HomeMy WebLinkAbout03-3499FEDERMAN 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
Citibank, N.A., As Trustee
10790 Rancho Bernardo Road
San Diego, PA 19127
Faye Bickhart
Or Occupants
3405 Walnut Street
Camphfll, PA 17011
Court of Common Pleas
Civil Division
Cumberland County
Term
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 fat 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 ASSOC/ATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1. Plaintiff is Citibank, N.A., As Trustee.
2. Defendant is Faye Bickhart and Or Occupants.
3, Plaintiff is the owner of premises located at 3405 Walnut Street, Camphill, PA
17011, 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 deliver up possession of same.
WHEREFORE, plaintiff seeks to recover possession of said premises.
By:
FEDERMAN AND PHELAN, LLP
RMAN, ESQUll~
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALL1NAN, ESQUIRE
Attorneys for Plaintiff
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VERIFICATION
Francis S. Halhnan, 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.
Date:
~rancis S. Hallinan, Esquire
Attorney for Plaintiff
FEDERMAN AND pHELAN L.L.P.
FRANCIS S. IIALLINAN, ESQUIRE
IDENTIFICATION NO. 62695
One Penn Center ~ Suburban Station, Suite 1400
1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
~1 ~) 5~-700fl
Cihbank, N.A., As Trustee
Faye Bickhart
Or Occupants
ATTORNEY FOR PLAINTIFF
COURT OF cOMMON PLEAS
CIVIL DiVISION
CUMBERLAND cOUNTY
NO. 03-3499-CIVIL TERM
PRAECIPE Tf} 1NI~F,~ (C. RF, GORV KF,~,qlNGF, R'I AS DEFF, NDANT
TO TIlE PROTHONOTARY:
Pursuant to P.A RCP. 410 (a)(2), kindly index Gregory Ke~inEer as Defendant in the
above captioned matter. Gregory Kessinger was found in possession of the premises located ~ 3405
Walnut Street, Camphill, PA 17011 and was served with a copy of the Complaint on July 29, 2003.
/Fj/ancis S. H~lli~an, Esqu~e
L~/~ttomey for Plaintiff
Date:~u~at 10:2003
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03499 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK NA
BICKHART FAYE
VS
CPL. MICHAEL BARRICK ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - EJECTMENT
BICKHART FAYE
DEFENDANT , at 1809:00 HOURS,
at 3405 WALNUT STREET
CAMP HILL, PA 17011
GREGORY KESSINGER, OCCUPANT
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
on the 29th day of July
by handing to
the
2003
- EJECTMENT
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00 /~-'~
Service 10.35
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
38.35 07/30/2003
FEDERMAN & PHELAN
Deputy Sheriff
Sworn and Subscribed to before
me this 6 ~ day of
J&~J A.D.
'Prothonotary ~ ,