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Home My WebLink About14-1493S E C T I 0 N A S E C T 0 N B • Supreme Court of Pennsylvania Cou , (of om iir u h? leas ivil Cover S et CUMBERLANDS County For Prothonotary Use Only: Lead Plaintiff's Name: FEDERAL NATIONAL MORTGAGE ASSOCIATION Docket No: Pi' /iti3 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: 0 Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: FEDERAL NATIONAL MORTGAGE ASSOCIATION Lead Defendant's Name: STEPHANIE A. MECK or Occupants Name of Plaintiff /Appellant's ❑ Check here if you have no attorney Attorney: Phelan Hallinan, LLP (are a Self - Represented [Pro Se] Litigant) Are money damages requested? : ❑Yes ! No Dollar Amount Requested: • within arbitration limits (Check one) • outside arbitration limits Is this a Class Action Suit? ❑ Yes VI-No Is this an MDJ Appeal? ❑ Yes 0No 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) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander /Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: Pa.R C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other ❑ Other: REAL PROPERTY Ejectment ❑ Eminent Domain /Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute ❑ Mortgage Foreclosure Residential ❑ Mortgage Foreclosure Commercial ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law /Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non - Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: Updated 1/1/2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ..r THE PR'CiffaOCJ;✓:. i r- r; '11RJUP4 10 PH 2: 49 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE $H4RIFF Federal National Mortgage Association vs. Stephanie A Meck Case Number 2014-1493 SHERIFF'S RETURN OF SERVICE 06/04/2014 09:55 AM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Complaint in Ejectment upon the within named Defendant, to wit: Stephanie A Meck, pursuant to Order of Court by "Posting" the premises located at 361 Belvedere Street, Carlisle Borough, Carlisle, PA 17013 with a true and correct copy according to law. MIC LLE GUTSHALL, DEPUTY SHERIFF COST: $40.78 SO ANSWERS, June 05, 2014 RNY R ANDERSON, SHERIFF (C) COuhtySuito Sheriff, Teieosoft. cc, AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF: FEDERAL NATIONAL MORTGAGE ASSOCIATION No: 14-1493 DEFENDANT: STEPHANIE A. MECK OR OCCUPANTS SERVE AT: 361 BELVEDERE STREET, CARLISLE, PA 17013-3504 XXX EVICT XXX Complaint in Ejectment Special Instructions: **Please Post per Court Order** SERVED Served and made known to STEPHANIE A. MECK OR OCCUPANTS Defendant on the day of , 20 , at o'clock, _M, at , City of , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. , an officer of said defendant company. Other: I, , a competent adult, being duly sworn according to law, depose and state that I personally handed to a true and correct copy of the Complaint in Ejectment issued in the captioned case on the date and at the address indicated above. NOT SERVED On the day of , 20 , at o'clock, _M,. Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 • N 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. STEPHANIE A. MECK or Occupants 361 BELVEDERE STREET CARLISLE, PA 17013 -3504 Defendant Attorney for Plaintiff F LED—CFFICE THE THE PROTHONO / r 2011s MAR 114 Att 10: 21¢ CUMBERLAND COUNTY Court of Common Pleas PENNSYLVANIA Civil Division CUMBERLAND County No. Jt% -J1193 l.:l u t Lr- 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 # 939505 1/63.7s-Peatai CIE2t 14161112? Z41" .36019� 1. Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION. 2. Defendant is STEPHANIE A. MECK 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. 201404228 and that Plaintiff is the owner of property located at 361 BELVEDERE STREET, CARLISLE, PA 17013 -3504 (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, STEPHANIE A. MECK 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 ichael Kolesnik, Esq., Id. No.308877 ttorney for Plaintiff Phelan Hailinan, LLP EXHIBIT "A" PH # 939505 :LANDEX Document Data Page 1 of 1 Instrument #: Recorded Date: Instrument Type: • County: Municipality: Recording Status: Notes: GRANTOR MECK,STEPHANIE A 201404228 FEB 28, 2014 09:42:35 AM DEED - SHERIFF 'S CUMBERLAND CARLISLE BOROUGH - 3RD WARD VERIFIED 361 BELVEDERE ST Book: Page: Total Pages: Parcel Numbers: 5 04210322284 GRANTEE FEDERAL NATIONAL MTG ASSOC http: / /www.landex. com/webstore /j sp/cart/DocumentSearchResults.j sp ?LastName= MECK &... 