HomeMy WebLinkAbout03-3453FEDERMAN AND PHELAN, LLP
By: Francis S. Halllnan, Esquire
Identification No. 62695
One Penn Center Plaza
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
Attorney for Plaintiff
Mortgage Electronic Registration Systems, Inc.
8201 Greensboro Drive, Suite 350
Mclean, VA 22102
Diane Brooks
Or Occupants
209 1st Street
Summerdale, PA 17093
Court of Common Pleas
Civil Division
Cumberland County
Term
No.
CWJL ACTION - ~.~,~TM~NT - .q020
Please he 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 Mortgage Electronic Registration Systems, Inc.
2. Defendant is Diane Brooks and Or Occupants.
3. Plainriffis the owner of premises located at 209 1st Street, Summerdaie, PA 17093,
a legai 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 rifle.
6. Plaintiff has demanded possession of the said premises from the said defendant who
has refused to deliver up possession of same.
WHEREFORE, plaintiff seeks to recover possession of said premises.
By:
FEDERMAN AND PHELAN, LLP
FRANK FEDERMAN, ESQUIRE
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
hundr~ ~-~ ~d
sou~west ~m~ Of ~e
~= ccn~r of ~e p~on ~1 d{~dinS ~e p~p~ now or fo~'~egy of K~nc~
L. PoP.Sec ~d Mil~d
hereby ~nv~; ~cnce ~w~ly ~u~ ~c ~n~ of ~ p~on w~
ca~ l~e of Water S~et
~e nor~ern ~= of~ No. 3, S~gon ~.' ~ ~e her~ m~doned ~ of
nor~w~y ~ong ~e wca~
%) foci. more or less. W
BErG ~ ~: 209 1st ST~f, S~, PA 1~093
VERIFICATION
Francis $. Hallinan hereby states that he is the attorney for thc Plaintiff in this
ev/cfion action and is author/zed to make tiffs verification. The statement~ made/n the
forego/rig Civ/l Act/on - Ejectment are conrcct to the bezt of my knowledge,/nformation,
and belief. I was Ihe attorney for the Plaintiff or Plahltiffs.predecessor in interest/n the
underlying foreclosure action. I am with the law firm on Ihe writ of execution, and my
law finn or an agent of my finn purchased Ihe propez/y on belmlf of the Plainfiffby
· bidd/ng on thc prop~y at Ihe sheriffs sale. I ~m w~ng tiffs vedficat/on rather flum a
representative of the Pla/n~ffbecause I hav~ personal knowledge of the purchase of tlds
propen'y at sheriffs sale.
The undersigned undc~ands that th/s statement is made subject to the penalties
of 18 Pa.C.S. §4904 relating to .nnworll falsification to authoritiez.
Francis S. Hallinan, Esquir~
Attorney for Plaintiff
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03453 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MORTGAGE ELECTRONIC REGISTR3tTI
VS
BROOKS DIANE
CPL. MICHAEL BARRICK ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - EJECTMENT
BROOKS DIANE
DEFENDANT ,
at 23 PINE RIDGE
ENOLA, PA 17025
DIANE BROOKS
a
at 1920:00 HOURS,
CIRCLE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 29th day of July , 2003
by handing to
true and attested copy of COMPLAINT - EJECTMENT
together with
and at the same time directing Her attention to the contents thereof.
Additional Comments
209 1ST STREET SUMMERDALE, PA IS VACANT.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
me this L~ day of
~~..~-~ · A.D.
'P~othonotary · '
So Answers:
R. Thomas Kline
07/31/2003
FEDERMAN & PHELAN
FEDERMAN AND P1
By: Frank Federman,
Lawrence T. Phelan, ]
Francis S. Hallinan, E
One Penn Center at
Suite 1400
Philadelphia, PA 191
(215) 563-7000
MORTGAGE ELEC
IELAN, LLP
Esquire I.D. No. 12248
isquire I.D. No. 32227
;quire I.D. No. 62695
tburban Station
~-1814
Attorney for Plaintiff
tONIC REGISTRATION SYSTEMS, INC.
Plaintiff Court of Common Pleas
CUMBERLAND County
's. No. 03-3453 CT
DIANE BROOKS O
PRAECIPE
TO THE PROTHON
Kindly withdraw th,
this case discontinm
Dat6
OCCUPANTS
Defendant(s)
WITHDRAW COMPLAINTe 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.
F~nk Federman,/Esquire
Lawrence, T. Phelan, Esquire
Francis S. Hallinan, Esquire
Attorneys for Plaintiff