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Home My WebLink About05-4892(? tt r form 3 1- C ) A . Ccc J ( IN THE COURT OF COMMON PLEAS OF PLAINTIFF, (-?tnnsii van lo) ( 0 irnb _ ta COUNTY, PENNSYLVANIA (CIVIL DIVISION d F. Fcfo(-d S-. (NO: LAS ill' 4.z a v . Lc__T?7? DEFENDANT. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE PROMPT ACTION. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANNULMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAINST YOU FOR ANY OTHER CLAIM OR RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YOUR CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM 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. LAWYERS REFERRAL SERVICE ,Im?ef land r latld? t?ql 14 ?A -7,0 1-25 Telephone:b o) c_; -n - ` cn For Petitioner Address: Telephone: 157 form 4 Lynn A. trf rd PLAINTIFF, v. ??: ErFOrd ?r DEFENDANT. ( IN THE COURT OF COMMON PLEAS OF ( (0-uni rt(In COUNTY, PENNSYLVANIA (CIVIL DIVISION (NO: COMPLAINT IN DIVORCE AND NOW COMES, the Petitioner, Gann A. Er -Fnrd by FILING PRO SE, who files this Complaint in Divorce a statement J of is as follow: 1 2 The Defendant is at raw.n adult individual currently residing 3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The titioner and Respondent were married on date: in the State of I Y-on ! 5. There (is) are child(ren) born of this marriage. Name(s) Birthdate(s): 6. Neither party is a member of any branch of military. 7. The marriage is irretrievably broken. 8. The Petitioner, Lunn A . b rfo rd respectfully requests this Honorable Court to a grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code. Resp tfully sub m" ted, am e: Full Address: 40 01 n &.. Act 9 Telephone: -7 Lb, - 1,85 I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Dated: 158 The Petitioner is L1 nn R t7rtnrcl an adu individual currently residing at 4') W. mf}1? 4- _ A J JY)oi ?nir??,rr- i-7,n? form 5 Lunn A Erfo? PLAINTIFF, V. (IN THE COURT OF COMMON PLEAS OF Pen(-f,- 41 vaf)n? ) (? r (n IICI COUNTY, PENNSYLVANIA ( CIVIL DIVISION :Poba F. Er card 5c DEFENDANT. (NO: AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF: ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared L_ Lj.- r? n who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. ame Sworn to and subscribed before me this day of 0Ae m her- , 200 -5- NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elaine M. Regi, Notary Public Carlisle Boro, Cumberland County My Commission Expires Nov. 6, 2008 Member, Pennsvivania Association Of Notaries 159 v O V C7 r?. G7 N Q na } Q -r? J x'" PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK, AS TRUSTEE FOR BEAR STEARNS ASSET BACKED SECURITIES CUMBERLAND COUNTY TRUST SERIES 2002-AC1 COURT OF COMMON PLEAS 2476 STATEVIEW BOULEVARD FORT MILL, SC 29715 CIVIL DIVISION Plaintiff, NO. 06-4892 V. RICKIE A. ROBINSON Defendant(s). . PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against RICKIE A. ROBINSON, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 8/23/06 to 10/13/06 TOTAL $55,894.04 $554.88 $56,448.92 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as s wn above, and (2) that notice has been given in accordance with Rule 237.1, attache E G. CHM G, QUIRE Attorney f Plainti f DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: D?o PRO ROTH 139217 PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 JP MORGAN CHASE BANK, AS TRUSTEE FOR : COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES TRUST SERIES 2002-AC I : CIVIL DIVISION Plaintiff CUMBERLAND COUNTY Vs. :NO. 064892-CIVIL TERM RICKIE A. ROBINSON Defendants TO: RICKIE A. ROBINSON FILE 867 MYERSTOWN ROAD GARDNERS, PA 17324 DATE OF NOTICE: SEPTEMBER 27.2006 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF 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 OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 - S. 111L NCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff . y (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JP MORGAN CHASE BANK, AS TRUSTEE FOR BEAR STEARNS ASSET BACKED SECURITIES TRUST SERIES 2002-AC 1 2476 STATEVIEW BOULEVARD Plaintiff, V. RICKIE A. ROBINSON CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 06-4892 Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on 20 By: L..'PEPUTY If you have any questions concerning this matter, please IEL . SCHMI , ES UIRE A or Plaintiff ONE PENN CENTER UBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "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." ' PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF JP MORGAN CHASE BANK, AS TRUSTEE FOR BEAR STEARNS ASSET BACKED SECURITIES CUMBERLAND COUNTY TRUST SERIES 2002-AC1 COURT OF COMMON PLEAS 2476 STATEVIEW BOULEVARD Plaintiff, v. CIVIL DIVISION NO. 06-4892 RICKIE A. ROBINSON Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant RICKIE A. ROBINSON is over 18 years of age and resides at, 867 MYERSTOWN ROAD, GARDNERS, PA 17324. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -(l. w GINI "E 'N ti Cr.: I7 n? T_ -t :.C Or cl-I Curtis R. Long Prothonotary (Off Me of the Protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor - (),Z - /gQ;?, , CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573 PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire ATTORNEY FOR PLAINTIFF Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 JP MORGAN CHASE BANK, AS TRUSTEE FOR Court of Common Pleas BEAR STEARNS ASSET BACKED SECURITIES TRUST SERIES 2002-AC 1 Civil Division Plaintiff V. RICKIE A. ROBINSON Defendant CUMBERLAND County No. 06-4892 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's April 17, 2009 Rule was sent to the following individual on the date indicated below. RICKIE A. ROBINSON 867 MYERSTOWN ROAD GARDNERS, PA 17324 DATE: Ph Haklinan & Schmieg, LLP By: Mic ele . Br ford, Esquire Attorney for Plaintiff OF THE FARY Z009 APR 30 N 10: