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Home My WebLink About05-6736UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com JPMorgan Chase 9350 Waxie Way San Diego, CA Bank As Trustee 92123 Plaintiff V. John Doe and/or Tenant/Occupant 335 West Perry Street Enola, (East Pennsboro Township) PA 17025 (Premises) Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. C S - 6.13 Clu, C--- CIVIL ACTION COMPLAINT IN EJECTMENT 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 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 any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICIN'A CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONEE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises") which address is set forth on the caption. 3. Premises, a legal description of which is attached hereto, was sold at Sheriff's Sale in accordance with law on December 7, 2005, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. (Abstract of Title). 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant (s) who have refused to deliver up the possession thereof. WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAW OFFICES, P.C. Mark J. Udren, Esquire ATTORNEY FOR PLAINTIFF a3i?a1 y3 ALL THAT. CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERT,= COUNTY, PENNSYLVANIA, HAVING THEREON ERECTED THE EASTERN HALF OF A .DOUBLE FRAME DWELLING HOUSE KNOWN AS 333 N. PERRY STREET, ENOLA, PENNSYLVANIA, FULLY BOUNDED AND DESCRIBED AS FOLLOWS: MORE BEGINNING AT A POINT AT THE NORTHERN LINE OF PERRY STREET, 82 FEET FROM THE NORTHEAST CORNER OF PERRY AND ZION STREETS, AT A LINE OF LANDS NOW OR LATE OF WALTER J. MANNING; THENCE NORTHWARDLY ALONG SAID LINE AND PARALLEL WITH ZION STREET, 120 FEET TO LOT NO. 9 ON THE HEREINAFTER MENTIONED PLAN; THENCE WESTWARDLY ALONG THE LINE OF LOT NO. 9, 32 FEET 6 INCHES, MORE OR LESS, TO A POINT ON THE LINE RUNNING THROUGH THE CENTER OF THE PARTITION WALL OF THE DOUBLE FRAME DWELLING HOUSE ERECTED IN PART UPON THE LOT HEREIN DESCRIBED, AND IN PART UPON THE LOT ADJOINING ON THE WEST; THENCE IN AN SOUTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE AND PARALLEL WITH ZION STREET, 120 FEET TO PERRY STREET; THENCE EESTWARDLY ALONG TEE NORTHERN LINE OF PERRY STREET, 32 FEET 6 INCHES, MORE OR. LESS, TO THE POINT OR PLACEOF BEGINNING. BEING A PORTION OF LOT NOS. 6, 7 AND 8, BLOCK. A, PLAN NO. 1, HOOPY'S ADDITION TO ENOLA. BEING KNOWN AS: 333 WEST PERRY STREET, ENOLA, (EAST PENNSECRO TOWNSHIP) PA 17025 (INCORRECTLY STATED IN LEGAL DESCRIPTION AS NORTH PERRY ST.) PROPERTY ID NO.: 09-14-0832-216 VERIFICATION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation; that he is authorized to take this verification and does so because Plaintiff must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904: relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark J. Udren, Esquire DATED: December 22, 2005 D 7 YL t. t?7 T.. -Tt ( r. Do r ca 'i SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-06736 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS DOE JOHN 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 DOE JOHN but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT the within named DEFENDANT , DOE JOHN STREET ENOLA. PA 17025 NOT FOUND , as to PER NEIGHBOR AT 335, 333 HAS BEEN VACANT SINCE 12/7/05. Sheriff's Costs: Docketing 18.00 Service 13.20 Not Found 5.00 Surcharge 10.00 .00 46.20 So answers;._ R. Thomas-Kline Sheriff of Cumberland County UDREN LAW OFFICES 01/06/2006 Sworn and subscribed to before me this day of j'-4 A.D. 7 7/1-h rothon y SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-06736 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JPMORGAN CHASE BANK VS DOE JOHN 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 TENANT/OCCUPANT unable to locate Him in his bailiwick COMPLAINT - EJECTMENT but was He therefore returns the the within named DEFENDANT 333 WEST PERRY STREET NOT FOUND , as to , TENANT/OCCUPANT PA 17025 PER NEIGHBOR AT 335, 333 HAS BEEN VACANT SINCE 12/7/05. Sheriff's Costs: So answers:__._ - Docketing 6 .00 --?" Service .00 Not Found 5 .00 R. Thomas Kline Surcharge 10 .00 Sheriff of Cumberland County .00 21 .00 UDREN LAW OFFICES 01/06/2006 Sworn and subscribed to before me this day of ,)cu(. A.D. n j PrpT hon Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor D- -? -7 3 L_CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF AND RECEIVING NO WITH RESPONSE - THE ABOVE INTENTION TO PROCEED IN ACCORDANCE WITH PA CASE IS HEREBY TERMINATED 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