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Home My WebLink About05-3218 THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / LD. No. 53002 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, v. SHANNON PETTY, KATHLEEN M. PETTY, THOMAS C. PETTY, JR., THOMAS CAPY PETTY, MATT CLAPPER and OCCUP ANT(S) OF 214 Oxford Street Gardners, P A 17324, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO, O~ - 3d./f C/U; t-r&.~ CIVIL ACTION EJECTMENT NOTICE NOTICIA YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAlNST THE CLAlMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WlTIllN TWENTY (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 THATIFYOUFAIL 100080 THE CASEMA YPROCEED WITHOUT YOU AND A JUDGMENT MAYBE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR 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 THlSPAPER TOYDUR lAWYER AT ONCE. lFYOVDO NOT HAVE ALA WYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIDS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IDRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES IHA I MAY OFFER LEGAL SERVICES TO EUGlBlE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service (717) 249-3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 LE HAN DEMANDADO A USrED EN LA CORTE. Sl USTED QUIERE DEFENDER8E DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGlNAS SIGUIENTES, USTED TlENE (20) DIAS DE PLAZO A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APAR!ENCIA ESCRlTA 0 EN PERSONA 0 PORABOGADO Y ARCHIV AREN LA CORTE SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA A VISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO A VISO 0 NOTIFICACION 0 POR CUALQIER QUEJA 0 ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, 8US PROPIEDADES 0 GTROS DERECHOS IMPORT ANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO lNMEDIAT AMENTE. SI NO IlENE ABOGADO 0 SI NO TIENE EL DINERO SUFIClENTE PARA PAGAR TAL SERVIClO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFlCINA CUYA DIRECCION SE ENCUENTRA ESCRlTA ARAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service (717) 249-3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 05.12509/ P051222 CIVIL ACTION -- EJECTMENT 1. The Plaintiff, Federal National Mortgage Association, is a corporation authorized to do business within the Commonwealth of Pennsylvania, having its principal place of business at International Plaza IT, 14221 Dallas Parkway, Suite 1000, Dallas, TX 75254-2916. 2. (a) The Defendant(s), Shannon Petty, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 214 Oxford Street, Gardners, PA 17324, hereinafter referred to as the "Foreclosed Premises". (b) The Defendant( s), Kathleen M. Petty, is an individual whom Plaintiffbelieves and therefore avers is residing at the Foreclosed Premises. (c) The Defendant(s), Thomas C. Petty, Jr., is an individual whom Plaintiff believes and therefore avers is residing at the Foreclosed Premises. (d) The Defendant(s), Thomas Capy Petty, is an individual whom Plaintiff believes and therefore avers is residing at the Foreclosed Premises. ( e) The Defendant( s), Matt Clapper, is an individual whom Plaintiffbelieves and therefore avers is residing at the Foreclosed Premises. (f) The Defendant (Unknown) Occupant(s) is/are individuals whom Plaintiff believes and theTefoTe avers are residing at the Foreclosed Premises, 3. The Foreclosed Premises which are described at Exhibit "A" attached hereto and incorporated herein by reference, were sold at the Cumberland County Sheriffs Sale conducted on June 8, 2005, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfY a Judgment entered in the Court of Common Pleas for Cumberland County at the suit of Sovereign Bank Y. Kathleen Petty and Thomas Petty, Jr., as Court Docket Number 04-6125. 4, The Foreclosed Premises were purchased by the Plaintiff at the Sheriffs Sale, said sale results being a matter of public record. The successful bid was assigned to this plaintiff. 5, The Plaintiff acquired title to the Foreclosed Premises on the date of and by virtue of said Sheriffs Sale, and is the real and current entitled owner of said Foreclosed Premises by virtue of a Cumberland County Sheriffs Deed Poll, to be recorded in the Cumberland County Recorder of Deeds' Office at the earliest possible date. 6. The persons in possession of the Foreclosed Premises are believed to be the Defendant(s) in this action and are occupying the Foreclosed Premises without right and without claim to title. 7. The Defendant(s) herein named were duly served with Notices of the Sheriffs Sale held on June 8, 2005. 8. Plaintiffhas demanded possession of the Foreclosed Premises from the Defendant( s) who have refused to deliver up the possession thereof. WHEREFORE, the Plaintiff, Federal National Mortgage Association, respectfully requests entry of judgment for immediate possession of the Foreclosed Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. Respectfully Submitted, THE LAW OFFICES OF BARBARA A. FEIN, p,c. Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 BY: ALL THAT CERTAIN tract of land, with the buildings and imrrovements thereon erected, 'situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a steel pin set on the eastern most dedicated right-of-way line of Township Road T-538, also known as Oxford Road, said pin marking the joinder of the line which extends between Lots Nos 8 and 9 on the hereinafter mentioned Plan of Lots, with the aforementioned dedicated right-of-way line; thence departing from the dedicated right-of~way line of Oxford Road and extending along Lot NO.8 on the hereinafter mentioned Plan of Lots, South 83 degrees 44 minutes 18 seconds East 252.30 feet to a steel pin at Lot no. 7 of the Plan; thence extending along Lot No.7 on the hereinafter mentioned Plan of lots South 6 degrees 15 minutes 42 seconds West a distance of 172.71 feet to a steel pin at lands now or late of Ross J. Richwine,; thence extending along lands now or formerly of Ross J. Richwine North 84 degrees 11 minutes 19 seconds West adistance of 152.70 feet to a steel pin on the eastern most dedicated right-of-way line of Township Road T-518, also known as O#ord Road; thence extending in and along the eastern most dedicated right-of-way line of Oxford Road North 23 degrees 32 minutes 15 seconds West a distance of 200.41 feet to a steel pin located on said dedicated right-of-way line at Lot No. 8 on the hereinafter mentioned Plan of Lots, said pin marking the place of BEGINNING. CONTAINING 35,124 square feet and being designated as Lot No.9 on the final plan of subdivision, prepared for John H. Fox by Jerry D. LaRue, R.S., dated November 28, 1977, and recorded in Plan Book 3'3, Page 3, Cumberland County records. HAVING thereon erected a dwelling house known and numbered as R.D. #1, Oxford Road, Gardn.ers, Pa. BEING THE SAME PREMISES which Richard A. Freeman and Diana L. Freeman, his wife, by Deed bearing date the 23rd day of September, 1985, and recorded on 23rd day of September, 1985 in the Office ofthe Recorder of Deeds in and for Cumberland County, Pennsylvania, in DeedlRecordBookl\>f31,Page 609, granted and conveyed unto Thomas Petty, Jr. and Kathleen Petty, his wife. UNDER AND SUBJECT TO restrictions and conditions as now appear ofrecord. TAX MAP PARCEL # 40-39-2211-008 i I EXHIBIT A . . VERIFICATION The undersigned, an officer of Federal National Mortgage Association, the instant Plaintiff, being authorized to make this Verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing "Civil Action -- Ejectment" are taken from the records maintained by persons supervised by the undersigned who maintains the Plaintiff's business records in the ordinary course of business and that those facts are true and correct to the best of her knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA,C,S. 54904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. FEDERAL NATIONAL MORTGAGE ASSOCIATION rf f) >, BY: -l11rJ Mary C, Newman, r/?{l/(v' --Co.. ^iP~~ V( ~ \) ~~ ~ '-!....... -- r-- V) V') -{) -Cl ,- C) C~ ...., = ~,::;::> <:11 C_ C". e o ., ::;J .1.. -n rn;;;".-::. ~ -"j' , ~ ~~ ~iJ .< '" o SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-03218 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PETTY SHANNON but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , PETTY SHANNON 214 OXFORD ROAD GARDNERS, PA 17324 DEFENDANT LIVES IN NEW YORK. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 7.40 5.00 10.00 .00 40.40 So ~" nswe :'," .-.-_--:;;? /0 ~~ (, R. Thomas Kline Sheriff of Cumberland County BARBARA FEIN 06/30/2005 Sworn and subscribed to before me P. ~ day 0/1 ~" L'-jl I this ;)01)~ A.D. QJfcL Q. h,J'.p,o ~ Pr t onotary , SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-03218 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CLAPPER MATT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , CLAPPER MATT 214 OXFORD ROAD GARDNERS, PA 17324 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 So answ~ :" /7 _____~ ~~~ R. Thomas Kline Sheriff of Cumberland County BARBARA FEIN 06/30/2005 Sworn and subscribed to before me this 1.2.1l:: day Of~ / J.1JtJ::, A.D. ~Q~~, Pro honotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-03218 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , OCCUPANT 214 OXFORD ROAD GARDNERS, PA 17324 THERE WERE NO OCCUPANTS, OTHER THAN THOSE LISTED. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 5.00 10.00 .00 21.00 So an.:_0/', ////;.//- ,:;c/~ ~~~ f R. Thomas Kline Sheriff of Cumberland County ;/ ...----' BARBARA FEIN 06/30(2005 Sworn and subscribed to before me this /.l.. ~ day of ~ :<.m;( A.D. C lU4d-'- Q ~ $- proihbnotary , SHERIFF'S RETURN - REGULAR CASE NO: 2005-03218 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon PETTY KATHLEEN M the DEFENDANT at 1905:00 HOURS, on the 29th day of June , 2005 at 214 OXFORD ROAD GARDNERS, PA 17324 by handing to KATHLEEN PETTY a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 rg~~.~ R. Thomas Kline 06/30/2005 BARBARA FEIN Deputy Sheriff Sworn and Subscribed to before By: me this /).. "E-- day of ~'f~~ h.-,,::D~ P othonotary . SHERIFF'S RETURN - REGULAR CASE NO: 2005-03218 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon PETTY THOMAS C JR the DEFENDANT , at 1905:00 HOURS, on the 29th day of June 2005 at 214 OXFORD ROAD GARDNERS, PA 17324 by handing to KATHLEEN PETTY, WIFE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavi t Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ..,_r/~;i "r-::";-;-- --::7P ,....~_f-'::.,J<.~..,II!-"'_i.....r '1 ,......-c~.>;(- -..-~ ...'-., ...... ~ ,/'~ d,'. ..-.J/-" f'," // ~" /-7 ~.A..,.,....--.-r R. Thomas Kline 06/30/2005 BARBARA FEIN Sworn and Subscribed to before me this J;i 'e day of Gq ;v,.{ A D 'tf::-'-- Q ~"'O,., J,,-c;:- othonotary ''-7 By: eputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2005-03218 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS PETTY SHANNON ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon PETTY THOMAS CAPY the DEFENDANT , at 1905:00 HOURS, on the 29th day of June , 2005 at 214 OXFORD ROAD GARDNERS, PA 17324 by handing to KATHLEEN PETTY, MOTHER a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ," / -~', R. Thomas Kline 06/30/2005 BARBARA FEIN Sworn and Subscribed to before By: me this J).. tb day of 0,P7 ~i A.D. c 7./(-,-, Q, /ru;P,,-, · ~z; P othonotary , THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 Kristen D. Little, Esquire / I.D. No. 79992 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff File No. 05-12509 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. NO. 05-3218 Civil Term SHANNON PETTY, KATHLEEN M. PETTY, THOMAS C. PETTY, JR., THOMAS CAPY PETTY, MATT CLAPPER and OCCUPANTS OF 214 Oxford Street Gardners, P A 17324, Defendants. PRAECIPE TO ENTER CONSENT JUDGMENT FOR POSSESSION TO THE PROTHONOTARY: Kindly enter the appended Consent Judgment for Possession in favor of Plaintiff and against the Defendants! t6J.i,,~ fYl. Pe.--I-t( ~ ih.on-kli C yd-J'-{ t JIZ .* THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: ~Q. Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 Dated: July 26, 2005 THE LAW OFFICES OF BARBARA A. FEIN, P.c. Barbara A. Fein, Esquire / J.D. No. 53002 Kristen D. Little, Esquire / 1.0. No. 79992 425 Commerce Drive, Suite 100 Fort Washington, P A 19034 (215) 653-7450 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIA nON, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. NO. 05-3218 Civil Term SHANNON PETTY, KATHLEEN M. PETTY, THOMAS C. PETTY, JR., THOMAS CAPY PETTY, MATT CLAPPER and OCCUPANTS OF 214 Oxford Street Gardners, P A 17324, Defendants. CONSENT JUDGMENT FOR POSSESSION AND NOW, this 14th day of June, 2005, it has been agreed by and between the parties that Judgment in Possession shall be immediately entered by the Prothonotary in favor ofthe Plaintiff, Federal National Mortgage Association, and against the Defendants, Kathleen M. Petty, and Thomas C. Petty, Jr., Sole Occupants of2l4 Oxford Street, Gardners, PA 17324. It is expressly understood by the parties that ejectment proceedings will continue, including, but not limited to, filing of record of this Consent Judgment for Possession, issuance of a Writ of Possession, and service of that Writ upon this Defendants. In the event that this Defendants fail to cooperate in accepting service of any pleading in this