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Home My WebLink About14-1492E T 0 N A E T 0 N B Supreme Court of Pennsylvania Courpif ommnJFIeas iyi1 Coyer S e t CUMBERLAND VS County For Prothonotary Use Only: Lead Plaintiffs Name: FEDERAL NATIONAL MORTGAGE ASSOCIATION Docket No: IL/ — / 4/9k_ The information collected on this form is used solely for court administration purposes. This form does not supplement or replace lheJiling and service ofpleadings or other papers as required by law or rules o court. Commencement of Action: EJ Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking Lead Plaintiffs Name: FEDERAL NATIONAL MORTGAGE ASSOCIATION Lead Defendant's Name: GLENN R. SULLIVAN or Occupants Name of Plaintiff/Appellant's 0 Check here if you have no attorney Attorney: Phelan Hallinan, LLP (are a Self-Represented [Pro Se] Litigant) ' Are money damages requested? : 0 Yes .ii No Dollar Amount Requested: 0 within arbitration limits (Check one) 0 outside arbitration limits Is this a Class Action Suit? 0 Yes Is this an MDJ Appeal? 0 Yes No 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) O Intentional O Malicious Prosecution O Motor Vehicle 0 Nuisance O Premises Liability O Product Liability (does not include mass tort) O Slander/Libel/ Defamation 0 Other: MASS TORT 0 Asbestos 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant 0 Toxic Waste O Other: PROFESSIONAL LIABLITY O Dental O Legal • Medical 0 Other Professional: Pa.R C.P. 205.5 CONTRACT (do not include Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card O Debt Collection: Other O Employment Dispute: Discrimination O Employment Dispute: Other 0 Other: REAL PROPERTY Ejectment O Eminent Domain/Condemnation 0 Ground Rent O Landlord/Tenant Dispute O Mortgage Foreclosure Residential 0 Mortgage Foreclosure Commercial 0 Partition 0 Quiet Title 0 Other: CIVIL APPEALS Administrative Agencies O Board of Assessment O Board of Elections 0 Dept. of Transportation O Statutory Appeal: Other 0 Zoning Board 0 Other: MISCELLANEOUS O Common Law/Statutory Arbitration O Declaratory Judgment 0 Mandamus 0 Non-Domestic Relations Restraining Order 0 Quo Warranto O Replevin 0 Other: Updated 1/1/2011 • ► Phelan Hallinan, LLP By: John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION P.O. Box 650043 Dallas, TX 75265 Plaintiff v. GLENN R. SULLIVAN or Occupants 426 ALLENDALE WAY CAMP HILL, PA 17011 -8408 Defendant Attorney for Plaintiff L., 11;',R !14 A, IQ: CUTIDERLAIID Court of Common Pigaki SYLVANIA Civil Division CUMBERLAND County No. /11 - pp/Q?•, l CIVIL ACTION — EJECTMENT 4,0 * *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 # 939019 - 1: Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION. 2. Defendant is GLENN R. SULLIVAN or Occupants. 3. Attached hereto as Exhibit A is a true and correct copy of the Recorder of Deeds Index Display in the possession, custody or control of Plaintiff, which reflects that a Sheriffs deed was recorded on 02/28/2014 in the Office of the Recorder of CUMBERLAND County as Instrument No. 201404230 and that Plaintiff is the owner of property located at 426 ALLENDALE WAY, CAMP HILL, PA 17011 -8408 (hereinafter the "Property "). The deed is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 4. Attached hereto as Exhibit B is a description of the Property. 5. Plaintiff contends that it is entitled to immediate possession of the Property. 6. Upon information and belief, the Defendants, GLENN R. SULLIVAN and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 7. Attached hereto as Exhibit C is a true and correct copy of a letter reflecting that Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who upon information and belief have refused to deliver up possession of the same. WHEREFORE, Plaintiff seeks to recover possession of the Premises. Jo • V ichael Kolesnik, Esq., Id. No.308877 A torney for Plaintiff Phelan Hallinan, LLP EXHIBIT "A" PH # 939019 ' LANDEX Document Data Page 1 of 1 Instrument #: Recorded Date: Instrument Type: County: Municipality: Recording Status: Notes: GRANTOR SULLIVAN,GLENN 201404230 FEB 28, 2014 09:45:21 AM DEED - SHERIFF 'S CUMBERLAND LOWER ALLEN TOWNSHIP VERIFIED 426 ALLENDALE WAY R Book: Page: Total Pages: Parcel Numbers: 6 13240807147 LOT 10 PL BK 11 PG 35 GRANTEE FEDERAL NATIONAL MTG ASSOC http: / /www.landex. com/webstore /j sp/ cart /DocumentSearchResults. j sp ?LastName= SULLIV... 