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HomeMy WebLinkAbout08-18500/ or 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 Wells Fargo Financial Pennsylvania 3476 Stateview Blvd. Fort Mill, SC 29715 . Civil Division V. Randall K. Dorman Or Occupants 27 Honeysuckle Drive Mechanicsburg, PA 17050-3166 Attorney for Plaintiff Court of Common Pleas Cumberland County Term No. D8 _ 1850 C ivi I er-N 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (888)-990-9108 PHS #: 174853 t 1. Plaintiff is Wells Fargo Financial Pennsylvania. 2. Defendant is Randall K. Dorman Or Occupants. 3. Plaintiff is the record owner of premises located at 27 Honeysuckle Drive, Mechanicsburg, PA 17050- 3166, a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of Cumberland County, on March 5, 2008, as evidenced by the Sheriffs deed recorded March 20, 2008 in the Office of the Recorder of Cumberland County in Instrument Number 200808338. 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. F cis S. Hallinan, Esquire Attorney for Plaintiff r ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company, as prepared by Gannett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 47, Page 52, and more particularly described as follows: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lot Nos. 141 and 142, as shown on the aforementioned Subdivision Plan; thence along same North 79 degrees 54 minutes 56 seconds East, a distance of 207.53 feet to a point; thence South 25 degrees 16 minutes 2 seconds West, a distance of 137.38 feet to a point at the dividing line between Lot Nos. 142 and 143; thence along same North 79 degrees 47 minutes 36 seconds West, a distance of 148.10 feet to a point; thence along the right-of-way line of Honeysuckle Drive, by a curve to the left, having a radius of 175.0 feet, an arc distance of 61.98 feet with a cord bearing North 16 degrees 33 minutes 17 seconds West, a fiord distance of 233.39 feet to the poiriL and Place of BEGINNING. BEING Lot No. 142 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company. CONTAINING 16,008 square feet, more or less. UNDER AND SUBJECT t a sanitary and storm sewer easement, other easements, set back lines and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 30B, Page 206. BEING THE SAME PREMISES WHICH Sewalt, Incorporated, a Pennsylvania Corporation, by Deed dated July 18th, 1986 and recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Deed Book A32, Page 825, granted and conveyed unto Chanh Trung Nguyen and Thanh Trung Nguyen, the Grantors herein. PARCEL#: 38-21-0289-142 PROPERTY BEING: 27 HONEYSUCKLE DRIVE 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. Date F ancis S. Hallinan, Esquire Attorney for Plaintiff W g :8 Ln ti od D a clp ) SHERIFF'S RETURN - REGULAR CASE NO: 2008-01850 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL PENNSYLV VS DORMAN RANDALL K ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon DORMAN RANDALL K the DEFENDANT , at 0930:00 HOURS, on the 31st day of March , 2008 at 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050 RANDALL K DORMAN by handing to a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 Nj0?JU? ? 37.60 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 04/01/2008 PHELAN HALLINAN SCHMIEG By: Deputy Sheriff A. D. 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 Wells Fargo Financial Pennsylvania Attorney for Plaintiff Plaintiff Court of Common Pleas Cumberland County VS. No. 08-1850 Civil Term Randall K. Dorman or occupants Defendant(s) 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. Date Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Attorneys for Plaintiff PHS # 174853 c? ? C ;?; . ?r- 11 _..- ??.. R? _ ?..„ -- T-. ` h,,;r ::?:?t C:;? --?