiff V. John Doe and/or Tenant/Occupant 220 Reno Avenue New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-811 Civil PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter, for possession of the property captioned under Defendants above, a description of which is attached hereto: �l='1 4-aa.5o ILo.05 O. al 103.'75 it . '15 16,50 pp Ayr/ Cr Is IS * 36A. rp, PD ATT/ 4a.a5£oe0 t,ea5a 309/(05 Gl�ri�-apf o� Attorney for Plaintiff Czn 3 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NTIONAL MORTGAGE ASSOCIATION 1900 Market Street, Suite 800 Philadelphia, PA 19103 VS. JOHN DOE and/or TENANT/OCCUPANT 220 Reno Avenue New Cumberland, PA 17070 No. 14-811 Civil Term Costs Attorney's $ 369.76 Plaintiff's $ Prothonotary $ 2.25 DUE CO 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 NTIONAL MORTGAGE ASSOCIATION being: (Premises as follows): POSSESSION OF PROPERTY CAPTIONED UNDER DEFENDANTS ABOVE, A DESCRIPTION OF WHICH IS ATTACHED HERETO: (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 2 of 2 No 14-811 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NTIONAL MORTGAGE ASSOCIATION VS. JOHN DOE and/or TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 369.76 Plff (s� $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Nicole LaBletta, Esquire - #202194 UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 By virtue of this writ, on the named , to have possession of the premises described with the Attorney for Plaintiff (s) Where papers may be served day of . I caused the within appurtenances, and Sworn and subscribed to before me this' Day of So Answers, Sheriff By RN 0034NB Tax Parcel No 25-25-0006-239 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 2013-2110 Civil Term Fulton Bank, N.A. Vs Arthur Clark ALL THAT CERTAIN PIECE OF PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED ACCORDING TO A SURVEY MADE BY GERRIT J. BETZ, R.S., DATED 30 MARCH, 1973, AS FOLLOWS, TO WIT: BEGINNING AT A DRILL HOLE ON THE SOUTH SDE OF RENO AVENUE (60 FEET WIDE) AT CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, BEING HOUSE NO. 222, SAD PONT BEING MEASURED ALONG THE SAID SIDE OF RENO AVENUE, FIFTY-NINE (59) FEET TO THE SOUTHEAST CORNER OF RENO AVENUE AND TAYLOR AVENUE; THENCE EXTENDING FROM SAD PONT OF BEGINNING AND ALONG RENO AVENUE, SOUTH FIFTY-ONE (51) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18) FEET TO A DRILL HOLE AT THE CORNER OF LANDS NOW OR LATE OF DERWIN SALTER, BEING HOUSE NO. 216; THENCE ALONG LANDS NOW OR LATE OF DERWIN SALTER, SOUTH THIRTY- EIGHT (38) DEGREES THIRTY (30) MINUTES WEST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO A PK NAIL ON THE NORTH SIDE OF CHERRY ALLEY; THENCE ALONG CHERRY ALLEY, NORTH FIF 1 YONE (51) DEGREES THIRTY (30) MINUTES WEST,THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18.00) FEET TO A HUB AT THE CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, NORTH THIRTY-EIGHT (38) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO THE POINT AND PLACE OF BEGINNING. BEING 3 FEET OF LOT NO.35 AND 15 FEET OF LOT NO. 36, BLQCK B ON THE GEORGE W. BUTTORFF'S ADDITION TO NEW CUMBERLAND AND RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK M, VOLUME 5, AT PAGE 500. BEING KNOWN AND NUMBERED AS 220 RENO AVENUE, NEW CUMBERLAND, PA 17070. BEING KNOWN AS: 220 RENO AVENUE, NEW CUMBERLAND, PA 17070 PROPERTY D NO.: 25-25-0006-239 TITLE TO SAD PREMISES IS VESTED IN ARTHUR CLARK BY DEED FROM TERRY W. BRIJBAKER SR. AND PAULA K. BRUBAKER„ HUSBAND AND WIFE DATED 06/14/2010 RECORDED 06/16/2010 IN DEED BOOK INSTRUMENT # 201015779. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff.~. ' `'� ///�'.cwn/�,.c� VIE ~ ~ 2014 SEP 21 Vkl�O7 ~ ' CUMBERL AND PT� Jody S Smith Chief Deputy Richard VVStewed Solicitor OFFICE, OF l'kE $1-4—RIFF Federal National Mortgage Association vs. John Doe (et al.) Case Numbe 2014-811 SHERIFF'S RETURN OF SERVICE 09/22/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. 10 attempts at service were made with negative results. The comploriginally posted per Court Order. Contacted attorney's office to get a copy of the court order for posting. 09/22/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. 10 attempts at service were made with native results. The complaint in ejectment was originally posted per Court Order. Contacted attorney's office to get a copy of the court order for posting. 0023/2014 02:16 PM - Deputy William Cline, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Property was posted pursuant to Court Order. 09/23/2014 02:16 PM - Deputy William Cline, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Property was posted pursuant to Court Order. SO ANSWERS, September 23, 2014 RONNYRANDERSON, SHERIFF (c) CountySuRa Sheriff, Teleasoft, inc, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ' ILEO- F 'ICL Sheriff ;r, THE : PI OTHi7NO i ttr t Jody S Smith" "` 2114 OCT -` PH 21 5 1 Chief Deputy c� Richard W Stewart CUMURL.ANO COUNTY Solicitor omcyor;lacPENNSYLVANIA Federal National Mortgage Association vs. John Doe (et al.) Case Number 2014-811 SHERIFF'S RETURN OF SERVICE 09/22/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. 10 attempts at service were made with negative results. The complaint in ejectment was originally posted per Court Order. Contacted attorney's office to get a copy of the court order for posting. 09/22/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Doe, but was unable to locate the Defendant in his bailiwick. 10 attempts at service were made with negative results. The complaint in ejectment was originally posted per Court Order. Contacted attorney's office to get a copy of the court order for posting. 09/23/2014 02:16 PM - Deputy William Cline, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Property was posted pursuant to Court Order. 09/23/2014 02:16 PM - Deputy William Cline, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 220 Reno Avenue, New Cumberland Borough, New Cumberland, PA 17070. Property was posted pursuant to Court Order. 10/08/2014 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 220 Reno Avenue, New Cumberland, PA 17070. SHERIFF COST: $170.12 SO ANSWERS, October 08, 2014 RONNY R ANDERSON, SHERIFF 3 /2690 (c) Cou^tySuite Sheriff', Tcleosofi, Inc 0034NB by these Presents Tax Parcel No 25-25-0006-239 1� w all Men 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 2013-2110 Civil Term Fulton Bank, N.A. Vs Arthur Clark ALL THAT CERTAIN PIECE OF PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED ACCORDING TO A SURVEY MADE BY GERRTT 3. BETZ, R.S., DATED 30 MARCH, 1973, AS FOLLOWS, TO WIT: BEGINNING AT A DRILL HOLE ON THE SOUTH SDE OF RENO AVENUE (60 FEET WIDE) AT CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, BEING HOUSE NO. 222, SAD PONT BEING MEASURED ALONG THE SAID SIDE OF RENO AVENUE, FIFTY-NINE (59) FEET TO THE SOUTHEAST CORNER OF RENO AVENUE AND TAYLOR AVENUE; THENCE EXTENDING FROM SAD PONT OF BEGINNING AND ALONG RENO AVENUE, SOUTH FIFTY-ONE (51) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18) FEET TO A DRILL HOLE AT THE CORNER OF LANDS NOW OR LATE OF DERWIN SALTER, BEING HOUSE NO. 216; THENCE ALONG LANDS NOW OR LATE OF DERWIN SALTER,, SOUTH THIRTY- EIGHT (38) DEGREES THIRTY (30) MINUTES WEST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO A PK NAIL ON THE NORTH SIDE OF CHERRY ALLEY; THENCE ALONG CHERRY ALLEY, NORTH FIFTYONE (51) DEGREES THIRTY (30) MINUTES WEST,THE DISTANCE OF EIGHTEEN AND ZERO HUNDREDTHS (18.00) FEET TO A HUB AT THE CORNER OF LANDS NOW OR LATE OF CLARIE BROOKIE, NORTH THIRTY-EIGHT (38) DEGREES THIRTY (30) MINUTES EAST, THE DISTANCE OF ONE HUNDRED FORTY AND ZERO HUNDREDTHS (140.00) FEET TO THE POINT AND PLACE OF BEGINNING. BEING 3 FEET OF LOT NO.35 AND 15 FEET OF LOT NO. 36, BLQCK B ON THE GEORGE W. BUTTORFF'S ADDITION TO NEW CUMBERLAND AND RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK M, VOLUME 5, AT PAGE 500. BEING KNOWN AND NUMBERED AS 220 RENO AVENUE, NEW CUMBERLAND, PA 17070. BEING KNOWN AS: 220 RENO AVENUE, NEW CUMBERLAND, PA 17070 PROPERTY D NO.: 25-25-0006-239 TITLE TO SAD PREMISES IS VESTED IN ARTHUR CLARK BY DEED FROM TERRY W. BRUBAKER SR. AND PAULA K. BRUBAKER„ HUSBAND AND WIFE DATED 06/14/2010 RECORDED 06/16/2010 IN DEED BOOK INSTRUMENT # 201015779.