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Home My WebLink About06-4992 . MILSTEAD & ASSOCIATES, LLC BY: Pina S. Wertzberger, Esquire ATTORNEY ill NO.: 77274 Woodland Falls Corporate Park 220 Lake Drive E., Ste 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff, Wells Fargo Bank:, NA as Trustee under Pooling and Servicing Agreement dated as of February 1,2004 First Franklin Mortgage Loan Trust Mortgage Loan Asset-Backed Certificates, Series 2004-FF1 1100 Corporate Center Drive Raleigh, NC 27607, Plaintiff, Vs. Dennis Robinson, and KnownlUnknown Occupants 610 Erford Road Camp Hill, PA 17011, Defendants. COURTOFCO~ONPLEAS CUMBERLAND COUNTY Case No.: C:J. - "99~ doiL~ ~ CIVIL ACTION COMPLAINT IN EJECTMENT {OO121326} ******************************************************************* NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ............................................................................... 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. {OOI21326} MILSTEAD & ASSOCIATES, LLC BY: Pina S. Wertzberger, Esquire ATTORNEY ill NO.: 77274 Woodland Falls Corporate Park 220 Lake Drive E., Ste 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff, Wells Fargo Bank, NA as Trustee under Pooling and Servicing Agreement dated as of February 1, 2004 First Franklin Mortgage Loan Trust Mortgage Loan Asset-Backed Certificates, Series 2004-FFl 1100 Corporate Center Drive Raleigh, NC 27607, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No.: 0<- -fflJ..... C,~~ L I~ Vs. Dennis Robinson, and KnownlUnknown Occupants 610 Erford Road Camp Hill, PA 17011, Defendants. CIVIL ACTION (REAL PROPERTY) LEASE OR EJECTMENT You have been sued in Court. If you wish to defend against the claims set forth on 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 an attorney and filing in writing with the Court, your defense or objects 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 claims or relief requested by the Plaintiff. You may lose money or personal or other rights important to you. YOU SHOULD TAKE TillS 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 Bar Association 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 {00121326} MILSTEAD & ASSOCIATES, LLC BY: Pins S. Wertzberger, Esquire ATTORNEY ill NO.: 77274 Woodland Falls Corporate Park 220 Lake Drive E., Ste 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff, Wells Fargo Bank, NA as Trustee under Pooling and Servicing Agreement dated as of February 1,2004 First Franklin Mortgage Loan Trust Mortgage Loan Asset-Backed Certificates, Series 2004-FFl 1100 Corporate Center Drive Raleigh, NC 27607, Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No.: 0 {. ... <Ill 9.2...,. Vs. Dennis Robinson, and KnownlUnknown Occupants 610 Erford Road Camp Hill, PA 17011, Defendants. COMPLAINT IN EJECTMENT 1. Plaintiff, Wells Fargo Bank, NA as Trustee under Pooling and Servicing Agreement dated as of February 1, 2004 First Franklin Mortgage Loan Trust Mortgage Loan Asset-Backed Certificates, Series 2004-FFl (herein referred to as "Plaintiff") is a bank, conducting business under the laws of the Commonwealth of Pennsylvania and brings this Ejectment action against Dennis Robinson and KnownlUnknown Occupants (hereinafter referred to collectively as "Defendants"). 2. Defendants are the individuals occupying 610 Erford Road, Camp Hill, P A 17011 (hereinafter referred to as "Premises") more fully described in the legal description attached as Exhibit "A". {00121326} 3. Plaintiff is the record owner of the Premises where Defendants reside, having filed a Complaint in Mortgage Foreclosure proceeded to judgment in that action and acquired Title to the Premises by a Sheriff Sale, which took place on August 09, 2006 in favor of Plaintiff. Please see a copy of the filed Writ of Execution attached hereto as Exhibit "B". 4. The Defendants have no valid legal right to possession and Title to the Premises. 