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Home My WebLink About02-4494 FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Cendant Mortgage Corporation F/K/A PHH Mortgage Services Corporation 6000 Atrium Way Mount Laurel, NJ 08054 Court of Common Pleas Civil Division v. Cumberland County Term Donald L. Severs Or Occupants 302 Widders Drive Mechanicsburg, P A 17055 No. 0:2 - l../l./9'1 (7,'(),'l ~~ mVTT. A n'l'TON R.TRn'I'MRN'I' lln?n NO'l'TnR Please be advised that this firm is a debt collector attempting to collect a debt. Any information received will be used for that purpose. If 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 alien against property. 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 ASSOCIATJON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 1. Plaintiff is Cendant Mortgage Corporation F/K/A PHH Mortgage Services Corporation. 2. Defendant is Donald L. Severs and Or Occupants. 3. Plaintiff is the owner of premises located at 302 Widders Drive, Mechanicsburg, PA 17055, 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 ofthe said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. 3/VYf1A~~ FRANK FEDER , ESQUIRE Attorney for Plaintiff - ALL THAT CERTAIN trace of ~and s;.tuate CUmber1and County, Pennsylvan~a, be~n9 more and descriDed as f01~ows, to wit: in Monroe Township, partieu1ar1y bounded BEG~NG at a po;.nt: on the northern s;.de of W;.dders Drive a f;.fty (SO) foot w;.de sereet; thence a100g Lot No. 71., North tw..nty-su (26) degrees ten (10) minutes forty (40) seconds West one h~~dred forty (1.40) feet to a point. at Lot No. 72; thence a10ng Lot No. 72 and Lot No. 74, North sixty-three (63) degrees forty-five (45) m;.nutes twenty (20) secorlCUs Bast, on hunl'ired twenty (J.20) feet t.o a point at Lot No. 69; .t.hence a10ng Lot No. 69 South twenty-s;.x (26) degr....s t..n (J.O) minutes forty (40) seconds East one hundred forty (1.40) feet to a point on the northern side of Wj"ddera Orive; thence a10ng the Northern side of Widders Drive, south .ixty-three (63) degrees forty-nine (49) minutes twenty (2$) seqonds West, one hundred twenty (120) feee to a poine, ene po;.",t and p:l:ace of BEG:INNJ:NG. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accordance wich a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March kO, 1972, and recorded in ~lan~ook 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widdere Drive. IT BEING the same premises Which Benjamin L. Breneman, single man, and R.L. Sheibley and Edith H. Sheibley, husband and wife, by deed dated August 24, 1972 and recordedln the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Eook T- 24, Page 969, granted and conveyed unto Donald J. Eordner a1ld Roseanna M. Borm1er, husband and wife, Grantors herein. - 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. RC.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. q 117/0) I I ~ Fra Federman, squire Attorney for Plain iff Date: '<l 1-\~ -- ~() '-? 1-J " ....0 ,.J .....) G" e,:. r-~ \../ ....:!- -.0 -c"',", I'l~ : :~i' ::.,..:' .,i> (; t~ ~~ ","") -.-, 'u c:t.J t.' . c. ..... . . ,_I G 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 Cendant Mortgage Corporation ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Donald Severs Angela Severs Defendant(s) No. 02-4494 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: ~~~ 0 ~ ~~S~ Francis S. Hallinan, Esquire Attorney for Plaintiff t; ~ tg, <J' <fl f"{'j -r,; ':. ", 0.... -0. :::-~;" Q, '9-0 fnr';~, ~~t? '.('.J ~'--r\ r:-;-, ;;:~~~ \~l '~~ 0) .' - o SHERIFF'S RETURN - REGULAR CASE NO: 2002-04494 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS SEVERS DONALD L RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon SEVERS DONALD L the DEFENDANT at 1551:00 HOURS, on the 23rd day of September, 2002 at 114 W GREEN STREET MECHANICSBURG, PA 17055 by handing to JOHN SEVERS, FATHER a true and attested copy of COMPLAINT _ EJECTMENT together with and at the same time directing His attention to the contents thereof. 302 WIDDERS DRIVE MECHANICS BURG IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.21 .00 10.00 .00 34.21 So Answers: ~~~<,r ~p R. Thomas Kline ? 09/24/2002 FEDERMAN & PHELAN Sworn and Subscribed to before By: Z?E~Lff ?fb- day of me this (7)UJ". .2~:L A.D. CJ.jf" () }y.,;p",,-, # I rothonotary ,