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HomeMy WebLinkAbout14-4979 Supreme Court ofPennsylvania X Cour * Com to Pleas Us For Prothonotary VN Prothonotarye Onlv: Hie'e t County Do&etNo: 0 b 6Ka& P The information collected on this form is used solely for court administration purposes. Thisfo rm does not Supplement or replace thefiling and ser ilice a fpleadiqgs or other papers as required by 1mv or rules of court. Commencement of Action: X Complaint 0 Writ of Summons 0 Petition S 0 Transfer from another Jurisdiction 0 Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C NATIONSTAR MORTGAGE LLC PATRICIA L.JORDAN T I Dollar Amount Requested within arbitration limits 0 Are money Damages requested?: 0 Yes No (Check one) outside arbitration limits 'IN7 Is this a Class Action Suit? 13 Yes NO Is this an MDJ Appeal? 0 Yes NO A Name of Plaintiff/appellant's Attorney:KML LAW GROUP,P.C. 13 Check here if you 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 APPEAL 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection:Credit Card 0 Board of Assessment 0 Motor Vehicle 0 Debt Collection:Other 0 Board of Elections 0 Nuisance 0 Dept.of Transportation S 0 Premises Liability 0 Zoning Board 1E 0 Product Liability(does not include 0 Employment dispute: 0 Statutory Appeal:Other mass fort) Discrimination C 0 Slander/Libel Defamation 0 Other 0 Employment Dispute:Other T 0 Other: I 0 MASS TORT 0 Other N 0 Asbestos 0 Tobacco 0 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS 0 Toxic Tort-Implant R Ejectment 0 Common Law/Statutory 0 Toxic Waste 11 Eminent Domain/Condemnation Arbitration B r_1 Other 11 Ground Rent 0 Declaratory Judgment 0 Landlord/Tenant Dispute 0 Mandamus 0 Mortgage Foreclosure:Residential 0 Non-Domestic Relations PROFESSIONAL LIABILITY 0 Mortgage Foreclosure;Commercial Restraining Order 0 Dental 0 Partition El Quo Warranto 0 Legal 0 Quiet title 0 Replevin 0 Medical 0 Other Professional: 0 Other 0 Other Pa.R.C.P. 205.5 Updated 11112011 r F'li_E -O FICED 'Gso Ci t . 4 Alli AGG 25 Aft IQ: 4 I 20144U� KML LAW GROUP,P.C. tlr ibES3L ND COUP i Y cukis C ^ ' l�. ©u Suite 5000 BNY Mellon Independence CentePENNS YLYANIA pE NS�N 701 Market Street YL A r Philadelphia,PA 19106 (215) 627-1322 Attorneys for Plaintiff NATIONSTAR MORTGAGE LLC 350 Highland Drive IN THE COURT OF COMMON PLEAS Lewisville,TX 75067 OF Cumberland COUNTY Plaintiff CIVIL ACTION-LAW VS. ACTION OF EJECTMENT PATRICIA L. JORDAN and OCCUPANTS J 1—L - 1 I q (V� 18 South Chestnut Street No. Mechanicsburg,.PA 17055 Defendants 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 twenty (20) days after the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE BAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE Q CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE S USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU C,I�# -1-, 1sgoil, ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION,ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. r CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is NATIONSTAR MORTGAGE LLC,with an address of 350 Highland Drive, Lewisville, TX 75067. 2. Defendants are PATRICIA L. JORDAN, and OCCUPANTS. 3. The Defendants, PATRICIA L. JORDAN and OCCUPANTS, occupy the property located at 18 South Chestnut Street, Mechanicsburg, PA 17055 ("the Property") and do so without right, and so far as the Plaintiff is informed, without claim of title. 4. Plaintiff is the owner of the Property by virtue of a Deed from the Sheriff of Cumberland County to Plaintiff that was recorded on 3/27/2014 at Instrument# 201406186 in the Recorder's Office of Cumberland County. A true and correct copy of the Sheriff's Deed containing the description of the Property is attached to this Complaint. 5. Plaintiff is entitled to immediate possession of the Property. 