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Home My WebLink About02-1370FEDERMAN AND PHELAN, L.L.P By: Frank Fedemian, Esquire Identification No. 12248 Attorney for Plaintiff One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Federal Home Loan Mortgage Corporation Foreclosure Unit, Mail Stop 61 P.O. Box 5000 Vienna, VA 22183-5000 Randy E. Signor, Sr. or occupants '~ 328 Fourth Street New Cumberland, PA 17070 : Court of Common Pleas Civil Division Cumberland County Term N°. O~--- 1370 CIVIl, ACTION - E.IF.f?TMF~NT..~020 NOTICE 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 (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 and other claim or relief requested by the plainti~.. You may lose 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 or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiffis Federal Home Loan Mortgage Corporation. 2. Defendant is Randy E. Signor, Sr. or occupants. Plaintiff is the equitable owner of premises located at 328 Fourth Street, New Cumberland, PA 17070, a legal description of which is attached. 4. Plaintiff became equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County on March 6, 2002. Plaintiff, by virtue of the above, is the equitable owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right, and so far as the plaintiff is informed, without claim of title. WHEREFORE, plaintiff seeks to recover possession of said premises. Premises: 328 4TH STREET, BOROUGH OF NEW CUMBERLAND CUMBERLAND COUNTY - PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIFFION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point or post on the South side of Fourth Street, 100 feet East of Reno Avenue; thence by the line of said Fourth Street, 25 feet in an Eastwardly direction to the line of Lot No. 23; thence by the line of said Lot No. 23, Southwardly 140 feet to an alley; thence by the line of said alley, Westwardly 25 feet to the line of Lot No. 21; thence by the line of LOt No. 21, Northwardly 140 feet to the place of BEGINNING. BEING Lot No. 22, Block K in the General Plan of George W. Buttorff's Addition to New Cumberland as recorded in the Recorder's Office of Cumberland County. BEING improved with one-half of a double two and one-half story frame dwelling house known as 328 Fourth Street, New Cumberland, Pennsylvania. BEING Tax Parcel # 25-25-006~025. VERIFICATION Frank Fedennan, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to take this Verification, pursuant to Pa. R.C.P. 1024 (c) and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: Federman and Phelan By: Frank Federman, Esquire Identification No. 19,9,48 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION VS Randy E. Signor, Sr. Or occupants 328 Fourth Street New Cumberland, PA 17070 No. 02-1370- Civil Cumberland County PRAF, C[PE FOR .HID~',~,,NT IN F, JF, CTI~[I~,NT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Federal Home Loan Mortgage Corporation and against the Defendant(s) Randy E. Signor, Sr. and Or occupants for possession of premises 328 Fourth Street, New Cumberland, PA 17070 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Default Judgment entered as indicated above. DATE Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification Number 12248 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF Federal Home Loan Mortgage Corporation COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Randy E. Signor, Sr. Or occupants No. 02-1370 Civ/1 TO: Randy E. Signor, Sr. or occupants 328 Fourth S~'eet New Cumberland, PA 17070 DATE OF NOTICE: April 16: 2flfl~ THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. EMPORTANT NOTICF~ 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 (I0) 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY COURTHOUSE COURT ADMINISTRATOR 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 Federman, Es4uire Attorney for Plaintiff Federman and Phelan By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (~.15) 563-7000 Federal Home Loan Mortgage Corporation v$ Randy E. Signor, Sr. Or occupants 328 Fourth Street New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-1370- Civil Cumberland County VI~,RUFICATION OF NON=MILITARY 8ERVICF~ FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for 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 Randy E. Signor, Sr. Or occupants, is over 18 years of age, and resides at 328 Fourth Street, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland Federal Home Loan Mortgage Corporation v$ Randy E. Signor, Sr. Or occupants 328 Fourth Street New Cumberland, PA 17070 COURT OF COMMON PLEAS CIVIL DIVISION No. 02-1370- Civil Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of.' 328 Fourth Street, New Cumberland, PA 17070 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 328 Fourth Street FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF Premises: 328 4TH STREET, BOROUGH OF NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCR/PTIO_______~N ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point or post on the South side of Fourth Street, 100 feet East of Reno Avenue; thence by the line of said Fourth Street, 25 feet in an Eastwardly direction to the line of Lot No. 23; thence by the line of said Lot No. 23, Southwardly 140 feet to an alley; thence by the line of said alley, Westwardly 25 feet to the line of Lot No. 21; thence by the line of Lot No. 21, Northwardly 140 feet to the place of BEGINNING. BEING Lot No. 22, Block K in the General Plan of George W. Buttorff's Addition to New Cumberland as recorded in the Recorder's Office of Cumberland County. BEING improved with one-half of a double two and one-half story frame dwelling house known as 328 Fourth Street, New Cumberland, Pennsylvania. BEING Tax Parcel # 25-25-006-025. '~l~t-'I' OF POSSESSION' FEDERAL HOME LOAN MORTG~Gg.TCORPORATiON ._%RA~D_I_]~__S_I_G_NO.R~ SR. pR OCCUPANTS 328 Fourth ~St~eet New C~nberland, PA 17070 ' Ejecrmenr Proceedings PRC P 3i60 - 3165 e:c, COURT C,F CO)J.LiON ?LEAS Cf CL-',. [3ERL.~.'~-U COL.-?, ,.-~', ?r_N.-NS-,:.~%.-..C~-L~' ....... _(~2=133_0 .................. T~_.--,_ 20 ...... ................................ T=,..= 20 ...... P~c'.'/. ~ 1.00 COM54 O-'~'¥E.~.L T?{ OF' COU.~ ~"r%' OF CU.M.BE. Rf_~N'D: FEDERAL HOME LOAN MORTGAGE CORPORATION .......................................................................................... being: ~P.-~--..2.~-~:%~ow~ : 328 FOURTH STREET, NEW CUMBERLAND, PA 17070 Dar.- .... _1~_ L1 ,. 2002 Curbis. R. 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