HomeMy WebLinkAbout02-1529
FEDERMAN AND PHELAN, LLP
By: Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
Attorney for Plaintiff
Citifinancial Mortgage Company, Inc.
1111 Northpoint Drive
Coppel, TX 75019
Court of Common Pleas
Civil Division
v.
Cumberland County
Donna Lee McDermott
Or Occupants
1330 Williams Grove Road
Mechanicsburg, PA 17055
No. Oa. -/5~ euJ
CIVTT. ACTION - R.TRCTMRNT -1020
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 plaintiff. 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 fmd out where you can get legal help.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
1. Plaintiff is Citifinancial Mortgage Company, me..
2. Defendant is Donna Lee McDermott and Or Occupants.
3. Plaintiff is the owner of premises located at 1330 Williams Grove Road, Mechanicsburg, PA
17055, a legal description of which is attached.
4. Plaintiff became owner of said premises by a Deed from the Sheriff of Cumberland County,
which Deed was lodged and settlement made with the Sheriff (Abstract of Title).
5. Plaintiff, by virtue of the above, is the 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.
6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to
deliver up possession of same.
WHEREFORE, plaintiff seeks to recover possession of said premises.
~~
FRANK. FEDERMAN
Attorney for Plaintiff
Premises:
1330 WILLIAMS GROVE ROAD, TOWNSffiP OF MONROE
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, mistalces or
omissions in a sum not to exceed Two Thousand Dollars.
DESCIUPTION
ALL THAT CERTAIN piece or parcel of ground, situate in the Township of Monroe, CQunty of
Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on the Western right-of-way line of the Williams Grove ROad, .,at corner of
Green Lane, as shown on the Plan of Lots hereinafter mentioned; thence by the right-o(.way line of
the Williams Grove Road, South 00 degrees 11 minutes 11 seconds West, two hundred twenty-five
and twenty-four hundredths (225.24) feet to a point; thence by the dividing line between Lots Nos. 1
and 2 on said Plan, South 87 degrees 32 minutes 12 seconds West, nine bundred eighty and fifty-
one hundredths (980.51) feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two
hundred twenty-five and twenty-ninebundredtbs (225.29) feet to a point on the Southern line of
Green Lane; thence by the Southern line of Green Lane, North 87 degrees 32 minutes 12 seconds
East, nine hundred seventy-nine and forty hundredths (979.40) feet to a point, the place of
BEGINNING.
BEING Lot No.1 in the Plan of Lots of Frank: E. Stoner, as recorded in Plan Book Q36, at Page
106. Cumberland County Recorder of Deed's Office.
. SUBJECT to setback lines as shown on said Plan.
HAVING thereon erected a dwelling known as 1330 Williams Grove Road.
TAX PARCEL NUMBER: 22-U-0278-Q78
VERIFICA nON
WILDA B. PRICE, ASST. SECY.
Hereby states that hel she is the is the
Of CITICORP MORTGAGE. INC.
Mortgage servicing agent for the Plaintiff in this matter, that he/she is
authorized to take this Verification, and that the statements made in the foregoing Civil
Action in Ejectment are true and correct to the best of his /her knowledge, information
and belief. 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.
ILoA B. PRICE, ASST. SECY.
Date: 3/~{;(bd-
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SHERIFF'S RETURN - NOT SERVED
CASE NO: 2002-01529 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CITIFINANCIAL MORTGAGE CO INC
VS
MCDERMOTT DONNA LEE
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
, to wit:
MCDERMOTT DONNA LEE
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - EJECTMENT
NOT SERVED , as to
the within named DEFENDANT
, MCDERMOTT DONNA LEE
1330 WILLIAMS GROVE ROAD MECHANICSBURG IS VACANT.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
6.21
.00
10.00
.00
3"4:21
~
Soansw : ~
~~
R. THOMAS KLINE. -
SHERIFF OF CUMBERLAND COUNTY
FEDERMAN & PHELAN
04/05/2002
Sworn and subscribed to before me
this If) 't' day of Cf,~il
.2fTl>:l./ A.D.
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Pro otary
PHELAN HALLINAN & SCHMIEG, LLP
BY: FRANCIS S. HALLINAN, ESQUIRE
Identification No. 62695
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Citimortgage, Inc.
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Plaintiff
Civil Division
vs.
Cumberland County
Donna McDermott
Defendant( s)
No. 02-1529
PRAECIPE
TO THE PROTHONOTARY:
X Please mark the above referenced case Discontinued and Ended without
prejudice.
_Please mark the above referenced case Settled, Discontinued and Ended.
Please mark Judgments satisfied and the Action settled, discontinued and
ended.
Please Vacate the judgment entered and mark the action discontinued and
ended without prejudice.
Please withdraw the complaint and mark the action discontinued and
ended without prejudice.
Date:~
~ u/) <; Jlq it--
Francis S. Hallinan, Esquire
Attorney for Plaintiff
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