6. Plaintiff has demanded possession of the Property from the Defendants who have refused to deliver up possession. WHEREFORE, Plaintiff requests judgment for possession of the Property. By: �w /1" KML LAW GROUP,P.C. Jay E.Kivitz Pa.ID 26769 Michael McKeever Pa.ID 5 29 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 ,,Salvatore Filippello Pa.ID 313897 Attorneys for Plaintiff i VERIFICATION o f1 d I `BOYS 1 C hereby states that he/she is the ' (�;y�(,1(,}Ql� of Plaintiff in this matter,NATIONSTAR MORTGAGE LLC, and that all of the facts set forth in the attached Plaintiff's Complaint are true and correct to the best of his/her information and belief. The undersigned understands that statements herein are made subject to the penalties of 18 P.S. §4904. NATIONSTAR MORTGAGE LLC By: Q Ir) Printed N me: lll r t d f� OYS i C Tit1e: �4rm��Pl� INa-�7v1-1 FILE#: 128112EJ REO ID#: PROPERTY: 18 South Chestnut Street Mechanicsburg PA 17055 DEFENDANT: JORDAN, PATRICIA L. EXHIBIT "A" SHERIFF'S DEED FILE#: 128112EJ PROPERTY: 18 South Chestnut Street Mechanicsburg PA 17055 0035P0 Tax Parcel No 17-23-0565-245 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$ 40,000.00 (Forty Thousand Dollars)to me in hand paid, do hereby grant and convey to Nationstar Mortgage LLC 2013-1668 Civil Term Nationstar Mortgage LLC Vs Patricia L.Jordan ALL THAT CERTAIN house and lot of ground situate on the West side of south Chestnut Street,in the Second Ward of the Borough of Mechanicsburg,County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at a point in the Western line of south Chestnut Street,at corner of Lot formerly of John Geiger, later of Harry W.Mountz,and now of Robert Mumma;thence extending along the Western line of South Chestnut Street in a Southwardly direction a distance of 64 feet,more or less,to a point at corner of Lot formerly of Frank L Mountz,now of RB.Groff;thence along the line of said Lot formerly of Frank L.vlount ,now fH.B. ra off in the Westwardly direction,a distance of 147 feet to a point in the Eastern line of public alley; n e eg Eastern line of said public alley in a Northwardly direction,a distance of 64 feet,more or less,to a point at corner of Lot formerly of Harry W.Mountz,now of Robit Mumma,aforementioned;thence along the line of said Lot now of Robe ll Mumma in an Eastwardly direction,a distance of 147 feet to a point in the Western line of South Chestnut Street,aforementioned,at the point and place of BEGINNING. HAVING THEREON ERECTED a frame dwelling house known and numbered as 18 South Chestnut Street (formerly numbered 16-18 South Chestnut Street),Mechanicsburg,Pennsylvania. BEING FURTHER identified as Tax Parcel#17-23-0565-245. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY BOROUGH OF MECHANICSBURG BEING PREMISES: 18 South Chestnut Street,Mechanicsburg PA 17055 SOLD as the property of PATRICIA L.JORDAN TAX PARCEL#17-23-0565-245 BEING THE SAME premises which Justin A.Szurgot,a single man by Deed dated July 2,2009 and recorded on July 10, 2009,as Instrument#200923994,granted and conveyed unto Patricia L.Jordan, a single woman. BEING THE SAME premises which Patricia.L.Jordan,a single woman by Deed dated April 21,2013 and recorded on August 19,2013,in the Office of the Recorder of Deeds in and for Cumberland County as Instrument#201327395,granted and conveyed unto PUG S. The same having been sold by me to the said grantee on the 4th day of December Airco Domini Two Thousand and Thirteen (2013) after due advertisement according to law,under and by Virtue of a Writ of Execution issued on the 21st of June Anno Domini 2013 out of the Court of Common Pleas of Cumberland County,Pennsylvania, as of Civil Term,Two Thousand and Thirteen (2013) Number 1668 at the suit of Nationstar Mortgage LLC—vs-Patricia L. Jordan In Witness Whereof, I have hereunto affixed my signature this 24th day of January Anno Domini Two Thousand and Fourteen(2014) RorPR. derson, 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 20' day of January Anno Dornini Two Thousand and Fourteen(2014 ProtY prothonotary,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018 I hereby certify that the residence And Post Office address of the Within Grantee is P.+.1 = 350 Highland Drive ' Lewisville,TX 75067 Ric lard W. Stewart Solicitor "q° V TAMMY SHEARER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE � � ` - • .tin... CARLISLE, PA 17013 717-240-6370 Instrument Number-201406186 Recorded On 3/27/2014 At 12:03:43 PM *Total Pages-5 *Instrument Type-DEED-SHERIFF'S Invoice Number-158388 User ID-MSW *Grantor-JORDAN,PATRICIA L *Grantee-NATIONSTAR MORTGAGE LLC *Customer-KML LAW GROUP FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES - $12.