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HomeMy WebLinkAbout08-1302IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff, V. BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, NO.: C)%- 150A Oiv;t IerN9 Defendants TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. WELT EINBERG & REIS C P.A. By ATTORNEYS FOR PLAINTIFF I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS: 10385 WESTMOOR DR STE 100 WESTMINSTER, CO 80021 AND THE DEFENDANTS ARE: 24 W. Locust Street 7055 MechanicsburINBEF WELT G & RE I , L.PA. ATTORNEYS FO PLAINTIFF I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS: 24 W. Locust Street Mechanicsburg, PA 17055 Bgh of Mech ' sburg WELTMAN, RG & REIS CO., L.P ATTORNEYS F R KA-INTIFF ISSUE NO.: CODE: TYPE OF PLEADING: COMPLAINT IN EJECTMENT FIILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Patricia L. Blais, Esquire PA ID #56648 WELTMAN, WEINBERG & REIS CO., L.P.A. Firm #339 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 434-7955 WWR# 06453733 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, V. Plaintiff, NO: BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, Defendants NOTICE TO DEFEND 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 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 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, v. Plaintiff, NO: Ok- /34-z Cc4;?l Z, BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, Defendants COMPLAINT IN EJECTMENT - PURCHASER AT SHERIFF'S SALE AND NOW, comes, Plaintiff by and through its attorneys, Weltman, Weinberg, & Reis, Co., LPA., and files the Complaint in Ejectment as follows: 1. Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, a lending institution duly authorized to conduct business within the Commonwealth of Pennsylvania. 2. Defendants are Barbara Harley, Michael Harley and Terre Tenant, individuals, residing at 24 W. Locust Street, Mechanicsburg, PA 17055. 3. Plaintiff is the equitable owner of the aforesaid premises, having purchased the premises pursuant to a sheriff's sale duly held in Cumberland County on December 5, 2007. A deed from the Sheriff of Cumberland County to Plaintiff was recorded on December 20, 2007 in Instrument No. 200746884. A true and correct copy of said recorded Sheriff's Deed is attached as Exhibit "A". 4. Said Sheriffs Sale was authorized under the terms of a foreclosure action and judgment thereon in the Court of Common Pleas of Cumberland County at No. 2007-2484. 5. The property was sold as the property of Barbara Harley and Michael Harley. 6. Defendants have no valid legal right to possession and title to said premises. 7. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants. WHEREOF, Plaintiff, Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, seeks judgment for the possession of the aforesaid premises. Respectfully submitted, Patricia L. Blais, Esquire PA I D #56648 WELTMAN,WEINBERG, & REIS, CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 008 12:42 FAX 215 627 7734 Tax Parcel No. 16-23-9565-038 Know all Men by these Presents 400BECK 2003 V m-w 19 %?V/U-7 4 ? 0ol 9 t4t/ That 1, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania Real Estate Sale No. 67 Writ No. 2007-2484 Civil Term Champion Mortgage, a Division Of Key Bank, National Association, Successor to the Interest of Champion Mortgage Co„ Inc. VS Barbara Harley and Michael Harley Atty. Joseph Goldbeck DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and Street of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at the corner of West Locust Street and Lamont Alley; thence by Lamont Alley in a northerly direction, 93.00 feet to Stouffer Alley; thence by Stouffer Alley in an easterly direction, 35.00 feet, more or less, to lands now or formerly of Snyder, thence by lands now or formerly of Snyder in a southerly direction, 93.00 feet to a point on the western line of Locust Street; thence by the western line of Locust Street In a westerly direction, 35.00 feet, moreor less, to a point, the place of BEGINNING. HAVING THEREOF erected a two-story frame dwelling known and numbered as 24 West Locust Street, Mechanicsburg, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 24 W. Locust Street Mechanicsburg, PA 17055 SOLD as the property of BARBARA HARLE`( and MICHAEL HARLEY TAX PARCEL #16-23-0565-038 IPPMRPM008 12:42 FAX 215 627 7734 GOLDBECK Z004 'llie same having been sold by me to the said grantee on the 5th day of December Anno DorAini Two Thousand and Seven (2007) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 29th day of August Anno Domini 2007 out of the Court of Common Pleas of Cumberland County, Pcimsylvonia, as of Civil Term, Two Th'oO Sand and Seven (2067) Number 2484 at the suit of Champion Mortgage, a Division of Key Bank, National Association, Successor to the Interest of Champion Mortgage Co., Inc. against Barbara Harley and Michael Barley. d VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Lo rl RL 'CaV( ?