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HomeMy WebLinkAbout02-4571GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDIIECK~ JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PItlLADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE IqOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff REBECCA A. M U LHOLLAND MICHAEL S. MUI,HOLLAND and OCCUPANT(S) 253 E. Louther Street Carlisle, PA 17013 Defendant(s) 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. ai;t CIVIL ACTION: EJECTMENT NOTICE LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO I1! I I),N D[ MANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA. LAS QUEJAS PERESENTADAS, ES A/5SOi I/'IA MEN l] NI( I SSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. I'\ R.\ l)lk I ND~ RSI] IS NECESSARIO QUE US/ED, O SU ABOGADO, REGISTRE CON EA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE LEGAL SERVICES INC 8 lrvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT I. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, Piano, TX 75024-3632. 2. Defendauts are REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND, and OCCUPANT(S). 3. Plaintiff is the owner of premises 253 E. Louther Street, Carlisle, PA 17013 a legal description o1' xvhich is attached hereto. 4. Plaintiffbecame owner of said property by a Deed from the Sheriff of Cumberland, which deed was lodged and settlement made with the Sheriffon (Abstract of Title) September 16, 2002. 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The Defendants, REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND and OCCUPANT(S), are occupying the same premises without right, and so flu' as the Plaintiff is informed, without claim of title. 6. Plaintiffhas repeatedly demanded possession of the said premises from the said premises fi'om the said Defendants, who have refused to deliver up possession of the same. WH ER EFORE, Plaintiff requests judgment for possession of the premises. ~, Esq. VERIFICATION I, Joseph A. Goldbeck, Jr. as the Attorney of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this corporation and the are true and correct belief. I understand that false subject to the penalties of 18 Pa. falsification to authorities. verification on behalf of the Plaintiff facts set forth in the foregoing Complaint to the best of my knowledge, information and statements therein are made c.s. 4904 relating to unsworn Jr. #1574064 REBECCA A. MULHOLLAND and MICHAEL S. MULHOLLAND Ail that certain tract or parcel of land and premises, situate, lying and being in the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: On the North by a public alley; On the East by property now or formerly of Mrs. Mary G. Jones; On the South by East Louther Street; and On the West by property now or formerly of Viola J. Spotte; Containing 25 feet, more or less, in front on said East Lourther Street, and extending back an even width 120 feet, to the aforesaid public alley, and having thereon erected a 2 ~ story brick dwelling house and necessary outbuildings, and being known as 253 East Louther Street, Carlisle, Pennsylvania. Tax Parcel #02-21-0318-173 Being known as 253 East Louther Street, Carlisle, PA 17013. SHERIFF'S RETURN CASE NO: 2002-04571 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLJ~ND - NOT FOUND COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that inquiry for the within named defendant, MULHOLLAND REBECCA A unable to locate Her in his bailiwick. COMPLAINT - EJECTMENT he made a diligent search and DEFENDANT but was He therefore returns the NOT FOUND , as to the within named DEFENDANT , MULHOLLAND REBECCA A HOUSE IS VACANT. DEFENDANT'S NEW ADDRESS IS 4233 6TH AVENUE TEMPLE, PA 19560. Sheriff's Costs: Docketing 18.00 Service 3.45 Not Found 5.00 Surcharge 10.00 .00 36.45 GOLDBECK MCCAFFERTY MCKEEVER 10/04/2002 answ ~..~-' So R( Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ~--- day of ~ ~ ~2_A.D. ProthOnotary- SHERIFF'S RETURN CASE NO: 2002-04571 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named defendant, DEFENDANT MULHOLLAND MICHAEL S unable to locate Him COMPLAINT - EJECTMENT ,Sheriff or Deputy Sheriff, who being search and in his bailiwick. but was He therefore returns the NOT FOUND , as to the within named DEFENDANT , MULHOLLAND MICHAEL HOUSE IS VACANT. DEFENDANT'S NEW ADDRESS IS 4233 6TH AVENUE TEMPLE, PA 19560. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 GOLDBECK MCCAFFERTY MCKEEVER 10/04/2002 this [~ day of ~ ~ A.D. PrOthonotary · So answey~s, :: ~ R' Thomas Klzne Sheriff of Cumberland County Sworn and subscribed to before me GOLDBECK McCAFFERTY & McKEEVER ]~Y: JOSEPH A. GOLDBECK~ JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE ]MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS INC. 7105 Corporate/_)rive PTX B-35 Plano, TX 75024-3632 Plaintiff REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANT(S) 253 E. Louther Street Carlisle, PA 17013 Defendant(s) I HEREBy CERTIFy THAT THis IS A TRUE AND CORRECT COPy OF THE ORIGINAL FILED IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION ~ LAW ACTION OF EJECTMENT Term No. Da -- 4..Cq { CIVIL ACTION: EJECTMENT NOTICE LEGAL SERVICES [NC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 TRUE COPY FROM RECORD In Testimony whereof, I hero unto set my hand and the s~al Of said Court at Carlisle, Fa. p~thonota~-~-'--r-~-.~ I HEREBY CERTIFy THAT THIS IS A TRUE AND CORRECT COPy OF THE ORIGINAL FILleD COMPLAINT IN EJECTMENT 1. Plamtiffis COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, Piano, TX 75024-3632. 2. Defendants are REBECCA A. OCCUPANT(S). MULHOLLAND, MICHAEL S. MULHOLLAND, and 3. Plaintiff is the owner of premises 253 E. Louther Street, Carlisle, PA 17013 a legal description o£which is attached hereto. 4. Plaintiff became owner of said property by a Deed from the Sheriff of Cumberland, which deed was lodged and settlement made with the Sheriffon (Abstract of Title) September 16, 2002. 5. Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The Defendants, REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND and OCCUPANT(S), are occupying the same premises without right, and so ~ar as the Plamtiffis informed, without claim of title. 6. . Plaintiff has repeatedly demanded possession of the said premises from the said premises fi-om the said Defendants, who have refused to deliver up possession of the same. WHEREFORE, Plaintiffrequests judgment for possession of the premises. ~Esq. VERIFICATION I, Joseph A. Goldbeck, Jr. as the Attorney of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false subject to the penalties of 18 Pa. falsification to authorities. Date: ~/~ statements therein are made C.S. 4904 relating to unsworn #1574064 Jr. REBECCA A. MULHOLLAND and MICHAEL S. MULHOLLA_ND Ail that certain tract or parcel of land and premises, situate, lying and being in the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: On the North by a public alley; On the East by property now or formerly of Mrs. Mary G. Jones; On the South by East Louther Street; and On the West by property now or formerly of Viola J. Spotte; Containing 25 feet, more or less, in front on said East Lourther Street, and extending back an even width 120 feet, to the aforesaid public alley, and having thereon erected a 2 ~ story brick dwelling house and necessary outbuildings, and being known as 253 East Louther Street, Carlisle, Pennsylvania. Tax Parcel #02-21-0318-173 Being known as 253 East Louther Street, Carlisle, PA 17013. GOLDBECK McCAFFERTY & McKEEVER BY': JOSEPH A. GOLDBECK~ JR. ATTORNEY I.D. #16132 SUITE 500 -- THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF I HEREBy CERTIFy THAT THIS IS A TRUE AND CORRECT COPy OF THE ORIGINAL F~LED COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANT(S) 253 E. Louther Street Carlisle, PA 17013 Defendant(s) 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. Oa - '-tSql CIVIL ACTION: EJECTMENT NOTICE YOIJ SI IOI;LD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO CUMBERLAND COUNTY BAR ASSOCIATION 2 Liber v Avel ue, Carlisle, PA 17013 LEGAL SERVICES INC 8 IrVhle Row, Carlisle, PA 17013 717-243-9400 AVISO LE IlAN I)l MANDADO A USTED EN LA CORTE SI DESEA DEFENDERSE CONTRA LAS QUEJAS pERESENTADAS, ES >,IgSOLI/TAM EN I'1 N~ ( ESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. I' \ RA DEl~ END[ RS I I'~; N E( ESSAR O QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FOP. aMA ESCRITA, EL PUNTO DE VISTA DE / ~Y;"l I l) ¥ CUAI OI JHR OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RE('1/I RI)I Si USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUiR CON EL PROCESO SiN SU PARTiC1PACiON. ISN I ONCES, LA ( ( )1 :Il FU EDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y REQUERIRA QUE USTED CUMPLA CON TODAS I AS PROVISIONFS D[ } STA DEMANDA. POR RAZON DE ESA DECiSiON, ES POSSIBLE QUE USTED PUEDA PERDER DiNrERO, PROPiEDADU LEGAL SERVICES INC 8 hvine Row Carlis e, PA 17013 ~1~-2~-~oo TRUE COPY FROM RECORD In Testimony whereof, I here unto set my h~ad a~,d the seal of Said Com-t at Carlisle, Pa. Pr~honota~ ' -/- ,' HEREBy CER},~ y THAT YHIS iS ~ TRUE AND CORRECT COPy OF THE ORIGINAL FILED COMPLAINT 1N EJECTMENT 1. Plaintiffis COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, Piano, TX 75024-3632. 2. Defendants are REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND, and OCCUPANT(S). 3. Plaintiff is the owner of premises 253 E. Louther Street, Carlisle, PA 17013 a legal description of which is attached hereto. 4. Plaintiffbecame owner of said property by a Deed from the Sheriff of Cumberland, which deed was lodged and settlement made with the Sheriff on (Abstract of Title) September 16, 2002. 5. Plaintif£, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The Defendants, REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND and OCCUPANT(S), are occupying the same premises without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiffhas repeatedly demanded possession of the said premises from the said premises from the said Defendants, who have refused to deliver up possession of the same. WH ER EFORE, Plaintiff requests judgment for possession of the premises. Esq. VERIFICATION I, Joseph A. Goldbeck, Jr. as the Attorney of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. #1574064 REBECCA A. Jr. MULHOLLAND and MICHAEL S. MULHOLLAND All that certain tract or parcel of land and premises, situate, lying and being in the Borou9h of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: On the North by a public alley; On the East by property now or formerly of Mrs. Mary G. Jones; On the South by East Louther Street; and On the West by property now or formerly of Viola j. Spotte; Containing 25 feet, more or less, in front on said East Lourther Street, and extending back an even width 120 feet, to the aforesaid public alley, and having thereon erected a 2 ~ story brick dwelling house and necessary outbuildings, and being known as 253 East Louther Street, Carlisle, Pennsylvania. Tax Parcel #02-21-0318-173 Being known as 253 East Louther Street, Carlisle, PA 17013. GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUlqTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-4571 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OW~,, TO OUR CLIENT. ANY INFOP. MATION OBTAINk,~ FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTIN(~ THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the legal owner of the premises, 253 E. Louther Street, Carlisle, PA 17013, pursuant to a deed from the Sheriff of Cu~nberland County. Plaintiff filed a Complaint in Ejectment on September 23, 2002. 3. Sheriff has been unable to effect service of the Complaint upon Defendants despite numerous attempts and despite the fact that Plaintiff's inspection of the premises indicates they are occupied. 4. As this is an action for possession, further investiqation is ,~n~ecessar~. 5. Defendants have no right, title or interest in the premises, 253 E. Louther Street, Carlisle, PA 17013. Plaintiff believes and therefore avers that Defendants are deliberately avoiding service. 6. Plaintiff's inability to affect personal service upon Defendants has deprived, and continues to deprive Plaintiff of the use and enjoyment of which it is the lawful owner. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. BY: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. %56129 COIINTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-4571 VERIFICATION I, MICHAEL T. MCKEEVER, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY No. 02-4571 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Ejectraent against Defendants which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Ejectment upon Defendants by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, MICHAEL T. MCKEEVER, ESQUIRE CaSe Nu~nber: ' A.V,.A.: Rebecca A AddresS: 253 E Loutber street property CarBsie, pA ~0~3 A LaSt Known Add~eSs: 4233 6th ~;~;;60 ~e~e, r~ - · ~e~' [ ) ' .. ~e~oses a~ says: _, tocetO~. Last~no~nN~u'~ ~o~nacco~d~ngt°~w'. ,~st(o[p~aye~S~t~°n~ boVen~ed AFFIX ~ I a~ e~P~°Yeu ~ cted an ~nves~,~ ~e as ~o~OWS. 2. On 101, , ~he fesul[s of de[egdegtLsh __ - -~,ON - ~ ,~QU~RY OF ~'-:ted the last r%~ 19560 ~tb,;h~ WesteV "~'= ~' '~ .aRorSi~t~ is 423~ ~:cV ban~533 · ,, . case~' ~NoU~Y O~ ~G~O~S" ,-,COA~ has no ~e ~o NIA _ IC~' · ~AT~' _,~ of Address ?~ ~emple, PAl~ ' ctoNAL ' N/s ot OctoO~' ~uthott~d o; m . ~utholla SHERIFFIS RETURN - NOT FOUND ~CASE NO: 2002-04571 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL R. Thomas Kline duly sworn according to inquiry for the within named defendant, DEFENDANT MULHOLLAND REBECCA A unable to locate Her in his bailiwick. He therefore returns COMPLAINT - EJECTMENT ,Sheriff or Deputy Sheriff, who being law, says, that he made a diligent search and but was the 'the within named DEFENDANT , NOT FOUND , as to MULHOLLA_ND REBECCA A HOUSE IS VACANT. DEFENDANT'S NEW ADDRESS IS 4233 6TH AVENUE TEMPLE, PA 19560. Sheriff's Costs: Docketing 18.00 Service 3.45 Not Found 5.00 Surcharge 10.00 .00 36.45 So answers:~'~. ~..-: ~ Ri Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 10/04/2002 Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN 'CASE NO: 2002-04571 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUIqD COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named defendant, DEFENDANT MULHOLLAND MICHAEL S ,Sheriff or Deputy Sheriff, who being search and but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT , NOT FOUND , as to , MULHOLLJ~ND MICHAEL S HOUSE IS VACANT. DEFENDANT'S NEW ADDRESS IS 4233 6TH AVENUE TEMPLE, PA 19560. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 R. Thomas Klihe /- Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 10/04/2002 Sworn and subscribed to before me this day of A.D. Prothonotary GOLDBECK MCCAPFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Lou~her Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-4571 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendants this ~day of October, 2002, by first class mail, postage prepaid. MICHAEL T. MCKEEVER, ESQUIRE COUNTRYWIDE HOME LOANS, INC., 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff Vo REBECCA A. MULHOLLAND and MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-4571 CIVIL TERM ORDER OF COURT AND NOW, this 6t~ day of November, 2002, upon consideration of Plaintiff's Motion for Substituted Service under Pa. R.C.P. 430(a), a~ad it appearing from the motion that Plaintiff has a good address for Defendants Rebecca A. Mulholland and Michael S. Mulholland, and there being no allegation that service has been attempted at that address, the motion is denied as to Defendants Rebecca A. Mulholland and Michael S. Mulholland, and granted as to unknown occupants of 253 E. Louther Street, Carlisle, Cumberland County, Pennsylvania. SAID UNKNOWN OCCUPANTS may be served by (a) regular mail to the property, (b) posting of the property, and (c) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania. ~oseph A. Goldbeck, Jr., Esq. GOLDBECK, McCAFFERTY & McKEEVER Suite 500 - The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff :rc BY THE COU3[T, esley Oler, ~.~ ' }. L, GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 -- THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAiNTIFF COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND & OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS O17 Cumberland COUNTY CIVIL ACTION - LAW EJECTMENT COMPLAINT Term No. 02-4571 CIVIL TERM PRAECIPE TO REINSTATE COMPiLA1NT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr. Attorney I.D. #16132 Suite 500- The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. REBECCA A. MULHOLLAND MICHAEL S. MULHOLLAND and OCCUPANTS 253 E. Louther Street Carlisle, PA 17013 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County No. 02-4571 CIVIL TERM PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended as to REBECCA A. MULHOLLAND, MICHAEL S. MULHOLLAND AND OCCUPANTS. The action is to remain in full force and effect as to the OCCUPANTS of the property. /O~ G-O~DB~K, ,JR , ESQUIRE SHERIFF'S RETURN - REGULAR CASE NO: 2002-04571 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon MULHOLLAND REBECCA Athe DEFENDANT at 253 E LOUTHER STREET CARLISLE, PA 17013 at 0016:26 HOURS, on the 3rd day of December , 2002 POSTED PROPERTY AT 253 E. a true and attested copy of NOTICE AND COMPLAINT IN EJECTMENT by handing to LOUTHER ST, CARLISLE, PA together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 3.45 POSTING 6.00 Surcharge 10.00 .00 37.45 Sworn and Subscribed to before me this /f~ day of ~ .~ ~. ~ ~ A.D. / P~othonota~~ So Answers: R. Thomas Kline 12/04/2002 GOLDBECK, MCCAFFERTY, HCKEEVER SHERIFF'S RETURN - REGULAR CASE NO: 2002-04571 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MULHOLLAND REBECCA A ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon MULHOLLAND MICHAEL S the DEFENDANT at 253 E LOUTHER STREET , at 0016:26 HOURS, on the 3rd day of December , 2002 CARLISLE, PA 17013 POSTED PROPERTY AT: 253 E. a true and attested copy of NOTICE AND COMPLAINT IN EJECTMENT by handing to LOUTHER ST, CARLISLE, PA 17013 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 POSTING 6.00 Surcharge 10.00 .00 22.00 Sworn and Subscribed to before me this . /£~--~ day of P~dthonotary So Answers: R. Thomas Kline 12104/2002 GOLDBECK, MCCAFFERTY, MCKEEVER By: