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HomeMy WebLinkAbout14-6563 Supreme_Court of Pennsylvania Couft�;oCommon, .leas r Civil Gover She #; For Prothonotary Use Only: C > RIEIANDt4 County rt Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or re lace thefiling and service o leadin s or other papers as required b law or rules o court. Commencement of Action: S O Complaint O Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction O Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T FEDERAL NATIONAL MORTGAGE MICHAEL K.CLOUSER or Occupants I ASSOCIATION O Name of Plaintiff/Appellant's Attorney:Phelan Hallinan LLP N D Check here if you have no attorney(are a Self-Represented Pro.Se Litigant) AAre money damages requested? : O Yes dNo 9 Dollar Amount Requested: ❑ within arbitration limits (Check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑Yes CONO Is this an MDJ Appeal? D Yes 060 Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include CIVIL APPEALS ❑Intentional Judgments) Administrative Agencies O Malicious Prosecution ❑ Buyer Plaintiff ❑ Board of Assessment ❑Motor Vehicle D Debt Collection: Credit Card ❑Board of Elections ❑Nuisance ❑Debt Collection: Other ❑Dept.of Transportation ❑Premises Liability ❑Statutory Appeal: Other ❑Product Liability(does not include mass tort) ❑ Slander/Libel/Defamation ❑Employment Dispute: S ❑Other: Discrimination ❑Zoning Board E ❑Employment Dispute:Other ❑Other: C T I MASS TORT N D Asbestos ❑Other: D Tobacco ❑Toxic Tort-DES B O Toxic Tort-Implant ❑Toxic Waste RE L PROPERTY MISCELLANEOUS D Other: �jectment O Common Law/Statutory Arbitration D Eminent Domain/Condemnation ❑Declaratory Judgment ❑ Ground Rent ❑Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations PROFESSIONAL LIABLITY D Mortgage Foreclosure Resi8ential Restraining Order D Dental ❑Mortgage Foreclosure Commercial D Quo Warranto ❑Legal ❑ Partition ❑Replevin ❑Medical ❑Quiet Title ❑Other: D Other Professional: D Other: Pa.R.C.P.205.5 Updated 1/1/2011 Phelan Hallinan,LLP By: Adam H. Davis,Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 � 215-563-7000 ' �. FEDERAL NATIONAL MORTGAGE Court of Common Pleas Q ' ASSOCIATION ...a r P.O. Box 650043 Civil Division , V'' Dallas, TX 75265 Plaintiff CUMBERLAND CountyV. MICHAEL K. CLOUSER or Occupants No. 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 Defendant U 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# 953555 I.-- Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION. 2. Defendant is MICHAEL K. CLOUSER 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 Sheriff s deed was recorded on 10/30/2014 in the Office of the Recorder of CUMBERLAND County as Instrument No. 201424916 and that Plaintiff is the owner of property located.at 317 EAST PORTLAND STREET, MECHANICSBURG, PA 17055-3355 (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, MICHAEL K. CLOUSER 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. Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP r EXHIBIT "A" PH# 953555 LANDEX Document Data Page 1 of 1 Instrument#: 201424916 Book: Recorded Date: OCT 30, 2014 Page: 09:48:52 AM Total Pages: 5 Instrument Type: DEED-SHERIFFS Parcel Numbers: 18220519139 County: CUMBERLAND Municipality: MECHANICSBURG BOROUGH- 3RD WARD Recording Status: VERIFIED Notes: 317 E PORTLAND ST LOT 5 GRANTOR GRANTEE CLOUSER,MICHAEL K FEDERAL NATIONAL MTG ASSOC http://www.landex.com/webstore/jsp/cart/DocumentSearchResults jsp?LastName=CLOU... 10/31/2014 EXHIBIT "B" PH # 953555 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger,Registered Surveyor, dated August 5, 1953, as follows: BEGINNING at a point on the Northern line of Portland Street ninety(90)feet West of the Northwest corner of the intersection of Portland Street and Filbert Street, also being at the dividing line between Lots Nos. 4 and 5, Block'A' on hereinafter mentioned Plan of Lots; THENCE Westwardly along the Northern line of Portland Street, sixty(60)feet to a point at the dividing line between Lots Nos. 5 and 6,Block'A', on said plan;THENCE North eighteen(18) degrees eleven (11)minutes West along same, one hundred thirty nine and nine one-hundredths(139.09)feet to a point at the dividing line between Lots Nos. 2 and 5,Block'A', on said Plan; THENCE South sixty- two(62)degrees three (03)minutes East along same and along the dividing line between Lots Nos. 3 and 5, Block'A'on said Plan,eighty-six and fifty-eight one-hundredths (86.58) feet to a point at the dividing line between Lots Nos. 4 and 5, Block'A' on said Plan; THENCE South eighteen (18) degrees eleven(11)minutes East along same, seventy-six and sixty-seven one-hundredths (76.67) feet to a point,the place of BEGINNING. BEING Lot No. 5,Block'A'on Plan of Lots known as White Acres, said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 6. TITLE TO SAID PREMISES VESTED IN Michael K. Clouser, an adult Individual, by Deed from Linda K. Metz, a widow, dated 07/16/2004, recorded 07/30/2004 in Book 264, Page 2185. PREMISES BEING: 317 EAST PORTLAND STREET,MECHANICSBURG,PA 17055-3355 PARCEL NO. 18-22-0519-139. EXHIBIT "C" PH # 953555 PHELANI Repro--endny Lendem In Nnmylvdnie 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Email: VIOLETA.PATORI@fedphe.com October 31, 2014 MICHAEL K. CLOUSER or Occupants 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 RE: 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 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 09/03/2014. 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 Hallinan LLP edamav H. Dis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP PH# 953555 ro • . L VERIFICATION jj Christopher Wolfe am 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 basad on corporate sources of information. I cmderstand that false statements therein are made subject to the penalties of 18 Pa.C,S. 4904 relating to unsworn falsification to authorities. Date: 11/6/2014 Printed Name: Christopher Wolfe Title/Depam ent: Asset Recover Manager----- Company: anager_____ _—Company: ___y:g,Mie Mn PH # 953555 /REO#P14000X Return to: Phelan Hallinan., LLP One Penn Center, Suite 1.400 1617 JFK: Boulevard Philadelphia., PA 19103 Attn: Eviction Department PH# 953555 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE PRO 1 €iON I A!` n Oft c.Frie. r r, �aW 2011i NOV 20 PM 3: 1 7 CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Michael K. Clouser Case Number 2014-6563 SHERIFF'S RETURN OF SERVICE 11/14/2014 08:08 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael K. Clouser at 317 East Portland Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. J ON KINSLER, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, November 18, 2014 ROW/ R ANDERSON, SHERIFF ;a CountySuite Sheriff, Te osoft, Phelan Hallinan, LLP e_ P,ul' Cressman, Esq., Id. No.318079 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs MICHAEL K. CLOUSER Or occupants 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 Defendant Attorney for Plaintiff 2:14 DEC 18 f';; to: 33 COURT OF COMMON PLEASCOU;:TY CIVIL DIVISION +1,0 YLYANIA No. 14-6563 CIVIL 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) MICHAEL K. CLOUSER and Or occupants for possession of premises 317 EAST PORTLAND STREET, MECHANICSBURG, PA 17055-3355 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: Pau Attorney Phelan Halli ressman rP Esq., Id. No.318079 aintiff n, LLP 0,,,pcksitp.sopd cutfti Cjc_ti g men 2_* 31tr38 Phelan Hallinan, LLP pauliCressman, Esq., Id. No.318079 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. 14-6563 CIVIL MICHAEL K. CLOUSER Or occupants 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 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 MICHAEL K. CLOUSER 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 MICHAEL K. CLOUSER Or occupants, is over 18 years of age, and resides at 317 EAST PORTLAND STREET, MECHANICSBURG, PA 17055-3355. (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: December 17, 2014 PH # 953555 °ff.-104A Paul 7‘1. , , Esq., Id. No.318079 Attorney • ' laintiff Phelan Halli an, 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 MICHAEL K. CLOUSER or Occupants Defendant TO: MICHAEL K. CLOUSER or Occupants 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 DATE OF NOTICE: December 5, 2014 Court of Common Pleas Civil Division No. 14-6563 CIVIL CUMBERLAND COUNTY ** 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 By: PH # 953555 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 J•at. than Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 14-6563 CIVIL MICHAEL K. CLOUSER Or occupants 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 Defendant CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 317 EAST PORTLAND STREET, MECHANICSBURG, PA 17055-3355 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION** Being Known as No. 317 EAST PORTLAND ST DATE: etilA+ 3 9P-Sd 3q,36 ar- liP. SDS, Li 4 Paul - ssm. , Esq., Id. No.318079 Attorney .or laintiff Phelan Ha an, LLP (1#00,)97) 4141--11-1731F Legal Description ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger, Registered Surveyor, dated August 5, 1953, as follows: BEGINNING at a point on the Northern line of Portland Street ninety (90) feet West of the Northwest corner of the intersection of Portland Street and Filbert Street, also being at the dividing line between Lots Nos. 4 and 5, Block 'A' on hereinafter mentioned Plan of Lots; THENCE Westwardly along the Northern line of Portland Street, sixty (60) feet to a point at the dividing line between Lots Nos. 5 and 6, Block 'A', on said plan; THENCE North eighteen (18) degrees eleven (11) minutes West along same, one hundred thirty nine and nine one-hundredths•(139.09) feet to a point at the dividing line between Lots Nos. 2 and 5, Block 'A', on said Plan; THENCE South sixty- two (62) degrees three (03) minutes East along same and along the dividing line between Lots Nos. 3 and 5, Block 'A' on said Plan, eighty-six and fifty-eight one -hundredths (86.58) feet to a point at the dividing line between Lots Nos. 4 and 5, Block 'A' on said Plan; THENCE South eighteen (18) degrees eleven (11) minutes East along same, seventy-six and sixty-seven one -hundredths (76.67) feet to a point, the place of BEGINNING. BEING Lot No. 5, Block 'A' on Plan of Lots known as White Acres, said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 6. BEING the same premises which LINDA K. METZ, ADMINISTRATIX of the ESTATE OF ROBERT WAYNE METZ, by Indenture bearing date February 28, 2000 and recorded March 2, 2000 in the Office of the Recorder of Deeds, in and for the County of Cumberland Deed Book No. 216, page 1088 etc., granted and conveyed unto LINDA K. METZ, A WIDOW, in fee. l of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. MICHAEL K. CLOUSER OR OCCUPANTS 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 No. 14-6563 Civil Term Costs Attorney's $ 200.05 Plaintiff's $ Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland Couhty, 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): ***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 12/18/14 (Seal) D. .Tell, Prothonot Common Pleas Court of Cumberland County, PA 2 of 2 No 14-6563 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. MICHAEL K. CLOUSER OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 200.05 Plff (s� $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY DECD!C29 AI9:„ . t ,UM'IBLRLAND Ci✓'<UN!T Y PENNSYLVANIA Federal National Mortgage Association vs. Case Number Michael K. Clouser 2014-6563 SHERIFF'S RETURN OF SERVICE 12/23/2014 04:42 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person represent • themselves to be the Defendant, to wit: Michael K. Clouser at 317 East Portland Street, M: . r sb • Borough, Mechanicsburg, PA 17055, Cumberland County, and informed Defendai • . • t, if same. SH T N HA' 9W , DEPUTY SHERIFF COST: $41.55 SO ANSWERS, December 24, 2014 RONNY R ANDERSON, SHERIFF (c) CountySutte Sheriff, Teleescft. Ins. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFC'EOFTKE.»,P! RIFF J J(:,''33 .: I .. r Fi 7 4 CUil3EilL A s`tiC Cf,..; PENNSYLVANIA Federal National Mortgage Association vs. Michael K. Clouser Case Number 2014-6563 SHERIFF'S RETURN OF SERVICE 12/23/2014 04:42 PM - Deputy Shawn Harrison, 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: Michael K. Clouser at 317 East Portland Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County, and informed Defendant of contents of same. 01/09/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. SHERIFF COST: $42.88 SO ANSWERS, January 09, 2015 (c) ^our; ySuite Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF a.* 99y/� Alt 3/5loa' M 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. MICHAEL K. CLOUSER OR OCCUPANTS 317 EAST PORTLAND STREET MECHANICSBURG, PA 17055-3355 No. 14-6563 Civil Term Costs Attorney's $ 200.05 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): ***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 12/18/14 (Seal) /tet Prothonotary, Common Pleas Court of Cumberland County, PA "7-77!F,' C+r 7y RFC:CtrID In Tostimonywhereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. U This .Vdayof ,20 (_I Prothonotary 2 of 2 No 14-6563 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. MICHAEL K. CLOUSER OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 200.05 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: eve6sman , ist. apIltlan Cru l linan Attorney for Plaintiff (s) (01 sK,, e ) L(vv --ii‘1&& Lp &Where pT s may be ved By virtue of this writ, on the day of . I caused the within named , to have possession of the premises described with the a IS- S(o3_7000 appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy ,,Legal Description ALL THAT CERTAIN piece or parcel of land situate in the Borough ofMechariicburg, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger, Registered Surveyor, dated August 5, 1953, as follows: BEGINNING at a point on the Northern line of Portland Street ninety (90) feet West of the Northwest corner of the intersection of Portland Street and Filbert Street, also being at the dividing line between Lots Nos. 4 and 5, Block 'A' on hereinafter mentioned Plan of Lots; THENCE Westwardly along the Northern line of Portland Street, sixty (60) feet to a point at the dividing line between Lots Nos. 5 and 6, Block 'A', on said plan; THENCE North eighteen (18) degrees eleven (11) minutes West along same, one hundred thirty nine and nine one -hundredths (139.09) feet to a point at the dividing line between Lots Nos. 2 and 5, Block 'A', on said Plan; THENCE South sixty- two (62) degrees three (03) minutes East along same and along the dividing line between Lots Nos. 3 and 5, Block 'A' on said Plan, eighty-six and fifty-eight one -hundredths (86.58) feet to a point at the dividing line between Lots Nos. 4 and 5, Block 'A' on said Plan; THENCE South eighteen (18) degrees eleven (11) minutes East along same, seventy-six and sixty-seven one -hundredths (76.67) feet to a point, the place of BEGINNING. BEING Lot No. 5, Block 'A' on Plan of Lots known as White Acres, said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 6. BEING the same premises which LINDA K. METZ, ADMINISTRATIX of the ESTATE OF ROBERT WAYNE METZ, by Indenture bearing date February 28, 2000 and recorded March 2, 2000 in the Office of the Recorder of Deeds, in and for the County of Cumberland Deed Book No. 216, page 1088 etc., granted and conveyed unto LINDA K. METZ, A WIDOW, in fee.