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Home My WebLink About06-0005 THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire I I.D. No. 53002 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, v. CATHERINE F. SWEENEY and OCCUP ANT(S) OF 920 Hamilton Street Carlisle, PA 17013 Defendants. File No. 05-13323 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. Ol..o - .s (J~Ll ~'2.R-YY( CIVIL ACTION EJECTMENT NOTICE NOTICIA YOU HA VEBEEN SUED IN COURT. IFYOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOlLOWING PAGES, VOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIIlNG IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE W ARNEDTHA TIFYQUFAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT RJRTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER ClAIM OR REUEF REQUESTED BY THE PLAINTIFF. YOU MAY WSE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BEWW. THIS OFF1CE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRlNG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGlBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Senr:ice (717) 249.3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUlENTES, USTED TIENE (20) DIAS DE PLAZQ A PARTIR DE LA PECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIAESCRITA 0 ENPERSONA 0 PORABOGAOO Y ARCmv AREN LA CORTE SUS DEPENSAS 0 SUS OBJECIONES A lAS DEMANDAS ENCONlRA DE SU PERSONA. SEAA VISADQ QUE SI USTED NO SE DEFlENDE, LA CORTE TOMARA MEDlDAS Y PUEDE ENTRAR UNA ORDEN CONlRA USTED SIN PREVIO A VISO 0 NOTIF1CACION 0 POR CUALQIER QUEJA 0 ALIVIO QUE ESPEDIDO EN LAPETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. llEVE EST A DEMANDA A UN ABOOADQ INMEDIA T AMENTE. SI NO TlENE ABOGADO 0 SI NO TIENE EL DINERO SUFIClENTE PARA PAGAR TAL SERVICI0, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFlCINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABNO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Senr:ice (717) 249.3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 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, Catherine F. Sweeney, is an individual whom Plaintiff believes and therefore avers is residing at the property address, that being 920 Hamilton Street, Carlisle, P A 17013, hereinafter referred to as the "Foreclosed Premises". (b) 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 December 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 ofCitimortgage. Inc.. dlb/a Citicor:p Mortgage slb/m to First Nationwide Mortgage Comoration v. Catherine F. Sweenev. as Court Docket Number 04-163 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 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 Sheriff's Sale held on December 7, 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, BY: Barbara A. Fein, Esquire Attorney for Plaintiff Attorney J.D. No. 53002 DESCRIPTION AlL THAT CERTAIN lot of ground with the improvements thereml erectm, siIuate In Nottb. Middleton Township, Cumbcrhmd COWIty, Pennsylvania, more parti<:ularly bounded and described according 10 survey made Febltlary 6, 1969, by ll10mas A. Neff. Reglslel"e4 Sur\"Cl'or, a.~ follows: BEGiNNING al a stake on the northern line of Hamilton Street (60 feet wide.) which stake is situat<d South sixty-three (63) degtees West, four hundred thirteen (413) feet fTOto tbe western tiue of L.R. 21083; thenco by tile northern tine of Ihmllton Street, Soudl sixty-lItree (63) degrees West. seventy-five alld no one-hundrcdtllA (1S.00) feet to II stake; .thence by a IiIU! of proporty now or fatltlJlrly of Marshall SUlrou, Nonlt twentY-8ewn (21) degrees West, \WI) hundt"" and no oue-hUl1c:1redtl" (200,00) fect I.tJ an ilon pipe; thence by Lot No. 48 01\ the hereilJafler mentkmcd plan, North sixty-three (63) c:IegreeA east, sevenly-five and no OIIf>ohundredths (75.00) feet to an iron pin; thence by lot llOW or funnerly of Andrew C. Keele)', South lwlmtY-1leven (27) degrees east. two hundred and 110 onc--hwlc!redths (200 .00) feel 10 the p~ of Beginning. BRING I.Ot No. 34 on the 'certain 'Plan of Additionlll \.olll nfGI"CCIlVllle' lllIi<! plan oFlOlll being entered of record in tlu: Office of the Recorder of Deeds at Carlisle, Pennsylvania, in Plan Book 6. Page 40. Being known as 920 Hamilton SI=t, Carlisle, PeonsylvanJa. Tax Parcel #19-1639.060 PREMISES BEING: 920 HAMILTON STREET, CARLISLE, PA 17013 . . I I IBIT , . 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 FALSlFICATION TO AUTHORITIES. (') -\:,Q.. ....~ 0 -p V1. () c::) 9 K ,~::::::> ~n lrI (;~- ;;.Y" ...... ~ ~ '--- 5-::!J ~'~:. n' (:.~ \I{ - \~~,j C> I - ~ -" I ~ v:> Ci ~ - - , ~ -c.J "":,"'''" ~.:.3 ~-~~ )-J :-~.r -"~ ....c r - ~ ..t:: C:"? :;"A .7 --0 :.'" (J) ':.0 :< y .c< _l -J-.- ----.L.... SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00005 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSN VS SWEENEY CATHERINE F 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 SWEENEY CATHERINE F but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , SWEENEY CATHERINE F 920 HAMILTON STREET CARLISLE, PA 17013 PER NEIGHBOR, NO ONE IS LIVING THERE HOWEVER IT IS FULL OF STUFF. MAIL IS STILL DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 13 .20 5.00 10.00 .00 46.20 ..-'-- County BARBARA FEIN 02/03/2006 Sworn and subscribed to before me this 113: day of J~~ J~, (~ 11), - pr,t:honotar . . SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00005 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSN VS SWEENEY CATHERINE F 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 920 HAMILTON STREET CARLISLE, PA 17013 PER NEIGHBOR, NO ONE LIVES THERE BUT IT IS FULL OF STUFF. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 'O"~~ R. Thomas Kine Sheriff of Cumberland County BARBARA FEIN 02/03/2006 Sworn and subscribed to before me this iP '7~ day of -:Jd" .... / o~" AD~ fJ..h .... ~ ero~o'"ry .. - THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein, Esquire / I.D. No. 53002 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. 06-5 Civil Term CATHERINE F. SWEENEY and OCCUPANT(S) OF 920 Hamilton 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: Dated: February 22, 2006 " .-. i-.'~ ; '- ' r',.) c:; r:';, ~L