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Home My WebLink About05-4832 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. CHARLES L. REIGEL aIkIa CHARLES REIGEL, FA WNE FITZWATER aIkIa FA WNE E. REIGEL, BILL J. REIGEL, GRADY S. VOIGT JR. AND OCCUPANTS OF 59 East Penn Street, Carlisle, P A 17013, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. OS -J{j>3~ {}IUd..~~ CIVIL ACTION EJECTMENT NOTICE NOTICIA vou 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 TIllS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITIEN APPEARANCE PERSONAlLY OR BY ATTORNEY AND FILING IN WRITING WITII THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTI! AGAINST YOU. YOU ARE W ARNEDTHATIFYOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT vou AND A JUOOMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT RJRTHER 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 RIOHfS IMPORTANT TO YOU. YOU SHOUID TAKE TInS PAPER TO YOUR LAWYER AT ONCE. IFYOUDO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFlCE SET FORTH BELOW. TIDS OffiCE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OffiCE MAY BE ABLE TO PROVIDE YOU WTIH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE 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 BAN DEMANDAOO A USlED EN LA CORTE. Sl USlED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUlENTES, USTED TIENE (20) DlAS DE PIAZO A PARTIR DE ]A FECHADE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGAOO Y ARCmv AREN LA CORTE SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SUPERSONA. SEAA VISADOQUE SI USTEDNO SE DEFlENDE,]A CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0 NOTlFICACION 0 POR CUALQIER QUEJA 0 AUVIO QUE ESPEDIIX> EN LA PETICION DE DEMANDA. USlED PUEDE PERDERDINERO, SUS PROPIEDADES OOTROS DERECHOS lMPORTANTES PARA USTED. LLEVE ESTA DEMANDAA UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DlNERO SUf1CIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA 0 UAME POR TELEFONO A LA OFlCINA CUYA DlRECCION SE ENCUENTRA ESCRITA ABAJO 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 05-12818/ P051942 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 II, 14221 Dallas Parkway, Suite 100 Dallas, TX 75254-2916. 2. (a) The Defendant, Charles L. Reigel, alk/a Charles Reigel, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 59 East Penn Street, Carlisle, P A 17013, hereinafter referred to as the "Foreclosed Premises". (b) The Defendant, Fawne Fitzwater, alk/a Fawne E. Reigel, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 59 East Penn Street, Carlisle, PA 17013, hereinafter referred to as the "Foreclosed Premises". (c) The Defendant, Bill J. Reigel, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 59 East Penn Street, Carlisle, P A 17013, hereinafter referred to as the "Foreclosed Premises". (d) The Defendant, Grady S. Voigt Jr., is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 59 East Penn Street, Carlisle, P A 17013, hereinafter referred to as the "Foreclosed Premises". (e) The Defendant (Unknown) Occupant(s) is/are individuals whom Plaintiff believes and therefore 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 Sheriff's Sale conducted on September 7, 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 ofCendant Mortl!al!e COI;poration v. Charles L. Reigel aIkIa Charles Reigel, as Court Docket Number 05-586 Civil Term. 4. The Foreclosed Premises were purchased by the Plaintiff at the Sheriff's 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 Sheriff's Sale, and is the real and current entitled owner of said Foreclosed Premises by virtue of a Cumberland County Sheriff's 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 Defendants in this action and are occupying the Foreclosed Premises without right and without claim to title. 7, The Defendants herein named were duly served with Notices of the Sheriff's Sale held on September 7, 2005. 8. Plaintiff has demanded possession of the Foreclosed Premises from the Defendants 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. BY: acbC0-~C Barbara A. Fein, Esquire Attorney for Plaintiff Attorney J.D. No. 53002 LEGAL DESCRIPTION All that certain lot or piece of ground with the building and improvements thereon erected, being known as (59 EAST PENN STREET CARLISLE, P A 17013), being further described on that certain Deed dated 08/16/2002 and recorded 08/23/2002 in the' office of the Recorder of Deeds in CUMBERLAND County in Deed Book No. 253, Page 1360. Folio (02-20-1800-286) BEING known as 59 EAST PENN STREET ~ , j j 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. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. FEDERAL NATIONAL MORTGAGE ASSOCIATION BY: rfb/Uj c f!h;JT)1(&~ Mary C. Newman, Vice-President p "t -- 6"- 't> ~ .t::.. -........:) D -ig, 'l~ -C lI't ~ C> w u-U ~F- i?- +-- ---!.... (') S; '"(1'':;:1 o5C" ~;7 (J; -<.- ~C:i ~() <ie,,) ,;1>C ~ . . ' . ....., g '~ <-'" ~ ~:o : ~0 -::l~ ~ ~~ iSm <." -~ ~ (..) 0' € 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 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. NO. 05-4832 Civil Term CHARLES L. REIGEL a/k/a CHARLES REIGEL, FAWNE FITZWATER a/k/a FAWNE E. REIGEL, BILL J. REIGEL, GRADY S. VOIGT JR. AND OCCUPANTS OF 59 East Penn Street, Carlisle, PA 17013, Defendants. PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark the above referenced matter settled, discontinued and ended without prejudice to Plaintiff. THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Kri~~~e, Esquire Attorney for Plaintiff Attorney I.D. No. 79992 Dated: October 14, 2005 ,--,,,, I ___ :.:-J '"', ) '......---'