3/4/2014 EXHIBIT "B" PH # 939019 Legal Description ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, described in accordance with a Plan of Lots entitled Section No. 1, Allendale Development Corporation, made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, dated April 18, 1960, and recorded in Plan Book 11, Page 35, as follows, to wit: BEGINNING at a point on the western side of Allendale Way, said point being 207.57 feet measured South, along Allendale Way from the southerly terminus of a 25 feet radius curve which connects the said side of Allendale Way and the southerly side of Candlewyck Road; thence extending along Allendale Way, South 22 degrees 30 minutes 16 seconds East, 110.00 feet to a point; thence South 67 degrees 29 minutes 44 seconds West, 149.24 feet; thence North 19 degrees 30 minutes 16 seconds West, 110.15 feet to a corner of Lot No. 11 on said Plan; thence along Lot No. 11, North 67 degrees 29 minutes 44 seconds East, 143.48 feet to the point and place of BEGINNING. BEING Lot No. 10 on the aforesaid Plan. HAVING THEREON ERECTED a split-level brick and frame dwelling known and numbered as 426 Allendale Way, Camp Hill, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Glenn R. Sullivan, married man, by Deed from Shari L. Weller and Scott Cogley, her husband, dated 12/06/2007, recorded 12/20/2007 in Instrument Number 200746967. PREMISES BEING: 426 ALLENDALE WAY, CAMP HILL, PA 17011-8408 PARCEL NO. 13-24-0807-147 EXHIBIT "C" PH # 939019. j ytrj 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX 4: 215-563-4491 Email: VIOLETA.PATORI@fedphe.com March 4, 2014 GLENN R. SULLIVAN or Occupants 426 ALLENDALE WAY CAMP HILL, PA 17011-8408 RE: 426 ALLENDALE WAY CAMP HILL, PA 17011-8408 Dear Occupant: We represent FEDERAL NATIONAL MORTGAGE ASSOCIATION which became owner of the above premises as a result of foreclosure and judicial sale by the Sheriff of the County of CUMBERLAND on 12/04/2013. You are now in possession of the premises without authority or permission of our client and you must vacate immediately. Unless you immediately vacate the premises and make them available for possession, court action will be taken against you at once. Very truly yours, John ael Kolesnik, Esq., Id. No.308877 A ney for Plaintiff elan Hallinan, LLP PH # 939019 1, Christopher Wolfe VI'RiFiCATFG an employed by the Plaintiff corporation as an Asset Recovery Manager and do hereby verify that the factual allegations set 'forth. in the foregoing Complaint are true and correct to the best of my knowledge or information and belief based on corporate sources of information, I understand that false statements therein are made subject to the, penalties of 18 Pa,C,S, 4904 !relating to =sworn Usitioation to authorities,. Date: 3/11/2014 Title/Department Asset Recovery ManaF,er Company annie Mae PH # 9 9 9 lREO # P130FRN Return to: Phelan Hainan,. UP One Penn, Center, Suite, 1400 1617 ,TF1c, Boulevard Philadelphia., PA 19103 Attn: Eviction Department Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY isAtfAc,...„` OFFICE:C*1'14E SRERIFP' , • !: : t t.) ROHON01,,, ?Oh APR -2 PM Li: 13 CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Glenn R Sullivan Case Number 2014-1492 SHERIFF'S RETURN OF SERVICE 03/21/2014 01:26 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Ejectment by "personally" handing a true copy to a person representing themselves to • - the Defendant, to wit: Glenn R Sullivan at 426 Allendale Way, Lower Allen Twp., Camp Hill, PA 70 WI • INE, D SHERIFF COST: $45.44 SO ANSWERS, a March 24, 2014 RONNY R ANDERSON, SHERIFF PUTY () County Suite Sheriff, Te lecisoff, Phelan,Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff COURT OF COMMON PLAMERLAND COUNTY CIVIL DIVISION PENNSYLVANIA vs No. 14-1492 Attorney for Plain FiLEB-OFF10E OF THE PROTHONOTAin 2014 APR 25 AMtJ 02 GLENN R. SULLIVAN Or occupants 426 ALLENDALE WAY CAMP HILL, PA 17011-8408 Defendant CUMBERLAND County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION and against the Defendant(s) GLENN R. SULLIVAN and Or occupants for possession of premises 426 ALLENDALE WAY, CAMP HILL, PA 17011-8408 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP ?/L Sc Ckat Pi/s4/342/ RA 3aq Rep tric Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Court of Common Pleas Plaintiff Civil Division VS No. 14 -1492 GLENN R. SULLIVAN or Occupants Defendant CUMBERLAND COUNTY TO: GLENN R. SULLIVAN or Occupants 426 ALLENDALE WAY CAMP HILL, PA 17011 -8408 DATE OF NOTICE: April 11, 2014 ** 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. ** 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 of 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 one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240 -6195 PH # 939019 By: Jo an Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 Phelan .Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 14 -1492 GLENN R. SULLIVAN Or occupants 426 ALLENDALE WAY CAMP HILL, PA 17011 -8408 Defendant CUMBERLAND County VERIFICATION OF NON - MILITARY SERVICE I hereby verify that I am the Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) that the defendant GLENN R. SULLIVAN is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) That defendant GLENN R. SULLIVAN Or occupants, is over 18 years of age, and resides at 426 ALLENDALE WAY, CAMP HILL, PA 17011 -8408. (c) It is unknown whether any other occupants are in the military or are over 18 years of age. This statement is made subject to penalties of 18 PA. C.S. §4904 relating to unsworn falsification to authorities. Date: April 24, 2014 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP PH # 939019 PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs GLENN R. SULLIVAN Or occupants 426 ALLENDALE WAY CAMP HILL, PA 17011 -8408 Defendant COURT OF COMMON PLEAS CIVIL DIVISION No. 14 -1492 CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 426 ALLENDALE WAY, CAMP HILL, PA 17011 -8408 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION** Being Known as No. 426 ALLENDALE WAY DATE: ks.Yy- cow -�. 1 0a.7s- e. .SG — 1' /Qy /4 Or: THE ED-OFFICE O RO C � r�'r 2014 APR 25 MI : 02 CUMBERLAND COUNTY PENNSYLVANIA q 1- Adam H. Davis, Es q., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP f.2 .SU hal/ C� /Sr /5�f3� Legal Description ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, described in accordance with a Plan of Lots entitled Section No. 1, Allendale Development Corporation, made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, dated April 18, 1960, and recorded in Plan Book 11, Page 35, as follows, to wit: BEGINNING at a point on the western side of Allendale Way, said point being 207.57 feet measured South, along Allendale Way from the southerly terminus of a 25 feet radius curve which connects the said side of Allendale Way and the southerly side of Candlewyck Road; thence extending along Allendale Way, South 22 degrees 30 minutes 16 seconds East, 110.00 feet to a point; thence South 67 degrees 29 minutes 44 seconds West, 149.24 feet; thence North 19 degrees 30 minutes 16 seconds West, 110.15 feet to a corner of Lot No. 11 on said Plan; thence along Lot No. 11, North 67 degrees 29 minutes 44 seconds East, 143.48 feet to the point and place of BEGINNING. BEING Lot No. 10 on the aforesaid Plan. HAVING THEREON ERECTED a split -level brick and frame dwelling known and numbered as 426 Allendale Way, Camp Hill, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Glenn R. Sullivan, married man, by Deed from Shari L. Weller and Scott Cogley, her husband, dated 12/06/2007, recorded 12/20/2007 in Instrument Number 200746967. PREMISES BEING: 426 ALLENDALE WAY, CAMP HILL, PA 17011 -8408 PARCEL NO. 13 -24- 0807 -147 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. 14 -1492 Civil Term GLENN R. SULLIVAN OR OCCUPANTS Costs Attorney's $ 194.19 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): 425 ALLENDALE WAY, CAMP HILL, PA 17011 -8408 * * * 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. Date APRIL25; 2014 -bemi.e/.> David D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA 2 of 2 No 14 -1492 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. GLENN R. SULLIVAN OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160 -3165 ETC. Costs Att'y $ 194.19 P1ff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: ADAM H. DAVIS, ESQ. PHELAN HALLINAN, LLP ONE PENN CENTER SUITE 1400 PHILADELPHIA, PA 19103 I D # 203034 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 Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy Legal Description ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, described in accordance with a Plan of Lots entitled Section No. 1, Allendale Development Corporation, made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, dated April 18, 1960, and recorded in Plan Book 11, Page 35, as follows, to wit: BEGINNING at a point on the western side of Allendale Way, said point being 207.57 feet measured South, along Allendale Way from the southerly terminus of a 25 feet radius curve which connects the said side of Allendale Way and the southerly side of Candlewyck Road; thence extending along Allendale Way, South 22 degrees 30 minutes 16 seconds East, 110.00 feet to a point; thence South 67 degrees 29 minutes 44 seconds West, 149.24 feet; thence North 19 degrees 30 minutes 16 seconds West, 110.15 feet to a corner of Lot No. 11 on said Plan; thence along Lot No. 11, North 67 degrees 29 minutes 44 seconds East, 143.48 feet to the point and place of BEGINNING. BEING Lot No. 10 on the aforesaid Plan. HAVING THEREON ERECTED a split -level brick and frame dwelling known and numbered as 426 Allendale Way, Camp Hill, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Glenn R. Sullivan, married man, by Deed from Shari L. Weller and Scott Cogley, her husband, dated 12/06/2007, recorded 12/20/2007 in Instrument Number 200746967. PREMISES BEING: 426 ALLENDALE WAY, CAMP HILL, PA 17011 -8408 PARCEL NO. 13 -24- 0807 -147 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson THE w sheriff YSvo ��o� mbrr,frro 2314 MAY -I AM IC: 2 O Jody S Smith Chief Deputy CUMBERLAND COUNTY Richard W Stewart PENNSYLVANIA Solicitor Federal National Mortgage Association Case Number vs. 2014-1492 Glenn R Sullivan SHERIFF'S RETURN OF SERVICE 04/29/2014 06:35 PM- Deputy Jason Kinsler, 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: Glenn R Sullivan at 426 Allendale Way, Lower Allen Twp., Camp Hill, PA 17011, Cumberland County, informed Defendant of contents of same. JASTRIKAS YER, DEPUTY SO ANSWERS, April 30, 2014 RONNS R ANDERSON, SHERIFF IC)Oc un y uieo shwti,i d oSCR 't. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oi ho,r14,4 Federal National Mortgage Association vs. Glenn R Sullivan Case Number 2014-1492 SHERIFF'S RETURN OF SERVICE 04/29/2014 06:35 PM - Deputy Jason Kinsler, 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: Glenn R Sullivan at 426 Allendale Way, Lower Allen Twp., Camp Hill, PA 17011, Cumberland County, informed Defendant of contents of same. 05/28/2014 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 426 Allendale Way, Camp Hill, PA 17011. SHERIFF COST: $96.53 SO ANSWERS, May 29, 2014 (c) CounI4S11.e St'enff, of:soft RONP4Y R ANDERSON, SHERIFF ‘14-77 6e0 gei 30t..5k