3/4/2014 EXHIBIT "B" PH # 939505 Legal Description ALL THAT CERTAIN tract of ground situated in the Third Ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe in the eastern line of Belvedere Street at corner of land of Kinzie L. Weimer and Miriam R. Weimer; thence by said land South 86 degrees 30 minutes East 200.25 feet to an iron pipe; thence by land of Dete et al., South 7 degrees West 105 feet to a point; thence by land of R. Dale Parr and Ruth C. Parr North 86 degrees 30 minutes West 200.25 feet to a point on the Eastern line of Belvedere Street; thence by the Eastern line of Belvedere Street North 7 degrees East 105 feet to the place of beginning. BEING part of a larger tract designated as Tract No. 1 which R. Dale Parr and Ruth C. Parr, husband and wife, by their Deed dated September 24, 1958, and recorded September 26, 1958, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 18 -R, Page 441, granted and conveyed unto John I. Adams and Elsie M. Adams, husband and wife. The said John I. Adams died October 14, 1966, wherein by operation of law title vested solely in Elsie M. Adams his widow, Grantor herein. Premises: 361 BELVEDERE STREET EXHIBIT "C" PH # 939505 Reprel-entonti Lender; in Penn5v1v4na 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX #: 215-563-4491 Email: VIOLETA.PATORI@fedphe.com March 4, 2014 STEPHANIE A. MECK or Occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 RE: 361 BELVEDERE STREET CARLISLE, PA 17013-3504 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, Phelan a. man, LLP Jo tae1 Kolesnik, Esq., Id. No.308877 orney for Plaintiff Phelan Hallinan, LLP PH # 939505 FICATION 1, Christopher Wolfe 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. 1 understand that false statements therein are made subject to the penalties of I 8 Pa,C,S. 4904 relating to unsworn falsification to authorities. Date: 3/11/2014 Printed Name: Chris opher Wolfe • Title/Department: Asset Recovery Manager__ Co PI1 # 939505 / REO # Pt30ISO Return to: Phelan Hannan, UP One Penn Center, Suite 1400 1617 JFK. Boulevard Philadelphia, PA 191.03. Attn: Eviction Department PanY: ..„ PH # 939505 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY et��m��a of:FIGF. or • r� THE. 0THAOT�i■'1 +"^ ... . _ PM 11. 13 CUMBERLAND COUNTY '.,NS\(U/&N\A Federal National Mortgage Association vs. Stephanie A Meck Case Number 2O14-14O2 SHERIFF'S RETURN OF SERVICE 03/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stephanie A Meck, but was unable to locate the Defendant in his bailiwick, The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Found" at 361 Belvedere Street, Carlisle Borough, Carlisle, PA 17013. Residence appears to be vacant, deputies were advised by a neighbor that she hasn't seen anyone at the residence in months. SHERIFF COST: $3978 SO ANSWERS, March 24, 2014 ]F` ANDERSON, SHERIFF 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 vs. STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14-1493 Action in Ejectment rTlrri .— CFN c` CD --r o.' MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan, LLP, moves this Honorable Court for an Order directing service of the Complaint upon the above -captioned Defendants by regular mail, and posting of the premises and in support thereof avers as follows: 1. Plaintiff commenced this action by filing a Complaint in Ejectment. 2. Attempts to serve Defendants with the Complaint have been unsuccessful. Plaintiff attempted to serve the Defendants on March 21, 2014as indicated by the Affidavit of Service attached hereto as Exhibit A. 3. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendants. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results from there are attached hereto as Exhibit B. 4. Plaintiff submits that is has made a good faith effort to locate the Defendants, but has been unable to do so. 5. Plaintiff verified through property inspection on April 30, 2014 that the property was occupied by an unknown person. 6. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion for Special Service to the defendant on May 7, 2014, and requested the Defendant's concurrence. Plaintiff did not receive any response from the Defendant. A true and correct copy of Plaintiff s letter pursuant to Local Rule 2083.(9) and postmarked certificate of mailing is attached hereto, made part hereof, and marked as Exhibit "C WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint and all future pleadings by regular mail and posting of the premises Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP Date: May 14, 2014 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 vs. STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14-1493 Action in Ejectment MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendants and the reasons why service cannot be made. Although Plaintiff has attempted to serve Defendants with the Complaint, Plaintiff's attempts have been unsuccessful. A true and correct copy of the Affidavit of No Service is attached hereto, made part hereof, and marked Exhibit A. Accordingly, Plaintiff ordered an investigation into the whereabouts of Defendants. A true and correct copy of the Affidavit of Reasonable Investigation is attached hereto, made part hereof, and marked as Exhibit B. The Affidavit reflects that Plaintiff's investigator has made at least three types of inquires listed under Rule 403.1(B)(1). Copies of any written responses obtained are attached to the Affidavit. The Affidavit also specifies the inquires made, responses made, and dates thereof, in accordance with Rule 430.1(B)(2). As Plaintiff's within motion and its affidavit are both in compliance with the applicable Pennsylvania and local rules, Plaintiff respectfully requests that its motion be granted. WHEREFORE, Plaintiff respectfully requests permission to serve the Complaint and all future pleadings by regular mail and posting of the premises. Respectfully Submitted: Adam H. Davis, Esq., Id. o.203034 Attorney for Plaintiff Phelan Hallinan, LLP Date: May 14, 2014 EXHIBIT "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Federal National Mortgage Association vs. Stephanie A Meck Case Number 2014-1493 SHERIFF'S RETURN OF SERVICE 03/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stephanie A Meck, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Found" at 361 Belvedere Street, Carlisle Borough, Carlisle, PA 17013. Residence appears to be vacant, deputies were advised by a neighbor that she hasn't seen anyone at the residence in months. SHERIFF COST: $39.78 SO ANSWERS, March 24, 2014 RONNY R ANDERSON, SHERIFF art EXHIBIT "B" AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 939505 Attorney Firm: Phelan Hallinan, LLP Subject: Stephanie A. Meck Current Address: 229 Hogestown Road, Mechanicsburg, PA 17050 Property Address: 361 Belvedere Street, Carlisle, PA 17013 Mailing .Address: 229 Hogestown Road, Mechanicsburg, PA 17050 L CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Stephanie A. M.eck - xxx-xx-7323 B. EMPLOYMENT SEARCH Stephanie A. Meck - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Stephanie A. Meck resid.e(s) at: 229 Hogestown Road, Mechanicsburg, PA 17050. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which indicated that Stephanie A. Meck reside(s) at: 229 Hogestown Road, Mechanicsburg, PA 17050. On 12-26-13 our office made a telephone call to the subject's phone number (717) 766-3115 and received the following information: spoke with Stephanie A. Meck who confirmed that she reside(s) at: 229 Hogestown Road, Mechanicsburg, PA 17050. III. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 12-26-13 we reviewed the National Address database and found the following information: Stephanie A. Meck - 229 Hogestown Road, Mechanicsburg, PA 17050. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. IV. OTI IER INQUIRIES A. DEATH RECORDS As of 12-26-13 Vital Records and all public databases have no death record on file for Stephanie A. Meck. V. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Stephanie A. Meck - 1965 * Our accessible databases have been checked and cross-referenced for the above named individual(s). * Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. c, 4904 relating to unsworn falsification to authorities. Mk S. The above information is obtained from available public records and we are only liable for the cost of the affidavit. EXHIBIT "C" Rt{irm=r tidiej lkil,t100 NinrIVIVania 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX #: 215-563-4491 Email: JOSEPH.GARDELLIS@phelanhallinan.com May 7, 2014 Stephanie Meck Or occupants 361 Belvedere Street Carlisle, PA 17013 RE: Federal National Mortgage Association vs. Stephanie A. Meck or occupants Cumberland County No. 14-1493 Dear Stephanie Meck, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, service of the complaint. Please respond to me within one week, by 05/14/2014 Should you have any questions, please feel free to contact me. Very truly yours, Phelan Hallinan, LLP. 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 vs. STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14-1493 Action in Ejectment CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Motion for Service Pursuant to Special Order was served by first class mail on the Defendant's on the date listed below: STEPHANIE A. MECK OR OCCUPANTS 361 BELVEDERE STREET CARLISLE, PA 17013-3504 DATE: May 14, 2014 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP 1 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant It is ordered thisAC day of ORDER Court of Common Pleas Civil Division CUMBERLAND County No. 14-1493 Action in Ejectment , 2014 that Plaintiff's Motion for Service of Complaint and all future pleadings Pursuant to Special Order of Court is GRANTED, permitting service by: X First Class Mail to STEPHANIE A. MECK or occupants at the property which is subject to this Ejectment Action*. Service by first class mail is effective upon the date of mailing. X Posting of the property which is subject to this Ejectment Action* * the property at: 361 BELVEDERE STREET CARLISLE, PA 17013-3504 PH # 939505 tc.cL siaa/iy BY THE COURT: Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. Attorney for Plaintiff Court of Common Pleas Civil Division No. 14-1493 STEPHANIE A. MECK Or occupants Defendant CUMBERLAND County PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. Date: May 29, 2014 PH # 939505 Jo than Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP cute' 4g. // -75dcbtoi, #lyals?D 75/ 3Lt&SO 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 Court of Common Pleas ASSOCIATION Plaintiff vs. STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant Civil Division CUMBERLAND County No. 14-1493 AFFIDAVIT OF SERVICE VIA REGULAR MAIL I hereby certify that a true and correct copy of the Complaint in Ejectment in the above captioned matter was sent by Regular Mail, to the following person(s): STEPHANIE A. MECK or Occupants at 361 BELVEDERE STREET, CARLISLE, PA 17013-3504 in accordance with the Order of Court dated May 22, 2014. The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. DATE: June 5, 2014 PH # 939505 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP t• -"D- ! 2 l4� Phelan Hallinan, LLP dain 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 VS STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant • Attorney for Plaintiff OF 2014 JUL -9 At 1i: /2 ,OFFIC41- ,1:7LED, 1Y, PROTHO 07-Ah'Y COURT OF COMMON pLE4tq-CNRNLsAyrvACNQIU4A1 CIVIL DIVISION No. 14-1493 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) STEPHANIE A. MECK and Or occupants for possession of premises 361 BELVEDERE STREET, CARLISLE, PA 17013-3504 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 0.(1U-1 g. to. Sopa{ CLI4 JY?Lt2QS TZ:g- 26&02%9 IVIC1:4,64 Phelan Hallinan, LLP ,y 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. 14-1493 STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 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 STEPHANIE A. MECK 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 STEPHANIE A. MECK Or occupants, is over 18 years of age, and resides at 361 BELVEDERE STREET, CARLISLE, PA 17013-3504. (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: July 8, 2014 _ PH # 939505 Y(c-t% Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400, One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff VS Court of Common Pleas Civil Division No. 14-1493 STEPHANIE A. MECK or Occupants Defendant CUMBERLAND COUNTY TO: STEPHANIE A. MECK or Occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 DATE OF NOTICE: June 26, 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 # 939505 By: Joi(athan 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 PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 1.7F rift PEO`' FEDERAL NATIONAL MORTGAGE 2°1:414 y r�c�Ip rAi , ASSOCIATIONg l(1. Plaintiff COURT OF COMMON PL> �r� '2 NT CIVIL DIVISION pE►�y�0 CO vs No. 14-1493 S YL VAtNIA STEPHANIE A. MECK Or occupants 361 BELVEDERE STREET CARLISLE, PA 17013-3504 Defendant CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 361 BELVEDERE STREET, CARLISLE, PA 17013-3504 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION** Being Known as No. 361 BELVEDERE STREET DATE: 3c - S Cat' 4b,18 "" t �3, 7S c. so_istt Lk Sa tk ,t(-d.A27 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP sa,as acre jL,)2* 30 W--314 U00- Legal Description ALL THAT CERTAIN tract of ground situated in the Third Ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe in the eastern line of Belvedere Street at corner of land of Kinzie L. Weimer and Miriam R. Weimer; thence by said land South 86 degrees 30 minutes East 200.25 feet to an iron pipe; thence by land of Dete et al., South 7 degrees West 105 feet to a point; thence by land of R. Dale Parr and Ruth C. Parr North 86 degrees 30 minutes West 200.25 feet to a point on the Eastern line of Belvedere Street; thence by the Eastern line of Belvedere Street North 7 degrees East 105 feet to the place of beginning. BEING part of a larger tract designated as Tract No. 1 which R. Dale Parr and Ruth C. Parr, husband and wife, by their Deed dated September 24, 1958, and recorded September 26, 1958, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 18-R, Page 441, granted and conveyed unto John I. Adams and Elsie M. Adams, husband and wife. The said John I. Adams died October 14, 1966, wherein by operation of law title vested solely in Elsie M. Adams his widow, Grantor herein. 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. 14-1493 Civil Term STEPHANIE A. MECK or OCCUPANTS Costs Attorney's $ 241.06 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 NATIONAL MORTGAGE ASSOCIATION being: (Premises as follows): 361 BELVEDERE STREET, CARLISLE, PA 17013 '- **SEE 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 7/9/14 '(Sea!) �� iTh .L�>��it David D. Buell, Prothonotary, Common Pleas Court of Cumberland County, 2 of 2 No 14-1493 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. STEPHANIE A. MECK OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 241.06 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: ADAM H. DAVIS, ESQUIRE PHELAN HALLINAN, LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 (215) 563-7000 By virtue of this writ, on the Attorney for Plaintiff (s) Where papers may be served 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED -OFFICE Sheriff OF THE PROTHONO TAR I com of Cumber/44a 2014 AUG -6 A.M ,9: 5 ^ - CUMBERLAND COUNTY Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF PENNSYLVANIA Federal National Mortgage Association vs. Stephanie A Meck Case Number 2014-1493 SHERIFF'S RETURN OF SERVICE 07/30/2014 08:36 PM - Deputy Dawn Kell, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 361 Belvedere Street, Carlisle Borough, Carlisle, PA 17013. Property was posted pursuant to Court Order. SHERIFF COST: $53.03 SO ANSWERS, August 05, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ED- Cir i` Sheriff i H PR0 T HON0 Tik Jody S Smith Chief Deputy Richard W Stewart Solicitor ZO14 AUG 25 PM 2: 55 CUMBERLAND COUNTY oF`e`'FT1,.T _' r PENNSYLVANIA Federal National Mortgage Association vs. Stephanie A Meck Case Number 2014-1493 SHERIFF'S RETURN OF SERVICE 07/30/2014 08:36 PM - Deputy Dawn Kell, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 361 Belvedere Street, Carlisle Borough, Carlisle, PA 17013. Property was posted pursuant to Court Order. 08/25/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $54.59 SO ANSWERS, August 25, 2014 RONZ ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. pot ek) 4,4 97kri ,3/6?3