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Home My WebLink About99-04020 1 i 1% 1. :?? W 'yA ??. 5.µS'. Ott ?. ?i .: Via.. N J f ''pl McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 S. Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 LaSalle National Bank, as Trustee for the Registered Holders of Nomura Asset Securities Corporation, Mortgage Pass-Through Certificates, Series 1994-5 c/o Household Bank Attorney for Plaintiff Cumberland County Court of Common Pleas V. Paul G. Engle and Linda S. Engle and John Doe, Occupant(s) and Jane Doe, Occupant(s) Number 99 -'/Ws. C, Vt Rl'j COMPLAINT IN EJECTMENT NOTICE AVISO 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 twenty (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 deienses or objections. to the claims set forth against you. You are warned that if you fof I to do so the case may proceed you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights iWortant 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 HELP. Le hen demsndado a usted an to torte. Si usted quiere defenderse de estas deorldas ex-puestas en Los paginas siguientes, usted tiene veinte (20) dies de plazo at partir de to fecha de to demands y to notification. Hate felts asentar me coaparencia escrita o an persona o con un abogado y entreaar a to torte en forme escrita sus defenses o sus objeciones a las demandas an contra de au persona. Sea avisado qua of usted no se deffende, to torte tomara medidss y Puede continuer to demands, en contra suya sin previo eviso o notification. Ademas, is torte puede decidir a favor del dem ridante y requiere que usted cumpla con todas Los provisioner de esta demanda. listed puede perder dinero o sus propfedades u otros derechos inportantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGAIDO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERV ICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Curberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MCCABE, WEISBERG AND CONWAY, P. C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 S. Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 LaSalle National Bank, as Trustee for the Registered Holders of Nomura Asset Securities Corporation, Mortgage Pass-Through Certificates, Series 1994-5 c/o Household Bank 961 Weigel Drive, P.O. Box 8632 Elmhurst, IL 60126 V. Paul G. Engle 2 Patton Road Mechanicsburg, PA 17055 and Linda S. Engle 2 Patton Road Mechanicsburg, PA 17055 and John Doe, Occupant(s) 2 Patton Road Mechanicsburg, PA 17055 and Jane Doe, Occupant(s) 2 Patton Road Mechanirsburn, PA 17055 Attorney for Plaintiff Cumberland County Court of Common Pleas Cumber ne?- 'oyo 1. Plaintiff is the owner of the premises known as 2 Patton Road, Mechanicsburg, PA 17055, the full legal description of which is attached hereto, made a part hereof, and marked as Exhibit "A.° 2. Plaintiff acquired title by reason of a Sheriff's Sale conducted by the Sheriff of Cumberland County on June 9, 1999, by reason of Writ of Execution issued out of the Cumberland County Court of Common Pleas, Number 97-5474 Civil at the suit of LaSalle National Bank, as Trustee for the Registered Holders of Nomura Asset Securities Corporation, Mortgage Pass-Through Certificates, Series 1994-5 v. Paul G. Engle and Linda S. Engle. 3. Defendants are in possession of the foregoing described premises without title, color of title, or benefit of a lease. 4. Defendants are wrongfully and unlawfully in possession of the premises. 5. Defendants have no rights of possession to said premises. 6. Defendants at the time this action is brought are still unlawfully and willfully retaining possession of said premises and continue to do so and have detained and continue to detain and keep the Plaintiff out of possession thereof and refuse to vacate and deliver up the said premises to Plaintiff. 7. Defendants have willfully remained in possession of Plaintiffs property have refused and still refuse to quit said premises and still occupy the same. WHEREFORE, Plaintiff demands a judgment be entered in its favor for possession of the property. TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff The undersigned, Annette Maciariello, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, Household Finance Consumer Discount Company, and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. ANN TTE MACIARIELLO ALL THAT CERTAIN piece or parcel of land situate in Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern side of Patton Road which point Is also the dividing line of Lots Nos. 10 and 11, Block D, on the hereinafter mentioned Plan of Lots: thence along said dividing line South 04 degrees 01 minutes 47 seconds East 121.82 feet to a point; thence along the dividing line of Lots Nos. 10 and 24, Block D, on the hereinafter mentioned Plan of Lots South 79 degrees 37 minutes West 98.19 feetto a point; thence along the dividing line of Lots Nos. 10 and 25 on the hereinafter mentioned Plan of Lots North 61 degrees 37 minutes West 43,87 feet to a point; thence along the Western side of Lot No. 10, Block D, 141.39 feet to a point on the Southern side of Patton Road; thence by an arc curving to the left having a radius of 175 feet an arc distance of 60,0 feet to a point and place of BEGINNING. UNDER AND SUBJECT to a 25 foot building setback line. Being known as premises 2 Patton Road, Mechanicsburg, Pa. Tax I.D. No. 18-22-0519-302. e EXHIBIT R „ I SHERIFF'S RETURN - REGULAR CASE NO: 1999-04020 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE NATIONAL BANK ET AL VS. ENGLE PAUL G ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon ENGLE PAUL G the defendant, at 20:00 HOURS, on the 1st day of July 1999 at 2 PATTON ROAD MECHANICSBURG, PA 170SS CUMBERLAND County, Pennsylvania, by handing to PAUL G. ENGLE a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.20 2 Affidavit .00 Surcharge 8.00 R? omas ine, Ski MCCAB$199 ISBERG & CONWAY by epu y 5 eri Sworn and subscribe to before me this ?2A-4 day of 19? A. D. rotnonotary SHERIFF'S RETURN - REGULAR CASE NO: 1999-04020 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE NATIONAL BANK ET AL VS. ENGLE PAUL G ET AL _ BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon ENGLE LINDA S the defendant, at 20:00 HOURS, on the 1st day of July 1999 at 2 PATTON ROAD MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to PAUL G. ENGLE a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 + Af fidavit . 00 1/?7 Surcharge 8.00 Kllrie'f S eri 07 2 9 $14.U0-MCGAOB$i9W?EEISBLLER?G,, & CON'WAY\\?by ,Y?L /I ?C ?iC1/G? epu y i Sworn and subscribed to before me this t wk day of 19 A. D. rornonorar SHERIFF'S RETURN - REGULAR CASE NO: 1999-04020 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE NATIONAL BANK ET AL VS. ENGLE PAUL G ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon DOE JOHN OCCUPANT the defendant, at 20:00 HOURS, on the 1st day of July 1999 at 2 PATTON ROAD MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to PAUL G. ENGLE a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 Service .00 Affidavit .00 Surcharge 8.00 IA's s &J.Ine 5nerlzl: $T4.00-MCCAB$ WEISBERG & CONWAY 07/02/1999 by e y i Sworn and subscribed to before me this day of 19_! t A. D. J-? l r'. h4,J rocnonoaar SHERIFF'S RETURN - REGULAR CASE NO: 1999-04020 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE NATIONAL BANK ET AL VS. ENGLE PAUL G ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon DOE JANE OCCUPANT the defendant, at 20:00 HOURS, on the 1st day of July 1999 at 2 PATTON ROAD MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to PAUL G. ENGLE a true and attested copy of the NOTICE AND COMPLAINT IN together with EJECTMENT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: _ Docketing 6.00 ,?., ?? Service .00 ? ' ® Affidavit .00 ?1 7 J4 Q Surcharge 8.00 ? ? ICI omas M, fTL" $.Lq . u u MCCAB$ WEISBERG & CONWAY 07/02/1999 by X. A4 ?i/w ' epu y eri Sworn and subscribed to before me this - day of 199? A. D. C rSf:Iionb?y