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Home My WebLink About06-5879 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Bank One National Association 'COURT OF COMMON PLEAS as Trustee :CIVIL DIVISION 9350 Waxie Way ;Cumberland County San Diego, CA 92123 Plaintiff John Doe and/or Tenant/Occupant 57 Waterside Drive Carlisle, PA 17013 (Premises) Defendant(s) CIVIL ACTION COMPLAINT IN EJECTMENT 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 twenty (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 any 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlise, PA 17013 717-249-3166 800-990-9107 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlise, PA 17013 717-249-3166 800-990-9107 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2. Defendant(s) are those named as such on the caption, and occupy the premises (hereinafter "Premises") which address is set forth on the caption. 3. Premises, a legal description of which is attached hereto, was sold at Sheriffs Sale in accordance with law on Septemeber 6, 2006, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof. (Abstract of Title). 4. The person(s) in possession of Premises are the Defendant(s) herein, and are occupying Premises without right or claim to title. 5. Plaintiff has demanded possession of Premises from Defendant (s) who have refused to deliver up the possession thereof. WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in this action. UDREN LAWjOFF , S , ?rarlf/? Udren, Esquire ATTORNEY FOR PLAINTIFF ALL those three trots of land situate in Lower Frankford Townslup, Cumberland County, Pennsylvania., bounded and descried as follows: TRACT NO 1: BEG T1VG at an iron pin and stake at the corner of land of Paul R. Young and Russell L. Mackey, et al; thence along the line of land'of Paul R. Young, crossing a private road and through an iron pin on the southern side thereof, South 44 degrees 30 minutes West 200 feet to an iron pin; thence by the same land and the same course, 35 feet, more or less, to the low water line of the Conodogainet Greek; thence by the said low water line, North 75 degrees 39 minutes West, 60 feet td a point on line of land conveyed or about to be conveyed to Alverta M. Fry; thence by the latter land, North 44 degrees 30 minutes East, 35 feet, more or less, to an iron pin; thence by the same land the same course, 211.29 feet, crossing a private road to an iron pin on the line of land of Russell L. Mackey, et al; thence by the latter land, South 65 degrees 18 minutes East, 55.14 feet to the Place of BEGINNING said description being in accordance with a survey thereof by Roger St. Germain & Associates, dated September 26, 1961. TOGETHER with a right-of-way for the purpose of ingress and egress over other lands of the Grantor herein and other owners to the property herein conveyed over a private road from the public road leading from Bergner's Bridge to Bloserville in common with the Grantor, his heirs and.assigns. SUBJECT to the aforesaid right-of-way for ingress and egress in favor of the owner or owners, their heirs and assigns, of the land to the West hereof TRACT NO 2: BEGRYA7 VG at a stake at line of other land of K. Swartz; thence by said land, South 44 degrees 30 minutes West, a distance of 225 feet, more or less, to the low water mark of the Conodoguinet Creek; thence by the same up the Creels, North 52 degrees 15 minutes West, a distance of 51.5 feet to a point; thence along lands of Chester Fry, North 44 degrees 30 minutes East, a distance of 231 feet to a stake; thence by the same, South 45 degrees 30 minutes East, a distance of 50 feet to a stake, the Place of BEGINNING. CONTARUNG 0.27 acres, more err less. TOGETHER with a right-of-way for the purpose of ingress and egress over other lands of the Grantor herein to the property herein conveyed, over a private road from the public road leading from Bergmes Bridge to Bloserviille in common with the Grantor, his heirs and assigns, said right-of-way to be appr xkwtely 1609 feet, more or less, fiom the said public road TRACT NO. 3: ALL that cattain tract of land situate in Lower Frankford Township Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin at the corner of land of Chester L. Fry and wife and Russell L. Mackey, et al; thence along the line of land aforesaid of Chester L. Fry and wife, crossing a private mad, South 44 degrees 30 minutes West 21129 feet to an iron pin; thence by the some land and the same courses, 35 feet, more or less, to the low water line of the Conodoguinet Creel ; thence by the said low water line, North 75 degrees 39 minutes West 120 feet to the line to land of Brinton F. Forney and wife; thence by the latter land, North 44 degrees 30 minutes East 35 feet, more or less, to an iron pin; them,. by the same land and the same course, crossing a private road, 234.38 feet to an iroi, pica on the line of land of Russell L. Mackey, of al; thence by the latter land, through an iron pin in the center of said line, South 65 degrees 18 minutes East 110.28 feet to the Place of BEGINNING; said Lion