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Home My WebLink About02-2961 FEDERMAN 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 (215) 563-7000 Attorney for Plaintiff Federal Home Loan Mortgage Corporation Foreclosure Unit, Mail Stop 61 P.O. Box 5000 Vienna, VA 22183-5000 Court of Common Pleas Civil Division v. Cumberland County Term Joseph M. Uhrinek Or Occupants 50 Pine Ridge Circle Enola, PA 17025 No. 0,;) - ,;2fc,1 ~ CTVTT. ACTION - R.TF,CTMRNT - 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 find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 I. Plaintiff is Federal Home Loan Mortgage Corporation. 2. Defendant is Joseph M. Uhrinek Or Occupants. 3. Plaintiff is the equitable owner of premises located at 50 Pine Ridge Circle, Enola, PA 17025, a legal description of which is attached. 4. Plaintiff became equitable owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County on June 5, 2002. 5. 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 plaintiff is informed, without claim of title. WHEREFORE, plaintiff seeks to recover possession of said premises. Premises: 50 PINE RIDGE CIRCLE. TOWNSHIP OF EAST PENNSBORO CUMBERLAND COUNTY PENNSYLVANIA !'lased upon ,he examination of evidence in the appropriate public records, Company cerrifies that [he premises endorsed hereon are subject to !he liens, encumbrances and exceptions [0 tide hereinafter set forrh. This Cerrificate does not constirute [itle insurance: liability hereunder is assumed by [he Company solely in its capaciry as an abstractor for its negligence, mistakes or omissions in a sum nor to exceed Two Thousand Dollars. DESCRIPrION ALL TH."'. T CERTAIN piece or parcel of land siruate in the Township of East Pennsboro, Coumy ':.Y/ Cumberland and Commonwealth of Pennsvlvania. beins! more hJI!\' desc~ibed :JS t'ol:c';,s: . ~ - ~. BEGINNING at a poim located on the Norrhern right of way line of Pine Ridge Circle and [he dividing line of Lot No. 14 Pine Ridge Estates. Phase 2. Plan Book 64. Page 37 and Lor "10. 13. he~ein described; thence by !he Northern right of way line of Pine Ridge Circle South 70 degrees, 48 minures. 01 second West a distance of 80.00 feet to a point at !he dividing line of LOI No. 12 and LOI No. 13, herein described: !hence by the same Norrh 19 degrees, 11 minutes, 59. seconds West a distance gJ'-/ 144.96 feet to a point at lands now or late of East Pennsboro Area School District; thence by the same North 70 degrees, 28 minutes, 55 seconds East a distance of 80.00 to a point at the dividing line of Lot No. 14, Pine Ridge Estates, Phase 2, Plan Book 64, Page 37 and Lot No. 13, herein described; [hence by the same, South 19 degrees, 11 minutes, 59 seconds East a distance of 145.40 feet to a point, [he place of beginning. BEING Lor No. 13, containing 11,614.30 square feet, as shown on Final Subdivision Plan of Pine Ridge Estates. Phase 4, recorded in Plan Book 65, Page 124. /' Tax Parcel #09-13-1000-121 .. 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 ofthe 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 unsworn falsification to authorities. Date TlInp. 19 ?007 SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-02961 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FEDERAL HOME LOAN MORTGAGE COR VS UHRINEK JOSEPH M 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, DEFENDANT UHRINEK JOSEPH M unable to locate Him in his bailiwick. He therefore returns the but was COMPLAINT - EJECTMENT the within named DEFENDANT , UHRINEK JOSEPH M , NOT FOUND , as to AT 117 LOCUST STREET 1ST FLOOR HARRISBURG, PA 17101. 50 PINE RIDGE CIRCLE IS VACANT. JOSEPH UHRINEK BELIEVED TO BE LIVING Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 ~SO. a.n..swer/..~._::" ~"_, './-::_'-~~:-~~ ;/__0~~ T'rhomas Kline/ Sheriff of Cumberland County FEDERMAN & PHELAN 07/19/2002 Sworn and subscribed to before me this .;l /k4 day of ~ .2011:2- A.D. ~ () rn, ;/7, Pr t onotary '+7 , 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 Federal Home Loan Mortgage Corporatioin ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Joseph M. Uhrinek Defendant( s) No. 02-2961 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: 1 })~tD I ~MY')J~ Francis S. 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