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HomeMy WebLinkAbout02-1613FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff WM Specialty LLC, Without Recourse 505 South Main Street Orange, CA 92868 Frank M. Romito, Jr. Or Occupants 51 West Keller Street Mechanicsburg, PA 17055 : Court of Common Pleas : Civil Division : Cumberland County : Term : No. ~,,2 -/b~3 ACTION - FJEC~TMENT - _~fl2O 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 fights 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 WM Specialty LLC, Without Recourse. 2. Defendant is Frank M. Romito, Jr. Or Occupants. Plaintiff is the owner of premises located at 51 West Keller Street, Mechanicsburg, PA 17055 a legal description of which is attached. 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). 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 plaintiffis informed, without claim of title. Plaintiffhas 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. Premises: 51 W. KELLER STREET, BOROUGH OF MECHANICSBURG CUMBERLAND COUNTY ~ PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed h~reon 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. .DESCRIPTION ~ ALL THAT CERTAIN House and Lot of Ground situate on the South side of West Keller Street, in the First Ward of the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at comer of Lot now or formerly of Charles Glenn and said West Keller Street; thence along said West Keller Street in an Eastwardly direction, a distance of twenty-seven (27) feet to a point in the line of Lot now or formerly of Charles Eppley; thence along the line of said Lot now or formerly of Charles Eppley, in a Southwardly direction, aa distance of one hundred forty' (140) feet, more or less, to a point in a public Alley; thence along said Alley in a Westwardly direction, a distance of twenty-six (26) feet to a point in the line of Lot now or fo~aerly of Charles Glenn, aforesaid; thence along the line of said Lot now or formerly of Charles Glenn in a Northwardly direction, a distance of one hundred forty (140) feet to a point in said West Keller Street, aforesaid, at the point and place of BEGINNING. HAVING thereon erected a two and one-half sto~y frame dwelling, known and numbered as 51 West Keller Street, Mechanicsburg, pennsylvania. TAX PARCEL #16~24-0787-023 VERIFICATION Frank Fede,nan, 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 unswom falsification to authorities. Date: ~infi ff ~ F~mk Fedemian, E~uir~e SHERIFF'S RETURN - REGULAR CASE NO: 2002-01613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY LLC WITHOUT RECOU VS ROMITO FRANK M JR BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon ROMITO FRANK M JR the DEFENDANT at 51 WEST KELLER STREET , at 0942:00 HOURS, on the 5th day of April , 2002 MECHANICSBURG, PA 17055 by handing to BONNIE ROMITO, WIFE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this /~ day of ~g ~0 2~ A.D. ! ~rothonotary ' So Answers: R. Thomas Kline 0A/09/2002 FEDERMAN & PHELAN By: FEDERMAN AND pI~ELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 One Penn Center ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WM Specialty LLC, Without Recourse COURT OF COMMON PLEAS VS Frank M. Romito, Jr. Or Occupants 51 West Keller Street Mechanicsburg, PA 17055 CIVIL DIVISION No. 02-1613-Civil Cumberland County PRAECJPF~ FOR .III1)GMENT IN F,.IF, CTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, WM Specialty LLC, Without Recourse and against the Defendant(s) Frank M. Romito, Jr. and Or Occupants for possession of premises 51 West Keller Street, Mechanicsburg, PA 17055 for failure to file an Answer with'm 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 for PI~ FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQUIRE IDENTH~'ICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION SUITE 1400 1617 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103-1814 (215) 563-7000 WM Specialty LLC, Without Recourse Frank M. Romito, Jr. Or Occupants ATTORNEY FOR PLA1NI'IFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-1613-Civil TO: Frank M. Romito, Jr., Or Occupants 51 West Keller Street