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $15.00 FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 MECHANICSBURG SCHOOL $0.00 DISTRICT MECHANICSBURG BOROUGH $0.00 TOTAL PAID $68.00 I Certify this to be recorded in.Cumberland County PA °V°UMe� o RECORDER OF DEEDS »so *-Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0035PO Illl{IIiIIIIIIIIIIIIIIIIi SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1{; 1,ir'i. ;,: Sheriff , et C..snnLr , Jody S Smith "Ott �r 20I4 OCT — I PH 2: 37 Chief Deputy Richard W Stewart , CUMBERLAND COUNTY Solicitor OR i =r THE VEMFP PENNSYLVANIA Nationstar Mortgage LLC vs. Patricia L Jordan Case Number 2014-4979 SHERIFF'S RETURN OF SERVICE 09/05/2014 07:42 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Wajunita Russo, Current Tendant, who accepted as "Adult Person in Charge" for Occupant at 18 South Chestnut Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. 09/23/2014 09:10 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Ejectment by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia L Jordan at 304 Hempt Drive, Hampden Town ip, Mechanicsburg, PA 17050. WN GU - ' LL, DEPUTY SHERIFF COST: $66.60 SO ANSWERS, September 24, 2014 (c) CountySuite Sheriff, Te-leosoff. Inc. RONIN R ANDERSON, SHERIFF KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 14-4979 CIVIL PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, NATIONSTAR MORTGAGE LLC and against the Defendants OCCUPANTS for failure to file an Answer in the above action within (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 Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is NATIONSTAR MORTGAGE LLC, 350 Highland Drive, Lewisville, TX 75067 and that the names and last known address of the Defendant OCCUPANTS is 18 South Chestnut Street, Mechanicsburg, PA 17055. B / By: : KML LAW GROUP, P.C. Jay E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 X, Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff GivjA tA:t._ -7goobaL '7 8-010S Rit ays t. Nooh-Le Nettle KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 14-4979 CIVIL CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Bethany Stewart, an employee of KML LAW GROUP, P.C., counsel for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 DATED: J 0/02 /IMF) ItP y. //.4...r A,1 AW G , P.C. Bethany Stewa egal Assistant 215-825-6354 (Direct Phone) B• K XML LAW GROUP, P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF NATION STAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants DATE OF THIS NOTICE: October 3, 2014 TO: OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Tenn No. 14-4979 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 If you are an active duty member of the United States Armed Forces or a dependent of an active duty servicemember, you may be entitled to rights as provided in the Servicemembes Civil Relief Act. In such case, you or your attorney should contact the nndtrsignrd at the telephone number at the top of this paper and provide proof of military service immediately so that we can determine if you fall under the protection of the Act. By: L • F, GROUP, P. . Jay E. Kivltz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa, ID 82628 Jill P. Jenkins Pa. ID 306588 Salvatore Filippello Pa. ID 313 897 Jennifer Lynn Frechie Pa. ID 316.1.60 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC Plaintiff vs. PATRICIA L. JORDAN Defendant(s) 14-4979 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned, an employee of KML Law Group, P.C., does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, OCCUPANTS, has a last known residence of 18 South Chestnut Street, Mechanicsburg, PA 17055. 3. Deponent is unable to confirm that the Defendant is in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date ?o a7 14 By: KML LAW GROUP, P.C. Jay E. Kivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 —)ZSalvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Ronny RAnderson Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY o�,.,0 of cum Jody S Smith vid. Chief Deputy i i` Richard W Stewart ' -.2 Solicitor or --7.:(•s, Or' E al;yRIFF Nationstar Mortgage LLC vs. Patricia L Jordan Case Number 2014-4979 SHERIFF'S RETURN OF SERVICE 09/05/2014 07:42 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Wajunita Russo, Current Tendant, who accepted as "Adult Person in Charge" for Occupant at 18 South Chestnut Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. CHRISTOFYHER SHARPE, DEPUTY 09/23/2014 09:10 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Ejectment by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia L Jordan at 304 Hempt Drive, Hampden Towns ip, Mechanicsburg, PA 17050. SHERIFF COST: $66.60 September 24, 2014 WN GU 'ALL, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF iv\I f- s': ;u C.'C c:. i_[ N, _ . . I, P:'c, .' allJu ..1 . ... C ..Il p(1 c FD:S' •• (cl CounlySuito Sheriff, Teleosoft Inc. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Curt Long -- Prothonotary NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants NOTICE Term No. 14-4979 CIVIL Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KML Law Group, P.C. at the following telephone number: (215) 825-6319 5-60 (2) (Rev.4/78)55 KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 191064532 215-825-6319 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants THE FRO'ffiON077-,RY 201 ti MI/ 10 /11h1: 39 CLq1E3Ei;LA13 COU I LOANIA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 14-4979 CIVIL PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, NATIONSTAR MORTGAGE LLC "and against the Defendants PATRICIA L. JORDAN for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237.1, written 10 day notice of Plaintiff's intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is NATIONSTAR MORTGAGE LLC, 350 Highland Drive, Lewisville, TX 75067 and that the names and last known address of the Defendant PATRICIA L. JORDAN is 18 South Chestnut Street, Mechanicsburg, PA 17055. By: KM A GROUP, P.C. i7Jay E. ivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa, ID 82628 Thomas Puleo Pa, ID 27615 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 14-4979 CIVIL CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Bethany Stewart, an employee of KML LAW GROUP, P.C., counsel for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: PATRICIA L. JORDAN 18 South Chestnut Street Mechanicsburg, PA 17055 DATED: 1/10NON By: KML LAW GR Bethany Stew 215-825-6354 ( , P.C. egal Assistant ect Phone) KML LAW GROUP, P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants DATE OF THIS NOTICE: October 24, 2014 TO: PATRICIA L. JORDAN JORDAN, PATRICIA L. 304 Hempt Drive Mechanicsburg, PA 17050 IMPORTANT NOTICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 14-4979 CIVIL YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 If you are an active duty member of the United States Armed Forces or a dependent of an active duty servicemember, you may be entitled to rights as provided in the Servicemembers Civil Relief Act. In such case, you or your attorney should contact the undersigned at the telephone number at the top of this page and provide proof of military service immediately so that we can determine if you fall under the protection of the Act. By: KM AWjGROUP, P.C. ✓Jay E. ivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC Plaintiff vs. PATRICIA L. JORDAN Defendant(s) NO. 14-4979 CIVIL VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): PATRICIA L. JORDAN, has a last known residence of 18 South Chestnut Street, Mechanicsburg, PA 17055. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date 11 (19 /14 By: ICML L G OUP, P.C. Michael McKeever Pa. JD 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center status Report uaant to Se came i s Civil Relief Act. Last Name: JORDAN First Name: PATRIIA Middle Name: L Active Duty Status As Of: Nov -05-2014 Results as of : Nov -05-2014 05:56:32 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,A" - + .. _ - -. No''',... NA This response reflects the lndivlduals' active duty status based on -the Active Duty Status Date „ T�R'tA ii Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA -. NA `- J.. ' ` 'fir`. { . . _ ..---No",, NA This response reflects where the individual left active duty status within 367 days preceding the Acute Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA 4,;t:, NA 1 * r. -'c No ` NA This response reflects whether the individual or his/her unit has received early nOtification to report for active duty - Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed, Services (Atmy, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 7FIBU9C4T005CF0 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 01r. Ceuro A.. • OCF QF WE Nationstar Mortgage LLC vs. Patricia L Jordan Case Number 2014-4979 SHERIFF'S RETURN OF SERVICE 09/05/2014 07:42 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Wajunita Russo, Current Tendant, who accepted as "Adult Person in Charge" for Occupant at 18 South Chestnut Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. CHRISTOPHER SHARPE, DEPUTY 09/23/2014 09:10 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Ejectment by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia L Jordan at 304 Hempt Drive, Hampden Town ip, Mechanicsburg, PA 17050, WN GU ALL, DEPUTY SHERIFF COST: $66.60 SO ANSWERS, September 24, 2014 RONF4Y R