- , Uyiafi/m LnJ , of P-T , plaintiff herein, (TITLE) (COMPANY) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. 2-l Date ( ignature) Harley - 06453733 O V1 n -6q. 00 00 .o b 00 ? gs L 00 ?.., r.> OD r -r? 1 -4 rr 1\ r SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01302 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUT VS HARLEY BARBARA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HARLEY BARBARA but was unable to locate Her in his bailiwick. 0(-)MDT.A TTT'T _ V=(-TMUI TrP He therefore returns the NOT FOUND , as to the within named DEFENDANT 24 W LOCUST STREET MECHANICSBURG, PA 17055 BUILDING IS CONDEMNED. HARLEY BARBARA Sheriff's Costs: Docketing 18.00 Service 9.60 Not Found 5.00 Surcharge 10.00 So answers,. - ?- R. Thom s Kline Sheriff of Cu erland County WELTMAN WEINBERG REIS 03/07/2008 00 / 42.60 Sworn and Subscribed to before me this day of A. D. r SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01302 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUT VS HARLEY BARBARA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HARLEY MICHAEL but was unable to locate Him in his bailiwick r"(-)MDTA TTTT' _ ' . 7L7rTMVMT He therefore returns the the within named DEFENDANT , HARLEY MICHAEL NOT FOUND , as to 24 W LOCUST STREET MECHANICSBURG, PA 17055 BUILDING IS CONDEMNED. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answer- i R. Thomas Kline Sheriff of Cumberland Co WELTMAN WEINBERG REIS 03/07/2008 unty Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01302 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUT VS HARLEY BARBARA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TERRE TENANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT the within named DEFENDANT , TERRE TENANT NOT FOUND , as to 24 W LOCUST STREET MECHANICSBURG, PA 17055 BUILDING IS CONDEMNED. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 00 21.00 _ So answers R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 03/07/2008 Sworn and Subscribed to before me this day of A. D. I COP'S FROM RECORD in Testimony whereof, I here unto set my barn aw th of said Court at Carlisle, Pa. g( rc.b aoog IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff, V. BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, .)OQ 0- i V11 -&M Defendants TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. WELT EINBERG & REIS C .P.A. ATTORNEYS FOR PLAINTIFF I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS: 10385 WESTMOOR DR STE 100 WESTMINSTER, CO 80021 AND THE DEFENDANTS ARE: 24 W. Locust Street 7055 MechanicsburINBEF WELTM G & RE I , L.P A B ATTORNEYS FO PLAINTIFF I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS: 24 W. Locust Street Mechanicsburg, PA 17055 Bgh of Mech ' sburg WELTMAN, RG & REIS CO., L.P ATTORNEYS R PlCAINTIFF ISSUE NO.: CODE: TYPE OF PLEADING: COMPLAINT IN EJECTMENT FIILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Patricia L. Blais, Esquire PA ID #56648 WELTMAN, WEINBERG & REIS CO., L.P.A. Firm #339 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 434-7955 WWR# 06453733 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, V. Plaintiff, NO: BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, NOTICE TO DEFEND 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 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 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff, V. NO: BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, Defendants COMPLAINT IN EJECTMENT - PURCHASER AT SHERIFF'S SALE AND NOW, comes, Plaintiff by and through its attorneys, Weltman, Weinberg, & Reis, Co., LPA., and files the Complaint in Ejectment as follows: 1. Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, a lending institution duly authorized to conduct business within the Commonwealth of Pennsylvania. 2. Defendants are Barbara Harley, Michael Harley and Terre Tenant, individuals, residing at 24 W. Locust Street, Mechanicsburg, PA 17055. 