Mechanicsburg, PA 17055 DATE OF NOTICE: April 26, 2002 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 of objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a heating 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN L.L.P. BY: FRANK FEDERMAN IDENrlFICATION NO. 12248 One Penn Center Plaza ~ Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 WM Specialty LLC, Without Recourse VS Frank M. Romito, Jr. Or Occupants 51 West Keller Street Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-1613-Civil Cumberland County Vi~,llllClCATIfIN Oi~ NON-MH,ITAR¥ 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 Frank M. Romito, Jr. Or occupants, is over 18 years of age, and resides at 51 West Keller Street, Mechanicsburg, PA 17055. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. ~ttorney f~ff PRAEC1PE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland WM Specialty LLC, Without Recourse VS Frank M. Romito, Jr. Or Occupants 51 West Keller Street Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CIVIL DIVISION No. 02-1613-Civil Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 51 West Keller Street, Mechanicsburg, PA 17055 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 51 West Keller Street k._)tYTORNEY Ot~e'PLAINTIFF ~' 717_E COL'M.- O? C ' ' ' 02-1613-Civil ................................ T=~ 20 ................................ 7~ 20 ...... C~ ............................... $ 104.40 P~cnv. - - ...........................!.oo C 0-% [~10.N%VEAL iZ-.' OF To i'-e .¢he~ of CUMBERLAND ................................... C o~ .-, .-.:: ~ .. < ! T? t.-fr,'y :he ~ud..~...e:-..: .~or .oc~es~.o.-. ia :~ze ~:o ','e =a.'zer vc.u ..................... WM S~ecialty LLC, Without Recourse .......................................................................................... ?!a~nfff beLn~: .P-'e----Jse~ z~ :'oH~'i : 51 West Keller Street Mechanicsburg, PA 17055 · 2' Fo sa~'~',- :?-e ,:~s:: ~:~.-~sc .';"e de'!.'e=dazI[ i. }'au az: roLl"ecg, ed to .~,-.- z_--x:,c ..u:v ~,,'9me:-7.,- c~' May 16, 2002 ._'. Curtis R. Long P:'omoaoc=:,-. C~,---._.-:x,, T p:~ Cea.-':. Co urzr.~, .. July .................... ~ 2002 · .,'a~. ~c. m~ 1/th _-d'=': ~>~ ............. ' ....... [c:~e4 ~ wi~in nm~ .... -V~-8~ci~t~c¥-L-E~W-~-eh~-R~e ....................... ~,.-=p~ie~n oirh, pr..-a'..is~ de'~'.:b'qX~i':'X~R~;~I~X~Ix~xX ....... ~%_~egt_l<,.~l,.l-e~ .......... ~t [~k~-~P~?kP~g~- -~- ~ ~ ................................................ ~ .......... Advance Costs: 1~0.00 Sheriff's Cost~j ........................................ S~fT*~'C~I~-[ .... ~6'.YI ....... .................... 103.19 Docketing $ 18.00 -S~r~g~ ........... 2~ ................................................................ [ ..... Poundage .91 ~th 1.00 Refunded t~ ~_~0_.27~57.02--. ~il~j~ ............... ~7~ .............................................. 46.81 Premises: 51 W. KELLER STREET, BOROUGH OF MECHANICSBURG 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. DESCRIPTION ALL THAT CERTAIN House and Lot of Ground situate on the South side of West Keller Street, in the First Ward of the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at corner of Lot now or formerly of Charles Glenn and said West Keller Street; thence along said West Keller Street in an Eastwardly direction, a distance of twenty-seven (27) feet to a point in the line of Lot now or formerly of Charles Eppley; thence along the line of said Lot now or formerly of Charles Eppley, in a Southwardly direction, aa distance of one hundred forty' (140) feet, more or less, to a point in a public Alley; thence along said Alley in a Westwardly direction, a distance of twenty-six (26) feet to a point in the line of Lot now or formerly of Charles Glenn, aforesaid; thence along the line of said Lot now or formerly of Charles Glenn in a Northwardly direction, a distance of one hundred forty (140) feet to a point in said West Keller Street, aforesaid, at the point and place of BEGINNING. HAVING thereon erected a two and one-half story frame dwelling, known and numbered as 51 West Keller Street, Mechanicsburg, Pennsylvania. TAX PARCEL #16~24-0787-023