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Home My WebLink About02-2884Federman and Phelan By: Frank Federman, Esquixe Identification No, 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation V$ TinaR. Haus OrOccupants 36 EdgewoodDrive Mechanicsburg, PA17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-2884 Civil Cumberland County PRAF/qIPE FOR JIIBGM~,NT IN' i~,.IF, fTI'M1E, NT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Federal Home Loan Mortgage Corporation and against the Defendant(s) Tina R. Hans and Or Occupants for possession of premises 36 Edgewood Drive, Mechanicsburg, PA !7055 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 pmecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. FIL~kNK FEDERM~q, ESQUIRE Attorney for Plaintiff Default Judgment entered as indicated above. DATE 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 : CWIL DMSION : CUMBERLAND COUNTY Tina R. Haus : No. 02-2884- Civil Term Or occupants TO: Tina IL Haus or occupants 36 Edgewood Drive Mechanicsburg, PA 17055 DATE OF NOTICE: Jnly 0:2002 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. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file m writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days fi.om the date of this notice, a Judgment may be entered against you without a heating and you may lose your property or other important fights. 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 ADM/NISTRATOR 4TH FLOOR CARLISLE, PA 17013 (717) 24O-6200 Attorney for Plaintiff Federman and Phelan By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Federal Home Loan Mortgage Corporation VS Tina R. Haus Or Occupants 36 Edgewood Drive Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 02-2884 Civil Cumberland County VI~.RIlh'ICATION OF N~N=M~1,1TARY gl~,RVTCF. 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 Tina R. Haus Or occupants, is over 18 years of age, and resides at 36 Edgewood Drive, Mechanicsburg, PA 17055. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unswom falsification to authorities. FI(tAlqK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA ./ COUNTY OF Cumberland Federal Home Loan Mortgage Corporation vs Tina R. Haus Or Occupants 36 Edgewood Drive Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CIVIL DIVISION No. 02-2884 Civil Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 36 Edgewood Drive, Mechanicsburg, PA 17055 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 36 Edgewood Drive FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF FEDERMAN AND PItELAN, 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 (215) 563-7000 Attorney for Plaintiff Federal Home Loan Mortgage Corporation Foreclosure Unit, Mail Stop 61 P.O. Box 5000 Vienna, VA 22183-5000 Tina R. Haus Or Occupants 36 Edgewood Drive Mechanicsburg, PA 17055 Court of Common Pleas Civil Division Cumberland County Term No. ~ '- ~a0y CML AC~TTC}N - FJi~f~TIVII~.NT _ 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 find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 SHERIFF'S RETURN CASE NO: 2002-02884 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL HOME LOAN MORTGAGE COR VS HAUS TINA R - REGULAR JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon HAUS TINA R the DEFENDANT , at 1504:00 HOURS, on the 17th day of June at 36 EDGEWOOD DRIVE , 2002 MECH~NICSBURG, PA 17055 JOHN WALTERS, HUSBAND 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 CostA: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this 2~ day of ~,._ o~ A.D. ' ~rothonotar~ So Answers: R. Thomas Kline 06/18/2002 FEDERMAN & PHELAN By: ty~SSerif f 1. Plaintiffis Federal Home Loan Mortgage Corporation . 2. Defendant is Tina R. Haus Or Occupants. Plaintiffis the equitable owner of premises located at 36 Edgewood Drive, Mechanicsburg, PA 17055, a legal description of which is attached. Plainfiffbecame equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriffof Cumberland County on June 5, 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 plaintffis informed, without claim of title. WHEREFORE, plaintiff seeks to recover possession of said premises. Premises: 36 EDGEWOOD DRIVE, 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 tract of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point of intersection of the Southern line of Edgewood Drive and the line of adjoiner between Lots Nos. 8 and 9 on the hereinafter mentioned plan of lots; thence by said line of adjoiner South 10 degrees 17 minutes 30 seconds West a distance of 111.90 feet to a point; thence South 79 degrees 37 minutes West a distance of 12.16 feet to a point; thence South 75 degrees 58 minutes 25 seconds West a distance of 47.31 feet to a point; thence South 79 degrees 42 minutes 30 seconds West a distance of 15.65 {eet to a point; thence North 10 degrees 17 minutes 30 seconds West along the line of adjoiner between Lots Nos. 7 and 8 on said Plan a distance of 115.00 feet to a point on the Southern line of Edgewood Drive; thence along said Southern line of Edgewood Drive, North 79 degrees 42 minutes 30 seconds East a distance of 75.0 feet to a point, the place of BEGINNING. BEING Lot No. 8, Block C, on the Final Plan of Part of Blocks, A, B, & C, Wynnewood Park, as recorded in Plan Book 44, page 17. UNDER AND SUBJECT, nevertheless, to building setback lines, conditions and restrictions as shown on said Plan and of prior record. HAVING thereon erected a dwelling house known as'~Edgewood Drive, Mechanicsburg, Pennsylvania. BEING Tax Parcel # 18-21q0287-042. VERIFICATION Frank Federman, 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 t/?rf~k Fed~nna~, E~uire "'~ttomey for Plal~tiff 'i~IRR~ OF POSSESSION FEDJRAL HOME LOAN MO.RT_~_~GE CORPORATION TINA R. HAUS OR OCCUPANTS 36 Edgewood Drive Mech~nicsbu~9, Pa. 17055 -~jecnne.nr Proceedings PRC P 3~60 - 3165 etc, ~ COL'R7 . CO},[Z,[ON ?LZAs C? No. 02-2884- CIVIL No ................................ T~ 20 C O-~ f~i O.N%VEAL iZ4 OF COL.~ ~-Fy OF ...... FEDERAL HOME LOAN MORTGAGE: CORBOR~T~ON -'- ....................................................................................... 0e.'ng: ,1 p.-~--_~_~ a~ ,:o~o~) 36 EDGEWOOD DRIVE, MECHANICSBURG, PA 17055 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my ~nd tim saal of ~ Co.u. at Cadisle, Pa. ~othon~mr~ D=.-.- -. _4 u. ly_ 2~.. _ 2_0_0. 2 - ~'-'---~.L' f=... -_ 14th~ ~ , · August X~ 2002 ~ ~ wi~n n~m~ Federal Home Loan Mortgage ~orp Mechani~sburg, PA 17055 Sheriff's Cpsts: 8~.~ . Poundage ~1.38 Possession 30.00 Refunded to Arty on 8/15/02 Surcharge 20.00 84.18