be' thereof by R=oger St. Germain & AssDciates? dated September in accordance with a survey 26, 196 1. TOGETHER with a right-of-way for the purpose of ingress and egress over other lands of the prior Grantors herein and other owners to the property conveyed over a private road from the public road leading f -om. Bergner's Bridge to Bloservi]le, in common with the prior Crantors, their heirs and assigns. SUB ECT to the aforesaid n&-of-way for ingress and egress m favor of the owner or owners, their heirs and assigns, of the land to the West hereof, HAVING THEREON ERECTED A DWELLING KNOWN AS 57 Ti7ATERSIDE DRIVE, CARLISLE, PA 17013. BEING THE SAME PREMISEES 67HICH Lee E. Grove and Laura Miller Grove by deed dated 1/22/00 and recorded in Deed Book 238 Page 228 granted and conveyed unto Sheila M. Gross. TO BE SOLD AS THE PROPERTY OF SHEILA M. GROSS ON JUDGMENT NO. 2003 571. ASSESSMENT: 14-07-0475-004 VERIFICATION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation; that he is authorized to take this verification and does so because Plaintiff must verify through agents and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge information and belief and the source of his information is public records and rennrr.c! nf undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: October 5, 2006 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 MARK J. UDREN* CHERRY HILL, NEW JERSEY 08003.3620 STUART WINNEG** 856.669.5400 GAYL SPIVAK*** FAX 856. 669. 5399 HEIDI R. SPIVAK*** MARISA JOY COHEN*** LORRAINE DOYLE** ALAN M. MINATO*** FREDDIE MAC *ADMITTED NJ, PA, FL "'ADMITTED NJ, PA PENNSYLVANIA TINA MARIE RICH DESIGNATED COUNSEL OFFICE ADMINISTRATOR PLEASE RESPOND TO NEW JERSEY OFFICE October 5, 2006 Sheriff of Cumberland County Cumberland County Courthouse One Courthouse Square Carlise, PA 17013-3387 Re: Bank One National Association as Trustee VS. John Doe and/or Tenant/Occupant Complaint in Ejectment Gentlemen: PENNSYLVANIA OFFICE 215.568.9500 In connection with the above captioned matter, enclosed please find the following: 1• Two copies of the Complaint in Ejectment to be served on John Doe and/or Tenant/Occupant at 57 Waterside Drive, Carlisle, PA 17013; 2. Our check payable to the Sheriff of Cumberland County in the amount of $100.00 in payment of your charges in this regard. Your assistance in this matter is greatly apprec Sincerely S, UDREN?I Esquire 'ICES, P. C. /rk Enclosures O^ f_ ?.? V Z \ r N ?a GI) (,f e ?J Ti -v- J' 17 U . . "Ok UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank One National Association :COURT OF COMMON PLEAS as Trustee 'CIVIL DIVISION 9350 Waxie Way :Cumberland County San Diego, CA 92123 Plaintiff NO. 06-5879 Civil Term V. John Doe and/or Tenant/Occupant 57 Waterside Drive Carlisle, PA 17013 (Premises) Defendant(s) PRAECIPE TO INDEX DEFENDANT PURSUANT TO PA.R.C.P. 410(b)(2) TO THE PROTHONOTARY: Kindly index as a Defendant, pursuant to Pa. R . C . P . 410(b) (2), Egard Coover, who was found in possession of the real property subject of the within action in Ejectment. UDREN LAW OFFICES, P.C. f /k Mark J. dren, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR -CASE NO: 2006-05879 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS DOE JOHN SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DOE JOHN the DEFENDANT , at 1919:00 HOURS, on the 18th day of October , 2006 at 57 WATERSIDE DRIVE CARLISLE, PA 17013 EGARD COOVER by handing to a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: • Docketing 18.00 Service 6.16 Affidavit .00 Surcharge 10.00 R. Thomas Kline 34.16 10/19/2006 UDREN LAW OFFICE Sworn and Subscibed to By: before me this day eputy Sheriff of A.D. t? ,.'' ? - r- ? G.-, n _ _ ?'~ ? ? .--; s-? _?, -- ? t..: r r- , ` - '"" v I't'?3 ?s CASE NO: 2006-05879 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS DOE JOHN SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT DOE JOHN was served upon DEFENDANT , at 1919:00 HOURS, on the 18th day of October at 57 WATERSIDE DRIVE CARLISLE, PA 17013 EGARD COOVER by handing to the 2006 a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 6.16 Affidavit * 00 Surcharge 10.00 R. Thomas Kline .00 34.16,/ 10/19/2006 UDREN LAW OFFICE ` Sworn and Subscibed to By: before me this day eputy Sheriff of A. D. CASE NO: 2006-05879 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK ONE NATIONAL ASSOCIATION VS DOE JOHN SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon TENANT the DEFENDANT , at 1919:00 HOURS, on the 18th day of October , 2006 at 57 WATERSIDE DRIVE CARLISLE, PA 17013 by handing to EGARD COOVER, ADULT IN CHARGE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Additional Comments TENANTS ARE SHEILA GROSS AND GREG MORAN. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 t-? .00 10.00 R. Thomas Kline nn Ib.UU? Sworn and Subscibed to before me this day 10/19/2006 UDREN LAW OFFI By. Deputy Sheriff of A.D. Curtis R. Long Prothonotary Office of the protbonotarp Cumberfantl Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 61, ?_CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573