5. Plaintiff claims the right to possession of the Premises to the exclusion of the Defendants. WHEREFORE, Plaintiff requests that this Court enter a Judgment for Possession against the defendants, Dennis Robinson and Known/Unknown Occupants. By: Pina S. Wertzberger, E #77274 {OO121326} VERIFICATION I, Pina S. Wertzberger, hereby certifY that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff's behalf. I verifY that the facts and statements set forth in the forgoing Complaint in Ejectment are true and correct to the best of my knowledge, infonnation and belief. This Verification is made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Name: Pina S. Wertzber Title: Attorney {00121326) ALL THAT CERTAIN messuage, tenement aDd tract of grcnmd situalc in East p_OOro TOWll5hip, Cumbel"1aJId CouDty, CommonWlOal.th of Pennsylvania, _ particularly bounded and described in accooIam:e with the survey of D.P. Raffcmperger, ~ surveyor, Camp HiI1, PelmsyIVlDia, dated May 18, 1968, as fon"",,: BEGINNING at a point on the eastetly line of ErfunI Road, which point is two one-hunclredtbs (269.02) filet north of the northeasterly comer of Elford Road and GIanwood DrM, and . dMding line b.k...o.. Lots Nos. 23 and 23X. BlocIc "H", on the hmeinaftcr meuli.omd pian of lots-, thence along the easterly line of Erford Road, north tWcnty..m degnea thirty minutes east (N 260 30~ E) a distance of forty (40) feet to a point at dMding line between Lots Nos. 23 and 22X, Block "H", on the said pJan; thence along said dMding line south sixty-tbree degr=a thirty minutes east (8 ""0 30. W) a distance of forty (40 feet to a point . dMding line between Lots Nos. 23 8Dd 23, Block "H" aforesaid; thence a10ng said dividing line UI!i tbrough the center of a partition wall and beyond, north sixty-tbree degr=a thirtyminutcs west (N 63030" W) a di........e of ooe hundred :fifteen (115) feet to a point, the place of Beginning. BEING KNOWN AS 610 ErfordRoad, Camp Hill, PA 17011 PARCEL ID NO: 09-16-01050-275 IMPROVEMENTS TIlEREON CONSIST OF: Residential Dwelling {00088646} t5 .04501- In the Court of Common Pleas of Cumberland County, P A WeDs Fargo Bank, N.A., as Trustee Plaintiff CIVIL ACTION NO.: 2005-06374 Vs. Dennis Robinson Defendant(s) Praecipe For Writ of Execution (Mortgage Foreclosure) TO THE PROTHONOTARY OF CUMBERLAND COUN1Y: 1. Directed to the Sheriff of Cumberland County; 2. Against the Defendant(s) in the above captioned matter; 4. Real property involved: 610 Erford Road CampHill,PA 17011 AMOUNT DUE INTEREST --------EtOm.-2t24/06 to Date (If Sale at $14.22 per diem 8 g "'" ..... v:-~ .." !1;!tr" rri ~~:: ~ ~~'.~.,I ~(::': .C ~ $86,482. a o -0 :i! rr:i2J -om :"0 89 :g g~ r:-? w-t o ?i5 co -< 3. and index this writ againSt the Defendant(s) as follows: Dennis Robinson $ TOTAL (Costs to be added) $ FebruaIy 23, 2006 {OO088646} "}:j (:\ "9- 1l \. "" l1'l - ~ U't (') ..., ~ C>- = ~ c:: = -~ "'"' :t:n s,.. ".. .... ~ ""tJG; c:::. - ~ ,-n['" t::"' ';Fii ~ Z')-- ":7""--- N -')6 (J) CP 9\ --< J '< -0 ~_J: :t, 2'(~: c:)~ :x z( >Lj orf1 c: <f? ~ z ::2 w CD '< "" MILSTEAD & ASSOCIATES, LLC By: Pina S. Wertzberger, Esquire Attorney ID# 77274 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff .......... File #: 5.04502 Wells Fargo Bank, NA as Trustee under Pooling and Servicing Agreement dated as of February 1, 2004 First Franklin Mortgag Loan Trust Mortgage Loan Asset-Backed Certificates, Series 2004-FF1, Plaintiff, Vs. Dennis Robinson, and KnownJUnknown Occupants Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 06-4992 Civil Term PRAECIPE TO DIMISS THE EJECTMENT ACTION : WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above captioned Ejectment Complaint without Prejudice. {00037415} Pina S. Wertzb Attorney ID No. ~ r--..) c:::;) ~ c::;) er- '"tJ ff; 0 :2. ~rn ("') n'1:::O 'T' -t 2''-' "TJ F;:; (J)) CO :.fJ Y -<"';. 0- C::C _,~C' ...,- -0 :::c =n ~C-) :E: lJ-'. ,If:,Ct gM )>e: - ~ .. -... N ~ N -< ~ ..~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04992 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS ROBINSON DENNIS 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 ROBINSON DENNIS but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT IN EJECTMENT , NOT FOUND , as to the within named DEFENDANT , ROBINSON DENNIS 610 ERFORD ROAD CAMP HILL, PA 17011 PROPERTY IS VACANT, PER NEIGHBORS, HAS BEEN VACANT FOR OVER ONE YEAR. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 13.20 5.00 10.00 .00 46.20;/' q/~1/() (, c+ Sworn and Subscribed to before SO~~ R. Thomas Kline Sheriff of Cumberland County MILSTEAD & ASSOCIATES 09/14/2006 day of me this A.D. *' 'lo SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04992 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS ROBINSON DENNIS 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 OCCUPANTS but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT IN EJECTMENT , NOT FOUND , as to the within named DEFENDANT , OCCUPANTS 610 ERFORD ROAD CAMP HILL, PA 17011 ADDRESS IS VACANT, PER NEIGHBOR, PROPERTY HAS BEEN VACANT FOR OVER ONE YEAR. qJ'-1JO~ Sworn and Subscribed 6.00 .00 5.00 10.00 .00 21.00/ MILSTEAD & ASSOC ~ 09/14/2006 to before SO~~ R. Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge day of me this A.D.