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HomeMy WebLinkAbout08-0050Phelan, 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 Fannie Mae 14221 Dallas Parkway Dallas, TX 75254-2916 Attorney for Plaintiff Court of Common Pleas Civil Division V. Paul A. Rheaume Or Occupants 15 West Factory Street Mechanicsburg, PA 17055 . Cumberland County Term No. 03 - 50 CIVIL ACTION - EJECTMENT Civi i arm '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 #: 167652 1. Plaintiff is Fannie Mae. 2. Defendant is Paul A. Rheaume Or Occupants. 3. Plaintiff is the record owner of premises located at 15 West Factory Street, Mechanicsburg, PA 17055 a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicil sale by the Sheriff of Cumberland County, on December 5, 2007 as evidenced by the Sheriff's deed recorded December 20, 2007 in the Office of the Recorder of Cumberland County in Instrument Number 200746887. 5. Plaintiff, by virtue of the above, is the record 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. ra is S. Hallina11 Esquire orney for Plaintiff Premises: 15 West Factory Street, Mechanicsburg, PA 17055 Mechanicsburg4th Ward, Cumberland County Pennsylvania DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate on the south side of West Factory Street, 4th Ward, in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the southern line of Factory Street, said point being measured in a southwesterly direction two hundred sixty (260.00) feet from the southwest corner of Factory Street and Market Street; thence south 21 degrees 25 minutes East along the western line of lands now or formerly of Aaron C. Kapp a distance of one hundred nineteen and sixteen hundredths (119.16) feet to a hub on the northern line of a fifteen (15.00) foot wide alley; thence South 71 degrees 33 minutes West along said northern line of alley a distance of sixty-one (61.00) feet to a hub; thence North 18 degrees 27 minutes west along the eastern line of lands now or formerly of John H. Weigel, Jr., a distance of one hundred nineteen (119.00) feet to a hub on the southern line of Factory Street; thence North 71 degrees 33 minutes East along said southern line of Factory Street a distance of fifty-four and eighty-three hundredths (54.83) feet to a hub, the point and Place of BEGINNING. HAVING thereon erected a 2'/z story frame dwelling and detached frame garage known and numbered as 15 West Factory Street. UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. BEING the same premises which Eric B. Hughes and Jean Hughes, his wife, by their deed dated June 30, 1992, and recorded July 7, 1992, in the Office of the Recorder of Deeds, in and for Cumberland County, in Deed Book T, Volume 35, Page 606, granted and conveyed unto Donald L. Stoner, Jr. and Jeanna J. Stoner, his wife, Grantors herein. Being Parcel # 19-22-0519-083 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 - Ejiectment 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. Date ran s S. Hallinan, Esquire At rney for Plaintiff N cz? ?(k 00 'rr ? c O 01 , S1? cn 00 -,a C) F-5 -5a n I I SHERIFF'S RETURN - REGULAR CASE NO: 2008-00050 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FANNIE MAE VS RHEAUME PAUL A JESSICA HERMANSEN , Sheriff or Deputy Cumberland County,Pennsylvania, who being duly swb says, the within COMPLAINT - EJECTMENT was ser RT RAITME PAUL A heriff of n according to law, ed upon the DEFENDANT , at 1959:00 HOURS, on the 22nd day of January 2008 at 15 WEST FACTORY STREET MECHANICSBURG, PA 17055 by handing to JEREMY RHEAUME, SON a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to th? contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 28.8 0 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 /avlpy ? ? 56.80 01/23/2008 „ PHELAN HALLINAN SCH IEG Sworn and Subscibed to By: j%m 4 before me this day of A. D. Sheriff PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esquire I.D. No. 32227 Francis S. Hallinan, Esquire I.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 FANNIE MAE VS. Plaintiff PAUL A.RHEAUME OR OCCUPANTS Defendant(s) Attorney for Plaintiff Court of Common Pleas CUMBERLAND County No. 08-50-CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. azif Date ? kro S &&/ '?04e41 Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff PHS # 167652 -r, r, li r ? t,?