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Home My WebLink About03-2830FEDERMAN AND PHELAN, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. 711 High Street Des Moines, IA 50392-0780 Court of Common Pleas Civil Division : Cumberland County Gerald L. Manhollan Or Occupants 104 North Enola Drive Enola, PA 17025 : Term : No. 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 a lien 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1. Plaintiff is Principal Residential Mortgage, Inc. 2. Defendant is Gerald L. Manhollan and Or Occupants. 3. Plaintiff is the owner of premises located at 104 North Enola Drive, Enola, PA 17025, a legal description of which is attached. 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). 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 dehver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. By: FEDERMAN AND PHELAN, LLP FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff Premises: 104 NORTH ENOLA DRIVE, TOWNSHIP OF EAST PENNSBORO 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 iot or piece of land situate in East Pennsboro Township. Cumberland Count,,,. Pennsylvania. bounded and described as follows, to vdt: - BEGINNING at a point in the eastern line of Brick Church Road at the distance of 45 feet measured northwardly along the eastern line or: Brick Church Road from the northern extremity of the curve connecting the northerly line of Perry Street with the said easterly line of'Brick Cht~rch Road and extending thence northwardly 10 degrees 20 minutes West, 22 feet'6 inches to a point; thence North 79 degrees 40 minutes East and through the center of the partition wall between house on lot hereby conveyed and house on lot adjoining on the North. a distance of 115 feet to a point: thence South 1~3 degrees 20 minutes East, 22 feet 6 inches to a point; and thence South 79 degrees 40 minutes West, 115 feet to the place of Beginning. HAVING THEREON ERECTED a two story frame dwelling house known and numbered 104 N. Enola Drive, or Brick Church Road, Enola, Pennsylvania. Tax Map #14-0832. Parcel #240 VERIFICATION Francis S. Hallinan, 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. l~rancis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-0282.0 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS MANHOLLAN GERALD L R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT MAiqHOLLA/q GERALD L unable to locate Him COMPLAINT - EJECTMENT ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and in his bailiwick. but was He therefore returns the the within named DEFENDANT 104 NORTH ENOLA DRIVE ENOLA, PA 17025 , NOT FOUND , MANHOLLAN GEP~ALD L PER NEIGHBOR, DEFENDANT LEFT MONTHS AGO. as to Sheriff's Costs: Docketing 18.00 Service 20.70 Not Found 5.00 Surcharge 10.00 .00 53.70 So answ~ ~~ z R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELA/q 07/01/2003 Sworn and subscribed to before me this 'l ~ day of ~ ~%~o~ A.D. · FEDERMAN AND P By: Frank Federman, Lawrence T. Phelan, Francis S. Hallinan, ! One Perm Center at Suite 1400 Philadelphia, PA 19~ (215) 563-7000 PRINCIPAL RESID ~ELAN, LLP Esquire I.D. No. 12248 Esquire I.D. No. 32227 isquire I.D. No. 62695 ,uburban Station 33-1814 '~NTIAL MORTGAGE, INC. Plaintiff GERALD L. MANE PRAECIPE ~1 TO THE PROTHON~ Kindly withdraw the this case discontinue, DLLAN OR OCCUPANTS Defendant(s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 03-2830 CT O WITHDRAW COMPLAINT~ WITHOUT PREJUDICE, AND DISCONTINUE AND END )TARY: complaint filed in the instant matter, without prejudice, and mark and ended, upon payment of your costs only. Date Fr/ank Federman~, Esquire ' Lawrence T. Phelan, Esquire Francis S. ]-Iallinan, Esquire Attorneys for Plaintiff