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Home My WebLink About07-6259 Phelan, Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Deutsche Bank National Trust Company, As Trustee For Morgan Stanley ABS Capital I Inc. Trust 2006-HE3 3476 Stateview Blvd. Fort Mill, SC 29715 V. Ronald L. Woods, Sr. Or Occupants 508 Market Street New Cumberland, PA 17070 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No. 01- Wq sq 0iq( ( - erm CIVIL ACTION - EJECTMENT **This firm is a debt collector attempting to collect a debt and any information obtained 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.' NOTICE 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. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS #: 163896 1. Plaintiff is Deutsche Bank National Trust Company, As Trustee For Morgan Stanley ABS Capital I Inc. Trust 2006-HE3. 2. Defendant is Ronald L. Woods, Sr. Or Occupants. 3. Plaintiff is equitable owner of premises located at 508 Market Street, New Cumberland, PA 17070, a legal description of which is attached. 4. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County, on October 3, 2007. 5. Plaintiff, by virtue of the above, is the equitable 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. F ncis S. Hallinan, Esquire Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land, with the buildings and improvements thereon erected, situate in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the Southerly line of Market Street which point is seventy- four (74) feet West of the Southwesterly corner of Fifth and Market Streets; thence South forty (40) degrees West one hundred fifty (150) feet to a point on the Northerly line of a fifteen (15) feet wide ordained alley; thence along same, North fifty (50) degrees West twenty-five (25) feet to a point; thence North forty (40) degrees East one hundred fifty (150) feet to a point on the Southerly line of Market Street aforesaid; thence along same South fifty (50) degrees East twenty-five (25) feet to a point the place of BEGINNING. HAVING THEREON erected a one story frame dwelling known as No. 508 Market Street. BEING THE SAME PREMISES WHICH Willard Robert Ott and Lois L. Ott, his wife, by their Deed dated January 30, 2006, and about to be recorded in the Office of the Recorder of Deeds in and for Cumberland, County, Pennsylvania, granted and conveyed unto Ronald L. Woods, Sr., Mortgagor herein. VERIFICATION Francis S. Hallinan hereby states that he is the attorney for the Plaintiff in this eviction action and is authorized to make this verification. The statements made in the foregoing Civil Action - Ejectment are correct to the best of my knowledge, information, and belief. I was the attorney for the Plaintiff or Plaintiffs predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on the property at the sheriffs sale. I am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this property at sheriffs sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. /o%y 017 Date rancis S. Hallinan, Esquire Attorney for Plaintiff p ca - = n-i O QO 00 Ct3 ? `= 00 a , Y?? I ' T ?. 0 C71 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06259 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS WOODS RONALD L SR WILLIAM CLINE , Sheriff or Cumberland County,Pennsylvania, who being says, the within COMPLAINT - EJECTMENT WOODS RONALD L SR puty Sheriff of y sworn according to law, s served upon the DEFENDANT at 1913:00 HOURS, on the 1 th day of November-, 2007 at 508 MARKET STREET NEW CUMBERLAND, PA 17070 byl handing to RONALD WOODS JR a true and attested copy of COMPLAINT - EJE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 32.64 .00 10.00 R. Thomas R .00 60.64 11/20/2007 PHELAN HALLII? day By: A. D. SCHM Cr ty Sheriff Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Deutsche Bank National Trust Company, as Trutsee for Morgan Stanley ABS Capital 1, Inc., Trust 2006-HE3 VS. Ronald L. Woods Or occupants 508 Market Street New Cumberland, PA 17070 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION No. 07-6259-Civil Term Cumberland County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, Deutsche Bank National Trust Company, as Trutsee for Morgan Stanley ABS Capital 1, Inc., Trust 2006-HE3 and against the Defendant(s) Ronald L. Woods and Or occupants for possession of premises, 508 Market Street, New Cumberland, PA 17070 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 237.1, written 10-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Fr cis S. Hallinan, Esq re orney for Plaintiff Default Judgment entered as indicated above. DATE AfF .4 ? Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff Deutsche Bank National Trust Company, as Trutsee for Morgan Stanley ABS Capital 1, Inc., Trust 2006-HE3 Vs. Ronald L. Woods Or occupants 508 Market Street New Cumberland, PA 17070 COURT OF COMMON PLEAS CIVIL DIVISION No. 07-6259-Civil Term Cumberland County VERIFICATION OF NON-MILITARY SERVICE FRANCIS S. HALLINAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant Ronald L. Woods Or occupants, is over 18 years of age, and resides at 508 Market Street, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 PA. C.S.S 4904 relating to unswom falsification to authorities. , ra cis S. Hallinan, Esqui A rney for Plaintiff -PHELAN HALLINAN & SCHMIEG, LLP ?By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 DEUTSCHE BANK NATIONAL TRUST COMPANY, : COURT OF COMMON PLEAS AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE3 : CIVIL DIVISION Plaintiff CUMBERLAND COUNTY Vs. :NO. 07-6259-CIVIL TERM RONALD L. WOODS, SR. OR OCCUPANTS Defendants TO: RONALD L. WOODS, SR, OR OCCUPANTS 508 MARKET STREET NEW CUMBERLAND, PA 17070 DATE OF NOTICE: DECEMBER 18, 2007 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 FRANCIS S. Attorneys for rkLL ESQUIRE ' '? C PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA County of Cumberland Deutsche Bank National Trust Company, as Trutsee for Morgan Stanley ABS Capital 1, Inc., Trust 2006-HE3 COURT OF COMMON PLEAS CIVIL DIVISION vs. No. 07-6259-Civil Term Cumberland County Ronald L. Woods Or occupants 508 Market Street New Cumberland, PA 17070 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 508 Market Street, New Cumberland, PA 17070 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 508 Market Street Fr neis S. Hallinan, E quire orney for Plaintiff C C -TI ? V- r? to ti LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land, with the buildings and improvements thereon erected, situate in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the Southerly line of Market Street which point is seventy- four (74) feet West of the Southwesterly corner of Fifth and Market Streets; thence South forty (40) degrees West one hundred fifty (150) feet to a point on the Northerly line of a fifteen (15) feet wide ordained alley; thence along same, North fifty (50) degrees West twenty-five (25) feet to a point; thence North forty (40) degrees East one hundred fifty (150) feet to a point on the Southerly line of Market Street aforesaid; thence along same South fifty (50) degrees East twenty-five (25) feet to a point the place of BEGINNING. HAVING THEREON erected a one story frame dwelling known as No. 508 Market Street. BEING THE SAME PREMISES WHICH Willard Robert Ott and Lois L. Ott, his wife, by their Deed dated January 30, 2006, and about to be recorded in the Office of the Recorder of Deeds in and for Cumberland, County, Pennsylvania, granted and conveyed unto Ronald L. Woods, Sr., Mortgagor herein. 2 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 VS. No. 07-6259 Civil Term RONALD L. WOODS Or occupants 508 Market Street New Cumberland, PA 17070 Costs Attorney's $ 177.14 Plaintiff s $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 being: (Premises as follows): 508 MARKET STREET, NEW CUMBERLAND, PA 17070 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. C is R. Lon o on Common Pl as Court of C Berland County, PA Date 1/07/08 (Seal) 2of2 No 07-6259 Civil Term By virtue of this writ, on the day of I caused the within named , to have possession of the premises described with the appurtenances, and vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 RONALD L. WOODS or Occupant WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 177.14 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP 1617 JOHN F. KENNEDY BLVD, SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 Attorney for Plaintiff (s) Where papers may be served Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. I.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC. TRUST 2006-HE3 Plaintiff Court of Common Pleas CUMBERLAND County VS. No. 07-6259-CIVIL TERM RONALD L. WOODS OR OCCUPANTS Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, SATISFY JUDGMENT AND DISCONTINUE AND END ACTION, WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, satisfy the judgment and mark this case discontinued and ended, upon payment of your costs only. /z? 9_ vo Date r p rl C., Francis S. Hallinan Attorney for Plaintiff PHS # 163896 ¦ By virtue of this writ, on the day of . I caused the within named to have possession of the premises described with the appurtenances, and PER ATTY 8 WRIT OF FXEQUIIUlq So .? Sworn and subscribed to before me this ? Day of , \7 s? Sheriff/ Byl! Q A L ?.??. l L Sheri,ff's Retu4n: Advance Costs: 150.00 Sheriff's Costs: 57.45 DOCKETING 18.00 92.55 SURCHARGE 20.00 POUNDAGE 1.13 PROTHONOTARY 2.00 Refunded to Atty on 4/17/08 MILAGE 1ffiG? 57'. 45 ? y1z f/o P 9- r- -., el"*% a ck `351C. .I 0 ? i s? 2of2 No 07-6259 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 VS. RONALD L. WOODS or Occupant WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of , . I caused the within named , to have possession of the premises described with the appurtenances, and Att'y $ 177.14 Plff (s) $ Prothy $ 2.00 Sheriff $ C, Plaintiff (s) attorney name and address: FRANCIS S. HALLINAN, ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP 1617 JOHN F. KENNEDY BLVD, SUITE 1400 PHILADELPHIA, PA 19103 215-563-7000 Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy 4- W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 VS. No. 07-6259 Civil Term- RONALD L. WOODS Or occupants 508 Market Street New Cumberland, PA 17070 Costs Attorney's $ 177.14 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL 1, INC., TRUST 2006-HE3 being: (Premises as follows): 508 MARKET STREET, NEW CUMBERLAND, PA 17070 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. C s R. Long, ono , Common P Ws Court of Qfimberland County, PA Date 1/07/08 (Seal)