Civil Action -- Ejectment, including the Writ of Possession, the terms and conditions of this Consent Judgment are null and void, and the Plaintiff may undertake to schedule the lock-out by the Sheriffs Department for the soonest possible date. Petty Consent Judgment for Possession July 14,2005 Page 2 of3 The Defendants must coordinate with the Plaintiff hereunder, its agents, servicing contractors, appraisers and realtors to permit access to the foreclosed premises with reasonable notice. Failure to cooperate with respect to this provision of the Consent Judgment renders it null and void, and the Plaintiff may undertake to schedule the eviction by the Sheriffs Department for the soonest possible date. The Defendants may remain in the foreclosed premises under further condition that do not make applications of any kind in any court to frustrate, delay, impede or postpone this Plaintiffs right to possession of the foreclosed premises, or to otherwise extend their occupancy beyond the terms provided for hereunder. The Plaintiff shall have no obligation to repair the foreclosed premises, and this agreement is not intended, nor should the same be construed, to create a Landlord-Tenant relationship between the parties, The Occupants remain responsible for payment of all utility and telephone bills, and warrant that there will be no outstanding utility charges or liens resulting from their actions or failure to act on or before August3l, 2005. The Defendants agree to have their personalty removed from the premises on or before August 31,2005. They also agree that the interior of the home will be in broom-cleaned and in habitable condition. The Defendants agree that any personalty not removed from the home by August 31, 2005, may be disposed of by Plaintiff. In exchange for and in consideration of the entry of Consent Judgment for Possession against the Defendants, Plaintiff agrees that it will not schedule formal ejectment of the current occupant to occur until after August 31,2005. Petty Consent Judgment for Possession July 14, 2005 Page 3 of3 Each of the parties warrants and represents to the other that each ofthem is authorized and empowered to enter into this Agreement and to perform its terms; that in entering into this Agreement and performing its terms, neither of them will be in violation of any other agreement, oral or written. The Defendants acknowledges that they have read and understood this Consent Judgment for Possession; that they have consulted with an attorney in this matter in advance of executing this agreement; and they further represent and warrant that they enter into this Agreement of their own free will and volition. THE LAW OFFICES OF BARBARA A. FEIN, P.C. Dated: ~ J. 5'" , 2005 BY: Barbara A. Fein, Esquire Attorney for Plaintiff Federal National Mortgage Association Dated: 7.~o ,2005 BY: Dated: 7/~8' , ,2005 BY: ,2005 ilip C riganti, Esquire Counsel for the Defendants Attorney !.D. No, 54852 Dated: 7~ BY: COURT OF COMMON PLEAS Cumberland County Court House One Courthouse Square Carlisle, PA 17013 CURT LONG, PROTHONOTARY TO: Philip C. Briganti, Esquire 74 West Pomfret Street Carlisle, PA 17013 Kathleen M. Petty 214 Oxford Street Gardners, PAl 7324 Thomas C. Petty, Jr. 214 Oxford Street Gardners, P A 17324 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. NO. 05-3218 Civil Term SHANNON PETTY, KATHLEEN M. PETTY, THOMAS C. PETTY, JR., THOMAS CAPY PETTY, MATT CLAPPER and OCCUPANTS OF 214 Oxford Street Gardners, PAl 7324, Defendants. NOTICE Pursuant to Rule 236 ofthe Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above captioned proceeding as indicated below. CURT LONG, PROTHONOTARY [XX] Consent Judgment entered IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: BARBARA A. FEIN, ESQUIRE AT (215) 653-7450. n ~ '" f f: * a- CI) -c CI) '\Y~ ~ -...(J () () :-tJ ~ 1? ---c- ~~ C) (,~ ~ -n S. e,n :~ . , c) -I =,1 f-ii.j= ":-1 .:..J ,) -:1 ; ~.,.:~ :-:_~ ;--[1 -,.. :..,..... (....) :~': o ~~ r....,:.. ~ ~ ~CJ ~ b-u --:::--+-r "f;-:I- t., v, .;:;- r J~~ br r(! ~ t:. L B THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / 1.D. No. 53002 425 Commerce Drive, Suite 100 Fort Washington, P A 19034 (215) 653-7450 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. NO. 05-3218 Civil Term SHANNON PETTY, KATHLEEN M. PETTY, THOMAS C. PETTY, JR., THOMAS CAPY PETTY, MATT CLAPPER and OCCUPANTS OF 214 Oxford Street, Gardners, PA 17324, Defendants. PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue a Writ of Possession in the above matter with respect to real property situated at 214 Oxford Street, Gardners, PA 17324. C..lJd~ I J12-.+- k~Lf..W fYL. fJe--+4 :a.ucL ~~ THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire Attorney for Plaintiff BY: 1SOt.Lb~G. ~ ...c --.. ~ - - ~ U'\ ).J 9...l- ~ ~ 0 _ \-'l ~ -DV1 - - ~ .J::. C> C C C> C- O 0' r 7' ~ " c C c -tJ t.. \l '\> c:. C c --- ...() c c - ~ ?- \) C> .t - - CY - :: ~ - + E> ~ 1/7 - .:: .::: ~ ~ - - - ~1f ~ - '" - - - ~ - - b - ::: - ~ Q. g ;;A c.._; co," I - --0. i:,.~ "_'i.J C::> ._ f',:; * I ~~ t Pi ~j:- _r;:;- ~\ \} -1::: yr ------- - ALL THAT CERTAlN tract of land, with the buildings and imJrovements thereon erected, 'situate in South Middleton Township, Cumberland County, Pennsylvania, more pai-ticularly bounded and described as follows, to wit: BEGINNING at a steel pin set on the eastern most dedicated right-of-way tine of Township Road T-538, also known as Oxford Road, said pin marking the joinder of the line which extends between Lots Nos 8 and 9 on the hereinafter mentioned Plan of Lots, with the aforementioned dedicated right-of-way line; thence departing from the dedicated right-of"way line of Oxford Road and extending along Lot No.8 on the hereinafter mentioned Plan of Lots, South 83 degrees 44 minutes 18 seconds East 252.30 feet to a steel pin at Lot no. 7 of the Plan; thence extending along Lot No.7 on the hereinafter mentioned Plan of lots South 6 degrees 15 minutes 42 seconds West a distance of 172.71 feet to a steel pin at lands now or late of Ross J. Richwine,; thence extending along lands now or formerly of Ross J. Richwine North 84 degrees 11 minutes 19 seconds West adistance of 152.70 feet to a steel pin on the eastern most dedicated right-of-way line of Township Road T-518, also known as OJ(ford Road; thence extending in and along the eastern most dedicated right-of-way line of Oxford Road North 23 degrees 32 minutes 15 seconds West a distance of200.41 feet to a steel pin located on said dedicated right-of-way line at Lot No. 8 on the hereinafter mentioned Plan of Lots, said pin marking the place of BEGINNING. CONTAIN1NG 35,124 square feet and being designated as Lot No.9 on the final plan of subdivision, prepared for Jolm H. Fox by Jerry D. LaRue, R.S., dated November 28, 1977, and recorded in Plan Book 3'3, Page 3, Cumberland County records. HAVING thereon erected a dwelling house known and numbered as R.D. #1, Oxford Road, Gardners, Pa. BEING THE SAME PREMISES which Richard A. Freeman and Diana 1. Freeman, his wife, by Deed bearing date the 23rd day of September, 1985, and recorded on 23rd day of September, 1985 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed/RecordBookM31, Page 609, granted and conveyed unto Thomas Petty, Jr. and Kathleen Petty, his wife. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. TAX MAP PARCEL # 40-39-2211-008 WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 3165 etc.) FEDERAL NATIONAL MORI'GAGE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSCX::IATION Term Term vs. Costs KATHLEEN M. PETTY AND THCMAS C. PETTY, JR. 214 OXFORD STREET GARDNERS, PA 17324 Au'y. PI'ff (s) Prothy, $ 209.90 $ $ 00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of n lMRF.RT .AND County, Pennsylvania (I) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: FEDERAL NATIONAL MORI'GAGE ASSCX::IATION, Plaintiff (s) being: (Premises as follows): 214 OXFORD STREET GARDNERS, PA 17324 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell hisfher (or their) interest therein. Prothonotary, Date AUGUST 1, 2005 By: (SEAL) Deputy >- C/J "d "d >- Z Z ::l'" '"' :4! ("'l_ Cl- '" 0 ;::: I~~ ~ <:l <:l Cl- ~ ez '"' ::l'" ~ ':" (l S:i ':" en "'!:f ~..., en ~ en ~ij ~ 0:1= alCl t"'lt"'l ~~Cl~ I =-'::; . 1'h: ~ ::Z=("'l lJ1 ~ lJ1 >- t""o ?='::z= "d . >-e I ~ ~~"d ~ ~~~~~ - Z::z= 0"" ~~~ 1:;..., ~"'H~'< =-,0 ("'lo :>' ...."'l e5 o"'l "OlJ1~ 0" . n ... ",,",0 '"' 0 --= ~ < e("'l 3 0 "d til '" ~o en ! ~o ~ r'Jl ~ '='~ H '" Z ....'Jl i .>< ~ .. H _. -t"'l u [ii'" ~'Jl -=~ ~ t-cI =. 'Jl ;p... ~ t':I U1'Jl 1;; t"'l0 '" ~ ~ t"'l- Zz ..., l--'~::.f) ...,0 ;:;l ;:;l < \0 V ~ Z-= '" OH H ("'lZ n Cl- ~t;J Ell V; V; V; V; . 'Jlt"" '"' '"' ~ H ><t"'l 3 3 f-' ~ ~ ~;>- 0 ~ ;>-'Jl 0 f-' ZO . 0 -"'l 0 ;>- "-' :;0 . 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 So Answers, Sworn and subscribed to before me this day of Sheriff By Prothonotary Deputy