3. Plaintiff is the equitable owner of the aforesaid premises, having purchased the premises pursuant to a sheriff's sale duly held in Cumberland County on December 5, 2007. A deed from the Sheriff of Cumberland County to Plaintiff was recorded on December 20, 2007 in Instrument No. 200746884. A true and correct copy of said recorded Sheriff's Deed is attached as Exhibit "A". 4. Said Sheriffs Sale was authorized under the terms of a foreclosure action and judgment thereon in the Court of Common Pleas of Cumberland County at No. 2007-2484. 5. The property was sold as the property of Barbara Harley and Michael Harley. 6. Defendants have no valid legal right to possession and title to said premises. 7. Plaintiff claims the right to possession of the premises to the exclusion of the Defendants. WHEREOF, Plaintiff, Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, seeks judgment for the possession of the aforesaid premises. Respectfully submitted, 2 Patricia L. Blais, Esquire PA ID #56648 WELTMAN,WEINBERG, & REIS, CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 (il; t?7i2b08 12:42 FAX 215 627 7734 GOLDBECK 2003 YOt (W P/av/67 'lax Parcel No. 16-23-0565-038 Know all Men by these Presents wt? 7 ,n That 1, R. Thomas Kline. Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the 'sum of $1.00, (Onc Dollar), to me in hand paid, do hereby grant and convey to Beneficial Consumer Discount CompaDy d/b/a Beneficial s4 ,; Mortgage Co. of Pennsylvania Real Estate Sale No. 67 Writ No. 2007-2484 Civil Term Champion Mortgage, a Division Of Key Bank, National Association, Successor to the Interest of Champion Mortgage Co., Inc.• VS Barbara Harley and Michael Harley Atty. Joseph Goldbeck DESCRIPTION r?. ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and Street of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at the corner of West Locust Street and Lamont Alley; thence by Lamont Alley in a northerly direction, 93.00 feet to Stouffer Alley; thence by Stouffer Alley in an easterly direction, 35.00 feet, more or less, to lands now or formerly of Snyder, thence by lands now or formerly of Snyder in a southerly r direction, 93.00 feet to a point on the western line of Locust Street; thence by the western line of Locust ?f Street In a westerly direction, 35.00 feet, more or less, to a point, the place of BEGINNING. HAVING THEREOF erected a two-story frame dwelling known and numbered as 24 West Locust Street, t Mechanicsburg, Pennsylvania. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 24 W. Locust Street Mechanicsburg, PA 17055 SOLD as the property of BARBARA HARLEY and MICHAEL HARLEY TAX PARCEL'#16-23-0565-038 -yam r r ,?,,., 1? 01%07!2008 /. T 12:42 FAX 215 827 7734 GOLDBECK Z004 '1'lie same having been sold by me to the said grantee on the Stb day of December Anno Domini Two Thousand and Seven (2007) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 29th day of August Anno a f? :> x d w Domini 2007 out of the Court of Common Pleas of Cumberland County, Pm-msylvania, as ' w of Civil Term, Two I usaiid and Seven (2d" j)'Number 2484 at the suit of Champion Mortgage, a Division of Key Bank, National Association, Successor to the Interest of Champion Mortgage Co., Inc. against Barbara Hurley and Michael Harley. s:- - r; a' F? 1 F?' VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. § 4904 , relating to unsworn falsifications to authorities, that he/she is d Uwielu '?ia1IS?- Lead , of P-'s Am <; , _l1 , plaintiff herein, (TITLE) (COMPANY) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. 2-k^-O'i? Date 4ign(ature) Harley - 06453733 I ? :E d L Z 933 90OZ A a. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff, NO: 08-1302 CIVIL vs. BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, Defendants. TYPE OF PLEADING: PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Patricia L. Blais, Esquire PA I . D. #56648 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 4367 th Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR# 06453733 P '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff, V. BARBARA HARLEY, MICHAEL HARLEY, and TERRE TENANT, Defendants NO: 08-1302 CIVIL PRAECIPE TO DISCONTINUE AND END WITHOUT PREJUDICE PROTHONOTARY: Kindly discontinue and end the above-captioned matter and mark the docket accordingly. Respectfully submitted: Sworn and subscribed before Weltman, Weinberg & Reis Co., L.P.A. By: atricia L. Blais, Esquire Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 4367 th Avenue Pittsburgh, PA 15219 (412) 434-7955 ZD day of PW Y1 , 2008 Notary Public -Notarial seal Heidi J. Kelly, Notary Public City of Pftbumfi, Alleg *'W Count My Commission E)Ores Nov. 4, 2009 Member, ?.: