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Home My WebLink About04-0573Federman and Phelan, LLP By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563-?000 Attorney forPlaintiff LaSalle Bank National Association 4901 West Irving Park Road Chicago, IL60641 Ralph Charles Crone Or Occupants 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Court of Common Pleas Civil Division Cumberland County Term No. - 5'q3 CVv~I, ACTION - ~,JE~TMENT **This finn 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 d/scharge in bankruptcy and this debt was not reaffffmed, this correspondence is not and shou/d 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 Plaintiff is LaSalle Bank National Association. Defendant is Ralph Charles Crone Or Occupants. Plaintiff is equitable owner of premises located at 1311 Old Willow Mt! Road, Mechanicsburg, PA 17055, a legal description of which is attached. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriffof Cumberland County, on December 10, 2003. 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. 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~lr~neis S. Hallinan, Esquire )~ttorney for Plaintiff B~.ING KNO~4N A~:: 1311 OLD WILLOW MILL ROAD, ~CHANICSBUi~G (SILVE~ SPRIN~ ~.), PA 170~ PROP~ ID NO.: TI~ TO S~D P~ISES IS ~ST~ IN ~pH ~ES ~O~ By ~OM ~PH C~ES ~0~ ~ S~ L. ~O~, HIS WIFE DAT~ 3/22/96 ~C0~ ~/24/00 B~K 219 PAGE 796. VERIFICATION Francis S. Hallinan, 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. ,5- ¢ 4~rancis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-00573 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOCIAT VS CRONE P~ALPH CHARLES R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT CRONE RALPH CHARLES unable to locate Him COMPLAINT - EJECTMENT NOTICE ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and in his bailiwick. the within named DEFENDANT 1311 OLD WILLOW MILL ROAD MECHAiqICSBURG, PA 17055 ABOVE ADDRESS IS VACANT. but was He therefore returns the , NOT FOUND , as to CRONE RALPH CHARLES Sheriff's Costs: Docketing 18.00 Service 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 So answer~ ~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN AND PHELAN 02/17/2004 Sworn and subscribed to before me this 23~, day of ~~ ~ A.D. tary FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire I.D. No. 12248 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 Attorney for Plaintiff LASALLE BANK NATIONAL ASSOCIATION Plaintiff RALPH CHARLES CRONE OR OCCUPANTS Defendant(s) Court of Common Pleas CUMBERLAND County No. 04-573 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT, WIT~ _AND DISCONTINUE AND E~.~D 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 ~ramk Feciermar~squire Lawrence T. Phelan, Esquire Francis S Hallinan, Esquire Attorneys for Plaintiff