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Home My WebLink About02-2968 LaW Office of Federman an~ phelan By: Frank Federman, EsqUlre Identification No. 12248 One Penn Center plaza 1617 JFKBoulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Court of Common Pleas Countrywide Home Loans, Inc. 7105 Corporate Drive, PTX-B35 PIano, TX 72024 Civil Division Cumberland County v. Term Timothy S. Clippinger or occupants 338 "C" Street Carlisle, PA 17013 No. tJrJ - a9(P~ avJ -nus firm is a debt collector attempting to collect a debt and any information oblained will be used for that purpose. U you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property.** CIVIL ACTION - EJECTMENT - 3020 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 1. Plaintiff is Countrywide Home Loans, Inc.. 2. Defendant is Timothy S. Clippinger or occupants. 3. Plaintiff is the owner of premises located at 338 "C" Street, Carlisle, PA 17013, a legal description of which is attached. 4. 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) . 5. 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 plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of the same. WHEREFORE, plaintiff seeks to recover possession of said premises. ~ F FEDER Attorney for Plaintiff , , . / / .' \ LEGAL DESCRIPTION ) ALL 'j,at ce,...ain tract of land with the improvements thereon situate in the ~rough of Carlisle. Ccmberlo"c CJunt:,. Penn<::"~'1ania., bounded and described as follows: nn the No"h by "C S :reet; on the East by property now or formerly of Carlisle TrJsr Company: on tho South by proportj now or formerly of Edward Brownawell and Rebecca E. Brownawell: and on the WestJY ?rope":' now or formerly of S. L. Diven. Said lot having a frontage on "CO Street of 48.35 feet and on :he South or a9,95 feet, and a depth of 101.40 feet and being made up of p:utS of LotS Nos, 37 and 38. Bleck la, at '.'" Carlisle Land and Improvement Company, and being known"" 338 "C Street. Carlisle. Penns,lvania. BEING the sarne premises which Raymond C. Bobn '1\ a::d Deborah ,\. Bobb, hIS wife. by their De.d dalee November 3. 1994 and recorded November 4, 1994 in the Office of the Recorder of Deeds of CJmberiano County in Deed Bool<. 114, Page 563, grantea and COnveyed 'Jnt~ John A. ~bb. single man. Grantor herelc,. . PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 JohnF. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Countrywide Home Loans, Inc. ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Timothy S. Clippinger Tracie A. Clippinger Defendant( s) No. 02-2968 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: C\\ 1L\~ ~Nl {1 ~ c;1'rL(j~ Francis S. Hallinan, Esquire Attorney for Plaintiff ."0\ '~'i.' ~ 1; -..-~ . 'r~\" ,,-~ '. \~;. \~. ~ ~ tt;<;:J c.~ 0') ".... --0 N 0' -0 ~':' ;i:.c. .f.;-,,-(__ -"'''":'1'- (~~: z :2 o -'f\ -' -f.:' ,",1 fn(" ?2i2:~ '~f~\ - .~-n ()C') ::C:.rt1 ,''') ,;::..\ '~.;." ~O ::..:. <-W .' o ..., 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 unsworn falsification to authorities. Date: c;~c1 /0.2 / / FZ~~ Attorney for Plaintiff '. - ~ , ~ 0 (:) 0 c: N " s: t- ..... ~ '""'00-) C:: ~Ti FIJ cprT! ;Z ..._ :t::~j -~C!1 -:r(.'-. N ~ (ji ~:~_ .::> is'I:' ... -~~ ....... -.~ ~c --..,"-) ;po " -r, ~ \\'- >c :x (-s:.:r) z~' Zl'5 " ~ ~..O - c,rn :J>c: .. ..::i ~ z: '" ?o ....... ::< Iv -< "-I SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-02968 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS CLIPPINGER TIMOTHY S R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: CLIPPINGER TIMOTHY S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT SERVED , as to the within named DEFENDANT , CLIPPINGER TIMOTHY S HOUSE IS VACANT BUT THERE IS MAIL IN MAILBOX. THERE IS A FOR SALE BY OWNER SIGN IN FRONT YARD. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.45 .00 10.00 .00 31. 45 :~~~ SHERIFF OF CUMBERLAND COUNTY FEDERMAN & PHELAN 06/24/2002 Sworn and subscribed to before me this y~ day of ~ :J-ov.L A.D. ~ D n....PP, J.~ Pro h notary