ANDERSON, SHERIFF Mf l ...1;;; :IJ p!...,!,141..C1; ;0 .to CounlySuilo Sheriff, Teleosoft OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Curt Long Prothonotary NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Plaintiff Defendants NOTICE Term No. 14-4979 CIVIL Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby noti3 d that judg> las been entered against you in the above proceeding as indicated below: Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings Confession of Judgment :otkronotd y 11\1010 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KML Law Group, P.C. at the following telephone number: (215) 825-6319 5-60 (2) (Rev. 4/78)55 C.P. 109 —P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 14-4979 CIVIL PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter, for possession of 18 South Chestnut Street Mechanicsburg, PA 17055 (describe property) alt,60_‘,084.0 A 049 0(4100 Nsi (L • So LL Ejectment Quiet Title A. 5 — 116 (Rev. 10/76) 1,1 S it gs JDJ a SEE ATTACHED LEGAL DESCRIPTION By: KM A GROUP, P. E. ivitz Pa. ID 26769 Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff to.9. aq_S P 7g26,034 31;42.93 'tiOrr I oss assveci WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160-3165) NATIONSTAR MORTGAGE LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland To the Sheriff of Cumberland County, Pennsylvania. COURT OF COMMON PLEAS Term No. 14-4979 CIVIL WRIT OF POSSESSION (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to NATIONSTAR MORTGAGE LLC, Plaintiff, being: (Premises as follows): 18 South Chestnut Street Mechanicsburg, PA 17055 (2) To satisfy the costs against the defendants you are directed to levy upon any property of the defendants and sell his, her or their interest therein. Dated: • 1 gf Prothonotary, ou of Common Pleas Cumberland County By: Deputy Term No. 14-4979 CIVIL IN THE COURT OF COMMON PLEAS Cumberland COUNTY NATIONSTAR MORTGAGE LLC vs. PATRICIA L. JORDAN and OCCUPANTS 18 South Chestnut Street Mechanicsburg, PA 17055 WRIT OF POSSESSION Costs KML LAW GROUP, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 825-6319 ALL THAT CERTAIN house and lot of ground situate on the West side of South Chestnut Street, in the Second Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Western line of South Chestnut'Strcet, at corner of Lot formerly of John Geiger, later of Harry W. Mountz, and now of Robert Mumma; thence extending along the Western line of South Chestnut Street in a Southwardly direction a distance of 64 feet, more or less, to a point at corner of Lot formerly of Frank L Mount; now of RB. Groff; thence along the line of said Lot formerly of Frank L. vlountz, now of N.B. Groff in a Westwardly direction, a distance of 147 feet to a point in the Eastern line of public alley; thence extending along the Eastern line of said public alley in a Northwardly direction, a distance of 64 feet, more or less, to a point at corner of Lot formerly of Harry W. Mount, now of Robert Mumma, aforementioned; thence along the line of said Lot now of Robert Mumma in an Eastwardly direction, a distance of 147 feet to a point in the Western line of South Chestnut Street, aforementioned, at the point and place of BEGINNING. HAVING THEREON ERECTED a frame dwelling house known and numbered as 18 South Chestnut Street (formerly numbered 16-18 South Chestnut Street), Mechanicsburg, Pennsylvania. BEING FURTHER identified as Tax Parcel #17-23-0565-245. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY BOROUGH OF MECHANICSBURG BEING PREMISES: 18 South Chestnut Street, Mechanicsburg PA 17055 SOLO as the property of PATRICIA L. JORDAN TAX PARCEL 07-23-0565-245 BEING THE SAME premises which Justin A. Szurgot, a single man by Deed dated July 2, 2009 and recorded on July 10, 2009, as Instrument #200923994, granted and conveyed unto Patricia L. Jordan, a single woman. BEING THE SAME premises which Patricia L. Jordan, a single woman by Deed dated April 21, 2013 and recorded on August 19. 2013, in the Office of the Recorder of Deeds In and for Cumberland County as Instrument #201327395, granted and conveyed unto PUG S. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC VS. No. 14-4979 Civil Term_ PATRICIA L. JORDAN AND OCCUPANTS Costs Attorney's $ 243.85 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)) NATIONSTAR MORTGAGE LLC being: (Premises as follows): for possession of 18 SOUTH CHESTNUT STREET, MECHANICSBURG, PA 17055 (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, Pro hono ' Common Pleas Court of umberland County, PA ef. ' Date 11/1012014, (Seal) _ 2 of 2 No 14-4979 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC VS. PATRICIA L. JORDAN AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 243.85 P1ff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: By virtue of this writ, on the named appurtenances, and Attorney for Plaintiff (s) Where papers may be served day of , . I caused the within , to have possession of the premises described with the Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE PRO THOHd (G I LI DEC -2 Pty 3:18 CUMBERLAND COUNTY PENNSYLVANIA OF OE OF THE EF!SRIFF Nationstar Mortgage LLC vs. Patricia L Jordan (et al.) Case Number 2014-4979 SHERIFF'S RETURN OF SERVICE 11/19/2014 09:12 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on November 19, 2014 at 2112 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to wit: OCCUPANT, of 18 S Chestnut Street, Mechanicsburg, Cumberland County, Pennsylvania 17050. The property was found to be vacant Therefore, the within Writ of Possession is being returned with no service as to the defendant, OCCUPANT, who was NOT FOUND. 12/01/2014 07:12 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: Patricia L Jordan at 304 Hempt Drive, Hampden Township, Mechanicsburg, PA 17050, Cumberland County, and informed Defendant of contents of same. SO ANSWERS, December 02, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySulte Sheriff, Teleosoft, Inc. 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC VS. No. 14-4979 Civil Term PATRICIA L. JORDAN AND OCCUPANTS Costs Attorney's $ 243.85 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)) NATIONSTAR MORTGAGE LLC being: (Premises as follows): for possession of 18 SOUTH CHESTNUT STREET, MECHANICSBURG, PA 17055 (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. OW //Sda( David D. Buell, PrY onotary, Common Pleas Court of Cumb-rland County, PA Date 11/10/2014 (Seal) 2 of 2 No 14-4979 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONSTAR MORTGAGE LLC VS. PATRICIA L. JORDAN AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 243.85 Plff (s) $ Prothy $ 225 Sheriff $ Plaintiff (s) attorney name and address: JAY E. KIVITZ, ESQ. KML LAW GROUP, P.C. SUITE 5000 BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-627-1322 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 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This/ %,> day of AP•60 201 Proth otary ALL THAT CERTAIN house and lot of ground situate on the West side of South Chestnut Street, in the Second Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Western line of South Chestnut Street, at corner of Lot formerly of John Geiger, later of Harry W. Mountz, and now of Robert Mumma; thence extending along the Western line of South Chestnut Street in a Southwardly direction a distance of 64 feet, more or less, to a point at corner of Lot formerly of Frank L Mauritz, now of RB. Groff; thence along the line of said Lot formerly of Frank L. vlountz, now of H.B. Groff in a Westwardly direction, a distance of 147 feet to a point in the Eastern line of public alley; thence extending along the Eastern line of said public alley in a Northwardly direction; a distance of 64 feet, more or less, to a point at corner of Lot formerly of Hang W. Mountz, now of Robert Mumma, aforementioned; thence along the line of said Lot now of Robert Mumma in an Eastwardly direction, a distance of 147 feet to a point in the Western line of South Chestnut Street, aforementioned, at the point and place of BEGINNING. I lAVING THEREON ERECTED a frame dwelling house known and numbered as 18 South Chestnut Street. (formerly numbered 16.18 South Chestnut Street), Mechanicsburg, Pennsylvania. BEING FURTHER identified as Tax Parcel #17-23-0565-245. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY BOROUGH OF MECHANICSBURG BEING PREMISES: 18 South Chestnut Street, Mechanicsburg PA 17055 SOLD as the property of PATRICIA L. JORDAN TAX PARCEL 417-23-0565-245 BEING THE SAME premises which Justin A. Szurgot, a single man by Deed dated July 2, 2009 and recorded on July 10, 2009, as Instrument #200923994, granted and conveyed unto Patricia L. Jordan, a single woman. BEING THE SAME premises which Patricia L. Jordan, a single woman by Deed dated April 21, 2013 and recorded on August 19, 2013, in the Office of the Recorder of Deeds in and for Cumberland County as Instrument #201327395, granted and conveyed unto PUG S.