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Home My WebLink About14-1044 Supreme Court of Pennsylvania t Court-4 Comfiioti'Pleas Civil Cover Sheet For Prothonotary Use Only: CUMBERLANY 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: S x❑ Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff s Name: Lead Defendant's Name: T PENNYMAC LOAN SERVICES, LLC EMERIC KOCSIS, JR or Occupants I Name of Plaintiff /Appellant's Attorney: Phelan Hallinan, LLP O N ❑ Check here if you have no attorne (are aSelf-Represented (Pro Sel Litigant A Dollar Amount Requested: ❑ within arbitration limits Are money damages requested?: El Yes QYI No (Check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes No Is this an MDJ Appeal? ❑ Yes CANO 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 CIVIL APPEALS ❑ Intentional Judgments) Administrative Agencies ❑ Malicious Prosecution ❑ Buyer Plaintiff ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ❑ Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include mass tort) ❑ Slander /Libel/ Defamation ❑ Employment Dispute: S ❑ Other: Discrimination ❑ Zoning Board E ❑ Employment Dispute: Other ❑ Other: C T I MASS TORT O ❑ Asbestos ❑ Other: N ❑ Tobacco • Toxic Tort - DES B ❑ Toxic Tort - Implant • Toxic Waste RE PROPERTY MISCELLANEOUS • Other: Ejectment ❑ Common Law /Statutory Arbitration • Eminent Domain /Condemnation ❑ Declaratory Judgment • Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure Residential Restraining Order ❑ Dental ❑ Mortgage Foreclosure Commercial ❑ Quo Warranto ❑ Legal ❑ Partition ❑ Replevin ❑ Medical ❑ Quiet Title ❑ Other: ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 1 /1/2011 - k 4lhelan Hallinan, LLP By: Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 r', One Penn Center Plaza ` w �a Philadelphia, PA 19103 - c, - 215 - 563 - 7000',' PENNYMAG LOAN SERVICES, LLC Court of Common Pleas q 6101 CONDOR DRIVE, SUITE 200` � c7 -" MOORPARK, CA 93021 Civil Division yam' Plaintiff V. CUMBERLAND County 'l EMERIC KOCSIS, JR or Occupants 126 E GREEN STREET No. m - I L A LI C (U 1 CAMP HILL, PA 17011 -6715 Defendant CIVIL ACTION — EJECTMENT "This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property. 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 (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 and 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. 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 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 PH # 940080 n� �olv:� s � 1. Plaintiff is PENNYMAC LOAN SERVICES, LLC. 2. Defendant is EMERIC KOCSIS, JR or Occupants. 3. Plaintiff is the record owner of premises located at 126 E GREEN STREET, CAMP HILL, PA 17011 -6715, a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of CUMBERLAND County, on 12/04/2013, as evidenced by the Sheriffs deed recorded 02/14/2014 in the Office of the Recorder of CUMBERLAND County in Instrument 201403351. 5. Plaintiff, by virtue of the above, is the record owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, Plaintiff seeks to recover possession of the Premises. Jo an Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP Legal Description ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the Borough of Shiremanstown, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern line of East Green Street, which point is 375 feet measured eastwardly from the eastern line of Spruce Street; thence eastwardly along the southern line of East Green Street, 75 1/2 feet to a point; thence southwardly 145 feet to a point on the northern line of Parish Alley; thence westwardly along the northern line of Parish Alley 75 1/2 feet to a point; thence northwardly 145 feet to the southern line of East Green Street, the place of BEGINNING. HAVING THEREON ERECTED a one story frame ranch style dwelling known and numbered as 126 E. Green Street, Shiremanstown, Pennsylvania. BEING the same premises which Anne Hollinger, single individual, by Deed dated May 28, 1999 and recorded June 1, 1999 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Bok 200, page 642, granted and conveyed unto Molly A. Brennan. The said Molly A. Brennan is now known as Molly A. Moore. Premises: 126 E GREEN STREET i� VERIFICATION hereby states that he /she is name Title of e t2(,1 .. � icing agent for Plaintiff in this matter, that he /she is authorized to make this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his /her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ig ature DATE: PH # 940080 Return to: Phelan Hallinan, LLP One Penn Center, suite 1400 1617 JFK Boulevard Philadelphia, PA 19103 Attn: Eviction Department PH # 940080 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r ILL Sheriff 0.f-IE:FROTHOt;c)IP,■; Jody S Smith Chief Deputy Richard W Stewart Solicitor OF FCE QF 2014 APR I I P11 2: 38 CUMBERLAND Of:/LINTY PENNSYLVANIA Pennymac Loan Services, LLC vs. Emeric Kocsis, Jr. Case Number 2014-1044 SHERIFF'S RETURN OF SERVICE 03/19/2014 02:56 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Eva Kocsis, Mother, who accepted as "Adult Person in Charge" for Emeric Kocsis, Jr. at 11 Cromwell Ct., Silver Springs, Mechanicsburg, PA 17050. SHERIFF COST: $78.85 March 20, 2014 t,c) CountySuite Sheriff; Teleosoft, Inc. JA' PUTY SO ANSWERS, 72- R NNY R ANDERSON, SHERIFF